Keeping Workers and Clients Safe during COVID-19 in Close Contact Services - including hairdressing, barbershops, beauty and nail bars, makeup, tattoo and spray tanning studios, spas, sports and massage therapy, well-being and holistic locations, dress fitters, tailors and fashion designers. The guidance is also designed for those who provide mobile close contact services from their homes and in other people's homes. 

Hairdressers and barbershops will be permitted to reopen for services that relate to cutting or treating hair on the head only, from 4 July 2020. A date is awaited for the beauty, therapy and wellbeing services.

Where a premises delivers a mix of services, only those services that are permitted to be open should be made available. For example, a hairdresser should ensure that beauty or nail treatments are not offered. Other services are to remain closed until further notice.  

The guidance does not replace existing health and safety duties, but should be considered by employers when assessing risk and implementing control measures.  Employers have a legal responsibility to protect workers and others from risk to their health and safety.  

Thinking about Risk

Employers must carry out a COVID-19 risk assessment in order to assess and manage the risks of COVID-19. This means thinking about the risks and doing everything reasonably practicable to minimise them, recognising it is not possible to completely eliminate the risk of COVID-19. Employers should also have particular regard to whether the people doing the work are especially vulnerable to COVID-19. The results of a risk assessment must be shared with the workforce and if possible, employers should consider publishing the results on their website. 

Regulators are carrying out compliance checks nationwide to ensure that employers are taking the necessary steps. Failure to complete a risk assessment which takes account of COVID-19, or completing a risk assessment but failing to put in place sufficient measures to manage the risk of COVID-19, could constitute a breach of health and safety law.  

Managing Risk

Employers have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures. In the context of COVID-19, this means protecting the health and safety of workers and clients by working through steps including ensuring workers and clients who feel unwell stay at home and do not attend the premises, increasing the frequency of hand washing and surface cleaning and where working from home is not possible, workplaces should make every reasonable effort to comply with social distancing guidelines (2 m, or 1m with risk mitigation where 2m is not viable). When it is not possible to maintain social distancing when providing close contact services, PPE, such as a visor, will be required. Further mitigating actions include keeping the activity time involved as short as possible, using screens and barriers to separate clients, using back-to-back or side-to-side working rather than face-to-face whenever possible and using a consistent pairing system, if workers have to be in close proximity. If people must work face-to-face for a sustained period, with more than a small group of fixed partners, then the guidance states employers need to assess whether the activity can safely go ahead.

Keeping your Clients and Visitors Safe

Businesses should assist the NHS Test and Trace service by keeping a temporary record of clients and visitors for 21 days. Premises should refrain from playing music or broadcasts that may encourage shouting or makes normal conversation difficult.  Additional steps include encouraging clients to use hand sanitiser or hand washing facilities as they enter the premises, calculating the maximum number of clients that can reasonably follow social distancing guidelines, asking clients to attend bookings on their own where possible and adjusting how people move through the premises to reduce congestion and contact. Other steps include using outside spaces for queuing, minimising contact between different workers whilst serving a client, such as photographers, models, make-up artists and stylists in a photo shoot, operating an appointment only system, limiting the use of changing facilities and asking clients COVID-19 related screening questions ahead of appointments. The guide recommends steps to ensure client toilets promote good hygiene, social distancing and cleanliness.  The guide recommends that businesses should display posters and ensure information is provided to clients and visitors to ensure people on the premises understand what they need to do to maintain safety. 

Who Should Go to Work

People who can work from home should continue to do so. Employers should decide, in consultation with their workers, whether it is viable for workers to continue working from home. Where it is decided workers should come into their place of work, this will need to be reflected in the risk assessments with steps taken to manage the risks of transmission as set out in the guide. The guide sets out steps to consider including considering which workers it is essential should be on site and protecting those at higher risk.

Social Distancing for Workers

The guide sets out detailed actions to maintain social distancing (2m, or 1m where 2m is not viable) wherever possible. The guide acknowledges that when providing close contact services, social distancing will not usually be possible and as such activity time should be kept as short as possible, hand washing and surface cleaning increased, screens or barriers should be used to separate clients, practitioners should use visors, waiting areas should be opened only where social distancing can be maintained and back-to-back or side-to-side working should be used where possible. Social distancing applies to all parts of a business including the room where the service is delivered but also waiting rooms, corridors and staircases, where applicable. The guide recommends further steps for when employees come to work and leave work such as staggering arrival and departure times and using more than one entry point to the premises in order to reduce congestion. Providing floor markings and signage to remind workers and clients to maintain social distancing at workstations and wherever possible is also recommended.  With regards to common areas, steps including staggering break times, encouraging workers to bring their own food and drinks and not allowing consumption of food and drink in central areas such as a salon are recommended.  

Cleaning the Workplace

The guide recommends that before reopening, employers should make sure any site or premises are clean. In order to keep the workplace clean, recommendations include spacing appointments to allow for frequent cleaning of work areas and equipment, clearing workspaces and removing waste and belongings at the end of a shift, not providing reading materials such as magazines, using disposable gowns for each client, maintaining good ventilation and encouraging staff to not wear their uniforms at home or to and from the workplace and to wash uniforms immediately after use. The guide also recommends steps to ensure everyone keeps good hygiene through the working day around hand washing, sanitation facilities, toilets, changing rooms and showers.  The guide recommends steps to reduce transmission when handling goods, merchandise and other materials such as enforcing cleaning procedures for goods and merchandise entering the site and minimising person-to-person contact when accepting deliveries.  

Personal Protective Equipment (PPE) and Face Coverings

The guide recognises in these types of workplaces, it is likely to be difficult to maintain social distancing.  The guide recommends that the person providing the service, such as a hairdresser, should therefore wear further protection in addition to any that they may usually wear.  This should take the form of a clear visor that covers the face and provides a barrier between the wearer and the client from respiratory droplets caused by sneezing, coughing or speaking.  The guide states there is no requirement for the client to wear any additional protection such as a mask or face covering, when the practitioner is wearing a visor.  The guide states there may be circumstances when wearing a face covering may be marginally beneficial as a precautionary measure.  However, face coverings are not an alternative to wearing a visor in close contact services.  This is because the evidence suggests wearing a face covering does not protect the wearer, but it protects others if the wearer is infected but has not developed symptoms.  Employers should support their workers in using face coverings safely if they choose to wear one.

Workforce Management

The guide advises how to change the way work is organised to create distinct groups and reduce the number of contacts each worker has.  Recommended steps include the use of teams and shift groups, remaining at a consistent workstation, staggering shift start times, creating a schedule for staff detailing in advance how treatments will take place and using a defined process to help maintain social distancing during shift handovers.  The guide also deals with work-related travel, communications and training including when returning to work and ongoing communications and signage to make sure all are kept up to date with safety measures.  

Inbound and Outbound Goods

The guide considers how to maintain social distancing and avoid surface transmissions when goods enter and leave the premises, especially in high volume situations, for example, despatch areas. Recommended measures include minimising unnecessary contact for deliveries including non-contact deliveries, considering methods to reduce the frequency of deliveries, having single workers load or unload vehicles or meet delivery people at the front door, scheduling deliveries for outside of client appointment times and re-stocking/replenishing supplies outside of workplace operating hours.  

Enforcement

Where HSE or a local authority identifies employers who are not complying with guidance to control public health risks, they will consider taking a range of actions to improve control of workplace risks including enforcement.  The HSE or local authority can issue enforcement notices to help secure improvements.  Serious breaches and failure to comply with enforcement notices can constitute a criminal offence, with serious fines and even imprisonment up to two years.  

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Erin Shoesmith

Erin Shoesmith

Partner, Health & Safety
United Kingdom

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