This article outlines the government's updated safety advice relating to Grassroots sport and gym/leisure facilities in England.

The government has updated its guidance to help ensure safety during the pandemic.  Under the new guidance, from 11 July, outdoor swimming pools and outdoor water parks are now permitted to re-open. The new guidance will also apply to sports facilities and venues that the government has indicated will re-open from 25 July 2020, such as indoor gyms, fitness and dance studios, indoor swimming pools and indoor water parks.   The guidance does not replace existing health and safety duties, but it should be considered by employers, employees and customers of this sector, when assessing risk and implementing control measures. As an employer, you have a legal responsibility to protect workers, customers, volunteers and others from risks to their health and safety. 

Thinking About & Managing Risk 

Employers must carry out a COVID – 19 risk assessment (which must be shared with employees after consultation and where possible should be published online).  Employers are also required to take preventative measures.  Failure to do so may lead to enforcement action.  That means working through the steps in the guide in order, i.e. ensuring workers and customers who feel unwell stay at home, increasing hand washing/surface cleaning, making every reasonable effort to work from home where possible and where working from home is not possible, to comply with social distancing (2m, or 1m with risk mitigation where 2m is not viable, is acceptable).  Mitigating measures include increasing cleaning, providing sufficient PPE, reducing activity time, using screens or barriers (including at points of service), using fixed teams and avoiding face to face working.  If people must work face-to-face for a sustained period with more than a small group of fixed partners, then employers will need to assess whether the activity can safely proceed.  No one is obliged to work in an unsafe environment.  Any measures that are put in place must be reviewed to ensure they are working.  Employers are expected to demonstrate this by displaying a notification in a prominent place in the business and on their website.  

The recommendations in the rest of the guide are those employers must consider as they go through this process.  They can also consider any sector-specific advice, e.g. individual sports governing bodies, who will often provide specific guidance on how their sport can be played or adapted to enable social distancing. 

Keeping your customers and users safe

The guidance anticipates that sports and gym/leisure facilities come in many different forms, so it is imperative that a careful risk assessment of both the venue and the activity is undertaken so that social distancing and infection control are effective.    Steps that will usually be needed include encouraging attendees to arrive at the facility in sports kit and where possible to travel home to change/shower, avoiding use of changing rooms and showering facilities where possible, and reconfiguring fitness equipment (either through spacing, using screens to separate it or taking equipment out of use) to maintain social distancing guidelines.  Lockers and other storage facilities in changing rooms should be readily accessible to avoid the need for opening them.  Online class/roster bookings are encouraged to avoid the risk of transmission through paperwork.   The guidance recommends that music is not played as this may make normal conversation difficult which in turn may encourage shouting, which increases the risk of aerosol/droplet transmission.  Numbers in swimming pools will need to be restricted to allow 3sqm per bather.  Saunas and steam rooms should stay out of use for the time being as the risk of transmission is unclear, however, hydrotherapy pools may be used provided social distancing is maintained. Where water flumes are in use, they must be used in a socially distanced manner. 

Prior to indoor fitness facilities re-opening on 25 July, the guidance recommends that steps are taken to calculate the maximum number of customers that can reasonably follow social distancing guidelines, implement one way systems with appropriate signage for customers, think about how queues might be managed safely and to consider which doors may be fixed open that can be safely left open where feasible.  Thought will also need to be given as to how customer entry might be managed, with hand sanitiser on entry, and customers should be prevented from waiting in groups.    The guidance also recommends that employees are each allocated a specific area of the gym/leisure facility to ensure social distancing measures are being adhered to by the customers within that section   Equipment should not be shared by users unless it is cleaned or sanitised between use.  Any water fountains that are in use should have signage prohibiting face-to-tap drinking.  

Guidance is also given on controlling spectators, through pre-booking, ticketing and other controls at access points.  Food and drink outlets can re –open, so long as they operate in accordance with guidance for that sector.

Who should go to work?

Everyone should work from home, unless they cannot work from home.  Employers should consider who needs to go to work as well as how to protect those at higher risk. The guide sets out steps to consider including planning for minimum numbers and the monitoring of staff and protecting those at higher risk. 

Social distancing at work 

The guide sets out detailed actions to maintain 2m social distancing (or 1m with risk mitigation, where 2m is not viable), including while arriving at and departing from work, while in work, and when travelling between sites as well as how to reduce risk when the guidelines cannot be followed in full including reducing activity time, using screens to separate fitness machines, the use of fixed teams and avoiding face to face working.  For leisure facilities, where it may be more difficult to socially distance, more one-way flow systems should be introduced throughout buildings.  Screens should also be installed to protect reception staff.  Instructors should only teach a limited number of classes in order to minimise instructors, and it may also be necessary to establish a private testing programme for rotating/visiting instructors.

Importance of ventilation

The guide makes clear that good ventilation in the sport or gym/leisure facility is imperative, and as a minimum, windows and doors should be opened more frequently.   Particular attention should also be given to ventilation and sufficient circulation space, especially around equipment and between groups, classes and instructors, as ventilation is an important part of mitigating against the transmission of COVID – 19.  Ventilation areas should provide 100% fresh air and not recirculate air from one space to another.   Ventilation systems should be checked regularly and serviced where necessary so they do not automatically reduce ventilation levels due to lower than normal occupancy levels. 

The government has also recommended that advice prepared by the Pool Water Treatment Advisory Group is followed when re- commissioning swimming pools prior to their opening.

Cleaning and sanitising the workplace 

The guide considers how to ensure that any premises that have been closed are clean and ready to restart; how to keep the workplace clean and prevent transmission by touching contaminated surfaces (including stationary gym equipment, free weights, mats and balls); how to help everyone keep good hygiene through the working day; how to minimise the risk of transmission in toilet facilities, changing rooms and showers.  The guide advises that frequent cleaning of work areas and equipment will be required, including the need for stationary gym equipment to be cleaned between use with cleaning products.  Spray and clothes should be provided, together with instructions for users to wipe down each machine after use.  If equipment cannot be cleaned after each use, it should not be used.  

Personal protective equipment (PPE) and face coverings 

COVID-19 is a different type of risk to the risks staff normally face in a workplace, and needs to be managed through social distancing, hygiene and fixed teams or partnering, not through the use of PPE. Workplaces should not encourage the precautionary use of extra PPE to protect against COVID-19 in most circumstances. Wearing a face covering may be marginally beneficial as a precautionary measure. Wearing a face covering is optional and is not required by law, including in the workplace. Employers should support their workers in using face coverings safely if they choose to wear one.  Pending further guidance from the government, if an employee does choose to wear a face covering, they should wash their hands before putting them on and before and after taking them of.  Wearing a face covering is compulsory on public transport. 

Managing your workforce 

The guide advises on how to change the way work is organised to create distinct groups and reduce the number of contacts each worker has including the use of shift patterns, working groups, and considering drop-off points or transfer zones to try to avoid direct contact.   It deals with communications and training including when returning to work and ongoing communications and signage to make all are kept up to date with safety measures. Employers should assist NHS Test and Trace be keeping a record of shift patterns for 21 days.  Read more about maintaining records for NHS Test and Trace here

Additional guidance for community sports

Many community sports clubs will heavily rely on volunteers giving their time to enable the club to deliver sport and operate safely.   There is no obligation on volunteers to return, so it is important that volunteers are satisfied the environment is safe.   Steps to consider include, consulting NVCO advice on volunteering, considering guidance from the relevant sporting body and conducting a risk assessment to determine the tasks that will need to be undertaken, together with the necessary numbers of volunteers.  The guidance also suggests that activities are separated out into separate sessions, to avoid contact across multiple groups.  A booking system should also be enabled to manage demand for facilities.  Volunteers should also be trained on COVID-19 related safety procedures. 

Where to obtain further guidance

Key Contacts

Erin Shoesmith

Erin Shoesmith

Partner, Health & Safety
United Kingdom

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Adrian Mansbridge

Adrian Mansbridge

Legal Director, Global Investigations
Leeds, UK

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