In this section
- COVID-19 ? the challenge
- Support for workers when returning to the workplace
- Managing risk ? things to think about when completing your COVID-19 risk assessment
- Managing risk ? practical steps when completing your COVID-19 risk assessment
- *The all-important risk mitigation measures are:
- What is a Type II face mask?
- The highest risk activities
- Advice to clients (in advance and on the day of the appointment)
- Advice to your workers
- Visors, goggles, masks and more - what you should know
- NHS Test and Trace
- Cleaning before and during reopening
- Toilets, changing rooms and washrooms
- Water and Legionella
- Laundry and Waste
- What if I get an outbreak?
- Workplace testing
- Nearly ready to open?
- Checking that you?re COVID-19 secure
- FAQ and Links to other sources
Last updated: 28 April 2021
The government’s COVID-19 Response – Spring 2021 has set out how COVID-19 restrictions plan to be eased over the coming months. Decisions about ‘how and when’ will be based on data for vaccine rollout, its effectiveness and infection rates. The impact of new variants will be kept under close scrutiny too.
This Bulletin is written to help those businesses which provide close contact services and intend to reopen from 12th April 2021 or beyond. It summarises the key elements of the Government’s guidance in place for 12th April and provides links to other reputable sources too.
If you read and put into place the measures included in this Bulletin it will help you make your premises COVID 19 secure, for the benefit of you and your workers, your clients, delivery drivers, visitors and indeed anyone else who comes into contact with your service.
For the purposes of this Bulletin, close contact services also includes the mobile version of these activities, (when provided from the home or to clients in their homes) and to those studying hair and beauty in vocational training environments.
Working in other people’s homes is specifically covered by other government guidance; https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/homes
The government advice for gym and leisure facilities also includes hot tubs, spa pools etc. too: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/providers-of-grassroots-sport-and-gym-leisure-facilities
The government’s guidance for close contact services is here: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/close-contact-services
The National Hair & Beauty Federation (NHBF) is a valued partner of CTSI and has produced its own reopening guide for the sector which can be obtained from its website, along with other COVID-19 resources: https://www.nhbf.co.uk/home/
COVID-19 is a highly contagious virus. It sticks to all sorts of surfaces, including skin, and can survive for hours or days, according to the surface material. Plastic keeps the virus viable for up to 72 hours, whereas stainless steel is up to 48 hours. For cardboard it’s 24 hours and for copper, just 4 hours. Aerosol droplets can remain viable for 3 hours at a time.
1Reference: New England Journal of Medicine https://www.nejm.org/doi/full/10.1056/NEJMc2004973?query=featured_home
Current evidence suggests that COVID-19 spreads between people through direct, indirect (through contaminated objects or surfaces), or close contact with infected people via mouth and nose secretions. These include saliva, respiratory secretions or secretion droplets. These are released from the mouth or nose when an infected person coughs, sneezes, speaks or sings, for example. People who are in close contact (within 1 metre) with an infected person can catch COVID-19 when those infectious droplets get into their mouth, nose or eyes.
Reference: World Health Organisation, July 2020
The incubation period of the virus is an average of 5.9 days according to most sources and most people (but not all!) will not be infectious until they show symptoms.
But with the right preparation and planning, there are things that you and your workers can do to minimise the spread and run a COVID-19 secure business.
The hair and beauty sector involves services that bring people into very close proximity to one another, often in the head or face area where aerosols from the mouth or nose might be produced (this being the highest risk zone). These activities present the most difficult challenges when it comes to minimising the spread of COVID-19 and operating safely. The sometimes-unpredictable nature of clients’ behaviour adds to the challenge.
What are the most import preparations for reopening that I should be doing right now?
- get ready to turn anyone away with COVID-19 symptoms (workers and clients) and have a plan for dealing with this when open for business
- review your COVID-19 risk assessment (to help you plan distancing and other measures)
- remind workers and customers of the rules
- clean, clean, clean!
- focus on good ventilation
- display your QR code – note that the rules have changed
- don’t underestimate the mental health aspects of COVID-19 which might affect anyone
It’s been a while since close contact services have been able to open. Talk to your workers before they return to work - they may have concerns. Help them understand the new measures in place to make the workplace COVID secure; this will help to reassure them. If you can involve them in reviewing your COVID-19 risk assessment and deciding on any new arrangements needed (your ‘mitigation measures’), then all the better.
Be mindful of those workers who are at a higher risk of infection and consider this as part of your risk assessment. This includes those who are clinically extremely vulnerable: https://www.nhs.uk/conditions/coronavirus-covid-19/people-at-higher-risk/who-is-at-high-risk-from-coronavirus-clinically-extremely-vulnerable/
Or those who may have other conditions requiring support. The NHS website lists several health conditions and further sources of information for each: https://www.nhs.uk/conditions/coronavirus-covid-19/people-at-higher-risk/other-conditions-and-coronavirus/
Other groups of people have been identified by Public Health England as being more at risk of being infected, or of having a worse outcome if infected. These are:
- are older males
- those who have a high body mass index (BMI)
- those who have health conditions such as diabetes
- those who are from some Black, Asian or minority ethnicity (BAME) backgrounds
You should consider this in your risk assessment, making reasonable adjustments to working patterns or tasks on site, for those most vulnerable.
No-one should be forced to work in an unsafe workplace.
Those advised to stay at home and stop infection spreading according to existing government guidance must not come into the workplace (see https://www.gov.uk/government/publications/covid-19-stay-at-home-guidance)
This applies to those with symptoms and those who live in their household or support bubble and those required by NHS Test and Trace to self-isolate.
If appropriate, you can enable workers to work from home but you cannot require or even encourage someone who is self-isolating, to come into the workplace.
Any workers with symptoms should self-isolate immediately and for 10 days. Equally, workers who are in contact with individuals who test positive for COVID-19 should self-isolate for 10 days.
Workers identified by NHS Test and Trace as a ‘close contact’ of a person who has tested positive for COVID-19 must also follow the requirement to self-isolate.
Keep mindful of the particular needs of different groups of workers – you will be breaking the law if you discriminate (directly or indirectly) against anyone because of their age, sex or disability, race or ethnicity. Employers also have particular responsibilities for new or expectant mothers (https://www.gov.uk/government/publications/coronavirus-covid-19-advice-for-pregnant-employees/coronavirus-covid-19-advice-for-pregnant-employees)
Health and safety and risk assessment
Health and safety law requires employers to protect people from harm. This means considering all risks posed to workers, clients and anyone else who might be affected and to minimise those risks to the lowest level they can be. These rules have been in place for many years.
COVID-19 is a new type of risk that must be assessed too
Prior to this latest lockdown, it is likely that you will have already assessed the risks from COVID-19, so now is the time to review your risk assessment. Your review should take on board any changes that you’ve made for the 12th April opening, which might affect the measures you need to put into place. For example, if you’ve changed the layout of the premises (more space or less space?) or are offering new treatments (new equipment?) – you will need to look again at your risk assessment to ensure that your COVID-19 mitigation measures are still keeping people safe.
If you’re starting from scratch, the nuts and bolts of risk assessment are given below.
If you have five or more employees you must keep a written record of your risk assessments, including your COVID-19 risk assessment and involve them in its creation.
If you have under five staff, it’s still good practice to have a written record of your risk assessments and share them with your employees.
In a salon environment, carrying out a risk assessment will require a bit of work, even in non-COVID times, given the breadth of things you should consider. But the task of assessing the risks isn’t usually as daunting as it seems. There are a lot of good quality free templates and resources available these days and this Bulletin will point you to them.
As a responsible business, your risk assessment will consider a multitude of things, including the use of chemicals (in dyes for lashes and hair), glues (for nails), machinery and equipment (for treatments) but also things like using cleaning products without damaging skin, or how to safely store products so as not to cause a tripping hazard or whether the lighting for a staircase is bright enough to prevent a tumble, for example.
The NHBF provides templates for risk assessments appropriate in a salon environment: https://www.nhbf.co.uk/nhf-shop/?p=2&type=113
The Chartered Institute of Environmental Health also provides a guide to assist salons and spas as they reopen: https://www.cieh.org/media/4309/salons-reopening-guidance-covid-19.pdf
The Health and Safety Executive has lots of good advice on risk assessment too: https://www.hse.gov.uk/coronavirus/working-safely/risk-assessment.htm
Your COVID-19 risk assessment is a legal requirement and it helps you decide what services you can safely provide on your premises and how you will provide them. It means assessing the risks from COVID-19 for each service provided and then deciding which steps you need to take (i.e., which ‘mitigation measures’ to use) to make the service as safe as possible for the client and for the practitioner delivering it.
Putting sufficient mitigation measure into place is also a legal requirement.
- think about the virus and how it’s transmitted
- identify what work activity or situations might cause transmission of the virus
- think about who could be at risk
- decide how likely it is that someone could be exposed
- act to remove the activity or situation, or if this isn’t possible, control the risk
Failure to complete a risk assessment (including a coronavirus risk assessment) or to put in place sufficient measures to control the risks identified, could be a breach of health and safety law.
This could lead to enforcement action and may affect your future licence applications (e.g. a skin piercing licence).
Remember that it’s your responsibility to keep up to date with the rules
It’s a good idea to involve your workers when producing your risk assessment – they are often best placed to understand the risks
Every premises is different and the way in which services are delivered may also be different. This is why your own risk assessment is so important.
Risk assessment templates will help you think about the task, but you must ensure that your findings suit YOUR premises and the mitigation measures you choose to use are sufficient for YOUR circumstances.
- your risk assessment should consider the risks of COVID-19 to workers and clients, delivery drivers, visitors - anyone who comes onto your premises.
- remember to consider any workers who receive clients in their homes or who travel to client’s homes.
- ensure that your risk assessment for COVID-19 considers every aspect of salon life in relation to COVID-19, not only when providing treatments but also when welcoming and booking in clients, the arrival and departure of staff, cleaning, breakout areas, eating and drinking, receiving deliveries etc. The checklist below may help.
Remember to review your risk assessment at sensible intervals or if you make any changes which could impact on your control measures.
Your risk assessment will help you decide the steps you should take. This means the physical aspects, such as safe walkways through the premises, reminder notices on the walls for social distancing and the wearing of face masks etc. but also what your rules are going to be and how you will communicate them.
Remember that you must reduce the risk from COVID-19 as far as far as you reasonably can for your workers and clients, so you will probably need to follow as many of these as possible, not just one or two of them.
- Ensure workers and clients who feel unwell stay at home
- Increase the frequency of handwashing and surface cleaning
- Make reasonable adjustments for workers or customers who need them (see the ‘vulnerability’ section below)
- Comply with the social distancing guidelines (two metres, or one metre with risk mitigation* where two metres is not possible) and remind workers and customers of the rules on your premises
- Where the social distancing guidelines cannot be followed in full in relation to a particular activity or treatment, you should consider whether you can redesign or in some way alter the way it’s delivered to achieve social distancing guidelines
- A visor and a Type II face mask should be work by practitioners when providing close contact services, if social distancing guidelines (2m, or 1m+ and risk mitigation measures) cannot be maintained. For example, when providing services in a client’s highest risk zone (i.e., the face, mouth and nose)
*The all-important risk mitigation measures are:
- increasing hand washing and surface cleaning
- keeping the activity time as short as possible (perhaps provide shorter or more basic treatments)
- using screens to separate clients from one another
- practitioners working in close proximity to clients for an extended period of time must wear a visor/goggles and a Type II face mask (therefore at this point, screens between the practitioner and the client will not be necessary). Close proximity means about an arm’s-length away for a sustained period of time
- working from the back (behind the client), or from the side, circling the client
- using back-to-back or side-to-side working (rather than face-to-face) whenever possible
- avoiding skin-to-skin contact wherever possible (unless crucial for the treatment) and using gloves where possible
- using a consistent pairing system, defined as fixing which workers work together, if workers have to be in close proximity
- keeping background music at a low level will help avoid the need to shout, which could transmit aerosol droplets
Even after re-design or alteration of the treatment or activity, if social distancing guidelines cannot be met, then consider whether that treatment needs to continue for the business to operate. If no, then stop the activity.
If yes, then take all the mitigating actions possible to reduce the transmission.
What is a Type II face mask?
This is a medical face mask made up of a protective 3-ply construction that prevents large particles from reaching the client or working surfaces.
This webpage provides more information about different types of mask: https://lloydspharmacy.com/blogs/coronavirus/face-masks
It is important to put on and use a face mask safely. Close Contact Services (section 6.1) contains instructions on this.
The highest risk activities
Following the Government’s guidance and this Bulletin will help you maintain a COVID-19 secure premises and therefore keep people on your premises safe too.
But sometimes, services in the highest risk zone will be so high risk that you may need to take more steps or even stop providing them altogether if you cannot be sure that it is safe.
For example, the highest risk services in the highest risk zone (those which place a practitioner only a few centimetres from the mouth or nose of a client, such that the breath and aerosol droplets from a client could be inhaled, especially during a cough or sneeze), might require more steps. It is circumstances like these where transmission is most likely to happen and so this particular service should be stopped, or redesigned to make it safer, which could might mean that professional PPE of the required standard should be provided.
In this context, PPE would be specifically chosen for the task, CE marked and fitted for the wearer. This might include CE marked safety goggles, or a Type IIR mask. There’s more information here:
Remember that your risk assessment should take into account whether your workers are especially vulnerable to contracting COVID1-19, then if you need to make any reasonable adjustments to work patterns or the type of work that they do, for some of your workers, then you should do so. Anyone that can work from home should do so too.
Remember to think about the needs of vulnerable clients such as those who may not understand your instructions or be physically unable to follow them. Vulnerable clients also include those who may be more likely to contract the virus.
See the earlier section entitled ‘Support for workers when returning to the workplace.’
Advice to clients (in advance and on the day of the appointment)
Completing your COVID-19 risk assessment will mean that you’ve:
- thought about the virus and how it’s transmitted
- Identified what services or situations might cause transmission of the virus
- thought about who could be at risk
- decided how likely it is that someone could be exposed
- acted to remove the activity or situation, or if this isn’t possible, controlled the risk using mitigation measures
The rules on your premises for running a COVID_19 secure business will come from your risk assessment and will need to be shared with your workers and clients alike.
Forewarning clients about salon rules can help manage expectations and prevent problems arising. You could do this via your website, emails and social media routes and when taking bookings, as well as having notices on the door or window as a reminder.
- it may be difficult to get an appointment at first due to high demand
- services will be by appointment only (not walk-ins), to allow sufficient time and space between clients for additional cleaning
- some services and treatments may not be on offer until further notice
- appointment times may be adjusted to take account of cleaning time in between clients
- you have put measures in place to protect staff and clients and clients are therefore expected to comply with them otherwise services will not be provided
- clients will be required to use hand sanitiser or handwashing facilities as they enter the salon
- clients must not come in if they feel unwell or live with someone who is unwell – you could use a pre-service screening questionnaire for this, sent by email in advance which should be returned ahead of the appointment. Or it could be completed over the phone. See below for some questions to include during screening
- you would prefer contactless payments, if not, pay ahead for treatments over the phone
- clients should arrive at their allotted time to avoid overlap with others and to attend on their own, if possible, as there will (possibly) be no waiting area.
Pre-service screening questionnaire (You can reduce the likelihood of COVID-19 entering your premises in the first place by using a pre-screening questionnaire - this is a great way of reducing the risk for all. These three simple questions can be asked of the client at the time of booking and reviewed on the day of the appointment, to help keep everyone safe.
If a client refuses to answer, or if it is obvious that they are not telling the truth, then it is your decision as the operator of the business, if you want to accept them as a client at that time.
- are you required to be self-isolating?
- have you had a recent onset of a new, continuous cough?
- do you have a high temperature?
- have you noticed a loss of, or change in, normal sense of taste or smell?
(the taking of a client’s temperature using a hand-held thermometer ‘gun’ isn’t a reliable indicator on its own)
If a client has any of these symptoms, however mild, they should stay at home, contact the NHS via 111 (or online) for advice and reschedule their appointment
Advice to your workers
No-one should come into work if they have symptoms of COVID-19 or have been in contact with anyone who has symptoms.
Anyone who can work from home should do so, but in the case of close contact services, this is unlikely to be practical. Remember that those you may be able to assign to home working, might not be suitable for it – i.e., people facing mental or physical health difficulties or who might have a difficult home working environment. Monitor the wellbeing of those who are working at home and keep them ‘connected’ to others working on site.
Those who are at higher risk of infection will need to be particularly protected if working in the workplace. These are:
- clinically extremely vulnerable: https://www.nhs.uk/conditions/coronavirus-covid-19/people-at-higher-risk/who-is-at-high-risk-from-coronavirus-clinically-extremely-vulnerable/
- those with other health conditions who might need support: https://www.nhs.uk/conditions/coronavirus-covid-19/people-at-higher-risk/other-conditions-and-coronavirus/
- Other groups of people have been identified by Public Health England as being more at risk of being infected, or of having a worse outcome if infected:
- are older males
- have a high body mass index (BMI)
- have health conditions such as diabetes
- are from some Black, Asian or minority ethnicity (BAME) backgrounds
Update workers on all the new measures in place, especially handwashing and social distancing. Discuss any new rules on site, such as how to deal with clients who refuse to do what’s asked of them for health and safety reasons.
If you’ve introduced queue management or one-way flow, or perhaps altered entrances/exits, explain why this is needed and ensure signage is clear.
Uniforms should be changed daily, ideally on site.
Workstations should be assigned to individuals (or fixed pairings) where possible. The use of floor tape or paint might be a useful reminder.
High standards of hygiene would always have been a focus in well run businesses that provide close contact services. A reminder of the need for cleaning hands, equipment and workstations between clients cannot be over-emphasized. The use of disposable items in some cases, might help with the task.
Break times could be staggered to reduce the pressure on staff areas (if this is an issue) and social distancing should be maintained in all areas where staff congregate. If it’s possible, providing outdoor space for staff would be sensible.
Bringing food for one’s own consumption, not sharing with others or with clients, is recommended. Hot and cold drinks provided to clients in disposable cups is the safest way to provide refreshment, but clients should remove their masks only to consume a drink and replace it again afterwards. Whilst the mask is removed, the practitioner should step back to create more space.
For workers who may be going into other people’s homes, ensure arrangements for safety and social distancing are discussed with the client before setting out.
Physical contact with delivered items that have been handled by others, or with those delivering them, can be minimised by reducing the frequency of deliveries (perhaps larger quantities and less often?) and scheduling deliveries for outside client appointment times.
Goods arriving should be sanitized. Establishing pick-up and drop-off points for deliveries is a good idea to minimise person-to-person contact, if there’s space for this.
Visors, goggles, masks and more - what you should know
- A clear visor or goggles should be worn when working in a client’s highest risk zone or when working in close proximity to a client (or several clients) during the day.
- A visor must fit the user and be worn properly, providing a barrier to respiratory droplets. It should cover the forehead, extend below the chin and wrap around the side of the face. A visor should be optically clear, resistant to fogging and have an adjustable head band. Goggles are a suitable alternative to a visor but only if they are polycarbonate safety spectacles or equivalent; close fitting with no obvious openings or vents that would allow droplets to enter the eyes.
- A Type II face mask should be worn with the visor or goggles, not as an alternative. The Type II face mask will help to protect the client by acting as a physical barrier to aerosol droplets coming from the wearer.
- Ordinary face coverings (the kind worn by members of the public in shops and on public transport) are not a suitable substitute.
- For the highest risk activities in the highest risk zone, professional PPE may be required (CE marked, etc.) to protect the practitioner. Your risk assessment will help you decide.
- There is no need for a practitioner to wear a visor/goggles or a Type II face mask when the client is not having a treatment or service but social distancing should be maintained.
- Practitioners should continue to wear other types of PPE if required for the task, e.g., aprons and gloves that would normally be used when applying hair dye.
- It is important to wear, handle and dispose of a Type II face mask properly. More detail on how to put on, use and take off a face mask can be found in s.6 of the government’s guidance, here: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/close-contact-services
- Members of the public are required to wear face coverings in premises providing personal care and beauty treatments. See here for more information: https://www.gov.uk/government/publications/face-coverings-when-to-wear-one-and-how-to-make-your-own/face-coverings-when-to-wear-one-and-how-to-make-your-own. Client’s face coverings should be worn while on the premises and only removed when essential for a particular treatment, i.e., a treatment on the face. A client may choose to wear a face visor and this is acceptable in addition to a face covering, not instead of it. This is because face visors do not adequately cover the nose and mouth and do not filter airborne particles.
- Help clients to wear their face coverings properly, using notices at the entrance. You are not obliged to provide face coverings for clients but you can control who comes onto your premises. The key steps for clients/face coverings are:
- wash hands/use sanitizer before putting it on
- avoid touching the face or face covering when wearing it
- change it if it becomes damp
- Exemptions - remember that not everyone has to wear a face covering if they have a legitimate reason not to. This includes those with a physical or mental illness or disability, or for whom the wearing of a mask will cause severe distress. More on this here: https://www.gov.uk/government/publications/face-coverings-when-to-wear-one-and-how-to-make-your-own/face-coverings-when-to-wear-one-and-how-to-make-your-own#exemptions
NHS Test and Trace
There a few business types that are legally required to follow the rules of NHS Test and Trace – this includes close contact services.
Businesses in this group tend to be those where services are provided on-site and where there is a high risk of transmitting COVID-19 because people on site may come into close contact with others outside of their household. Also, because these businesses necessitate people spending a while there, indoors.
Many other types of business, such as food retailers, may choose to be involved too and may voluntarily display their own QR code and encourage people to use it.
By following the Test and Trace rules you will help NHS Test and Trace to identify and notify people who may have been exposed to the virus.
As a business which provides close contact services you must be particularly vigilant about this. Ensure that you have created a QR code for your premises (at https://www.gov.uk/create-coronavirus-qr-poster). If you operate from more than one venue you will need a separate QR code for each.
The poster will be supplied to you via email soon after application. You will need to print it out and display it promptly so all visitors can see it and scan it when arriving.
You should encourage all customers and visitors over 16 to check in by scanning the QR code using their smartphone when they arrive at reception and check in for their treatment. At the same time, you should check their phone screen to ensure they have successfully checked in. At this point you could also ask your COVID-19 screening questions
– see the section entitled ‘pre service screening questionnaire,’ earlier.
Those who cannot or do not want to scan the QR code should provide you with particular pieces of information which you should then retain for 21 days, as follows:
- the name of the customer or visitor
- a contact phone number for each customer or visitor. If a phone number is not available, you should ask for their email address instead, or if neither are available, then postal address
- date of visit, arrival time and, where possible, departure time
- the name of the assigned staff member, if a customer or visitor will interact with only one member of staff (for example, a hairdresser). This should be recorded alongside the name of the customer or visitor
If you can also record arrival and departure times, this would be helpful too but isn’t a legal requirement.
If you are operating an ‘advanced booking only’ policy, then it’s likely that you will already have this information stored, in the event of someone not wanting to scan the QR code.
Scanning the QR code is the preference (as this automates everything) but keeping a logbook is the alternative for those who can’t/won’t use the QR code. A person should not do both.
Staff records (shift times and contact details) must be recorded too (which is usually the case anyway) and staff may choose to check in using the QR code as well, if they wish.
Where someone refuses to do either, the law doesn’t require you to refuse them entry providing you’ve done what you can to encourage them. However, as the proprietor of the business you have the right to refuse entry to anyone you wish.
If someone becomes unruly, follow your own security procedures, which might involve a call to the police if necessary.
For counter sales only, where the customer arrives to buy a product and leaves immediately, the Test and Trace requirements won’t apply. The same is true for deliveries or collections. If you believe that someone doesn’t have the mental capacity to provide the details then you won’t be breaking the rules if they don’t participate in the requirement to scan the QR code or to provide their details to you instead.
The person responsible for the organisation is responsible for ensuring that clients, visitors and everyone on site within scope of the rules are complying with the Test and Trace requirements. A fixed penalty fine of £1000 (rising to £10,000) may be applied if not.
The accuracy of the information given to you is the responsibility of the person giving it, not your responsibility. This means that you don’t have to verify an individual’s identity for this purpose.
NHS Test and Trace will only ask for your help (and your records) if someone who has tested positive for COVID-19 has listed your premises as somewhere they’ve recently visited.
Cleaning before and during reopening
Along with social distancing, cleaning is one of the most important control measures when it comes to COVID-19 and all your cleaning steps should be considered as part of your risk assessment. Especially when reopening, assess the task ahead and devote sufficient time and the right materials to it.
The Government’s guidance on cleaning outside the home (in a workplace) is here: https://www.gov.uk/government/publications/covid-19-decontamination-in-non-healthcare-settings/covid-19-decontamination-in-non-healthcare-settings
Cleaning after a known or suspected case of COVID-19 should follow specific guidance (also in the link above).
You may need ventilation or air conditioning systems to be serviced or adjusted having been out of use.
Allow time between appointments for cleaning seats, surfaces and items which may have been touched by clients or other workers
Door handles and other items touched frequently should be prioritised. Touch-free bins would be a good idea. As is not providing reading materials for clients, such as magazines, as these will need sanitising in between handling.
Toilets, changing rooms and washrooms
These can be kept open for staff and clients providing they are properly managed. Indeed, washrooms are essential for maintaining good personal hygiene. Your risk assessment should take toilets and washrooms into account.
If the use of changing rooms can be avoided (by asking clients to change and shower at home), then this will reduce the burden on you to manage them. Ideally, changing rooms will remain closed.
Posters and signage will be helpful reminders for all, in particular, the queuing arrangements (one in, one out? Floor markings?) – and don’t forget the likelihood of bottlenecks forming. Hot and cold running water, soap and drying materials too. For the avoidance of doubt, the use of hot air dryers is acceptable. Good ventilation is key, too.
Providing hand sanitizer for use prior to entering toilets is a good idea.
Providing extra cleaning and checks on facilities is sensible, including more regular removal of waste generated.
A useful poster on handwashing, from the World Health Organisation, is here: https://www.who.int/gpsc/5may/resources/posters/en/
Water and Legionella
A critical element in any salon!
The water system must be properly considered as water in tanks and pipework may well have been ‘standing’ for a period of time. Warm weather conditions may have created the right environment for Legionella bacteria to grow (Legionella bacteria thrive at temperatures between 20°C and 50°C). Given the COVID-19 pandemic and its effects on people’s respiratory systems, more people might be susceptible to Legionnaires’ disease than before.
- run taps for 5 minutes
- raise the temperature of tanks to at least 60 degrees
- disinfect tap and sinks areas
See the CIEH guidance on legionella for more information: https://www.cieh.org/media/4208/legionella-guidance-covid-19.pdf
Recent expert advice around COVID-19 suggests that good ventilation is one of the most important control risks for preventing transmission.
An adequate supply of fresh air in any workplace is important. A room with good ventilation is safer than an enclosed space with none. Ventilation helps reduce the risk of spreading the virus, whether that’s by mechanical ventilation or opening windows and doors (not fire doors).
Air conditioning systems should be set to ‘fresh air supply’ rather than recirculation.
Increase the ventilation rate as much as possible, without making the environment uncomfortable. Don’t forget to check filters in accordance with manufacturer’s instructions.
The Health and Safety Executive has produced some guidance on ventilation and COVID-19, including how to identify poorly ventilated areas and how to assess and improve the environment: https://www.hse.gov.uk/coronavirus/equipment-and-machinery/air-conditioning-and-ventilation/index.htm
Laundry and Waste
Disposable gowns and towels, or washable ones that will be washed in accordance with the manufacturer’s instructions, will suffice. No additional temperatures or chemicals are needed. See the Government’s guidance on cleaning: https://www.gov.uk/government/publications/covid-19-decontamination-in-non-healthcare-settings/covid-19-decontamination-in-non-healthcare-settings
Waste should be collected and removed as often as required to prevent any over spilling items. Black bags and usual collection arrangements will suffice.
If someone on site shows symptoms of COVID-19 or tests positive for it, then other steps should be taken – see the government’s guidance on cleaning, given above.
In an emergency, for example, an accident or fire, people do not have to maintain social distancing if it would be unsafe to do so whilst dealing with the emergency. But apply sanitation measures afterwards as soon as possible.
You’ll probably already be familiar with the requirements of RIDDOR reporting
(the reporting of accidents, diseases and dangerous occurrences) and for COVID-19 there’s clarification from the HSE on when to make a report:
What if I get an outbreak?
Your risk assessment should include a plan for this. It could include the following:
- Who will lead on making contact with the local Public Health Team
- What are the contact details? See https://www.gov.uk/health-protection-team
- You may need to provide assistance in identifying contacts via the NHS Test & Trace system
Businesses were able to register by 31st March 2021 for a supply of rapid lateral flow tests, for testing employees with no symptoms of COVID-19. This was made available as part of the approach to reducing transmission of the virus.
Read more information on this here:
Nearly ready to open?
Here’s a checklist as a final reminder:
- risk assessment – carry out your risk assessment and involve your workers in its creation – they may know the job better than you! Share the results with them too as these will inform the new working arrangements and the rules on site
- let your employees know the date of opening and the new arrangements and what they must do to protect themselves and others
- plan to manage demand – how many clients can you fit in at a time to meet social distancing? Will you prioritise clients or operate a ‘first come first served’ approach? What about a ‘vulnerable clients’ hour at less busy times? Longer hours, shift working? Waiting areas? Allow more time between clients for cleaning
- update your website with the new rules and how to book. If you don’t have a website, display the information at the entrance to the salon.
- contact your clients – see Advice to Clients (above)
- order equipment and cleaning supplies – make a list and allow extra time for deliveries:
- PPE (gloves, aprons etc.) and face visors/safety goggles
- Fit screens or barriers at reception and in between clients/workstations, if your risk assessment shows that this is an appropriate mitigation measure for your premises
- Cleaning materials – are they up to the job?
- Cleaning equipment such as mops and disposable or washable cleaning cloths.
- A steam cleaner if you have upholstered furniture
- Clothes washing powder/gel/liquid for towels/uniforms etc.
- handwashing soap and paper towels for washrooms
- hand sanitiser (which must be 60- 95% alcohol content) for clients to use (team members should wash their hands regularly using soap and water). Provide this in multiple locations throughout the premises
- disposable tissues near clients in case of sneezing
- bins and disposable bin liners
- additional waste storage
- sterilising equipment
- single-use tools for use where possible.
- towels/disposable towels
Clean, clean, clean!
- check everything works:
- water systems (see legionella information above)
- heating and ventilation systems
- electricity and gas supplies
- salon software
- payment systems
- put up notices on the door or window:
- your reopening date
- opening times
- how to make appointments
- your QR code
- advance warning about the protective measures you will have in place
- an instruction to clients not to enter your premises if they feel unwell or live with someone who is unwell
- display the Government’s poster so everyone can see your commitment to your responsibilities https://www.gov.uk/government/publications/staying-covid-19-secure-in-2020-notice
- put up notices in the salon as reminders:
- touch as little as possible and avoid touching retail displays
- sneeze and cough into tissues and dispose of the tissues immediately
- wash or sanitize hands, for example, after coughing/sneezing or going to the loo
- pay using contactless. Place a reminder at the till of the maximum amount that can be paid using this method to encourage clients to use contactless
- not to pass on cash tips hand-to- hand – use the containers provided.
- remove items that clients will handle, to save you the task of sanitizing in between each use:
- style/treatment example books. Ensure clients don’t handle iPads when showing styles/treatments online
- magazines and newspapers
- books and toys for children
- product testers
- leaflets and loose price lists
- only allow water to be consumed indoors, no food. Perhaps obtain a water cooler or a supply of bottled water?
Checking that you’re COVID-19 secure
From time to time you may be inspected by Environmental Health Officers from your local authority (local council). These are highly trained professionals whose job it is to check that you’re complying with the health and safety and licensing requirements applicable to your premises, keeping everyone safe. They will give you advice and may signpost you to templates and sources of information to help you. They work closely with the Health and Safety Executive.
Local councils’ websites are often a source of helpful and free information on many topics and are usually tailored for a local audience too.
You can find your local authority here: https://www.gov.uk/find-local-council
HSE’s COVID-19 enquiries hotline is: 0300 790 6787 or contact them online at: https://hsegov.microsoftcrmportals.com/workingsafelyenquiries/
Enforcement action is always a last resort and only usually used for persistent offenders, or those who have the most blatant disregard for the rules or when things go very wrong. Enforcement can mean the service of notices requiring steps to be taken, the use of fixed penalty notices, the closure of premises and prosecution.
England only, applicable from 12th April 2021
Q1: What are the rules about clients wearing face coverings and social distancing etc. when on my premises?
The law requires that members of the public wear face coverings in particular venues, including those businesses providing close contact services. This applies ‘other than where necessary to remove for treatments.’ Or where an individual is exempt or has a reasonable excuse. See https://www.gov.uk/government/publications/face-coverings-when-to-wear-one-and-how-to-make-your-own/face-coverings-when-to-wear-one-and-how-to-make-your-own
As the business proprietor, you are obliged to take reasonable steps to ensure members of the public comply with the law regarding the wearing of face coverings when on your premises.
You and your client will need to agree when it’s a sensible moment for them to remove their face covering and when to put it on again. Different treatments will necessarily mean different timings for on/off - do the best you can.
The most effective methods of preventing the transmission of COVID-19 are still social distancing and regular handwashing. These steps should still be followed as far as possible.
As the proprietor of the business, you set the rules for clients when they are on your premises, this means you can insist on them following your rules and/or decline to offer your services if they don’t follow them. You can also ask them to leave. Remember that you have a legal responsibility to protect anyone on site from harm, so if one customer threatens to jeopardise that, you should act accordingly.
Enforcement of face coverings worn by members of the public in shops and other indoor environments, is carried out by the police. More details are here: https://www.gov.uk/government/publications/face-coverings-when-to-wear-one-and-how-to-make-your-own/face-coverings-when-to-wear-one-and-how-to-make-your-own
Q2: Do I need to close my business if a customer tells me that they have tested positive for COVID-19 after they have been for a treatment in my premises?
The customer should confirm to you that they have been in contact with the NHS Test and Trace service and are following the advice given.
(If the customer has not followed the advice given then contact your local health protection team for advice).
Test and Trace will be interested in those people that the customer has been ‘in close contact’ with during the 48 hours prior to developing symptoms and since developing symptoms.
Close contact means:
- having face-to-face contact with someone (less than 1 metre away)
- spending more than 15 minutes within 2 metres of someone
- have recently visited a setting with other people (which might include your premises)
You may therefore be contacted by Test and Trace, so be prepared to provide information about your workers and other customers that may have come into contact with them (see the Bulletin section ‘NHS Test and Trace’).
You will not automatically be obliged to close your business.
If you are working in teams or zones, as part of your mitigation measures, it might be possible to narrow down those who were more likely to have been in significant contact with the infected person, so only this team will need to self-isolate. This is why one of the suggested ‘mitigation measures’ is working in teams, or zones.
Q3: Should a practitioner wear a visor when providing services to clients’ hands, for example, a manicure?
Social distancing is the key here. In reality, 2m is likely to be unachievable when providing a manicure for a client, so 1m + mitigation is needed.
In the case of a manicure, a screen of the right size between the practitioner and the client is likely to be satisfactory in most cases. This will achieve 1m + mitigation (the screen being the mitigation).
Your risk assessment should assess how the manicure is carried out in your particular premises, to make sure a screen will suffice.
Consider if other services are being provided close by, as additional screening might be needed if distances are less than 2m.
Don’t forget to check the list of other mitigating measures too, and put into place as many of these as you can.
Q4: What about having children on the premises?
There are no specific rules about children other than that salons should request that clients keep children under control in order to most effectively reduce any risk of spreading the virus. Ideally, clients will also arrive alone and on time (so as not to cause a queue in reception which will have to be managed – and might require customers to wait outside).
Q5: Should I keep the toilets closed or restricted to workers only?
No. With the right steps in place, there is no reason to close your toilets. Remember to increase the cleaning programme and the checks on availability of soap etc. and to empty the waste more often.
Q6. Can I continue with my ‘drop in’ system, rather than appointment only?
It’s best not to. The government guidance says businesses should operate an appointment only system, maintain social distancing in waiting areas and consider moving to a one-in-one-out policy if available space is an issue.
When taking bookings, this provides an opportunity to ask the client the screening questions, as outlined in the earlier part of this Bulletin, which is a really effective way to keep COVID-19 out of your premises. When taking bookings you could also alert the customer to the requirement for scanning the QR code or providing details to you if unable to do so.
If the client has any of the symptoms, however mild, they should stay at home and reschedule their appointment. Contact the NHS too.
Q7. Why should I only offer bottled water or water in disposable cups?
This helps keep things simple. If you continue to offer the full range of refreshments, this generates a lot of equipment which will need washing and sanitizing or disposing of, plus someone to collect it all and handle it safely, generating additional movements around the premises and bringing people closer to each other than strictly needed. If your risk assessment can demonstrate that you’ve thought about all of this and can safely continue to offer a wider menu of refreshments, then you could continue to do so.
Q8: What about the use of fans in the salon during hot weather?
The government has not specifically made any rules or recommendations about this. Good ventilation is sensible because air changes help remove the virus from the vicinity. Fans used with windows shut could conceivably spread the virus in a closed environment. Fans + open windows are better. There is more information about this from the Health and Safety Executive: https://www.hse.gov.uk/coronavirus/equipment-and-machinery/air-conditioning-and-ventilation.htm
Q9: Should I be temperature-screening clients on arrival using a thermometer gun (a non-contact infra-red thermometer)?
No. Elevated temperature is one of the symptoms of COVID-19. However, it is possible that someone may have the virus but not exhibit any symptoms and their temperature may show as normal. Equally, someone may have an elevated temperature for another medical or physical reason, not connected to COVID-19.
Add to this the fact that the equipment itself may be untested or uncalibrated or used incorrectly or the readings misinterpreted.
Therefore, relying solely on this is risky. Temperature controls could be part of a screening process which includes further questions about medical history or recording very obvious symptoms – this would all be part of the risk assessment that you use to determine whether a client may be booked for an appointment.
Links to Other Sources
Working Safely during coronavirus (CIVOD-19), including its 14 chapters for different sectors, including Close Contact Services (hair and beauty sector):
Coronavirus (COVID-19) pages: https://www.gov.uk/coronavirus
Transmission characteristics and principles of infection prevention and control
From the National Hair & Beauty Federation
Website: with links to a Reopening Guide, FAQ, risk assessments and other documentation. Available to members and non-members (some free of charge).
Chartered Institute of Environmental Health
Reopening salons and spas following lockdown
Looking after your mental health and wellbeing: https://www.cieh.org/media/4153/covid-19-health-and-wellbeing.pdf
From the Health and Safety Executive
Website: Risk assessment, communicating with workers, protecting the vulnerable, cleaning, etc.
The control of legionella: https://www.hse.gov.uk/pubns/priced/hsg282.pdfBack to top