Restarting our services safely

Beyond Level Zero - What the Scottish Government restrictions and practice guidance say now

From the 9th of August the country moved to a new set of protective measures which are sometimes described as beyond level 0.  This means the previous protection level system is not currently in use and many restrictions previously in place were relaxed further. 

An overview of the current requirements and advice in Scotland is available here.  Basically, it means that many of the restrictions to reduce the impact of the virus either no longer apply, or have been reclassified from mandatory legal requirements to highly recommended  advice.  Here is more information on the precautionary and mandatory measures currently in place.

Remember:

The virus is still a real threat and a reminder that variants of concern can still emerge and threaten to undo the progress we have made so far. The Scottish Government has said that other restrictions could be reintroduced if transmission of the virus keeps  increasing. 

Since this is something none of us wants to see the SCS team recommends that, to be extra safe, follow the good practice advice in the government's guidance as though it was still a mandatory requirement. Also make use of the Scottish Government’s Stop The Spike toolkit to help those using your services do all they can to keep us all safe during this period of increased infections.

Summary of measures affecting community organisations and services

It's important to note that:

• Previous guidance for Community Learning & Development settings has been archived and is no longer available.

• Guidance for Community centres and facilities has also be archived

There is now one main source of Scottish Government guidance about what is permitted and/or recommended. This is the Coronavirus (COVID-19) Safer business and workplaces guidance.

The key messages for each area are summarised below.

Face coverings

Legal restrictions: These must be worn in most indoor public places

Guidance and advice: Here are the details of where face coverings must be used - including community centres, leisure facilities, libraries etc.

You should also read SCS information on face coverings.

Physical distancing

Legal restrictions: Although not required by law physical distancing is still strongly recommended in the current guidance.

Guidance and advice: The guidance below strongly encourages you to think about ways to maintain safe distancing and suggests voluntary adoption of measures including; limiting numbers to manage capacity, keeping one-way systems and having signs to support distancing.  Please look at the section on Good Practice in particular.

You should also read SCS information on physical distancing.

Risk assessment

Legal restrictions: You must still carry out careful risk assessment to keep your staff and service-users safe from COVID. These should be kept under review and updated regularly

Guidance and advice: The government expectations of your risk assessment are described here. We provide more information on assessing risk and producing the assessment later in this section.

You should also read SCS information on risk assessment.

Ventilation

Legal restrictions: The previous guidance on ventilation and the need to maintain good air quality not only still applies, but has become increasingly important as more indoor activities start up again.

Guidance and advice: The safer business and workplace guidance on ventilation can be found here. Our advice, supported by Health Facilities Scotland, on practical steps to achieve good ventilation is available here.

You should also read SCS information on ventilation.

Cleaning

Legal restrictions: Good hand and respiratory hygiene and surface cleaning measures are already a key health and safety requirement for safe workplaces. 

The safer business and workplaces guidance also advises that, as a precautionary measure you should maintain a robust cleaning schedule as part of COVID basic mitigation measures.

You should also read SCS information on cleaning and disinfection.

Guidance and advice:

• Guidance from the Health and Safety Executive on cleaning here.

• Safer businesses and workplace guidance on cleaning measures here.

• Our advice on cleaning and disinfection can also be found here.

Testing

Legal restrictions: It continues to be a legal requirement that everyone must follow Test and Protect rules i.e. self-isolate immediately if you have symptoms and book a test, even if you have had two doses of vaccine.

In general, if you have no symptoms but have been identified as a close contact you can end self-isolation if you have had two doses of vaccine and have had a negative PCR test.

The safer business and workplaces guidance has specific information on what to do when someone tests positive or becomes unwell whilst at work.

In general there is no longer a legal requirement to collect contact details of people who use your services, unless you are a hospitality venue.  This includes cafes, restaurants, pubs and nightclubs.  Many community venues let out buildings for private functions - there is no specific mention of this in the guidance.

Ensure that... 

• those hiring your space  are very clear about your COVID safety rules.

• they follow your process for collecting peoples details for test & Protect

• that they submit their risk assessment or tell you how they plan to keep people safe.

• that users comply with your instructions on ventilation of the and your physical distancing capacity limits, spacing of people and equipment etc.

• that everything is as it should be during the activity.

• the space after use and before it is used again.

You can register your premises with Check-in Scotland to make it easier to collect contact details.

Guidance and advice:

• You can email the National Services Testing mailbox here.

• You can find out about registering for Check-in Scotland here.

You should also read SCS information on testing.

Vaccination

Legal requirement: There is no current legal requirement to get vaccinated, however the Scottish Government strongly encourages everyone to accept the invitation to be vaccinated as soon as it is made. Employers are encouraged to support the national effort to increase vaccination uptake by; highlighting the benefits of vaccination, making accessible information from trusted sources available to all employees and volunteers, and allowing paid time off to attend appointments.

Guidance and advice:

• The safer business and workplaces guidance on vaccination can be found here.

• General information on vaccines can be found here.

You should also read SCS information on vaccination.

If  you are a community group, third sector organisation or volunteer network you will have a particular relationship with your community and your service users. You will often need to assess risk in your service taking the needs of a broad range of people,  including those who are especially vulnerable to COVID, into account . 

The values of community organisations put the needs of communities first. We suggest that it is helpful to apply the following principles to the actions you take to protect people to help your planning.

Our risk assessments and the things we do as a result will:

• Maintain the maximum public health protections for our service users, staff and volunteers and our wider community.

• Ensure that we avoid the legal liabilities that could damage our services and communities by taking all steps to avoid transmission of the virus.

• Achieve both of these while delivering services that meet the needs of those we work with.

Requirements to responsibilities - what it means in practice

It's now easier to find the official guidance on restrictions during the recovery as it's mainly based on a single source for business, public services and communities. This tries to balance the public health risks, economic factors and individual freedoms by permitting more people from different households to mix and reducing the legal restrictions on doing so.

The current Scottish Government guidance puts it like this.

“Moving beyond Level 0 does not signal the end of the pandemic.  Although many legal restrictions will be lifted, and many people are now fully vaccinated, it is still possible for the virus to spread between people. It will continue to be important for everyone to remain cautious and follow guidance on precautionary measures.”

So, the guidance urges community services themselves to make good decisions about what is safe. It's clear that the Government wants you to build on the mandatory safety measures and, if it's appropriate, to keep doing those that you think work.  This is likely to include  some which were part of the previous restrictions. Here is an example of what the latest guidance says about physical distancing, something no longer required by law.

“Although the law has changed, it is important people keep thinking about how the virus can be transmitted. We would encourage people and businesses to think about how best to use the space available. Where practical and appropriate, this could include the retention of certain measures such as:

• voluntary limits on maximum capacity where appropriate

• manage the inflow/outflow of premises through ongoing use of one-way systems and/or traffic lights systems

• protective screens

• table service/apps for ordering

• electronic ticketing”

What  this means is that the responsibility has shifted from government instructions to community organisations making informed judgments. It may be that to make good ethical decisions about people's safety, in line with your organisation's values you choose to do more than what the law dictates. 

If you are open now, or thinking about re-opening soon we encourage you to keep thinking carefully  about what is safest for your service users, staff and volunteers. This involves implementing both the remaining restrictions and the good practice advice in the latest government guidance. 

We strongly suggest that, for now, you should stick with physical distancing for a little while longer. We recommend 1.5 metres where practical.   

We encourage you to use our bespoke space calculator to calculate the number of people who can safely use your space safely.  Enter whichever physical distancing measurement you have decided to work with and the size of your space in square metres.  It will work out the maximum number of people who can safely do so.

The reason we suggest 1.5 metres  is based on what happened when we thought about our premises, a large city centre office in Glasgow used for meetings, as staff base and other activities. 

Since we practice what we preach we used Supporting Communities safely to carefully measure the office and think about what different distancing amounts would mean for us.   Our actual workings for the decision are set out below.

• We took accurate measurements  following the SCS step by step guide.

• We ensured that all of our windows can be opened to ensure a really good air exchange rate throughout the building. We will be monitoring this as we go. 

• Using the calculator we noted staff capacity in each room based on 1m, 1.5m & 2m 

• We chose the dynamic category as there is a fair amount of ongoing movement in our rooms.

• We rejected 1m as impractical as we felt this would be too little space and also impossible to enforce.

• Two metres felt like more than we needed given the improving situation.

• We therefore settled on 1.5m but intend to keep this under review if more people develop the illness or the scientific advice suggests we should do so. 

Liability

Whilst we know that people’s safety is the biggest concern for community organisations, it is important to remember that, if you are also legally responsible under health and safety legislation and as operators for a facility or service, you are expected to put effective health and safety measures in place to minimise the risk of and spread of coronavirus and other risks. This has implications for your governance and particularly issues like insurance. SCVO has produced useful advice on this. 

This section has some tips on things to think about when planning to re-open or reviewing whether you should stay open.  It’s important to remember that even where guidance suggests that opening is permitted or that restrictions have changed there is still a requirement for local groups to carefully assess their own circumstances and make judgements on what to do, when and how.  You are unlikely to have needed to make these kinds of choices very often before. Decision-making should be influenced by current public health information, ongoing discussions with your communities and what tools and resources are available to you to help you keep people safe. We recommend being thorough and systematic in considering the issues. Below are some suggestions that might help you to do this.

Who should be involved in decisions?

Your group should take the time to really think about these questions. They are the foundation of making good decisions about risk and what to do next.  It's also important to make sure you take account of other views.  We recommend that you:

Spend some time thinking it through on your own:  If  you are co-ordinating a service it's important to have clarity about what’s permitted, to inform decisions on how to proceed. This will help others with assessment and planning processes.

Get the right people together: You will need to develop a collective view by sharing your thinking and testing your assumptions with the other people involved. This might include staff, board members or volunteers who have:

• A sound understanding of what you do

• Current practical knowledge of how your service works day to day

• A clear idea of the needs of your users

• Ability to judge what is feasible and how users might respond 

Plan a safe space for discussion: This could be online, in the park or a well-ventilated place where you can observe basic mitigations of face coverings, physical distancing and good hand hygiene.

You could also invite service user representatives to share their ideas and, if possible those from closely associated services. This might include staff from the centre where you rent the room, the community transport group etc. Once you have discussed the issues carefully take note of what you decide and what needs to be done next.

Should we open up now?

Community facilities  are now legally allowed to open with very few compulsory restrictions.  However, at the same time we are also still encouraged to work from home where possible, and outside if we can when delivering services.   

Perhaps a better question to consider about our services is whether the types of services you provide can be considered ‘essential’ enough in the short term for the wellbeing of those you support, or whether what you provide could be delivered in another way e.g. online for a bit longer.  

Examples of essential services might include; crisis services for homeless people such as provision of shelter, emergency food or other aid,mental health crisis services, one to one counselling and/or therapy services, respite services and provision of social support  to very vulnerable people.  Examples of less critical services might include; leisure and recreational services in areas where people have fewer life pressures, activities where a further delay in reopening may be unfortunate but not critical to wider wellbeing. These examples are not exhaustive and we know that many services have already re-opened. 

In a context where we know that transmissions can rise unexpectedly and quickly the key decision is whether the risk of not opening outweighs the risk of opening, and adding to transmission of the virus.  This is something to consider carefully and honestly, whether you are reviewing your decision to start again or re-opening for the  first time.  The government has identified four harms which affect people in Scotland arising directly or indirectly from the impact of the virus. Thinking about these could help you to make decisions.

You are the people on the ground who now need to make these decisions. If you can make your services safe by reliably implementing current mandatory guidance and good practice advice you should be able to run services safely. If you can't do this for some reason then there is a real possibility that your service could be the cause of an outbreak in your area, and unfortunately we have heard of examples of this happening. Delaying your re-opening for a bit longer and supporting people in other ways is probably a good idea at times when infections are rising.

Although there are now fewer COVID restrictions overall, the latest Scottish Government guidance still requires you to regularly risk assess the situation for their users and staff. Ths link takes you straight to what the guidance says about this.  

COVID risk assessments should be linked to whatever else you do in relation to risk assessment generally.  If  that is an informal approach this would be a good time to do something more systematic. Ultimately, you need to be able to answer these questions

• Are you sure that you are able to run your service with minimal risk of service users or staff picking up the virus?

• Are you sure that delivering your service won't increase the risks of community transmission?

• Do your actions reduce risk, protect users, and your organisation in terms of liability for actions that could cause harm or injury?

If the honest answer to any of these is no or not sure, you should go back to your risk assessment and strengthen your plans to make your service safe.  If it does not support a reasonable belief that you can open safely you should delay until the conditions are more favourable.

Balancing harms

In the previous section we considered  balancing the harms which affect individuals and communities. Although  what is permitted is now more flexible you are still expected  to carefully think about risk and respond to it.  The risk assessment is about showing how you have made decisions that can be used to do practical things which protect everyone. 

The earlier sections ask you to consider important questions about the nature of your activities and the needs of your users as part of decision making about if, when and how you restart services.  These are the early stages in producing risk assessments. and are an important way to plan and record what your doing to make sure that:

• All hazards are spotted and planned for

• Everyone knows their role in dealing with them

• You  monitor how safely you are delivering and if anything needs to change

If done well, risk assessments  are systematic, publicly available documents which reassure yourself, your service users, partner organisations and funders that you have really thought about how you can keep people safe. Don't write more than you need in a risk assessment but, where others need to know what's happening to play their part properly a written document is important.

They might seem complicated but we all do risk assessments every day, when we cross the road or decide what we can let the kids do on their own.  With COVID-19 the thought process is the same but there are more factors to think about including:

• What do we know about how the virus behaves - in the air and on surfaces?

• How does it affect different kinds of people?

• How does it move from person to person indoors and outdoors

• How do the spaces we use and the things we do help or hinder it’s spread?

What we need to do to stop its transmission?

Here are some thoughts from Jason Leitch National Clinical Director, NHS Scotland on the factors that matter in assessing risk for the people you support, in your activities and the buildings you use. These factors mean that you need to think carefully about your own circumstances and the risks involved, and devise their own individual plan.

Jason mentions guidance for the nature of risk for individuals from COVID , especially staff. This may also be useful in helping thinking about risk.  Although his comments were made some time ago when the first lockdown had come to an end, they are still relevant to where we are now in Sept 21.

Identifying and overcoming risks

We know that even though fewer people get very ill from COVID now stopping it spreading is vital in every aspect of our life or in delivering our services, so we must minimise chances for it to move from person to person. 

Though we may be tired of hearing it, sticking to the basic mitigation measures on face coverings, hand hygiene, avoiding close contact between households and isolating if infected are still the foundation of what we need to do to minimise risk.

How your risk assessment should be structured

Writing things down is an important part of planning, reflecting and delivering safely, especially if you need to share the thinking and expected actions with other people. Your assessments don't have to be long and complex, but they should carefully note the risks, how you're going to reduce them, and who's doing what to get this done. If you're running services you will already be doing some form of risk assessment or contributing to one prepared by others. COVID risk assessment is an extension of this.

When we are dealing with coronavirus risks the detail is very important. How much detail will depend on the complexity of the service, where it takes place and the vulnerability of those using it. 

Your COVID risk assessments need to be able to identify where risks might be  and think through;

What are the vulnerabilities in my service and those who use them.

• How do you make it safe to: 

  • Get there - especially of you provide transport

  • Get in and out - entry and exit points can be tricky to control ,especially on shared buildings.

  • While people use you services - being aware of COVID safety when you have control of the environment in the spaces you working in

  • And also in shared spaces like kitchens and toilets - where your safety measures are only as good as the others you share with 

  • How you work with service users to maintain basic measures like physical distancing of using face coverings and keeping the place really clean

• How you work co-operatively with others using places to build the safest environment possible

• How you monitor what's going on and keep on top of anything that needs to change

Clear links between; the risk, what you do to minimise it and who is doing what are the key to risk assessment. How you set this out on paper and communicate it to others is important.  

There are lots of really useful advice and risk templates that can help you to think about how you might do this, and the SCVO Coronavirus Hub brings together all of the main Scottish Government guidance for different kinds of service delivery settings, alongside other materials on assessing risk. Their page on safer premises provides comprehensive advice on how to make your premises more COVID secure, with links to materials developed across the UK. This includes information for small multi-use halls. 

You will need to find the templates that suit you and there are lots of examples online.  Here are three that we would recommend you take a look at: 

• A guide and set of templates from the Health and safety  Executive including a form that you can edit for your own group and save as your own risk assessment.

• Another for small community buildings and village halls developed in England but also useful for groups in Scotland. When using this one,make sure that you are applying up to date Scottish rules on basic mitigation alongside the useful general advice it contains.  

• The Scout movement have produced a number ofrisk assessment templates for different activities, and offers some tips on what you need to consider and how to lay it out.

Ask for help when you need it

Assessing and dealing with risk should be quite straightforward for some activities but for other, more complex situations you might need help. This might be delivery of different services in one location with different groups, or the same services taking place in a number of locations in community premises, in the outdoors or in people’s homes. We suggest that if you are unsure about the right course of action you should ask for more help from  local contacts for Health Protection Teams for your area. 

The other source of local advice are local Environmental Health Teams. This link takes you to the Food Standards Scotland website where you can enter your own local authority area and get an up to date list of contacts for your local team.

These services give information and advice to a wide range of groups, services and business. You should try and make contact as quickly as possible to give them time to respond to your questions or enquiries. 

Further information

For more information on this document you can contact:

Mick Doyle from Scottish Community Development Centre on Mick.Doyle@scdc.org.uk

Other Links:

• NHS Inform

• Ready Scotland

• Health Protection Scotland

• Scottish Government

• Food Standards Scotland

• Public Health Scotland

• Scottish Community Development Centre

• Guidance for the Community Learning and Development (CLD) sector
  
  

Next page: Creating Covid-safe spaces

Further information about SCS