On 22 February 2021 the Prime Minister announced a “roadmap” out of national lockdown. As part of this we can once again look forward to organised sport making a return to our lives from 29 March 2021.
The benefits of the return of grassroots sport are sure to be felt nationwide, with not only the physical and mental health benefits, but also the benefits to local communities. However, before players can resume their chosen sport there are some health and safety considerations for all clubs seeking to open their doors again.
A risk assessment should be the first action taken, and be formally documented. Under the Management of Health and Safety at Work Regulations 1999 the essential points that must be covered by the assessment are:
- Identifying what could cause injury or illness (hazards);
- Deciding how likely it is that someone could be harmed, and if so how seriously (risk); and
- Taking action to remove the hazard, or if this is not possible, control the risk.
Whilst no club can be expected to eliminate all risks, they are expected to take all reasonable steps to protect people from harm. A balanced view should be taken, weighing the risk itself and the measures to control it against the time, cost and trouble to do so. The decision, along with any steps taken and the reasoning behind them, should be recorded within the formal risk assessment document.
Some examples of steps to mitigate an identified risk could be:
- Provide, replace or amend the equipment, process or policy (e.g. providing personal protective equipment (PPE), and limiting the number of individuals on site)
- Introducing new processes to mitigate the risk (e.g. implementing “one way systems” around sites and cleaning all training equipment before, during and after use; and
- Organising to reduce exposure to the risk (e.g. staggering or limiting the use of locker rooms/showers.)
By now we are all familiar with the impact that COVID-19 has had on our lives. At the time of writing, the Government have not issued specific guidance on how organised sport should return, but have stated in their roadmap that it should be “compliant with guidance issued by national governing bodies”.
However, as we are all too aware the COVID-19 guidance can change suddenly and drastically, meaning clubs should keep a close eye on the guidance as they continue to return to play.
Steps that clubs could consider to mitigate the risk presented by COVID-19 during a phased re-opening are:
- Regular testing of members and staff;
- Temperature screening of individuals on arrival;
- Use of PPE where appropriate (e.g. correct wearing and use of face masks by staff, coaches and members wherever possible and provision of hand sanitiser at key touch points such as entrances, exits and bathrooms);
- Social distancing measures (e.g. where possible members, staff, players and coaches should maintain a distance of 2 metres apart). Additionally clubs could consider limiting the number of individuals on site (e.g. limiting attendance by only one parent with a child at a time), and when spectators are allowed to return, limiting the number on site to allow for social distancing to be maintained;
- Regular cleaning and disinfection of equipment (including balls and other equipment used in games and training) and other frequent touch points;
- Controlling the use of facilities to reduce chances of transmission (e.g. closing or strictly limiting the use of: changing rooms, locker rooms, shower facilities and ensuring all bathroom/toilet facilities allow for social distancing to be maintained);
- Prohibit the sharing of personal equipment (e.g. no sharing of water bottles, food, personal clothing etc.); and
- If someone tests positive for COVID-19, or arrives with symptoms, have a procedure in place to deal with this.
With many clubs having had to close their premises during the national lockdown, there is a risk of water system stagnation due to the lack of use, which in turn increases the risk of Legionnaires’ disease. A risk assessment should cover the hazards and risks associated with this. Clubs should also bear in mind it is not just water systems, but also certain types of air conditioning units that present a risk in this scenario.
Some basic steps to consider in light of this are:
- Flush the system fully to prevent water stagnation;
- Ensure the system is clean; and
- Change out any condensate trays, humidifiers or other components where water can stagnate and allow bacteria to grow.
Clubs may require a specialist plumber or technician to assist with this, and should ensure all steps are taken before a premise is open and occupied again.
Club catering facilities, in whatever form they may take, should follow the latest government guidance for hospitality venues. At the time of writing, premises can only offer food and non-alcoholic drinks for takeaway until 11pm. At all times, social distancing should be maintained and appropriate PPE worn by both staff and customers.
People should not share food or drink, and ideally should not consume food on the premises until further along the re-opening roadmap. Anyone wishing to eat and drink on site should use only their own water bottles and containers to mitigate the risk of transmission.
Subject to each stage of the Government’s roadmap being achieved on schedule then catering facilities will be able to offer outdoor service from no earlier than 12 April 2021. This will likely be subject to limits on the sizes of groups, such as the rule of six, or two households; meaning groups should be no larger than six people, or if they are, then the individuals should be from a maximum of two separate households.
Again subject to the Government’s roadmap, from no earlier than 17 May 2021 indoor service will be allowed. As previously this may be subject to limits on group size, and it is advisable for clubs seeking to re-open catering facilities to always check the latest Government guidance.
There are also some general points which should be considered by clubs as part of their health and safety risk assessment before re-opening:
- If buildings have been closed and left un-staffed for a prolonged period, a thorough inspection should be undertaken prior to re-opening to check for any defects that could present a risk;
- In addition to the requirements placed on clubs by the Government’s legislation and guidance relating to COVID-19, all requirements from existing health and safety legislation should continue to be complied with;
- When spectators are allowed to return, clubs should consider the capacity of their venues. This may mean needing to limit the numbers attending training or fixtures and stagger arrival/departure times;
- Clubs should provide staff members and other individuals integral to the running of the club, with training on any new systems, policies and equipment and ensure this is delivered (and documented) before re-opening; and
- Clubs must remember that personal data concerning health is considered as “special category data”, which means they must not disclose specific details of any individuals who have tested positive.
The most important step is for clubs to undertake and document a thorough risk assessment, and then take any appropriate action to mitigate the risks identified before return of grassroots sports on 29 March 2021.
COVID-19 will obviously be at the forefront of everyone’s minds, but clubs should not allow this to distract from other risks relating to the general day-to-day activities of the club both on and off the pitch.
All reasonable steps should be taken to mitigate any risk and consideration given that it may not be practical to completely remove every risk. Whilst the points raised in this article are not exhaustive, and every club will have to consider their own circumstances, it is hoped that it provides a starting point for anyone unsure of what steps to take to ensure the safety and well-being of their staff, members and visitors.
Author: Luke Singleton