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Dealing with visits from regulators to your pubs

As the hospitality industry is gearing up to reopen, so too are the teams of regulators, including local EHOs, Police and Licencing Officers, preparing themselves to ensure the Covid Secure requirements are being followed.

We have asked our Trusted Partners from Shield Safety Group to give you some tips to help you prepare for any visit. SSG also run the BII’s free EHO Helpline for members only and are there to support you in every aspect of risk and compliance going forward.

 

Covid 19 Risk Assessment

 

  • It is very likely that any visit from a Regulator will focus on the risk assessment. It is therefore of high importance that the document is accurate and understood by all team.
  • It’s a legal requirement to record the significant findings of your risk assessment if you employee more than 5 people, but we strongly recommend you have one in place even if you employ less than this – it will prove that you understand the risks and how best to tackle them
  • Include your team in the risk assessment process – get them thinking about how to deal with issues as they arise
  • Train your team how to conduct the task you have risk assessed, they must understand the control measures you have in place.
  • Keep a record of the training you have given, and keep a copy of your risk assessment. Don’t forget to update it if things significantly change, and review it regularly.
  • Be very clear in the risk assessment those activities that are not permitted at this time, for example live music.
  • Don’t forget your Fire Risk Assessment. You will need to review your assessment to identify if there has been any impact from changes in the operation.

 

 

 Records up to Date

 

  • By maintaining accurate records, you are demonstrating compliance to the Regulating Officer.
  • Ensure your records are up to date and ensure all members of the management team know the location of them and are able to discuss the contents with the Regulating Officer.

Documents that need to be up to date include: food safety, fire safety, health and safety, risk assessments, return to work questionnaires and daily and weekly checks. If you are unsure what is required, then please do contact the BII EHO Helpline and they will support you.

It is recognised that sometimes things do not go as planned. It is important to record when this is the case and then note the corrective action to bring the non-conformance back on track.  Regulators are rightly suspicious of pages and pages of ticks and are more interested on what action has been taken if issues have been identified.

  • Consider implementing an Incident Log of when guests have not followed the social distancing requirements or other Covid controls. Again, this will help to demonstrate the action that has been taken by the site if issues have been identified.
  • Remember that there is an expectation that a record of all guests and visitors will be maintained and these details kept for at least 21 days. 

 

Communication with Team and Guests

 

  • Posters, floor markings and messages on websites and social media are all great way of demonstrating how you communicate the expected behaviour to both team and guests. Make sure these communications are in place and easily readable.

The BII have created some excellent “Positive Posters” for you to use – download those here.

 

Other aspects of safety

 

  • Whilst the focus is likely to be around controls for Covid, the other elements of food safety, health and safety, fire safety and licencing must be adhered to. One way of helping demonstrate this is by showing the pre-opening checks you have completed.
  • If you do not have an opening checklist, you can access more information from Shield Safety.

 

 Work with the Officer

 

  •  As with any new piece of legislation or guidance, it will be subject to interpretation. The BII is working hard alongside the other key trade bodies to ensure that the local authorities are offering a consistent service across the board to avoid conflict and confusion.
  • If the Officer has concerns, be open to discussing them and understanding what further controls are required. If you are unsure, go back to the government guidance to understand the requirements.
  • If you believe the request to be unreasonable or a misinterpretation of the requirements, further support can be found through contacting the Helpline.

 

 Keep up to date

 

The coronavirus situation is fast moving and changing constantly. This is true for you as a licensee and for those responsible for enforcing the requirements. Keep up to date with the latest requirements and ensure your team are aware of any changes. All amendments must be captured in the risk assessment and team training.

Remember, if you have residents or businesses who are opposed to your premises, they often turn to the local council or Police for action. In the past this may be to report instances such as alleged noise nuisance, antisocial behaviour or littering.  In the same way, those opposed to you trading could use any alleged breach of Covid controls to report your business.

In these cases it is even more important to ensure controls are being followed and you are able to demonstrate this to the Regulator.

For all queries relating to any H&S issue, your BII EHO Helpline is available from 8.30am to 5.00pm, Monday to Friday. All 7 of the BII Helplines can be found on our Helplines page.

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