Re-opening Church halls
Welsh Government Guidance has now been issued about the re-opening of community centres (including church halls). This should be closely followed by local trustee bodies as they seek to re-open their halls. A Church in Wales guidance note is available below with links to Welsh Government guidance.
Please read the guidance below then download:
Guidance on re-opening of church halls
Guidance on re-opening of churches for visitors
Church Halls fall under the definition of community centres under the Health Protection (Coronavirus Restrictions) (No. 2) (Wales) Regulations 2020(1).
Section 12states that community centres may be opened. Section 14 confirms that people may gather indoors and outdoors for certain purposes.
The purposes for which people can gather are limited but somewhat detailed and reproduced in the appendix to this note. The point is that halls can only be opened to provide voluntary or charitable services that meet these purposes. You cannot operate services from a hall which the public has no legal right to leave home for.
Welsh Government guidance on this provision is available at:
MACs/PCCs should follow Welsh Government guidance in re-opening their halls.
Set out below are some key considerations in the light of Welsh Government guidance.
General Considerations for the Re-opening of Church Halls
There is no longer a requirement to seek local authority consent to use of your hall but in order to understand which activities are allowed to take place those responsible for the hall must also familiarise themselves with, and adhere to, regulation 14 of the Health Protection (Coronavirus Restrictions) (No 2) (Wales) Regulations 2020 which details the restrictions on indoor gatherings and regulation 14A in respect of outdoor gatherings and the reasonable excuses for doing so in both cases.
In simple terms, PCC/MACs must not allow activities to take place either directly organised or by hiring to a third party which are not covered by the legitimate reasons for leaving home. Activities which would clearly be legitimate would include:
- Children’s play groups and nurseries
- Blood donation services
- Wedding receptions and funeral wakes (with a limit on attendance of 30 and see https://www.ukhospitality.org.uk/page/WalesGuidance for more advice on how to operate such events safely).
- Exercise classes
It should be noted that gathering for outdoor activities should be limited to 30 people.
In particular, our understanding is that buildings may not currently be let to commercial operations which are not included in the list at Appendix 1 (such as weight loss clubs which do not include exercise) nor for activities which are purely social with no element of “service”, nor which are closed activities for the members of a club or society only (and therefore not “public”).
It is strongly recommended that any decision to re-open a hall and to permit community activities (either directly organised or by hire to third parties), should be clearly minuted by the PCC/MAC, with an explanation of the reasoning adopted in coming to that decision, in case questions are raised at a later date.
In opening the hall, you are obliged by law to take all reasonable precautions to prevent the spread of coronavirus.
The operation of the hall, and any activities within it must comply with Covid-19 secure guidelines. The principles of these are the same as for opening churches or any other building: maintaining two-metre physical distancing between people, ensuring regular hand washing/sanitizing and regular cleaning of premises especially surfaces.
You should carefully review the Track Trace and Protect guidance referenced in the Welsh Government guidance. NB Regulation 12 of the Health Protection (Coronavirus Restrictions) (No 2) (Wales) Regulations 2020 places a duty on those responsible for the community centre to collect contact information from each person at the premises or, in relation to persons from the same household, from one of them, and retaining it for 21 days for the purpose of providing it to the Welsh Ministers or to a public health officer upon either’s request. A consent form and privacy notice can be found on the Church in Wales website.
Church Halls are facilities provided by a MAC/PCC as building manager in which activities are organised. Some of these activities are operated directly by the MAC/PCC whilst others are operated by a third party (a user/hirer).
Considerations for the MAC/PCC as Building Manager
As the building manager, the MAC/PCC has an overall duty to make sure the building is used in such a way as to prevent the spread of coronavirus. This means you should take reasonable steps to ensure activity organisers plan their activities appropriately. It is not sufficient to ‘leave it to the user’. You should:
- Review the Guidance: Take time to work through the guidance from Welsh Government at https://gov.wales/safe-use-multi-purpose-community-centres-covid-19
- Prepare: Make sure the building is ready for use including maintenance checks, electrical and heating checks, check water systems (e.g legionnaires disease measures). The grounds and access routes should be tidy and safe
- Survey and measure: survey the building to think about how its layout would impact on maintaining 2-metre distancing. Consider walkways and access routes in and around the building. You need to calculate the safe capacity for different activities whilst maintaining 2-metre distancing. With this information, you can discuss detailed use arrangements with each user.
- Signage: Ensure signage is in place to remind people of requirements. See https://gov.wales/safety-and-physical-distancing-signs-employers-coronavirus
- Plan your cleaning regime: The general requirement is that areas of buildings that are used are cleaned before and after use. The section in the Welsh Government guidance headed Cleaning and Infection Control is very useful in helping you think about your cleaning regime. You should review your cleaning arrangements to ensure that an appropriate cleaning regime is reliably implemented.
- Hygiene: Whilst activity organisers are likely to include this in their own precautions, you should ensure sanitizer/hand washing facilities are available.
- Face Coverings: From September 14 2020, it is a requirement that all persons aged over 11 (including ministers) gathering indoors should wear a face covering. This applies to all activities and services within the building. Further guidance for the public is available at:
and for premises managers at:
The public should be reminded of the requirement to wear a face covering and a standard sign can be found HERE
- Toilets: Toilets are a particular challenge and will need detailed planning. WG guidance is that toilets can be opened providing that physical distancing and hand hygiene guidance is followed. These areas should be cleaned regularly using normal cleaning products with particular attention to areas that are frequently touched such as door handles and taps. Suitable handwashing facilities should be available including running water and liquid soap. Drying should be by paper towels or hand dryers (not communal towels). Paper towels should be in a dispenser and disposed of carefully. Specific guidance is available at https://gov.wales/providing-safer-toilets-public-use-coronavirus-html
- Record your arrangements (Risk Assessment): You must complete a risk assessment before re-opening. This should set out the precautions and mitigation measures you will put in place. This should then be shared with users/activity organisers. You should share this Risk Assessment with your Archdeacon too. A template risk assessment document is attached.
- Liaise with Activity Organisers: Make contact with your activity organisers to start discussing appropriate risk mitigation measures. You should check carefully that their activity is permissible under the latest regulations. They should provide you with a risk assessment for their activities within your building. This should be based on any government guidance for the safe operation of their particular activity. You should carefully study this to make sure that it dovetails with your own arrangements.
A major part of managing physical distancing so as not to exceed the safe capacity of your hall is to control access carefully. Generally, it should be for activity organisers to manage this as they are inviting people to attend. This will be easiest for pre-booked attendees. If attendees can simply ‘turn up’, the activity organiser will need to consider stewarding arrangements
If the PCC/MAC is not satisfied that proper arrangements can be put in place for safe operation, the activity should not be permitted. There may be sense in re-opening for a limited range of activities as a first stage. Groups that make use of the hall on a very regular basis e.g nurseries, would be a good place to start. It makes sense to work with trusted users as you develop your procedures.
Considerations for MAC/PCC when directly organising an activity in the hall
- Permissible activity: You should check carefully that the activity is permissible under the latest regulations.
- Consider the activities you wish to undertake: The way these are undertaken will need to change to ensure appropriate precautions. Be creative to ensure activities can be undertaken safely but also enjoyably. Don’t forget that some elements of your activity might be most safely conducted on-line rather than in person.
- Risk Assessment: Prepare a written risk assessment setting out how you will operate the activity to comply with government guidance. The focus should be on physical distancing, hygiene and cleaning arrangements. The risk assessment template can be easily adapted for this purpose. You should prepare a risk assessment for each separate activity. This should be discussed and shared with all involved with running the activity.
- Physical Distancing Issues: It may be that essential activity will require some breaching of the two-metre distancing. You will need to consider carefully how this will be safely managed. This might include rigorous hand washing regimes before and after such a breach and the wearing of face coverings especially where people are likely to breach 2 metre distancing see https://gov.wales/face-coverings-frequently-asked-questions
Updated 14 September 2020
The Health Protection (Coronavirus Restrictions) (No. 2) (Wales) Regulations 2020
PART 4 Gathering with other people
14. Restriction on indoor gatherings
(1) No person may, without a reasonable excuse –
- (b) gather in premises indoors with any other person apart from –
- (i) the members of their household,
- (ii) their carer, or
- (iii) a person they are providing care to.
(2) A reasonable excuse includes the need to do the following –
- (a) obtain medical assistance, including accessing any of the services referred to in paragraph 10 of Schedule 4 or accessing veterinary services;
- (b) provide or receive care or assistance, including relevant personal care, within the meaning of paragraph 7(3B) of Schedule 4 to the Safeguarding of Vulnerable Groups Act 2006(24), where the person receiving the care is a vulnerable person;
- (c) provide or receive emergency assistance;
- (d) donate blood;
- (e) work or provide voluntary or charitable services;
- (f) where the person is an elite athlete, train or compete;
- (g) attend a solemnization of a marriage or formation of a civil partnership
- (i) as a party to the marriage or civil partnership,
- (ii) if invited to attend, or
- (iii) as the carer of a person attending.
- (h) attend a funeral –
- (i) as a person responsible for arranging the funeral,
- (ii) if invited by a person responsible for arranging the funeral, or
- (iii) as the carer of a person attending;
- (hza) participate in a gathering of no more than 30 people at open premises to celebrate a solemnization of a marriage or formation of a civil partnership that takes place on or after 22 August 2020, celebrate the life of a deceased person whose funeral is held on or after 22 August 2020;
- (ha) attend a place of worship;
- (i) meet a legal obligation, including attending court or satisfying bail conditions, or to participate in legal proceedings;
- (j) access or receive public services
- (ja) access childcare or participate in supervised activities for children;
- (k) in relation to children who do not live in the same household as their parents, or one of their parents, continue existing arrangements for access to, and contact between, parents and children, and for the purposes of this paragraph, “parent” includes a person who is not a parent of the child, but who has parental responsibility for, or who has care of, the child;
- (l) move home;
- (m) undertake activities in connection with the purchase, sale, letting, or rental of residential property.
- (o) avoid injury or illness or escape a risk of harm.
- (p) exercise with others, in a gathering of no more than 30 people, at a fitness studio, gym, swimming pool, other indoor leisure centre or facility or any other open premises.
(3) Paragraph (1) does not apply to a person who is homeless.