Cytûn – Churches together in Wales
Level 2 Covid-19 Restrictions
This update does not constitute legal advice, and should not be used for that purpose.

On December 17 2021 Welsh Government announced that restrictions which “draw on elements from the alert level two regime” will be introduced on December 27. The details of these restrictions will be announced during the week December 20-24.

In order to help churches plan for the period following the (western) Christmas this paper outlines the Level 2 restrictions as they are outlined in the Health Protection (Coronavirus Restrictions) (No. 5) (Wales) Regulations 2020, Schedule 2. This paper is a planning tool; the regulations which come into force on December 27 will certainly be different in a number of important details. Churches should check the Welsh Government website (gov.wales/coronavirus) regularly in order to see the latest changes. Every effort will be made to update Cytûn’s website and social media also, but we cannot guarantee to do so in a timely fashion over the holiday period. It is the responsibility of the controllers of regulated premises to know, understand and implement the relevant regulations. Cytûn cannot accept any responsibility for the consequences of any errors or omissions in this briefing paper or our website.

Level 2 restrictions are subject to the rules in place under the current Level 0 – such as the statutory duty on the controllers of all “regulated premises” (including places of worship and community centres) to draw up a risk assessment covering all “reasonable measures” which can be taken to reduce the spread of coronavirus; and the wearing of face coverings when meeting others indoors in regulated premises. Welsh Government guidance on ventilation should also be followed. A summary of these and links to detailed guidance can be found on Cytûn’s website.

The “reasonable measures” that will need to be taken from December 27 in regulated premises, including places of worship, will include keeping a physical distance of 2m between each household or extended household – this was announced by Welsh Government on December 17.

It was also announced that the coronavirus regulations will be amended to place a legal duty on employers to allow their employees to work from home if possible, and on employees to do so where practicable. “Work” in this context includes voluntary work, so churches should plan for carrying out remotely as much of their work as is reasonably practicable from December 27.

In addition to these measures announced on December 17, under level 2 restrictions if implemented in full, the following could be expected:

• Restricting organised events to 30 people indoors and 50 people in the open air. Children under 11 years of age and those working or volunteering in the event (such as leaders, stewards, etc.) could be additional to these numbers. These upper limits are not applicable to marriage or funeral services. They are also not applicable to religious services in general, where it is held in premises ordinarily used for that purpose. This means that a building not ordinarily used foir worship could not be hired in order to gold a service for more than 30 people. (A building which is regularly hired to hold religious services, however, could be used to host a service for more than 30).
• All outdoor and indoor visitor attractions could open, with appropriate safety measures in place.
• All cafés and similar hospitality facilities could open, with safety measures in place (such as table service only for food and drink; restricting to 6 the number at each table unless they are members of the same household; ensuring 2m between each household at all times; wearing face coverings when not sat at table; keeping records for Test Trace Protect; and so on). See below for more informal catering arrangements.

• Community centres could be used for all purposes, including for entertainment and social activities, within the above limits on numbers. But in Level 2, the sale of alcohol is prohibited in licensed entertainment venues where live or recorded music is played.
• Meetings in private dwellings (including manses, parsonages and church workers’ homes) would be restricted to the members of a single household or extended household. An extended household could include all the members of 2 households only. The extended household needs to be an exclusive ‘bubble’ throughout the period of restrictions.
• Limiting meetings in private gardens to a total of 6 people from up to 6 different households. Children under 11 and carers for others who are present could be additional to these numbers. Working or providing voluntary or charitable services is also an exception to this upper limit, so church governance meetings or a meeting to arrange activity could be held in a private garden (but not indoors in a private dwelling) or in a place of worship or centre, if it could not be arranged remotely, and having carried out a risk assessment.

Therefore, churches should not arrange activities in private dwellings or private gardens beyond these limits after December 27, until it is certain whether or not these restrictions will be reintroduced.

The Level 2 regulations are not entirely clear regarding serving refreshments in places of worship and community centres. Following discussion with officials from Welsh Government during the previous period of Level 2 restrictions, the following guidance was agreed:

1. Where a community centre or place of worship has formal café facilities, then these can be opened following the applicable regulations and This guidance must be followed in full even when food and drink is served free of charge or for a donation, for example following a service. Informal mixing is not permitted. A full risk assessment must be completed before providing food and drink.
2. Where a centre or place of worship holds a current Food Hygiene Certificate, and a full general risk assessment has therefore been carried out (perhaps pre-Covid) and the location is known to the authorities, then food and drink may be served (for payment, for a donation or free of charge) if the centre can be arranged and operated as a café – table service only; restricting to 6 the number at each table unless they are members of the same household; ensuring 2m between each household at all times; wearing face coverings when not sat at table; keeping records for Test Trace Protect; and so on, in line with the guidance for cafés. A full risk assessment must be undertaken before doing so.
3. Where no Food Hygiene Certificate is held, or where it is not possible to set out the centre in café format or follow the guidance, then food and drink should not be served at the present time. If those attending an activity in the centre wish to eat or drink, they should bring their own food and drink, which should not be shared between households.

It is suggested that churches make their arrangements for catering from December 27 in line with the approach outlined above until further certainty is provided.

Gethin Rhys  17.12.2021