The Corporate Insolvency and Governance Act 2020 has now received Royal Assent. It applies to most companies as well as Limited Liability Partnerships.
Yesterday, (23 June) the Prime Minister announced significant changes to lockdown measures for organisations and individuals in England. From 4 July, churches will be able to hold regular services for small groups of worshippers, and weddings with up to 30 attendees will be permitted to take place for the first time since lockdown began on 23 March.
Until then, however, churches and other places of worship can only open for private prayer and must be “Covid-secure” in any event. The Government recently published guidance for the safe use of places of worship during the pandemic, which church leaders may wish to consider as places of worship begin to reopen.
Preparing for reopening
As outlined in our earlier briefing, (Churches: Time to open the door safely) churches have an obligation under the Health and Safety at Work Act 1974 to ensure the health and safety of their employees and members of the public who attend their properties or are affected by their activities. Compliance with the Government’s new guidance will be a strong indicator that an organisation is complying with its health and safety obligations.
Before reopening, churches should complete a rigorous Covid-19 risk assessment, as set out in our previous e-briefing, to cover their reopening and all planned activities. The Church of England has published a helpful risk assessment template. The assessment will need to carefully consider the risks posed to those who enter churches to prepare for reopening and arising from buildings remaining unused, in addition to the risks arising from Covid-19.
The guidance makes clear that church staff, volunteers and contractors may enter the church building in order to prepare it for reopening. That preparation may include essential maintenance and repairs, in particular where this is identified as necessary during the reopening risk assessment. A thorough cleaning of the building will also need to take place before reopening and then at regular intervals once open. The guidance suggests that church leaders consider the frequency of regular cleaning in the risk assessment.
Church leaders may also wish to carry out the following actions recommended by the guidance:
- Rearranging the building where possible to encourage social distancing. This may include restricting access to parts of the buildings, installing clear signage, floor markings, moving furniture and creating a ‘one-way’ system to move around the church;
- Making handwashing facilities available, including providing hand sanitiser and disposable paper towels (try to avoid using hand driers);
- Removing communal objects, such as bibles, hymn books and kneeling cushions; and
- Implementing restrictions on capacity so that individuals and households can always maintain two metres’ distance from each other (although Government guidance may alter this distance). This will, of course, depend on the size and nature of the church building.
Churches will also need to consider how to communicate the measures that will be implemented in the church to potential visitors in an accessible way: for example, making a large print version of any communication available. Where possible, arrangements should be made to ensure that those attending are aware in advance of the measures that they will be required to follow.
What is and what isn’t allowed?
The guidance is clear that collective communal prayer is not permitted yet, and this includes a Minister of Religion or lay person leading prayer. Until 4 July, an individual and their household must pray alone and should be socially distanced from others from different households.
The guidance advises churches not to make any food or drink available and to close any shared washing areas. Activities such as singing and playing instruments are not permitted by the guidance, though it does make an exception for organists, who can use church buildings for practice where appropriate social distancing is maintained.
Though it is advised that communal resources such as bibles and service sheets are removed from the church building, churches can provide single-use alternatives as long as these are removed by the worshipper after use.
Church leaders may also wish to discourage cash donations and welcome online giving and card payments where possible. If cash offerings continue to be made, it may be advisable to for church staff and volunteers to wear gloves when handling any notes or coins.
Shielding and Self-Isolating
The guidance re-emphasises the importance of protecting people who are clinically vulnerable and urges individuals who are shielding to follow Government advice for those in this category (this guidance has recently been altered). Anyone, including religious leaders, staff and volunteers, who displays symptoms of Covid-19 should stay at home and self-isolate.
Church leaders may wish to consider setting aside specific days or times when the church is open for individual prayer for vulnerable individuals only: for example, for those over 70.
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