Overview This guidance is for the retail sector in Scotland. Its purpose is to assist businesses that provide retail and close contact services to operate safely and in accordance with the Scottish Government guidance. A list of services permitted to open and when they can do so, is available within our question and answers section. Coronavirus (COVID-19): framework for decision making – Scotland’s route map through and out of the crisis sets out a phased approach to exiting from the lockdown. To judge whether and when restrictions can be changed we will consider a range of evidence on the progress of the pandemic in Scotland, using the principles set out in the Framework for Decision Making and our long-established commitment to fair work, which was set in the context of the current crisis in a joint statement with the STUC. Guidance will be reviewed on a regular basis as our priority remains containing the spread of the virus, saving lives and safeguarding the NHS. The Coronavirus (COVID-19): Strategic Framework update – February 2021 sets out how we plan to restore, in a phased way, greater normality to our everyday lives. It updates the original Strategic Framework to take account of important developments, including new and highly infectious strains of the virus and progress with the vaccination roll-out. Our strategic intent remains to: suppress the virus to the lowest possible level and keep it there, while we strive to return to a more normal life for as many people as possible. The Framework explains how we will use all of the tools we have available to get coronavirus to the lowest possible level and keep it there. This guidance has been developed in collaboration with industry, trade unions, regulators, and others. Protecting the health of workers is at the heart of our approach. Partnership working is fundamental to establishing a shared confidence around the safety of workplaces, protecting public health and supporting Scotland’s economic recovery. We have worked with employers and trade unions to ensure that this guidance is evidence-based, fair and ethical, clear and realistic. Each retailer will need to translate this guidance into the specific actions they need to take depending on the nature of their business (i.e. the size and type of business, how it is organised, operated, managed and regulated) using this document as a guide. This is provided as guidance only and does not amount to legal advice. Employers may wish to seek their own advice to ensure compliance with all legal duties. As each workplace is different it is for individual businesses to work with trade unions or workforce representatives selected by employees to determine how best to apply this guidance in their circumstances. It has been designed to be applied to cover the spectrum of different retailers in Scotland from department stores to independent traders, with additional guidance for food retailers on the Food Standards Scotland Website. The operational guide for retailers section has a downloadable checklist for retailers with actions to consider. There are also posters available to print off to encourage the use of mandatory face coverings and health and safety messaging. These can be found in the “supporting files” section below the checklist. Retailers are encouraged to display these posters, or posters with their own branding in their premises. To help you decide which actions to take, you need to carry out an appropriate COVID-19 risk assessment, just as you would for other health and safety related hazards. The checklist included with this guidance should provide you with a good starting place. Risk assessments should be undertaken in consultation with trade unions, employee representatives or employees. The key areas which you need to consider are outlined in each of the sections. This guidance will assist businesses already operating, in identifying, reviewing and maintaining the changes they will need to make to prevent the spread of COVID-19 across their operations. As a retailer you should consider whether you could operate using online and mail-order services and click and collect safely and in line with this guidance. There is also value in working together in smaller towns through business associations and chambers of commerce to manage safe re-opening and trading co-operatively. As we progress through fully unlocking the economy there will be complex issues to navigate and we ask that retailers use this guidance to inform their decision making in terms of when the right time to reopen is and the measures that need to be implemented to ensure it is done safely. Where we are now Coronavirus (COVID-19): framework for decision making – Scotland’s route map through and out of the crisis was published on 21 May 2020. It set out a phased approach to exiting from the lockdown announced by the First Minister on 23 March 2020. Inevitably, opening parts of our economy and society has provided new opportunities for the virus to spread and the Coronavirus (COVID-19): Strategic Framework update – February 2021 sets out how we will work to suppress the virus to the lowest possible level and keep it there, while we strive to return to a more normal life for as many people as possible and tackle the four harms we know the virus causes. This framework sets out a new approach to outbreak management based on five levels of protection consisting of four levels above the Route Map Phase 3 baseline (or “Level 0”) as set out below: Level 0 (baseline) and Level 1 Within these levels, we would expect to see low incidence of the virus with isolated clusters, and low community transmission. Broadly, these levels are the closest we can get to normality, without a vaccine or effective treatment in place, before conditions will allow us to move to Phase 4 of the Route Map. They would be similar to the measures in place during summer 2020, once we reached Phase 3. The Phase 3 baseline and Level 1 are designed to be sustainable for longer periods. All retail businesses and close contact services will be able to operate in these levels. Levels 2-3 Within Levels 2 and 3, we would expect to see increased incidence of the virus, with multiple clusters and increased community transmission. There would be a graduated series of protective measures to tackle the virus, focusing on key areas of risk – broadly, indoor settings where household mixing takes place with less, or less well-observed, physical distancing and mitigations. The measures would be intended to be in place for relatively short periods (2-4 weeks), and only for as long as required to get the virus down to a low, sustainable level. All retail businesses and close contact services (including mobile close contact services from 26 April 2021, if data allows) will be able to operate in these levels. Level 4/Lockdown Within this level we would expect to see very high or rapidly increasing incidence, and widespread community transmission which may pose a threat to the NHS to cope. It is likely that this level would see the introduction of measures close to a return to full lockdown. To judge whether and when restrictions can be changed we will consider a range of evidence on the progress of the pandemic in Scotland using the principles set out in the framework document. The safety of people – customers, employees and business owners – is the number one priority and we are working with retailers to ensure that people can still shop as safely as possible. Guided by the need to ensure shopping is as safe as possible, we want people to use their local high streets, towns and city centres, to ensure that crowding is avoided, that good hygiene measures and ventilation are in place and that physical distancing is maintained at all times. Essential retail will be able to remain open in Level 4. From 5 April 2021, the list of retailers allowed to open in Level 4 areas has been extended to include:
garden centres and plant nurseries
key cutting shops
mobility and independent living aids shops
baby equipment shops
electrical goods shops, for the purposes of repair
premises-based hairdressers and barbers which, by law, must be by appointment only and for a specified time
homeware showrooms. Face-to-face design consultations within showrooms should be by appointment where possible, with the size of shopping groups to be kept to a minimum
motor vehicle showrooms (appointment only) and forecourts. By law, customer access to an indoor showroom must be by staggered appointment with, where reasonably practicable, a gap between each appointment
A full list of businesses that can remain open during Level 4 is in the Health Protection (Coronavirus)(Restrictions and Requirements) (Local Level) (Scotland) Regulations 2020, as amended. The list of services permitted to open and when they can do so, is available within our Question and Answers section. Updated risk and equality impact assessments must be used to ensure that retail remains as safe as possible for staff and customers, who should continue to implement and strictly observe FACTS guidance and other mitigations. Essential retailers should consider restricting access to non-essential retail concessions as an option to control the risk of COVID-19 transmission as part of their risk assessment process. Statutory hospitality guidance applies to restaurants and cafes, including where they are situated in other businesses. From 5 April all retail businesses will be able to operate click and collect services via a “permitted collection service”. You can find information on how click and collect services should operate in the Click and Collect services section. Close contact services, with the exception of premises-based hairdressing and barbers, will remain closed. Stay local From 2 April, the 'stay at home' requirement in Level 4 areas will be replaced with a “stay local” requirement. From this point, those living in Level 4 areas will be allowed to travel for non-essential retail within your local authority area. Restrictions on non-essential travel across local authority boundaries will remain in place. People must stay within their council area for non-essential shopping (including Click and Collect) and should only travel to another area for essential shopping if there are no practical alternatives. We have considered what additional measures we can advise to reduce the increased risk of transmission of the strains of coronavirus and further reduce opportunities for infection. One of the key areas we can focus on is the workplace. Working from home as a public health measure has been a crucial factor in mitigating the transmission of the virus in the general public and is an effort we must continue. Our current position is that anyone who is able to work from home, must do so. See the “Continue home working” section of the general guidance for safer workplaces for more information. We continue to need every business to work with their workforce to look at their operations, and to make sure that every single function that can be done by people working at home, is being done in that way. Key mitigations The new, more transmissible variants of COVID-19 mean that it is essential to continue to rigorously adhere to effective mitigations which include physical distancing, ventilation, face coverings and good hygiene practices. Fuller advice is available later in this document, but the following are especially important in retail settings. Businesses should ensure that at least 2-metre physical distancing is applied to all parts of a workplace, including staff canteens, entrances and exits, break rooms, smoking areas, and similar settings. Good ventilation can help reduce the risk of spreading coronavirus, so a focus on improving general air flow, preferably through fresh air or effective mechanical systems will help keep staff and other building users as safe as possible when planning a return to work. Where possible, employers/building managers should consider ways to maintain and increase the supply of fresh air, for example, by opening windows and doors (please note that fire doors need to remain closed) in all areas of the building. Face coverings are required to be worn by law, unless an exemption applies, in retail settings, storage and distribution facilities, and communal staff areas There is more advice on face coverings available on our website. We have added additional advice in particular for people at higher risk. Assessing risk You should make sure that the risk assessment for your business addresses the risks of COVID-19, using this guidance to inform your decisions and control measures. The outcome of the risk assessment is to identify and implement sensible measures to control the risks in your workplace. Employers have a duty to consult employees on health and safety. Consultation should occur with full-time, part-time, contractors, shift workers, security staff and facilities and cleaning staff. You can do this by listening and talking to them about the work and how you will manage risks from COVID-19. Your employees will have an in-depth knowledge of the risks in the workplace and will have a view on how to work safely. In a small business, you might choose to consult your workers directly. Larger businesses may consult through a health and safety representative, chosen by your employees or selected by a trade union. As an employer, you cannot decide who the representative will be. This process should be a continuation of an existing process in involving employees in optimising health and safety outcomes. Key issues for employers
a full risk assessment should be undertaken in consultation with employees
constructively engage with employees when carrying out a risk assessment
ensure the result of the risk assessment is visible and communicated to employees
ensure that the actions taken as the result of the assessment do not disproportionately impact those with vulnerabilities such as people with disabilities, single parents, younger or older people and consider how to support those with additional needs to comply with physical distancing and other mitigations
The mental health of employees should be factored in to the risk assessment with signposting to employer led, government and third sector support made available to staff to manage issues such as confrontation, stress and isolation as needed. Guidance on the duty to manage stress under the health and safety legislation is available on the HSE website
Workforce planning and support Information about supporting those who should come to work, and those who should not.
As a minimum we expect:
working from home to continue, where possible. It is recognised that this is not going to be possible for many retail employees but where it is possible (for example in the case of back office / management functions) this should be undertaken.
health factors to be considered in any phasing of who returns to work, with employees living in vulnerable households only expected to return when new safe working environment measures have been fully tested and a return to onsite work is consistent with medical advice.
new retailing arrangements should be tested and modified in agreement between employers and employees, including by phasing where possible. Employers should be aware of other regulatory compliance measures and any impacts.
employers to also take account of travel to work considerations.
employers to take account of childcare arrangements, in the case of nurseries and schools not being fully operational.
employers to take account of vaccination appointments
Implementation timetable An implementation timetable should be undertaken, structured broadly as follows: Planning Undertake an analysis to ensure you understand where the risks are to your business in being able to operate, in particular taking into account the challenges of maintaining physical distancing, adequate ventilation and enabling hand washing, and fair work principles and is designed to allow business to trade while protecting health and well-being. Preparation Produce a plan that incorporates your physical distancing, ventilation and hygiene solutions and identifies what work is required to operate safely – screens, measures to manage the flow of people, 2 metre physical distancing, staff rooms, face coverings, PPE and its provision where appropriate, hand sanitisers, enhanced cleaning etc. You should also think about what customer communication and displays will be needed to ensure customers are able to comply with your requirements. Your preparation should also include what actions you will take if customers do not comply with your requirements. Pilots Experience confirms the value of trialling the new way of working before a fuller restart is attempted, so a limited-scale pilot to test systems, find weaknesses and make improvements is recommended. Continue home working As minimising the spread of the virus will remain important in ensuring the overall protection of public health and NHS, planning for working as safely as possible should assume that those able to work from home will continue to do so in line with Scottish Government guidance on working from home. Employers should plan for the minimum number of people needed in stores to perform safely and effectively. Employers must ensure that staffing is sufficient for safety, giving consideration to fire exits, manual handling, security and first aid. Staff must be made aware that they should not report to work if they have coronavirus symptoms. Employee health and wellbeing Individual health circumstances and protected characteristics should be considered and discussed with employees before prioritising who is asked to work and when. This should recognise the protective measures required to minimise health risks to vulnerable or shielded workers or those living in vulnerable households, exploring whenever possible how these staff can work from home. Consideration of health circumstances and protected characteristics should be part of the risk assessment process. Permission should be sought from individuals before collecting any information on health conditions of those within an employee's household. Planning should recognise that ongoing physical distancing measures required to reduce the spread of the virus may mean that the number of employees able to be accommodated safely in the workplace will be limited. Employers are encouraged to work with recognised trade unions or employee groups to enable workers to work from home while self-isolating if appropriate. If able to work from home, employees should continue to do so after a period of self-isolation has ended. Pay for workers who are self-isolating, sick or balancing care responsibilities is likely to be a source of concern for employees. Employers should work with trade unions, workers’ representatives or employees to provide early guidance to workforces on processes and support for individuals affected by these issues. Opportunities to facilitate home working where feasible should be actively pursued and maintained. The initial move to home working is likely for many to have been implemented at pace as a result of COVID-19 and therefore may not have involved normal health and safety planning to ensure people have suitable working arrangements and equipment at home. Businesses should consider what measures need to be put in place to support their staff to continue to working from home safely and effectively and in a way that addresses both physical and mental health and wellbeing, as well as the practical issues such as provision of laptops, mobile phones, suitable furniture, video conferencing etc. services etc.). The Health and Safety Executive has published advice on safely working from home. Employers should ensure the organisation culture is inclusive and every employee feels they are returning to a supportive and caring environment. The pandemic has had an unequal impact across the workforce, as different employee groups, and individuals will have been affected in diverse ways according to factors such as their job role, and demographic/personal circumstances. Therefore, it is important the organisation fosters an inclusive working environment that does not tolerate discrimination. There is also a risk of victimisation of those infected, suspected, or more vulnerable to COVID-19 which should be addressed. Occupational health advice should be sought whenever possible. While it is not within the Scottish Government's legislative power to compel businesses as employment law is the UK Government's competence - we strongly recommend employers to support their staff at these times to reduce their risk of transmission, including assuring appropriate time off to obtain a vaccine. Protecting people at higher risk People who are at the highest risk from coronavirus (people on the shielding list) have specific additional advice which can be found on www.mygov.scot/shielding. This includes:
going back to work from 26 April 2021
advice about work in Level 4
working if you have been vaccinated
making workplaces safer
There is also extra advice at all protection levels for those who are at highest risk from coronavirus (people on the shielding list). A letter from the Chief Medical Officer (CMO) was sent to all those on the shielding list on 23 March 2021. This included the advice to work from home for the remainder of lockdown and Level 4, and detailed changes in work advice which is effective once the levels system is re-introduced on 26 April 2021. This letter also acts in a similar way to a fit note, can be used as supporting evidence for Employment and Support Allowance and Statutory Sick Pay applications, and is valid up to 30 June 2021. The CMO letter advised that at Level 4 those on the shielding list should work from home or if they can’t work from home they should not go to work during the time the area they live or work in is at Level 4. This is a change to advice previously issued regarding working at Level 4. The letter also advised that the guidance for people on the shielding list currently applies whether they’ve had one or both doses of the vaccine. In Levels 0-3, Clinical Occupational Health consultants continue to advise that the majority of workplaces can be made safe, even for those who are most clinically at risk. This is reflected in the extra advice for those on the shielding list aligned to Levels 0-3. This advises that the majority of workplaces can be made safe following an individual workplace risk assessment and employers should make the necessary adjustments to make the workplace safe. People who need to self-isolate Individuals who are advised to stay at home under existing government guidance should not physically come to work. This includes individuals who have symptoms of COVID-19 as well as those who live in a household with someone who has symptoms. All workers should be supported to follow up to date health protection advice on isolation if they or someone in their household exhibits COVID-19 symptoms. Advice within workplaces should continually remind workers of the symptoms to look for and clear advice should be provided on how to respond if symptoms become apparent while at work. The success of this public health intervention will depend on the continued willingness of the population to comply with these measures. Workers should therefore be supported to isolate if necessary. The Coronavirus (COVID-19) shielding, support and contacts guidance provides useful information and financial advice. Financial assistance for people at higher risk If you are not attending your workplace due to the advice from the Chief Medical Officer, your employer, at their discretion, may be able to furlough you through the Coronavirus Job Retention Scheme which has now been extended until September 2021. If you are furloughed, HMRC will give a grant to your employer to cover 80% of your normal salary, and your employer will need to pay National Insurance and pension contributions. You are encouraged to discuss this directly with your employer. Otherwise you may be eligible for Statutory Sick Pay, Universal Credit, or other benefits, during this period. To find out further information about what benefits you may be entitled to, speak to your employer, or visit or the gov.uk website or contact Citizens Advice Scotland. Some employers may offer additional financial support for employees who are off work for coronavirus-related reasons which may be set out in your terms and conditions of employment. To find out what financial support you will get, you should contact your employer. The Coronavirus Job Retention Scheme does not apply if you are self-employed or to any loss of income from self-employment. However, you may qualify for support under the Self-Employed Income Support Scheme. There are other issues that employers need to consider to ensure workplaces are inclusive. The Equality and Human Rights Commission can provide advice on a range of issues such as non-discrimination, communication with employees on equality issues, adjustments for disabled people, support for pregnant employees, flexible working for those with caring responsibilities, support for employees affected by domestic abuse, how to deal with harassment at work, and mental health issues. Test and Protect Test and Protect, Scotland’s approach to implementing the “test, trace, isolate, support” strategy is a public health measure designed to break chains of transmission of COVID-19 in the community. All employers will need to be familiar with our Test and Protect advice for employers, which outlines how to support employees who are required to self-isolate. It is essential that steps are taken to enable all staff to comply with the requirements of Test and Protect and that they are encouraged to report to their managers when they are experiencing symptoms. Employers must also ensure that staff follow advice to self-isolate if they are living with a person who has symptoms or has tested positive, or they have been informed by a NHS contact tracer that they have been in close contact with someone who has tested positive. Employees can request an isolation note through NHS Inform. All staff reporting symptoms of COVID-19 should also be encouraged to arrange a test as soon as possible through NHS Inform. Employers must ensure staff are fully supported when they are required to self-isolate. Until staff have been tested and told that it is safe to leave home or have recovered from COVID-19, employers should make sure that staff are not placed under any obligation to return to the workplace. While it is not within the Scottish Government's legislative power to compel businesses as employment law is the UK Government's competence - we strongly recommend employers undertake a Return to Work Fitness Assessment with employees. In order to support Test and Protect, it is important that employers have clear and robust records of staff working on each shift, the make-up of teams and details of any visitors to the site, in case of a need to contact trace. Employers should also monitor reports of illness across their workforce and report to their Local Health Protection Team when potential outbreak is suspected. Guidance on this can be found at the Health Protection Scotland website. If an outbreak is confirmed, employers will be asked to record details of symptomatic staff and assist with identification of contacts. Identification of an outbreak will also require a review of COVID-19 control measures in order to identify any breakdown which may need to be addressed to prevent future incidents. Local Health Protection Teams may themselves identify clusters of cases amongst employees through Test and Protect. In this situation, employers will again be asked to support the Health Protection Team with further investigation, communication with the workforce, and review of existing control measures. It is advisable for employers to identify a single point of contact to act as liaison with Health Protection Teams for any matters relating to Test and Protect, reporting potential outbreaks and seeking advice on matters relating to COVID-19 illness in the workforce.You can find contact details for your Local Health Protection Team in the HPS guidance for non-healthcare settings. The Protect Scotland app is a free, mobile phone app designed to help us protect each other and reduce the spread of coronavirus. The app helps with contact tracing which is vital for slowing the spread of the virus, and for making sure the virus stays at low, manageable levels. It enhances existing contact tracing and quickly alerts app users that are at risk because they have come into close contact (less than 2 meters for 15 minutes or more) with an app user that has since tested positive for COVID-19. The app signposts to existing guidance on NHS Inform, Ready Scotland and the Scottish Government website, including on what to do if you receive an alert and are advised to self-isolate. Shift patterns Employers may develop plans to change shift patterns and opportunities for flexible working patterns to both protect the workforce and optimise productive capacity. While this might help fulfil orders it would require proper consultation with trade unions or employees if it involved a change in employee terms and conditions. Personal Protective Equipment (PPE) Health Protection Scotland (HPS) have provided COVID-19 information and guidance for general (non-healthcare) settings. The HPS guidance also offers advice on the use of PPE, confirming workplaces should use PPE consistent with local policies and in line with measures justified by a risk assessment. Both the Scottish Government and the Health and Safety Executive (HSE) recommend a risk based approach focused on a hierarchy of control which seeks to eliminate risks, combat risks at source, adapt workplaces to individual needs, ensure adequate staff training around processes to manage the risk and then use PPE where required. Where PPE is deemed necessary, an adequate supply and quality must be maintained and provided free of charge to workers who need it. Any PPE provided must fit properly. Face coverings Regulations came into effect on 10 July 2020 that made it mandatory for face coverings to be worn in retail settings, with additional regulations from 9 October 2020 that made it mandatory for face coverings to be worn in storage and distribution facilities, and for face coverings to be worn in communal staff areas in both retail and storage and distribution facilities. There is more advice on face coverings available on our website. Face coverings are in addition to other public health strategies and not a replacement. The measure applies to customers and staff with exemptions noted in this section. A face covering can be a covering of any type, except a face shield, that covers the mouth and nose. It is recommended that it be made of cloth or other textiles and should be two, and preferably three layers thick, and through which you can breathe. Face shields may be used, but only if they are worn in addition to a face covering underneath, as the evidence shows that they do not provide adequate protection. Customers are expected to provide their own face coverings but we strongly encourage retailers to have their own stocks of face coverings available as an initial encouragement to those customers without face coverings. Failure to comply with legislation on wearing a face covering is a criminal offence with the potential for a fixed penalty notice to be issued if the law is broken. Shop workers and retailers are not required to enforce this law, but we ask you to talk to customers who are not wearing a face-covering and explain the law. If customers refuse to wear a face covering, retailers and shop workers are asked not to stop customers from entering the store or from being served. The responsibility to wear a face covering rests with the individual. Customers are required to wear a face covering but there are exemptions, which include:
children under 5
people with health conditions who cannot put on, wear or remove a face covering because of any physical or mental illness or impairment or disability or without severe distress
if people need to take medication or to eat or drink where reasonable necessary
temporary removal to comply with a request by a relevant person or another person acting in the course of their duties
for customers with a hearing impairment and those who lip-read, and temporary removal of the face coverings by others, as necessary, to provide advice, information or assistance to such customers
for age-restricted sales customers are asked to ensure that they remove face coverings in accordance with requests from staff
in some food-handling settings where the wearing of a mask could compromise the hygiene practices that are already in place to ensure food safety
Staff only exemption
in customer-facing areas where 2 metres physical distancing can be maintained or if there is a partition such as a Perspex screen between customers and staff
Considerations for staff Where a face covering may need to be temporarily removed, such as the point of sale to ensure age-restricted sales checks or at staff rest areas when eating/drinking, facilities should be provided to manage the risk this could pose e.g. wearing a face guard; physical distancing; screens and hand sanitiser. Where staff have concerns about wearing face coverings this should be resolved in discussion between staff and managers. The guidance applies in indoor shopping malls including those with covered walkways, retail service settings such as spas, salons hairdressers, barbers. The mandatory requirement to wear a face covering also extends to wholesale settings/storage and distribution facilities where traders and members of the public are present and in all other communal areas including collection and drop off points. Food-based retail This measure is applicable to all businesses which sell food by retail. It does not apply to hospitality premises which provide table service such as bars, pubs cafes and restaurants for which there is separate guidance on tourism and hospitality. In businesses offering both take-away and table service, face coverings should only be removed in designated seating areas which are provided for customers to eat and drink. Food Standards Scotland’s guidanceprovides more information on the control of COVID-19 in all businesses involved in food production and service. It is recognised that there may be certain tasks that staff in food shops need to carry out where face coverings may not be appropriate. For example, where staff are handling food items or preparing meals and it is assessed that the wearing of a mask could increase the risk of other types of infection (non-COVID) from getting into the food which could potentially make it unsafe. COVID-19 is a respiratory infection and the wearing of face coverings is intended to prevent the spread of infection between people. There is no evidence that it can make people ill through food. It is therefore important that wearing a face covering doesn’t affect the hygiene controls that should already be in place to ensure food is protected from other bacteria and viruses that can cause food poisoning. If there is any concern that wearing a face covering could present a risk to the food, the shop worker would not be required to wear one, but other mitigating measures must be in place to reduce the risk of transmission. Travel Transport Scotland's Transition Plan sets out guidance on travel and transportation. Ventilation The provision of fresh air into indoor environments is essential to reducing the risk of the spread of COVID-19. Taking measures to increase the volume of outside air entering a building, such as opening windows, doors or vents, can help minimise the risk of spreading COVID-19 to staff and customers. The Scottish Government has developed ventilation guidance to support the mixing of individuals safely in indoor domestic and commercial properties where this is necessary. Ventilation should be considered as part of a hierarchy of risk controls approach. These include:
effective fresh air ventilation, working alongside face coverings, distancing and enhanced hygiene regimes
restricting or reducing duration of activities indoors
utilising rooms with good ventilation and avoiding the use of those without
use of face coverings should be considered alongside ventilation for reducing far-field aerosol transmission risks
factoring in the use of suitable air cleaning devices to enhance indoor air quality.
A well ventilated space reduces the concentration of viral load in the air, reducing the risk of transmission of the virus. Evidence to date suggests that poorly ventilated spaces pose the highest risk, so it is recommended that mitigation measures focus on those spaces where ventilation is absent or inadequate. It is important to note that air cleaning devices do not provide additional fresh air into a space. Specialist ventilation engineering advice should be sought prior to investment/installation of these devices. Security The interpretation and use of any guidance should be considered in line with normal protective security operations and practices. Organisations should consult with and involve their security departments in the interpretation and implementation of the guidance. In particular, security should be considered in any revised risk assessment. Under no circumstances do we advise the removal or alteration of, or reduction in, existing protective security measures without providing clear recommendations (e.g. from the National Technical Authority/police CT specialists) on how to maintain effective protective security. This should extend to measures not primarily intended to provide a protective security benefit, but nonetheless doing so, for example removal of street furniture that could make moving or queueing pedestrians more vulnerable to vehicle-as-a-weapon attacks. Security staff should remain focused on security duties. Where COVID-19 creates additional staffing requirements, e.g. queue management, employers should ensure additional suitable staff resource is made available. Employers should ensure security staff feel as safe as possible, e.g. having access to appropriate PPE and hand-washing facilities, and that they are able and confident to raise any concerns. Further detailed guidance can be found on the Centre for the Protection of National Industry - staying secure during COVID-19 and the UKG National Counter Terrorism Security Office webpages. Close contact services This guidance will be updated again before the reopening of all close contact services, intended for 26 April.
Examples of close contact services are:
hairdressing and barber services
beauty and nail services (including make-up services)
hair removal services
tattoo, piercing and body modification services
fashion design, dress-fitting and tailoring services
indoor portrait photography and art services
complementary and alternative medicine services requiring physical contact or close physical proximity between persons, but not osteopathy and chiropractic services
spa and wellness services
other services or procedures which require physical contact or close physical proximity between a provider and a customer and are not ancillary to medical, health, or social care services
For close contact services, customer and practitioners should refer to their local Strategic Framework level and associated guidance to understand whether they should seek or provide services. A person who provides a close contact service must not provide that service in a Level 4 area, subject to the exception regarding premises-based hairdressers and barbers which may operate by appointment only from 5 April 2021. If a customer and practitioner are located in areas at different levels, they should default to whichever level is highest, for example:
customers unable to obtain services in their area because they are not permitted at the current level should not travel to areas in lower levels to obtain those services
practitioners unable to provide services in their area because they are not permitted at the current level should not travel to areas in lower levels to provide those services
neither customers nor practitioners should travel into areas at higher levels to seek or provide services
Business owners and staff should also follow the principles in the wider retail guidance, including guidance relating to the high risk zone and good practice, which may restrict the services that can be offered. NHS Inform general advice is a useful source of information for clients who might be at highest risk of COVID-19. Test and Protect and customer contact details To assist NHS Scotland’s Test and Protect service in responding to outbreaks of COVID-19, close contact service providers should collect individual customer contact details in a safe and secure manner, which is compliant with data protection legislation, in line with existing guidance. We strongly urge all premises and providers with the means to sign up and use the free Test & Protect ‘Check-in Scotland’ digital service. All guidance, a user toolkit and to register to generate you unique QR poster can be found at: Check-in Scotland - mygov.scot Services offered in the ‘high risk zone’ The “high risk zone” is defined as “the area in front of the face where splashes and droplets from the nose and mouth may be present, which can pose a hazard”. If treatments in the high risk zone cannot be carried out without the ability to be provided from the side of the face or behind the head and therefore require prolonged periods in the highest risk zone then they should not be offered. Good practice Consideration should be given to which practice is as safe as possible Practitioners should assess their practice for all therapy treatments they deliver to ensure they only provide services in the safest possible settings. Practitioners should seek to avoid skin-to-skin contact with colleagues and clients if it is not crucial for the treatment. Gloves provide a barrier where there is anticipated contact with blood or body fluids and should continue to be used for any treatments where this is a risk as in usual practice. However over-use of gloves leads to contamination of both the user’s gloves and the surrounding environment. Frequent hand decontamination is very important. Frequent hand decontamination is very important. Alcohol-based hand rub should be used regularly where hand washing cannot occur. WHO Guidelines on Hand Hygiene in Healthcare state that alcohol solutions containing 60-80% alcohol are most effective. Good practice involves the practitioner continually moving from side to side or from the back avoiding the high-risk zone, inactive periods, and keeping the activity time involved as short as possible. Good hygiene principles for non-healthcare settings Hand hygiene
COVID-19 is spread when respiratory secretions from an infected person enters the mouth, nose or eyes of another. One way in which this can happen is by touching your eyes, nose or mouth with contaminated hands. It is therefore important to avoid touching the face with unwashed hands
perform hand hygiene regularly and especially before and after eating
promote good hand hygiene for all staff/visitors/service users
ensure there are sufficient hand washing facilities and provision of alcohol based hand rub (ABHR) at key areas such as entry and exit points
Coughs and sneezes
catch coughs and sneezes in a tissue and dispose of any tissues into a bin and wash hands immediately
if an individual does not have tissues to hand, they should catch coughs and sneezes in the crook of their elbow
ensure regular detergent cleaning schedules and procedures are in place using a product which is active against bacteria and viruses and following the manufacturer’s instructions for dilution, application and contact times for all detergents and disinfectants.
ensure regular (at least twice daily) cleaning of commonly touched objects and surfaces (telephones, keyboards, door handles, desks, counter tops etc.).
face coverings are now mandatory for close contact services. Read more about face coverings.
it is important to note the difference between face masks and face coverings
face masks are surgical or medical grade masks that are used in health and social care situations
a face covering can be a covering of any type, except a face shield, that covers the mouth and nose. It is recommended that it be made of cloth or other textiles and should be two, and preferably three, layers thick and fit snugly while allowing you to breathe easily
the use of face masks is not currently recommended for the general population. We have issued guidance on the personal use of face coverings
the provision of fresh air into indoor environments is essential to reducing the risk of the spread of COVID-19. Taking measures to increase the volume of outside air entering a building, such as opening windows, doors or vents, can help minimise the risk of spreading COVID-19 to staff and customers. The Scottish Government has developed ventilation guidance to support the mixing of individuals safely in indoor domestic and commercial properties where this is necessary
Personal Protective Equipment (PPE)
PPE protects the user against health or safety risks at work. It can include items such as safety helmets, gloves, eye protection, high-visibility clothing, safety footwear and safety harnesses. Occupations should continue to use any PPE required as per local policies (business as usual) and there are no requirements for additional PPE to be worn.
We have developed a checklist that should be considered by close contact business owners as part of a risk assessment. Mobile close contact services Mobile close contact services describe services where a practitioner visits their customers/clients to provide services, rather than customers/clients visiting them at a fixed premises which the practitioners owns, rents or otherwise operates from. They include services that are provided in the home of a client/customer, or other locations where such services are requested, for example wedding venues or hotel rooms. From 26 April 2021, mobile versions of close contact services are permitted to operate in Levels 0 through 3. As mobile close contact service practitioners may visit multiple clients/customers each day, it is particularly important that every effort is taken to reduce the risk of transmission from one location to another location. There are different risks associated with working in customers/clients’ homes and in multiple locations and so, as well as understanding the broader close contact services guidance as set out above, practitioners should follow the additional advice for delivery of mobile services.
prior to visiting a location for work, mobile practitioners should clearly establish their expectations with the customer/client regarding the workspace, the services to be delivered, and who will be present during the services
practitioners should consider remote video consultations in advance of treatments as a way to reduce the time spent with the client/customer
mobile practitioners should only meet the client/customer they will be working with; however a client/customer’s carer/chaperone/attendant can be present if appropriate, and if physical distancing is maintained from the practitioner
practitioners should not work in locations where a client/customer or a member of their household is isolating or experiencing symptoms of COVID-19, including:
a new continuous cough
loss of, or change in, sense of smell or taste
practitioners should not continue to work if they are experiencing symptoms of COVID-19, or have been told to self-isolate
workspaces should be limited to a single well-ventilated room where possible with any non-essential items removed. The area should be tidy and clean for arrival, with sufficient space for the service to be provided safely. Ventilation can be provided through an open window. See guidance on ventilation for more information.
practitioners should limit their movement in the location to their designated treatment area if possible, and should avoid visiting the bathroom unless absolutely necessary
practitioners should decline any offer of refreshment but can bring their own with them
additional consideration should be given to cleaning and industry good practice. Hand hygiene remains vital and should be followed by both the mobile practitioner and client/customer.
ensure that both practitioners and clients/customers wash their hands regularly especially in relation to treatments where gloves cannot be worn for example aromatherapy and massage. Alcohol Based Hand Rub (60% alcohol minimum) should be used regularly where hand washing cannot occur.
practitioners should implement risk reduction controls to minimise hazards and risks. While in the premises, practitioners should as far as possible avoid touching surfaces or items that do not belong to them.
workspace surfaces should be thoroughly cleaned before and after a service has taken place
sheets or coverings that can be disposed of, or safely packaged and washed after use, provide useful protection between the practitioner and surfaces
materials and equipment used to provide the service must be brought by the practitioner and appropriately cleaned (and where appropriate, disposed of) before and after use, with linens and towels washed at 60 °C as a minimum
equipment that belongs to the client/customer should not be used
utensils and equipment should be disinfected at the location when preparing for the close contact service and again before leaving.
if a service is being provided to more than one customer/client at the same location, utensils and equipment should be disinfected or substituted between customers/clients
single use items may be preferable where practical
after the treatment or service is completed, items that are to be removed from the premises for cleaning should be double-bagged or placed in a suitably sealed container for transport and, if appropriate, disposal
all equipment that a practitioner takes from their own premises should be cleaned regularly, irrespective of whether it has been used or not
Face coverings are a legal requirement wherever a good or service is being sold or hired; they should be kept on throughout the treatment or service and not removed for, or during the treatment. Services that require a face covering to be removed should not be offered or performed. More information can be found in close contact services: questions and answers. Risk assessment Mobile close contact service practitioners should assess the risk to themselves and to others presented by the services or treatments provided, and put in place measures to minimise the risk of transmission of COVID-19. Practitioners can find more information on risk assessments when working in other people’s homes on the Healthy Working Lives website. You should also refer to the checklist for close contact service business owners as part of a risk assessment. Operational guide and checklist for retailers
This section of the guidance provides a usable guide for retailers to follow to ensure that they have made at least the minimum provisions for the health and safety of their staff. We have provided a checklist for retailers as an annex to this guidance. This is aligned to the Scottish Government’s Returning to Work Safely guidance. The checklist should be fully considered and implemented where possible by store managers, health and safety officers, small business owners and sole traders. Guidance for retailers preparing food Food Standard Scotland has produced guidance for consumers and food businesses that takes account of food industry guidelines produced to provide a safe working environment. Guidance for customers Retailers following government guidance are working to ensure the safety of customers and colleagues. To ensure we keep transmission of coronavirus low and ensure that shops and stores are able to serve the public whilst also protecting their employees, customers also have a strong role to play. We have published customer guidance to explain how the customer experience in shops has changed and what needs to be done to ensure a safer shopping experience for everyone. Click and Collect services From 5 April 2021 click and collect services can be offered by all retailers in Level 4 areas, in line with permitted collection services regulations. The use of click and collect services is subject to the stay local restrictions in Level 3 and 4 areas where, by law, no-one is permitted to leave their local authority area unless it is for an essential purpose. Permitted collection services It is important that all collection services are operated in a way that minimises any opportunity for contact between staff and customers and between customers. From 5 April, all non-essential retailers are able to offer a permitted collection service only where it meets the following legal requirements:
it is operated by a staggered appointment system for collection with, where reasonably practicable, a gap between each appointment to separate customers from each other
limits access to the premises only to the extent, if any, that is required to offer the collection service. Access to other areas of the closed store is not allowed
Retailers should therefore ensure that there is a gap between appointments unless there is a good reason why that is not practicable. The length of the gap may vary according to the circumstances, bearing in mind that this requirement is imposed in order to keep staff and customers safe. While permitted collection restrictions do not apply to essential retailers, the use of appointments to collect pre-ordered goods is strongly encouraged. Whilst these measures apply, retailers who are open should strive to implement similar controls, wherever possible, in order to minimise the need for customers to enter the premises and to minimise interactions with each other and with staff. Other measures that may be put in place could include:
avoiding passing goods hand-to-hand
frequent cleaning of any surfaces involved in collection services and reducing touch points
messaging customers in advance of collection to emphasise the need for face coverings to be worn and that 2 metre physical distancing is to be maintained
additional appropriate measures to ensure customers with disabilities are able to collect safely and securely
Deliveries and distribution
As a minimum we expect employers to:
provide early clarity to their supply chain about honouring of orders in the system, linked to new production capacity and consumer demand/contracts
treat all visitors including suppliers and delivery drivers, as if they were employees, ensuring they are offered the same protections and are expected to follow the same rules
Early supplier engagement COVID-19 is an international crisis impacting most countries. The global nature of the virus means it may continue to impact on demand for some goods and on normal supply chain relationships. Engagement with suppliers is recommended to understand how well placed suppliers will be to provide inputs at the level required to meet an expected demand including logistical issues associated with the current functioning of international supply networks. Minimising pressures on supply chains is paramount to ensuring that suppliers at risk are better able to cope with the current crisis and ensure service continuity and delivery during and after the outbreak. Employers are encouraged to work with suppliers to understand their specific pressures and identify potential solutions on a case-by-case basis. Operational guide for retailers in managing deliveries and supply (COVID-19)
have in place pick-up and drop-off collection points, procedures, signage and markings. For example asking customers who are picking up online orders to open the boot of their car, so if required workers can load the goods to avoid unnecessary contact between employees and customers.
order larger quantities of goods to reduce the number of deliveries
where possible and safe have single-employees unload vehicles or keep employees in consistent pairs or groups
enable delivery drivers to access welfare facilities when required, consistent with other guidance
encourage drivers to stay in their vehicles where this does not compromise their safety and existing safe working practice
create one-way flow of traffic in stockrooms
ensure face coverings are worn by all staff in indoor communal and delivery/distribution areas
Training and compliance
As a minimum we expect:
training around processes and working environment expectations should be essential for all staff particularly if a businesses is restarting following a period of closure or moving between the levels set out in the Scottish Government’s Strategic Framework.
employers to establish measures, agreed with employees, to monitor compliance with relevant regulations and processes put in place to maintain a safe return to production
Workforce training Every workplace should look and feel substantially different to pre-Covid operations for employees. Physical distancing, ventilation and enhanced hygiene requirements have changed how workplaces operate. Training is essential to build a common understanding of requirements within the new working norm and instil confidence that changes put in place will contribute to a safe working environment. Issues such as exemptions on wearing face coverings, awareness that some customers have unseen disabilities will be important in ensuring fair treatment of customers in these difficult circumstances. Training methods will need to enable effective delivery of legislative and specific measures and the expectations of staff whilst at work in a way which maintains physical distancing in line with the business and physical distancing guidance. It is anticipated visual aids will be required as part of training and ongoing guidance and communications with staff to reinforce individual responsibilities in a new normal working environment. Training is essential as a means to deliver assurance and compliance and as part of building confidence in the workplace that safety is paramount. Employers should put in place, with employee and/or trade union support, robust local arrangements to monitor compliance with operational arrangements. Remedial actions should flow from that monitoring and be augmented by advice, guidance and support from external enforcement authorities. Compliance The co-regulators for health and safety at work, the Health and Safety Executive (HSE) and Local Authority Environmental Health services are applying their expertise to ensure people at work are protected and utilising the powers at their disposal under the Health and Safety at Work Act 1974. HSE is treating COVID-19 as a workplace health issue with regard to the protection of workers from infection. HSE can and will use the Health and Safety Work Act to ensure physical distancing in the workplace in relation to workers. These actions will be taken under existing health and safety law (HSWA). A framework agreement between Police Scotland and local authorities supports the referral of complaints about lack of reasonable physical distancing at work to the relevant local authority. Local authorities will ensure that those complaints relevant to HSE are referred quickly. This would, for example, cover employers not taking appropriate action to physically distance or to ensure workers can follow the NHS advice to self-isolate for a period specified. The actions enforcement agencies can take include the provision of specific advice to employers through to issuing enforcement notices to help secure improvements or stop certain activities until issues are resolved, or in more extreme cases prosecution. Employers and employees should always work together to resolve issues. If concerns still cannot be resolved, employees can raise them with HSE or their relevant local authority. A risk assessment or adoption of mitigation measures should not be a one off exercise, rather it should be part of a regular and ongoing dialogue and feedback loop between employers and trade unions or employee representatives to identify what measures are working, where refinements are possible and any gaps remaining. Reviews of measures and risks should be frequent. The ongoing engagement between business and trade unions will enable adjustments to measures to be made to create a safe working environment quickly and smoothly at the relevant stage. Employers should ensure that communication with staff on COVID-19 risks and measures for preventing transmission are refreshed to take account of any updates to guidance and ensure levels of knowledge and understanding are maintained and that messages are not becoming stale. Updates should be provided at team meetings (weekly is suggested), and reinforced through all available channels for staff communications (e.g. TV screens/digital signage, intranet and newsletters). It is important to ensure language is not a barrier when communicating the importance of COVID-19 controls with employees. Simple, clear messaging and images should be used to explain guidelines, taking into consideration employees for which English may not be their first language and those with protected characteristics such as visual impairments. Posters, leaflets and other materials are available online which can be used to reinforce these messages throughout the workplace.