Guidance on face coverings
Face coverings have become mandatory in Wales in all public indoor spaces for both employees and customers / service users from 14th September 2020 unless they are exempt or have a reasonable excuse not to wear one.
This guidance sets out the relevant messages and best practice for face coverings to maximise the safety of all employees and customers / service users.
All front facing services that are provided in indoor spaces will be required to wear face coverings as a legal requirement. These include:
- Reception areas in public buildings.
- Leisure facilities.
- Any place where members of public enter Council buildings etc.
Additionally, Carmarthenshire County Council is mandating the wearing of face coverings in non-public facing indoor spaces where social distancing cannot be maintained. These include:
- Vehicles that have been approved by Silver/Gold to carry more than one individual.
- Visits inside domestic premises where the householders are present.
- Public spaces that are closed but could be accessed by members of public e.g. public conveniences that are closed for cleaning or inspections/maintenance.
These additional mandatory areas will be identified through the service risk assessments in liaison with health and safety and service managers.
The use of face coverings in all indoor public spaces DOES NOT remove the requirement to implement 2 metre social distancing wherever possible or remove the requirement for high standards of hygiene as these continue to be the most effective methods for preventing the spread of coronavirus.
There are several steps that are required to ensure the safe use of face coverings whilst at work. These include:
- Three-layer face coverings be worn in line with Welsh Government and World Health Organisation (WHO) Guidance.
- Washing hands before putting on and after taking off face coverings.
- Ensuring that the face covering is worn correctly over the nose AND mouth.
- Not touching the front of the face covering whilst it is being worn.
- Only handling the straps of the face covering when putting on or taking it off.
- Correct storage of a re-usable face covering until it can be washed.
- Appropriate disposal of single use face coverings.
Face coverings are a personal item and must not be shared with anyone else. Any areas the face covering may have touched e.g. the desk, must be cleaned and hands should continue to be washed frequently throughout the working day for a minimum of 20 seconds using soap and water or hand sanitiser until access to hand washing facilities is available.
Exemptions defined in law removing the requirement to wearing face coverings are:
- Children under the age of 11 years.
- Where food and drink are sold or provided and consumed on the premises.
There are also reasonable excuses, defined in law, not to wear a face covering, these are:
- The user is not able to put on or to wear a face covering because of a physical or mental illness, or because of a disability or impairment.
- The user has to remove the face covering to communicate with another person who has a difficulty communicating (through speech, language or otherwise).
- The user is escaping from a threat or danger and doesn’t have a face covering.
Some examples of reasonable excuses could include:
- An individual with complex learning disabilities.
- A member of staff or customer / service user relying on lip reading to communicate during their visit.
- A victim of domestic violence.
There may be occasions where there are reasonable excuses for face coverings to be
temporarily removed, the following may be a reasonable excuse for this:
- The user needs to take medicines.
- The user needs to eat or drink; or
- The user needs to remove a face covering to avoid harm or injury, either to themselves or others – for example to get somebody’s attention about a danger.
Some examples of reasonable excuses to temporarily remove a face covering could include:
- Where an individual has a medical condition such as diabetes and needs to eat or drink to maintain their health.
- Where the temperature is excessive and to maintain health, regular access to water is required.
- Where an individual is required to remove the face covering for ID purposes e.g. to have a picture taken for a blue badge for example.
- Where exercising would cause more risk to the user if they continued to wear a face covering.
Each case of a reasonable excuse will vary depending on the individual and the circumstances. If a face covering is to be removed temporarily, other measures must be in place to prevent the spread of coronavirus to those present e.g. physical screens or barriers.
Employees who unreasonably refuse to wear face coverings in mandatory areas without a reasonable excuse or exemption will be reported to the Head of Service / Director and may be subject to disciplinary action.
Some exemptions or reasonable excuses will not be obvious. These may require further enquiries into their identification. This should be undertaken with dignity, respect and must remain confidential and on a case by case basis.
If an employee believes they are exempt or have a reasonable excuse, they should discuss this with their line manager who will be able to ensure that arrangements are put in place appropriate for their individual circumstances.
If a customer or service user believes they are exempt, they should inform the service they are accessing, and Government guidance recommends they carry information to support their individual circumstance. Some health or disability organisations (such as Hidden Disabilities, MIND etc.) have created exemption cards or badges that the users can be directed to access if they feel they are appropriate e.g. transport operators, disability groups etc.
If an individual has concerns relating to wearing a face covering that may affect their medical condition, they should seek advice from their GP or medical practitioner.
Employees should give the customer / service user an opportunity to inform the service of their reason for exemption or reasonable excuse and provide information / documentation to support their exemption or reasonable excuse.
Carmarthenshire County Council should make every reasonable effort to prevent noncompliance and that may include not permitting access to services if the user refuses to comply and does not declare an exemption or reasonable excuse.
Employees are not responsible for the enforcement of the law. Enforcement of the law will be the responsibility of relevant enforcement agencies including the police, HSE and environmental health officers.
Any violent or aggressive behaviour (including the refusal to comply) may require the attendance of the police and reporting of the incident following the authorities accident / incident reporting system via Accident / Incident System.
Employees should discuss the supply of face coverings with their line manager who can order them from the PPE General Store.
It will be a decision for head teachers and managers as to whether a pupil is exempt from any requirement to wear face coverings. School Community Health Nurses can be contacted for advice.
Re-usable face coverings will be provided for pupils and staff by PPE General. Any schools who have not received their stocks can contact PPE General.
All staff in Primary and Secondary Schools are required to wear face coverings in all communal areas including corridors, halls, kitchens, dining rooms, meeting rooms and reception areas.
All Pupils in Secondary Schools are required to wear face coverings on school transport and in all communal areas including corridors, halls, kitchens, dining rooms, meeting rooms and reception areas.
Further information or requirements may be contained in school specific risk assessment.
Page updated: 08/02/2021 11:59:49