These questions and answers are aimed at providing further clarity to sector businesses following publication of Scottish Government retail sectoral guidance. It is not separate to government guidance but designed to complement it and further the understanding of what businesses need to consider and do to ensure they are operating safely and within the legal requirements.
As we move through Scotland’s route map, guidance is being regularly reviewed and updated. It remains a gradual process and while the retail sector has made significant progress to date with reopening, a high level of caution and awareness is essential in order to avoid any set-backs. Government does not want to keep restrictions in place a moment longer than is necessary, but safety must come first. Businesses are therefore requested to maintain the excellent work that has been undertaken so far and to continue working with authorities to build on that progress.
The shopping experience
Q: Which businesses can stay open in Level 4?
A: The businesses which must close at Level 4 are set out in law. Those that can remain open are:
- food retailers, including food markets, supermarkets, convenience stores and corner shops
- off-licences and licensed shops selling alcohol (including breweries)
- pharmacies (including non-dispensing pharmacies) and chemists
- building merchants and suppliers of products and tools used in building work and repairs
- petrol stations
- car repair and MOT services
- bicycle shops
- taxi or vehicle hire businesses
- banks, building societies, credit unions, short-term loan providers, savings clubs, cash points and undertakings which by way of business operate a currency exchange office, transmit money (or any representation of money) by any means or cash cheques which are made payable to customers
- post offices
- funeral directors
- laundrettes and dry cleaners
- dental services, opticians, audiology services, chiropody services, chiropractors, osteopaths and other medical or health services, including services relating to mental health
- veterinary surgeons and pet shops
- agricultural supplies shops and agricultural markets
- storage and distribution facilities, including delivery drop off or collection points, where the facilities are in the premises of a business included in this sub-paragraph
- car parks
- public toilets
- livestock markets or auctions
- outdoor markets, and outdoor motor vehicle lots, but only for the collection of a vehicle that has been purchased, or the delivery or collection of a vehicle for the purposes of a repair, MOT or service
Businesses which are allowed to stay open will be expected to follow all other legal requirements, rules and guidance.
Q: My business isn’t in the list above – do I have to close in Level 4?
A: Yes. For retailers which have been defined as non-essential – i.e. not on the list of essential businesses above - the legal position is that they will need to close in Level 4. Any decision to move an area into level 4 will only be made if absolutely necessary as a short, sharp intervention to address very high transmission rates. Most retail is permitted in levels 0-3, with mobile close contact being limited to levels 0-1. Mobile hairdressing only can operate in levels 2-3
Q: If I am in the non-essential category, can I still trade online?
A: Yes – shops and retail businesses that close in Level 4 can continue to make deliveries to fulfil orders received online, by phone, text or post.
Q: Are there any restriction to shopping hours?
A: There are no current plans to restrict shopping hours.
Q: How have you engaged with business around this?
A: We have been engaging with retail sector representatives and business organisations to understand their concerns and will continue to do so.
Q: What are you closing in Level 4?
A: Level 4 is broadly similar to full lockdown where the priority will be to reduce movement as far as possible to address high transmission rates and this will necessitate closing non-essential retail. Essential retail will be able to remain open in Level 4. All retailers will be able to continue online shopping and outdoor retail will also be able to operate in all levels.
Q: How will shutting shops reduce the spread of the virus?
A: In moving to Level 4 we would expect to see very high or rapidly increasing incidence of the spread of COVID–19 and widespread community transmission which may pose a threat to the NHS. The priority in level 4 is to reduce movement of people so that we can reduce transmission of the virus. Shopping is an area which can attract a lot of people, many of whom travel to shops, including on public transport. By shutting non-essential shops, we limit the spaces where people are exposed to others in enclosed spaces for prolonged periods. Measures would be designed to be in place for a short period, to provide a short, sharp response to quickly suppress the virus. It is likely that this level would see the introduction of measures close to a return to full lockdown.
Q: Will people have to queue to get into a store?
A: Possibly, yes. Closing some parts of the high street can mean that customers will have a smaller number of stores to choose from, resulting in increasing queues / numbers. The need for businesses to maintain 2m distancing also means that fewer people can safely be inside a shop or store at any one time. Businesses will be expected to determine how many people can safely be accommodated at any one time and implement queuing and other measures to prevent overcrowding. Customers are expected to follow any measures that retailers put in place. The priority in Level 4 is to reduce movement of people so that we can reduce transmission of the virus.
Q: Will you support a campaign to get people to shop local?
A: We would encourage everyone to observe the stay at home regulations and think about whether their journey to the shops is necessary and to walk or cycle to local stores, where that is possible.
Q: Will people be able to buy a new or used car?
A: Yes – car sales will be allowed. However, people must adhere to the stay at home regulations and only leave their homes for an essential purpose. This restriction would also apply to the purchase of a new car. Showrooms must close and outdoor motor vehicle lots may only open for the collection of a purchased vehicle (or for delivery or collection of a vehicle for service, repair or MOT). Businesses must put in place measures to operate safely, for workers and customers, including face coverings, physical distancing and staggered appointments. Customers will be expected to adhere to these measures. Wherever possible any paperwork required should be completed online.
Q: How should collection be arranged for a customer who has purchased a car?
A: The safety of all staff and customers is vitally important, and so businesses should put in place measures to operate safe collection including face coverings and physical distancing. It is recommended that the measures for other retail collections is also followed:
- Putting in place a staggered appointment system with a gap between each appointment where reasonably practicable, and
- Limit access to the premises only when absolutely necessary.
Q: Can car auctions continue to operate?
A: Car auctions must adhere to the Regulations which state that showrooms must close and outdoor lots may only open for the collection of a purchased vehicle.
Q: Can a potential buyer take a car for a test drive before buying it?
A: No. Showrooms must close and outdoor vehicle lots may only open for the collection of a purchased vehicle (or for delivery or collection of a vehicle for service, repair or MOT).
Click and collect services
Q: What changes are being made to the way click and collect services currently operate?
From 16 January 2021 click and collect services can only be offered by businesses that are classified as essential retailers or businesses that are listed in the Amendment Regulations as being able to offer a permitted collection service:
- baby equipment shops
- book shops
- clothing shops
- electrical goods shops, including repair shops
- footwear shops
- garden centres and plant nurseries
- homeware shops
- key cutting shops
- shoe repair shops
It is important that click and collect transactions are carried out in a way that limits contact between staff and customers and between customers. Therefore, businesses that can provide permitted click and collect services must by law:
- Put in place a staggered appointment system with a gap between each appointment where reasonably practicable, and
- Limit access to the premises only to the extent necessary to provide the service.
Other measures that may enhance protection and should be considered including:
- 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 (which could also be advised for collection outside premises) and physical distancing to be maintained.
- Additional appropriate measures to ensure customers with disabilities are able to collect safely and securely.
It is important to remember that stay at home regulations mean that people should only be leaving home for an essential purpose. Using a delivery service if at all possible is preferable to either shopping in person or using click and collect. If you must use click and collect it should be for an essential purpose only.
Q: Is click and collect for essential items only?
The Regulations apply to types of retailers not to types of product. There is no list of essential or non-essential items. The stay at home regulations state that you must remain in your home except to fulfil an essential purpose. That will be determined by the circumstances If you must use click and collect it should be for an essential purpose only. If you are purchasing items that are not for an essential purpose you should arrange for those to be delivered.
Q: Do the changes to the way click and collect operates also apply to essential retailers?
A: The conditions for collection set out in the Regulations only apply to the list of currently closed retailers that are permitted to continue to offer click and collect services. However, the safety of all retail staff and customers is vitally important, and so it is recommended that essential retailers also implement these measures wherever possible, to ensure their click and collect processes are as safe as possible.
Q: Can click and collect be offered by retailers within shopping centres?
A: Yes, from a retailer permitted to offer these services.
Q: Is collection from a convenience store still permitted?
A: Essential retailers can continue to provide a collection service, which would include grocers /convenience stores.
Is collection by car still permitted and does it need to be by staggered appointment?
Collection of items by car is still permitted. The new Regulations on how click and collect must operate apply to all the retailers listed as being able to provide permitted collection services.
Q: Can customers still access the retail store for click and collect purchases?
A: The Regulations state that access to the premises must only be given to the extent necessary to provide the service. Access to other areas of the closed store is not allowed.
Q: Do click and collect items need to be paid for beforehand?
A: Orders should be paid for at the time they are placed to minimise the collection time and contact with customers. No additional products should be added to the order once the customer attends the business to pick up their goods and no cash should change hands to prevent contact. If cash cannot be avoided it should be used in a way that avoids hand-to-hand contact.
Q: What happens if a retailer is unable to comply with the restrictions to click and collect?
A: If a retailer is unable to comply with the law they should cease click and collect services.
Q: If items have already been ordered an item for click and collect before 16 January can they be picked up?
A: Items ordered before 16 January from non-essential retailers not on the permitted list, cannot be picked up after 15 January. An alternative delivery method will need to be put in place. Items ordered before 16 January from permitted retailers can be collected but this must be in accordance with the new operating rules.
Q: Can distribution centres remain open to service online and Click and Collect shopping as well as deliveries?
Q: Can items still be picked from a self-service kiosks or locker?
A: Yes, but customers must bear in mind that it is unlawful to leave the house for anything other than an essential purpose.
Q: Will deliveries of large items such as furniture or white goods still be permitted?
A: Businesses providing a service in someone’s home should refer to the general guidance for safer workplaces.
Strategic Framework and Levels
Q: Why has this approach been introduced?
A: Our ability to control the virus requires us to restrict economic activity as part of wider efforts to minimise transmission risks, and protect lives and the NHS. This approach will provide a more transparent and easily understood framework for managing outbreaks and allow us to respond appropriately and proportionately. It means those areas with low rates of infection do not need to be under the same protective measures designed to suppress the virus in areas with much higher rates.
Businesses will want to know in advance what may happen if there’s a risk of either a rise or drop in the infection rate in their area so that they can manage staffing, deliveries, services etc. Having a strategic framework helps them plan in advance for any changes - either up or down the levels.
Q: How will the Levels system operate?
This framework sets out 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
We would expect to see low incidence of the virus with isolated clusters, and low community transmission. The Baseline and Level 1 are designed to be sustainable for longer periods.
All retail businesses and close contact services including mobile services will be able to operate in these levels.
We would expect to see increased incidence of the virus, with multiple clusters and increased community transmission. 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.
Retail businesses will be able to operate in Levels 2 and 3, as will close contact services that are delivered from a salon, shop or other static site, such as a home treatment room.
Mobile hairdressing and barbering can also continue in Levels 2 and 3.
All other mobile close contact services will not be able to operate in Levels 2 or 3.
Essential retail will be able to remain open in Level 4.
All other non-essential retail will be expected to close.
All close contact services – static or mobile – will be closed.
Q: Can I travel between areas in different Levels?
A: To suppress the spread of COVID-19 it is essential that, with limited exceptions, there is no travel to or from areas where higher numbers of people may be carrying the virus. If people do not abide by the guidance on travel and transport there is a risk that the virus will spread to areas where it is less common and we may have to return to national restrictions.
Q: How often will the levels change?
A: Local areas and the levels they are in will be reviewed weekly to decide whether levels should be maintained, increased, or reduced. However, while levels will be reviewed weekly, areas are likely to move between levels less frequently than that. Once set, levels are likely to be in place for two to four weeks at least, to give time for the effect of changes to be observed in data about the virus, and to ensure that the incidence and prevalence of the virus are responding to measures put in place to suppress it. The First Minister has stated that the outcome of the weekly review will be reported on a Tuesday with any changes proposed coming into effect on a Friday.
Q: What boundaries are being used to decide where the Levels are?
A: The Levels will be assigned to each local authority area. For very large geographic areas, such as the Highlands, it may be that the levels are established by Ward area.
Q: What evidence is being used to make a decision if Levels will change?
A: Decisions will be made on the basis of advice from local Directors of Public Health and Public Health Scotland, through the National Incident Management Team, and the assessment of our own senior advisors against the four harms. We will also engage with our local authority partners prior to making decisions and on the delivery bodies we rely on to implement and oversee the measures.
Q: What are the “Four Harms”?
A: These are the impacts of COVID-19 assessed over the following areas:
The virus causes direct and tragic harm to people's health.
The virus has a wider impact on our health and social care services in Scotland.
The restrictions which have been put in place affect our broader way of living and society.
The impact on our economy, with a damaging effect on poverty and inequality.
Q: Will there be clarity on customers' personal travel between local authorities on different Levels and what it means for Click and Collect etc?
A: To suppress the spread of COVID-19 it is essential that, with limited exceptions, there is no travel to or from areas where higher numbers of people may be carrying the virus.
If people don’t abide by the travel guidance set out here, there is a risk that the virus will spread to areas where it is less common and we may have to return to national restrictions.
Q: Are people in Level 4 areas allowed to travel to Level 3/2 to shop?
A: The recommendation is that people in a Level 4 area do not travel outside their local authority area unless for work or if it is absolutely necessary.
Q: Can distribution centres remain open to services online and Click and Collect shopping as well as delivereies?
Q: Will deliveries of large items such as furniture or white goods still be permitted?
A: Yes. There’s more information on this in the general guidance for safer workplaces.
Q: Is the installation of goods such as washing machines permitted?
A: Yes – this is also covered in the general guidance for safer workplaces
Q: What are “other services or procedures which require physical contact or close physical proximity between a provider and a customer” that are “ancillary to medical, health, or social care services”?
A: The Health Protection (Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 2020 (legislation.gov.uk) as amended set out the definition of a close contact service. The lists in the definition vary depending on the protection level area and depending whether the close contact service is premises based or a mobile service. It is recommended that you check the definitions relevant to the protection level for your area.
The definition of a close contact service that applies to premises based close contact services in Level 4 areas lists a number of services, including ‘massage therapies’ and ‘CAMS’. The list also includes ‘other services or procedures which require physical contact or close physical proximity between a provider and a customer and which are not ancillary to medical, health or social care services’. This captures services or procedures which require close contact, and which are not covered by the specific services listed. Where these ‘other services or procedures’ are ancillary to medical, health or social care services they may continue in Level 4 areas – this is to ensure that necessary medical, health or social care services, including care packages, may continue.
In relation to what “other services” are considered ancillary to medical, health, or social care services and may therefore continue in Level 4 areas, the Scottish Government cannot provide advice in relation to specific or individual examples - it is for individual practitioners to ensure that any “other services or procedures” they provide under Level 4 restrictions are legitimately ancillary to medical, health, or social care services. In Level 4 areas, we would advise that the focus of such treatment/care should be restricted to essential or urgent treatment of clinically diagnosed conditions where no treatment would have a significantly adverse impact on the wellbeing of the patient. For example, this could be treatment or care being provided in a hospice as part of a palliative care package.
Q: Do Allied Health Professionals provide other services or procedures which require physical contact or close physical proximity between a provider and a customer and are ancillary to medical, health, or social care services?
A: Allied Health Professionals such as physiotherapists or podiatrists may operate in Level 4 areas if they are providing ‘other services or procedures’ which are ancillary to medical, health or social care services. However, we continue to call on their professionalism and clinical judgement to ensure the range of treatments provided is appropriate and delivered in a way that does not have an adverse impact on the national effort to keep COVID-19 under control. We ask that face to face services provided by Allied Health Professionals in Level 4 areas focus on essential or urgent treatment of clinically diagnosed conditions, where no provision of treatment would have a significantly adverse impact on the wellbeing of the patient.
Public protection remains our absolute priority and wearing face coverings, maintaining physical distancing and observing proper hygiene procedures are the keys to breaking the chain of transmission. Read more information on these measures on the Scottish Government website . As well as all relevant Scottish Government guidance, it is also important that AHPs continue to adhere to the Public Health Scotland Covid 19 Guidance as well as to all applicable guidance from statutory regulators and professional bodies.
Q: What support will there be for businesses that have to close?
A: Details of support for businesses facing closure or restrictions will be published shortly. Information on current support is available on the Find Business Support website or on the UK Government’s Work and Financial Support pages.
Close contact services - face coverings
Q: Do my clients/customers need to wear a face covering?
A: Yes, under Schedule 7 of the Health Protection (Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 2020 any person including staff and clients/customers must wear a face covering in a location used for the retail sale of goods or services – including shops and salons. Practitioners and clients/customers are encouraged to refer to current Scottish Government face-covering guidance for further information.
Q: Can I ask the client/customer to remove their face covering to perform a treatment on the face?
A: You should not ask a client/customer to remove their face covering. No treatment should be performed that requires the face covering to be removed. This includes treatments that your service might routinely provide.
Whilst beauty therapists are able to operate, certain therapies should not be performed if they break other guidance or regulations. This means treatments that require the removal of a face covering should not be offered or carried out, even if the client is exempt from wearing a face covering and the area is exposed.
Current professional advice is that, for safety reasons, close contact services should not be performed where face-coverings cannot be worn.
Q: Does my salon or treatment room count as a shop?
A: Yes, under Schedule 7 of the Health Protection (Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 2020 the requirement to wear a face covering applies to any location used for the retail sale or hire of goods or services.
Q: As a business owner/third sector organisation do I need to enforce this law on my clients/customers?
A: Where face coverings are required, people responsible for relevant premises should take reasonable steps to promote compliance with the law.
If necessary, the police have enforcement powers including issuing fines of £60 (halving to £30 if paid within 28 days) if members of the public do not comply with this law.
Q: Do I need to wear a face covering while cutting hair or treating clients/customers or does it only apply to my clients/customers?
A: Yes. Schedule 7 of the Health Protection (Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 2020 also applies to staff who must wear a face covering, subject to the exemptions. Further to this, your risk assessment under the Health and Safety at Work legislation must cover measures to ensure the aerosol/droplet transmission hazard is controlled. A face covering is a practical measure to control this risk. If an exemption applies and staff cannot wear a face covering the business / third sector organisation must implement another control which achieves the same effect. A face shield alone would not control the risk from transmission.
Q: If staff wear a visor do I need a face covering too?
A: Face shields/visors do not constitute an adequate face covering for the purposes of meeting your obligation under Schedule 7 of the Health Protection (Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 2020 Face shields or visors may be used, but only if they are worn in addition to an adequate face covering, as the evidence shows that they do not provide adequate protection. However, if you are unable to wear a face covering due to an exemption, a face visor or face shield can be worn as it does provide a limited level of protection.
Q: Who is exempt from wearing a face covering in a retail setting e.g. a shop?
A: Those who are exempt from wearing a face covering. These include:
- a child who is under the age of 5
- a constable acting in the course of their duty
- an emergency responder (other than a constable) acting in their capacity as an emergency responder
Read the full list of exemptions
Q: Can services still be provided if the practitioner or customer/client is exempt from wearing a face-covering?
A: We have published guidance on the public use of face coverings and for the retail sector.
Organisations have a duty under the Equality Act 2010 to make reasonable adjustments for disabled persons. The Equality and Human Rights Commission website includes guidance on using a service: reasonable adjustments for disabled people and retailers’ legal responsibility to disabled customers, and you can contact the Commission for further advice.
Close contact services - physical distancing
Q: How does physical distancing impact close contact services?
A: Regulations allow for physical distancing of at least 2m “so far as reasonably practicable’. As close contact services cannot be provided from a 2m distance, these services can continue to take place (provided your business operates in a Level that allows you to open.)
Where possible, 2m should be maintained in order to reduce the contact between individuals on site, for example, clients/customers should be at least 2m from one another when on the premises.
Q: Do I need screens between treatment areas/chairs?
A: 2 metre physical distancing is the legal minimum physical distance between persons without a partition. If 2m cannot be guaranteed then screens should be used to ensure physical distancing is maintained.
Q: Can I use all the chairs in my barber’s shop/salon if they are spaced at 1m from one another?
A: It is recommended that chairs be spaced at distances of at least 2m from one another. Where this cannot be achieved it may be possible, with additional controls, to have chairs located at a reduced distance. Remember there must be at least 2m physical distancing between persons. If this cannot be guaranteed screens/barriers should be put in place.
Q: Should I install screens between chairs?
A: Yes where 2m physical distancing cannot be guaranteed. Screens/barriers may provide a degree of comfort for clients/customers and act as an additional control, however, where clients/customers are less than 2m apart it is likely that they will still be considered a contact in the event that someone in the salon tests positive for COVID-19. In these instances it is likely that anyone within less than 2m of that individual will be required to self-isolate for a period of 14 days.
Q: The only wash hand basin within the salon is in the staff toilet, do we need to install more?
A: Wash hand basins should be accessible to staff within the premises. The suitability will be dependent upon the location, the further away from the work environment the more unlikely they will be frequently used. However, within a hairdressing salon the backwash sinks could be utilised for hand washing.
Where hand washing facilities are located in other parts of the premises it is important to ensure that surfaces such as door handles are cleaned regularly to minimise contamination.
You should consider the provision of hand sanitising stations as an additional measure to supplement wash hand basins. Clients/customers should be asked to sanitise their hands on arrival.
Q: I’m delivering mobile close contact services – where can I do that?
A. Mobile close contact services can be delivered in a customer/clients home or in any other place where the client/customer may have requested the treatment, such as a community facility or a hotel. Practitioners should only see one client/customer at a time and ensure appropriate hygiene and physical distancing measures are taken to manage risks of working in an external environment. Practitioners can find more information on risk assessments when working in other people’s homes on the Healthy Working Lives website.
Q: How do I increase the ventilation in my business?
A: Advice on ventilation is provided by HSE
Close contact services - Test and Protect
Q. Do I need to record customer details?
A. Yes – clients/customers details should be collected either through a booking system or manually on the day of the appointment.
The gathering of contact information in a secure and safe manner from clients/customers or visitors to premises, will assist NHS Scotland's Test and Protect service to identify and contact individuals who may have been exposed to the virus, and request them to take appropriate steps to prevent the potential onward spread of the virus. The data will also be helpful to the NHS and key local partners to manage and contain location-specific outbreaks.
Q. Do I have to use the Protect Scotland app?
A: Protect Scotland is not a requirement – however it is important that we all download and use the app to help stop the spread of coronavirus. We know the more of us that do, the more effective it will be. We encourage all businesses, staff, practitioners, and their customers to download the Protect Scotland app.
Q: How long do I need to keep client/customer details on file for Test and Protect / contact tracing purposes?
A: Client/customer details should be retained for 21 days. Where details are to be retained electronically a business needs to be registered with the Information Commissioner’s Office. The ICO has produced specific guidance on this for businesses.
Q: What details should I be keeping for clients/customers?
A: As a minimum you should be retaining the clients/customer’s name and contact number or email address along with the name of the individual who provided treatment
Where possible, it is recommended that you note the room/location or chair that the client/customer occupied during the treatment. The more specific information that you can record about a treatment, the greater the benefit in the event that Test and Protect need to trace individuals. This could also protect the continuity of your business/third sector organisations/practitioners by limiting the number of staff/people having to self-isolate.
Close contact services - appointments
Q: Do I need to have an appointment system in place?
A: The majority of close contact service practitioners operated prior to lockdown with an appointment based system in place and should continue to do that. Where a /practitioner previously operated on a walk in basis (barber shops, nail bar, brow bar etc.) it is strongly recommended that consideration be given to the adoption of an appointment system. This will ensure that your client/customers will not be disappointed if they turn up and cannot be served or allowed into the premises. In the event that large numbers of people attend on the same day, you as the practitioner are responsible for the queueing both inside and outside your premises (even if on the public footpath). Where a number of different practitioners operate side by side this could become difficult to manage particularly when physical distancing requires to be maintained in a queue.
Q: Can clients/customers bring a chaperone / attendant / family member /children into the salon?
A: It is recommended that the number of people on the premises be kept to a minimum and that this should only be those who are there to receive treatment. The more people who are on site, the greater the number of contacts and the higher the risk. If the client/customer makes you aware in advance that they will be bringing a chaperone or attendant with them you can ensure arrangements are in place to maintain physical distancing between them and others within the salon i.e. move chairs to further increase the distance.
A chaperone or attendant can be either a family member, friend, carer, care worker, translator or interpreter that assists the client/customer regularly with any health or social/religious requirements.
Q. The guidance says mobile practitioners should only meet the clients/customers they will be working with although a chaperone/attendant can be present if appropriate and if physical distancing is maintained. Who can this chaperone/attendant be?
A. A chaperone or attendant can be either a parent or other family member, friend, carer, care worker, translator or interpreter that assists the client/customer regularly with any health or social/religious requirements.
Q: Can I allow clients/customers to use the toilet on the premises?
A: Toilets can continue to be used in a managed way and provided that hand contact surfaces are cleaned between uses. It is also recommended that, where possible, the frequency at which mechanical ventilation operates within toilet facilities be increased. It is important to remember that some clients/customers may require to use the facilities for medical reasons.
Q: Can I offer clients/customers a cup of tea whilst on the premises?
A. No drinks should be offered to clients/customers when in the salon. Clients/customers may bring their own drinks with them if needed and may temporarily remove a face covering to drink from their own container, maintaining a 2 distance from others where possible.
Q: Can I still use the waiting room as normal for clients/customers that turn up early?
A: It is not recommended that the waiting room be used unless it is possible for clients/customers to maintain the required distance. It is strongly recommended that clients/customers be encouraged to arrive at the time of their appointment and no earlier. Where an early arrival occurs, clients/customers should be asked to wait in their car or outside if it is not possible for them to maintain the required distance within the premises.
Where a waiting room is used procedures will require to be in place for the regular cleaning of hand contact surfaces such as arms of chairs, tables etc.
For close contact services operating in Level 3, additional protective measures to further inhibit the virus and enhance the safety of practitioners and customers/clients should be considered. Types of additional protective measures can include eliminating the waiting area outright.
Q: Do I have to remove magazines from the waiting room?
A: It is recommended that all unnecessary hand contact surfaces be removed from the premises and that clients/customers be advised to bring their own reading materials with them and take them with them when they leave.
Close contact services - treatments (including the High Risk Zone)
Q: What is the ‘high risk zone’?
A: The ‘high risk zone’ is the term used to describe the face, mainly the mouth and nose.
Q: What are acceptable control measures to allow treatments to be carried out in the high risk zone?
A: Considerations could include; minimising the time being spent working on the high-risk zone and implementing additional control measures (working from the side of the face etc.) or procedures to mitigate the increased risk. Treatments should not be performed that require the client’s/customer’s face covering to be removed.
Where additional controls cannot be implemented, treatments should not be offered.
It should be noted that if, at a later date, the client/customer is identified as a case who was infectious at the time of treatment, the individual performing the treatment will be considered a close contact and required to self-isolate regardless of the control measures implemented.
Q: In relation to treatments involving the face (high risk zone) what is the definition of “prolonged period”?
A: Health Protection Scotland has produced contact tracing guidance that contains information on close contact in non-healthcare settings. This suggests that ‘prolonged periods’ could be:
- no amount of time: if face-to-face contact is at 1 metre or less; (i.e. in effect this should not be permitted)
- 1 minute: if contact is 1 metre or less, but does not involve face-to-face contact
- 15 minutes: if contact is between 1 and 2 metres, whether or not contact is face-to-face
The limitation on the provision of any treatment is the ability to provide it from the side or behind the head. If you can provide the treatment from the side or from behind the head you should reduce the time in the high risk zone as much as possible. Treatments should not be provided in the area covered by a face covering – even if the client is exempt from wearing a face covering and that area is exposed.
Q: The guidance states that the therapist may work shoulder to shoulder with the client/customer. Can the client/customer turn to face therapist during treatment and vice versa?
A: Face to face treatment in any setting should not be carried out at present until government guidance changes.
Q: Is there a maximum time that a treatment can be carried out?
A: Services which require workers to be within the high risk zone of clients/customers, for the entire duration of the treatment or the majority of the time the service is being provided, should not be resumed until government guidance changes.
Q: What makeup applications can take place?
A: All treatments currently permissible must be applied from the side or behind the head and the clients face covering should not be removed. Given these limitations it is expected that only eye make-up can be provided at this time.
Q: Can Semi Permanent Make Up (SPMU) treatments be performed?
A: SPMU must be performed from the side or behind. The client’s/customer’s face covering should not be removed, which may limit what SPMU treatments can be offered.
Q: Can I use a hairdryer?
A: Yes hairdryers can be used, although we would suggest that as they may cause the client/customer to raise their voice they are used only when necessary.
Q: Can I play music/television and converse with clients?
A: In general, sources of background noise like hairdryers, music, and television that might cause raised voices should be avoided, and clients/customers and practitioners are encouraged to limit conversation as much as possible
Q: Should I ask clients/customers to wash their hair before arrival at the salon?
A: Only if this is something you require before treatments normally.
Q: Can a facial steamer be used?
A: Treatments that require the client/customer to remove their face-covering should not be offered at this time.
Close contact services - equipment
Q: Do I need to replace all my reusable tools with disposable ones?
A: No. Where equipment can be adequately disinfected it does not need to be replaced. Depending upon the contact time of the chemicals used to disinfect, it may be necessary to have additional items available should they be required. Any equipment used must be fully disinfected between clients/customers.
Q: Do I need to use plastic aprons on my clients/customers?
A: Plastic aprons are one method of limiting the spread of COVID-19 through contact with potentially contaminated surfaces. Regular aprons, fabric face coverings, towels etc. can still be used, provided that they are changed between clients/customers and that they are washed at 60°C. Where reusable items are to be used it is essential to ensure that you have sufficient supply available.
If using disposable items it is recommended that these be double bagged prior to disposal, with particular care given to items that are used for treatments in the high risk zone.
Close contact services - photography studios
Q. Do my clients/customers have to wear a face covering at all times?
A. If you are operating a shop or studio that is in a retail setting and is open to the public, a face covering has to be worn by clients/customers unless an exemption applies.
Q. I operate from a studio which clients/customers attend on an appointment – only basis. Do the close contact guidance requirements apply?
A. Yes, in as much as you should not offer any beauty or make up treatments that are not currently recommended when working in the high risk zone and that require the removal of a face covering. Photographs must be able to be taken by the photographer providing that there is a partition between the photographer and the customer/client, or a distance of at least 2m is maintained between the photographer and the customer/client.