Wearing Face Masks at Church
A new law from the government to curb the spread of coronavirus means that face coverings are now mandatory in places of worship. The rules came into force on Saturday 8 August in England and this article is a summary of the rules and implications for churches.
This guidance is much as expected, and confirms the explanation I gave at the FIEC Leadership in Lockdown webinar on Wednesday 5 August, which you can watch here.
The Scottish Government has announced that face coverings will be mandatory in places of worship from Monday 10 August and will publish its own regulations and guidance. Face coverings are not currently mandatory in places of worship in Wales or Northern Ireland, and the respective devolved administrations have not indicated an intention to impose this restriction on churches.
The main points from the update for England are as follows.
1. What is a ‘face covering’?
A face covering is ‘something which safely covers the nose and mouth. You can buy reusable or single-use face coverings. You may also use a scarf, bandana, religious garment or hand-made cloth covering but these must securely fit round the side of the face.’
This means that visors alone do not count as face coverings for the purpose of the new law.
2. Where will you have to wear a face covering?
The new regulations and guidance extend the mandatory obligation to wear face coverings to:
- Indoor places of worship
- Community centres including youth centres
- Crematoria and burial ground chapels
- Public areas in hotels and hostels
- Concert halls, exhibition halls and other public halls
- Museums, galleries, aquariums, indoor zoos and visitor farms, and other indoor, or indoor parts of, tourist, heritage or cultural sites
- Bingo halls
- Public libraries and reading rooms
The new regulations define an ‘indoor place of worship’ as;
‘any building, room or other indoor premises used for public religious worship.’
It also states that:
‘You should also wear a face covering in indoor places not listed here where social distancing may be difficult and where you will come into contact with people you do not normally meet.’
It is clear from this that face coverings will need to be worn inside church buildings, and when churches hire other indoor spaces for their public worship services, whether that be a school, community centre, hotel, cinema or theatre.
The guidance further states that:
‘You are expected to wear a face covering before entering any of these settings and must keep it on until you leave unless there is a reasonable excuse for removing it.’
The obligation to wear a face covering does not apply to outdoor public spaces, which will include the car park, courtyard and garden of a church building.
It should be noted that the obligation to wear face coverings applies to the place and not the activity of public worship. This means that face coverings should be worn at all events and activities taking place at the place of worship. This will include any home groups, prayer meetings, children’s or youth meetings, and third-party use where the premises have been hired to another group.
The place of worship is the whole premises, and not just the ‘sanctuary’ where services are held. It will include all other halls and indoor spaces in the buildings on the site. The number of people present in the place of worship is irrelevant to the obligation to wear a face covering, so the law will apply even if a small group meets in a large hall.
Where the place of worship includes office facilities, these too are subject to the requirement for face coverings to be worn, although there are exemptions that will apply to church employees and volunteers that mean they would not have to wear face coverings in a church office environment. However, others attending the church office would need to do so.
Congregants will be able to remove their face covering to partake in the Lord’s Supper. Those distributing the Lord’s Supper must wear a face covering as they do so.
3. Who is exempt from wearing a face-covering?
There are various general and specific exemptions from the legal duty to wear a face covering which are defined as a ‘reasonable excuse’.
- children under the age of 11 (Public Health England do not recommended face coverings for children under the age of 3 for health and safety reasons)
- people who cannot put on, wear or remove a face covering because of a physical or mental illness or impairment, or disability
- where putting on, wearing or removing a face covering will cause you severe distress
- if you are speaking to or providing assistance to someone who relies on lip reading, clear sound or facial expressions to communicate
- to avoid harm or injury, or the risk of harm or injury, to yourself or others - including if it would negatively impact on your ability to exercise or participate in a strenuous activity
People entitled to exemptions can print off an exemption card from the internet, though this is not legally required.
Note that children aged 11 and over will have to wear a face covering in church and as they attend Sunday School or other groups in the church premises.
The good news for churches is that those preaching and leading services, or other events taking at the place of worship, and those assisting them to do so, have been granted a specific exemption from wearing face coverings. The revised guidance for places of worship points out:
‘Face coverings In England, face coverings are currently required by law to be worn in shops, supermarkets, indoor transport hubs, indoor shopping centres, banks, building societies, post offices and on public transport. From 8 August, face coverings are also required by law to be worn in a greater number of public indoor settings including places of worship, museums, galleries, cinemas and public libraries.
There are valid exemptions for some individuals and groups to not wear a face covering in these settings. In particular, those who are leading services or events in a place of worship, and those who assist them (for instance by reading, preaching, or leading prayer) do not always need to wear a face covering, although one should be worn especially if physical distancing cannot be maintained (i.e. distributing consumables) This exemption does not apply to worshippers, who should wear face coverings consistent with the requirements for any other public space.’
This exemption, together with the exemption below for employees and volunteers, will be sufficient to cover those leading Sunday School, children’s and youth groups and other events that take place in the place of worship.
Whilst there is an exemption for preachers and leaders etc, other mitigations might be necessary, such as a plexiglass screen or additional distance from the congregation. This ought to be considered as part of the risk assessment. More mitigation will be required if preachers and leaders cannot keep their voice to a normal conversational level and use amplification for projection and audibility.
Church Employees & Volunteers
There is also a specific exemption for employees in the guidance as follows:
‘employees of indoor settings (or people acting on their behalf, such as someone leading part of a prayer service)… - although employers may consider their use where appropriate and where other mitigations are not in place, in line with COVID-19 Secure guidelines’
Whilst preachers and service leaders may often be employees of the church, this exemption will cover all other church staff, and volunteers acting on their behalf. An employed or volunteer women’s worker, youth worker, church manager or ministry trainees would not therefore be required to wear face coverings in the place of worship. The church may decide that they should do so as to ensure a COVID-secure environment. This should be addressed in the risk assessment.
There is ls a specific exemption for weddings so that during the marriage the couple being married and the officiant are exempt from having to wear a face covering.
4. How does this affect other social distancing?
The imposition of the requirement to wear face coverings in the place of worship does not remove or diminish the requirement to observe other elements of social distancing in the guidance. For example, it remains the case that 2m social distancing ought to be observed unless the nature of the premises make this non-viable. The mere fact that the congregation must wear face coverings does not entitle the church to reduce the social distancing between seating to 1m. Nor does it affect the existing guidance on conversation between congregants or the guidance that prevents congregational singing.
At the same time that we have been informed of the new regulations/guidance on face coverings the government officials have also sent out a summary sheet highlighting the other guidance that remains in force:
Places of Worship Guidance – significant updates since publication Information all in one place for Places of Worship
Lines have been added to the guidance outlining that worshippers should limit their interactions with anyone they are not attending your place of worship with. Regulations currently allow up to two households to mix, as long as social distancing guidance is maintained. Worshippers should try where possible not to engage in conversation with anyone outside of their household or anyone they are attending your place of worship with. A household means those people who usually live together under the same roof and share facilities with you; if you have family members who do not normally live with you they need to be treated as a separate household.
‘Professional’ singers are now permitted to sing outside with an audience. It is not permissible to sing inside with an audience. Where appropriate, recordings should be used as an alternative to live singing. As we have previously updated, pilots are currently being undertaken to assess the science of spreading coronavirus through singing. We had hoped that these might result in a loosening of restrictions from 1 August, however the increase in prevalence of COVID-19 has meant that this has not been possible. We will update when we are able to.
If outdoor worship is taking place in the grounds of a place of worship (e.g. car park), and the grounds belong to the place of worship, services can be held outdoors. The guidance reflects this.
The guidance to local authorities about use of these powers is here.
Local authorities cannot impose generalised lockdowns – they can issue a direction restricting or closing specified premises. The guidance makes clear that, to make a direction under these Regulations a local authority needs to be satisfied that the following three conditions are met:
- the direction responds to a serious and imminent threat to public health in the local authority’s area
- the direction is necessary to prevent, protect against, control or provide a public health response to the incidence or spread of infection in the local authority’s area of coronavirus
- the prohibitions, requirements or restrictions imposed by the direction are a proportionate means of achieving that purpose
- A direction can be appealed to the courts or representations made about it to the Secretary of State.
As we have seen in the past week in Greater Manchester, East Lancashire and West Yorkshire, the Secretary of State for Health and Social Care can impose more general restrictions on a local area if the rate of infection rises to a level where this is warranted. These restrictions could include the closure of all places of worship if this is deemed necessary. Please be assured, where possible we will alert you to any changes like this ahead of time; however, decisions may be taken at speed in response to changes in the infection rate.
Failure to wear as face covering when required without a ‘reasonable excuse’ will be liable to fine of £100. Churches are not required to enforce the law, but the Prime Minister has instructed the police to increase their visibility to ensure that the new law is enforced, and face coverings are worn where required.
6. Suggested preparations and actions for churches
As I said at the webinar, there are a number of actions that churches ought to take as they prepare for Sunday services.
- Inform their congregations of what is expected and required under the new rules
- Provide disposable face coverings at the door for those who may not have brought one
- Brief stewards on how to determine if people are entitled to an exemption – including anticipating who amongst the regular attendees is likely to be entitled not to wear a face covering
- Conduct a risk assessment on people participating in services or events, and employees and volunteers, who are not going to be required to wear a face covering to ensure that appropriate mitigation is in place
- Decide in advance what to do if someone refuses to wear a face covering. Remember that churches have the right to refuse admission to anyone who ought to be wearing a face covering but refuses to do so
7. Links to relevant Government Guidance
The latest guidance ‘Face coverings: when to wear one and how to make your own’ can be found here.