Managing risk as the UK lockdown eases
Hotels and guest accommodation managing risk

As the UK hotel industry reopens its doors after the COVID-19 lockdown, stringent health and safety measures are in place for establishments to adhere to. Focus will be on effective risk management, both for the immediate future and for long-term business continuity in one of the hardest-hit industries of the pandemic.

When the UK Government imposed a nationwide lockdown on 23rd March 2020 due to the spread of COVID-19, those in the hospitality and leisure industry hoped that this would be a short-term setback. However, Government guidance that ‘no person should stay overnight away from their home for a holiday or similar purpose’1 remained in place for over three months, causing extreme disruption across the industry, and financial disaster for many hotels and guesthouses.

The challenge for businesses then became the safe reopening and ongoing operation of these venues for staff and guests. From 4th July hotel and guest accommodation providers were given the green light to reopen with limits to some facilities and services such as indoor swimming pools, spas and gyms, until these facilities were permitted for use on 25th July as lockdown eased further.

Over the coming weeks and months the hospitality sector must embrace a ‘new normal’ and the hotel industry will need to follow strict rules and regulations in order to create a safe and enjoyable guest experience. While Government guidance is now available for hotels to welcome guests once more, the mitigation and management of risk will be a priority.

Risk management for the hotel industry

We are on hand to help our clients in the hotel and accommodation sector to navigate through the complexities of risk management as they get back to business. We have researched the available information issued by both the Government and trade associations, and this article will highlight key points from our findings, but it is by no means exhaustive.

While we are sure you will have carried out your own research, the situation with COVID-19 is continually evolving and much of the available information is regularly updated. Therefore we would encourage you to keep up to date with Government advice and other trusted industry sources. Please note that Government advice may be different for the devolved administrations.

Government guidelines for guest accommodation

The latest official guidance for hotels and guest accommodation in the UK can be found on the Government’s website2 which sets out how to reopen safely while minimising the risk of spreading coronavirus. To summarise:

  • Private rooms in all indoor accommodation can reopen as long as they have en-suite showering facilities, or one designated shower facility per guest room.
  • Shared toilet facilities can also be opened. If shared toilet and shower facilities are in the same room, guests are able to use the toilet but can only use the shower if it is assigned to one household or support bubble or run using a reservation and clean rota.
  • Accommodation owners must complete an individual risk assessment for the premises and work activities outlining how these guidelines are being implemented.

You will find more information on cleaning, PPE, social distancing, workforce management, and inbound and outbound goods on the Government website. There is also a vast amount of recommended advice from trade bodies on how to adhere to the guidance within specific areas of your business, much of which we will cover in this article.

COVID-19 risk assessment

Below we have outlined suggested control measures to consider as part of your COVID-19 risk assessment and development of risk management procedures for the protection of staff. This guidance applies across all businesses that employ staff (please note this list is not exhaustive).

  • Staff should be instructed not come to work if they have a high temperature, new continuous cough or the loss of taste or smell. They should self-isolate for seven days, or as long as prevailing guidance dictates.
  • Workplace training should include details on social distancing requirements, the correct wearing of face coverings, routes of virus transmission and the importance of increased and timely hand washing and surface disinfection.
  • Heightened cleaning and disinfection regimes should be put in place to disinfect all frequently touched areas such as tables, chairs, counters, tills, card machines, etc.
  • For staff break areas/canteens, stagger timings so that groups of staff have slots to come for their meals to reduce gathering.
  • In office/admin areas, many people could be sharing the phone, keyboard, mouse and desks. Cleaning products should be made available for cleaning these items before and after use.
  • Enforce social distancing rules at lunch or smoking/vaping breaks.
  • For uniforms or clothing, there is more control if laundry is carried out in-house or professionally, rather than staff taking it home.

If you would like further advice on your risk assessment please speak to your usual Gallagher representative. We offer a COVID-19 risk assessment validation service to help you meet Government guidelines.

Staff consultations

You must consult your workers on health and safety and encourage them to be actively involved in managing health and safety processes.

This is an important area of risk management as your business goes through the consultation process, completes the necessary documentation, and revises any contractual terms and conditions as necessary. Getting this right be will be key to defending any potential claims.

You may need to repeat these discussions if the situation changes, such as lockdown restrictions being applied, someone in the workplace contracting COVID-19, plans you have put in place not working as expected, or if new guidelines have been published.

The HSE has produced a guide for employers on how to talk to their staff about reducing the risk of the spread of coronavirus3 covering everything from organising the workplace, cleaning and sanitising, social distancing, and wellbeing and support. Training is important for all staff to ensure they understand the new risks.

NHS Test and Trace

To help reduce the spread of COVID-19, hotels and guest accommodation businesses will be required to keep a temporary record of customers and visitors for 21 days and to assist NHS Test and Trace with requests for that data if needed.

Please be aware this could be a potential area for data breach risk and you will need to follow strict guidelines. Customer Test and Trace data needs to be kept secure, not held longer than the specified 21 days, deleted securely, and only used for the purpose for which it was intended in order to comply with GDPR.

Key risk management areas for hotels and guest accommodation

The COVID-19 risk assessment guidelines we have listed will apply across all areas of the workplace. To help you and your employees apply these to specific areas of your business and premises, we have put together some more detailed points to consider:

Reception areas

  • Reception desks should be organised so that staff can be at the Government recommended distance away from guests as much as possible.
  • Where appropriate and achievable, consider screens between staff and guests/visitors in communal areas.
  • Ensure all reception staff, guests and visitors have access to hand sanitiser at the front desk and that staff use this between serving guests.
  • Adopt non-contact payment methods/electronic signing of documents, etc. where practicable.
  • Use floor markings or other physical indicators, where appropriate and achievable, to act as visible reminders of social distancing requirements.
  • Consider a central key card deposit box placed in the lobby for disinfection of room keys.

Room Service

  • Explain to guests your staff’s social distancing process with regards to food delivery and collection.
  • Staff should wash their hands before and after picking up the room service tray, and collecting the tray should be done in a timely manner to avoid cross contamination.
  • Paperwork and cash tips should be avoided.
  • Single use items should be used where possible and disposed of in accordance with relevant guidelines.
  • After use, crockery and cutlery should go in the dishwasher without delay, and the tray must be disinfected.


  • Review the frequency of the cycle of cleaning and in-room services and communicate the necessary information to the guest, including in pre-arrival communications.
  • Keep room collateral to a minimum to avoid cross-contamination between guests and reduce cleaning time.
  • Room cleaning should be undertaken in the absence of the guest, unless it is difficult for the guest to leave the room (e.g. due to mobility constraints) in which case social distancing must be observed.
  • Make a checklist of hand contact surfaces and disinfect them between guests. This list could include, but is not limited to, the following: – Door handles, light switches, bedside tables, remote control, taps, flush handles and toilet seats, hair dryer handles, iron and ironing board, trouser press, safe buttons, wardrobe doors, mini bar handle, kettle handle and lid, heater and/or air conditioner controls.
  • Glasses and crockery should be removed and washed in a dishwasher, not the room sink.
  • Towels and linens should be washed in accordance with washing instructions without delay.

Spa Facilities

  • Customers should be strongly advised to wear face coverings before entering the premises and during treatment, and to use hand sanitiser on arrival.
  • The person providing a service, e.g. hair dresser or nail technician, should wear a clear face visor, and, if practicable other PPE such as gloves and overalls before carrying out treatments.
  • Visors should be worn over the forehead, extend below the chin, and wrap around the side of the face. A re-usable visor must be cleaned and disinfected regularly using normal cleaning products.
  • Protective screens should be used to separate customer areas e.g. in a nail salon.
  • Make any changes to entrances, exits, queue management and waiting areas to adhere to social distancing guidelines.
  • Refrain from playing music at a volume that may encourage voices to be raised, so as not to increase the potential for increased risk of virus transmission through the air.
  • Treatments should be kept to the minimum time necessary.

Leisure Facilities

  • Public Health England (PHE) or equivalent posters should be on display informing customers and staff of social distancing and cleanliness/hygiene protocols throughout the facility.
  • If operators observe that any staff or customers show any signs of COVID-19 (temperature, cough and difficulty breathing), they should ask them to leave the premises immediately and to follow Government regulations regarding self-isolation.
  • Hand wipes/sanitisers should be available, or clear signage to direct customers to the nearest handwashing facility.
  • Operators should ensure that social distancing is adhered to according to any given area, including gyms, hot tubs, spa pools, whirlpools, hydrotherapy and swimming pools.
  • Use of shared changing rooms should be avoided if possible, although must be available for participants with disabilities or special needs, and are likely to be needed after swimming.
  • Clear signage should be displayed around hand washing, social distancing and limiting surface contact.
  • Face masks will not be mandatory for staff, unless their role requires this.
  • It is down to the individual customer to take reasonable personal responsibility when taking part in physical activity.

Other health and safety considerations


  • Reduce maximum occupancy for lifts.
  • Consider minimum lift usage from reception, encouraging use of stairs where possible.
  • Provide hand sanitiser nearby and encourage its use before lift operation via clear signage.
  • Advise guests on your protocols for safer lift usage in their pre-stay communications.


  • Ensure adequate signage and posters are displayed to build awareness of good handwashing technique, increased handwashing frequency, avoidance of touching your face, and to cough or sneeze into a tissue which is disposed of safely, or into your arm if a tissue is not available.
  • Consider the use of social distancing marking in areas where queues normally form, and the adoption of a limited entry approach, with one in, one out (whilst avoiding the creation of additional bottlenecks).
  • Consider making hand sanitiser available on entry to toilets where practical, ensure the availability of liquid soap and suitable hand drying options (either paper towels or hand driers).
  • Increase the frequency of cleaning, paying attention to frequently touched surfaces, including taps, hand driers and door handles. Use disposable cloths or paper roll to clean hard surfaces.
  • Keep the facilities well ventilated, for example by fixing doors open where appropriate.
  • Put up a visible cleaning schedule can keep it up to date.
  • Provide extra waste facilities and more frequent collection.

Waste disposal

  • Contact your waste contractor to advise them of any changes in your procedures, such as increased frequency of collections.
  • Consider additional litter bins on your premises to encourage customers to dispose of their own waste, such as takeaway containers or wrappers.


  • Consider air filtration to keep spaces and rooms well-ventilated.
  • Where possible and appropriate, choose natural ventilation.

Water systems

  • You should review your risk assessment and manage legionella risks when you reinstate a water system or restart some types of air conditioning units.
  • If hot and cold water outlets are used infrequently, flush them weekly to prevent water stagnation.
  • Drain, clean and disinfect spa pools and hot hubs before reinstatement.
  • Check HSE guidance4 for more detailed guidance on methods of control.

Guest transportation (e.g. airport pick-up)

  • Amend vehicle capacities to help ensure social distancing.
  • Provide sanitiser dispensers with signage in shuttle bus services.
  • Ensure the vehicle is disinfected before each journey.
  • Encourage the use of face coverings by bus/taxi drivers and passengers in line with Government guidelines.
  • Use contactless payment systems where possible.
  • Remove unnecessary collateral within the vehicle to reduce touched surfaces.
  • Drivers should minimise assisting with luggage. If it’s necessary they should maintain the required distance where possible, and sanitise their hands afterwards.

Please note that the information we have outlined here is not exhaustive. Every establishment must formulate customised measures that are fit for their location, premises and capacity. We have included links at the end of this article for further reading.

Protection for the hotel industry – what happens now?

As the bigger picture unfolds for the hospitality and leisure insurance market, owners of hotels and guesthouses across the UK and beyond must firstly look carefully at their existing cover. Then, they will need to navigate their way through any policy changes implemented by their insurance company, as well as keeping up to date on what’s happening in the wider market with product suspension and exclusions. Obtaining sufficient cover can suddenly seem much more complex.

When the COVID-19 pandemic took hold, many businesses across the hospitality and leisure sector turned to the business interruption sections of their policies. However, most policies do not provide cover for pandemics and many claims for losses arising from disruption to business caused by COVID-19 have been declined5 .

The FCA is currently looking into the way insurers have responded to COVID-19 related claims and the outcome of its findings is due to be published in September6 , so some of these decisions could be overturned.

Meanwhile, some specialist insurers that previously offered solutions for pandemics have discontinued these products or added exclusions that relate to losses arising from coronavirus (including COVID-19) or any future epidemic or pandemic that poses a threat to human health. This is compounding the issue of an already hardening market and leaving customers unsure on how best to proceed when selecting adequate cover for their establishments. All of these considerations are leaving business owners in the hotel industry wondering where this would leave them in the event of another pandemic or similar global health event years down the line.

How can Gallagher help?

Gallagher has extensive experience in the hospitality and leisure sector, providing insurance and risk management solutions for all kinds of guest accommodation, from multinational hotel chains to boutique B&Bs.

No one is entirely sure yet what the ‘new normal’ will be for the hotel industry, and more to the point, how it will adapt to these new circumstances and begin to thrive again. In the immediate term, through our risk management consultancy services, we can assist you in managing the health and safety aspects of reopening your hotel or guesthouse to the public, helping you to meet Government guidelines specific to COVID-19 in your risk assessment. We also offer a Competent Person Service which can assist you with your health and safety obligations

For the longer term, we can help you navigate the changes in market offerings and design tailored cover for your business, as well as working with you to develop a robust business continuity plan for the months and years ahead.

Download PDF Version


  3. HSE
  4. HSE
  5. FCA
  6. FCA