Organising Christmas events
Christmas activities such as winter wonderlands, light shows, reindeer trails and other similar activities are highly likely to constitute an event for the purposes of the Health Protection (Coronavirus Restrictions) (No. 4) (Wales) Regulations 2020. This may include cases where existing premises or attractions are augmented on a temporary basis (e.g. in relation to the festive season).
The definition of an event in the Regulations is broad:
“…an occasion— (i) which is planned or scheduled for a particular purpose, and (ii) at which any number of people are in the same place for that purpose, whether or not they are participating in a gathering.”
An event can, therefore, consist of a number of separate attractions.
Therefore, regulation 7 (prohibition on organising events) applies. In respect of an event that is wholly or mainly indoors, regulation 7 provides that no person may be involved in organising an event at which more than 15 people are in attendance excluding any person under the age of 11 or who is working or providing voluntary services at the event. For outdoor events, no more than 30 people may be in attendance excluding those under 11 or those working or providing voluntary services at the event.
Anyone planning to organise an event will need to consider and plan very carefully including in relation to how numbers will be strictly managed to ensure that they do not exceed the maximum number of 15 or 30 attendees at the event site at any time. For example, if 30 people are in the event you cannot also have an additional 30 people queueing to enter. Regulation 35 of the Health Protection (Coronavirus Restrictions) (No. 4) (Wales) Regulations 2020 provides that it is an offence to contravene the requirements of regulation 7.
Anyone organising an event under these Regulations will also be required to undertake a risk assessment and to take reasonable measures to minimise the risk of exposure to coronavirus, including taking all reasonable measures to ensure that 2m distance is kept between persons who are not of the same household and not to sell or supply alcohol at the event.
There are limited exceptions, with the following not treated as events:
(i) he showing of a film;
(ii) a market;
(iii) a religious service;
(iv) a sporting event at which only elite athletes are competing.
What about Christmas markets?
Markets are not treated as events for the purposes of the Regulations. However, those responsible for organising any Christmas markets must take all reasonable measures to minimise the risk of exposure to and prevent the spread of coronavirus.
Please see the guidance for retailers for more information.
Can I visit Santa’s grotto?
Yes, but if the grotto is part of a number of separate attractions, it is highly likely that the rules above on events will apply.
The grotto organiser will also need to take all reasonable measures to minimise the risk of exposure to the virus. This includes social distancing whilst queueing, flows in and out, ventilated space if possible. Santa and anyone over 11 need to wear a face covering and maintain social distancing. Prospective Santas need to also consider exposure /any vulnerabilities and make judgement regarding putting themselves at risk. The rules on “gathering” together within the Regulations must be complied with.