As more states show progress in the fight against the coronavirus, restaurants and other food and beverage venues are examining what a post-COVID-19 world might entail. Will desperate patrons tired of shelter-in-place orders be able to again frequent the dining rooms of their favorite local restaurants?
And assuming patrons are willing to return, what sanitation protocols will restaurants be required to implement? Or perhaps most fundamentally, will there ever be a return to “normal”?
Restaurateurs here in the U.S. don’t yet have definitive answers to these questions, at least as of this writing. But measures being taken in countries further ahead in their COVID-19 recovery, and the self-directed policies and practices of leaders in other hospitality industry verticals—including cruise, lodging and airline—may provide us a glimpse of things to come.
Looking at those countries that have started implementing mandatory sanitation protocols for restaurants and other businesses seeking to reopen (e.g., Singapore, China, Austria and Denmark), and those global hospitality industry members (including Genting Cruise Lines, Accor, Marriott and Emirates) that have elected to self-impose improved sanitation protocols and practices to provide guests and patrons the confidence needed to venture out again, we start to see some re-occurring themes.
- Social Distancing. Some form of social distancing is required—expressed as minimum required distances between patrons and/or tables, group size limitations (no more than four patrons at any one table) and/or caps (percentage) on use of building’s legal maximum occupancy. This requirement applies not only to front-of-house table placement and required spacing in congested waiting areas and lobbies, but also to back-of-house food preparation areas where individual workstations must be clearly marked.
- Patron Protocols. All patrons are screened, including possible temperature readings, upon arrival. Where available, patrons are required to produce appropriate health certifications or declarations. Patrons are required to wear masks except when eating or drinking. Payment transactions are handled entirely online via mobile phone application or other electronic device so that no exchange of currency occurs.
- Employee Protocols. Mandatory health screenings, including possibly daily temperature readings, of back-of-house and front-of-house employees are a regular occurrence. Employees returning from areas under quarantine or shelter in place orders are required to self-quarantine for 14-day periods. Infected workers are immediately removed and quarantined. Service staff are required to wear masks and gloves.
- Cleaning Protocols. Public areas are sanitized and disinfected with greater frequency—in some instances, hourly—using newest available technology and hospital-grade disinfectants. Records detailing sanitization schedules must be maintained. Sanitizer stations are widely available for employees and patrons.
- Food Hygiene. Disposable cutlery is available upon request. Stricter, improved procurement guidelines are mandated and contractually imposed on suppliers. Self-service buffets or stations are no longer available.
- Sanitization Manager or Committee. Member of management team (or committee) is charged with implementing, monitoring and enforcing—and periodically reviewing/updating—protocols.
In some instances, these protocols are used as part of a broader audit or certification process to evaluate and report on the practices of a particular facility or venue. These are similar to those widely used in restaurants by state, county and city health departments today, but with a particular focus on updated and improved post-COVID-19 protocols.
Whether some or all of the above protocols are ultimately adopted by state, county and/or city health regulators here in the U.S. will depend on any number of factors. It’s safe to say that at least initially, until the risks substantially subside or the protocols are proven ineffective, many of the protocols will play a critical role in any attempted return to “normal.”
A few final words of caution: Care must be taken whenever adopting and/or implementing these types of standards. First, in your attempt to allay the health-related fears and concerns of your patrons, don’t over commit.
Whether any of the identified protocols and procedures—even if followed religiously—will prove effective in combatting the virus and its spread is largely unknown. As a restaurateur, you are in no position to assure your patrons of a healthy and safe experience while dining at your restaurant.
Second, recognize that once adopted, your sanitization practices and protocols, like all good policies, become reality regardless of whether they are ever actually implemented.
In other words, if you assure patrons that your cooks and servers are being tested daily for respiratory distress or fever—even if you never test a single person—your patrons will understandably rely on those assurances. And if not accurate, those assurances may be used against you if guests contract the virus or suffer from any other condition that could have been reasonably prevented through the actual use of the subject protocols. If you adopt, you must implement.
Finally, the implementation of certain of the listed protocols entails the collection and use of potentially sensitive health-related information about employees and patrons. Before implementing any screening strategy, it’s important to understand what legal requirements, if any, might attach to your processing of that information.
Greg Duff is a principal at Foster Garvey in Seattle and chair of the law firm’s Hospitality, Travel and Tourism practice.