Risk Management decisions and in person worship post July 19th re-opening

Sunday 25th July will be a crunch date in the calendar. This is the first Sunday after the formal relaxation of all COVID restrictions in England. It means that there will no longer be regulations and fines relating to failure to wear masks or socially distance at a church gathering. Singing will also be allowed although it is worth remembering that singing was not overed under regulations but under guidance previously.

However, the lifting of regulations does not mean that the problem of COVID-19 has gone away. Nor does it mean that churches no longer have responsibility in this area. In fact, it is arguable that a greater burden of responsibility now falls on churches as well as individuals.  Indeed, the current situation regarding singing is perhaps comparable to what we might expect the situation to be post July 19th for other measures.  The point about singing being advised against under guidance is that should your congregation start singing now, it would not necessarily lead to the police turning up or you being issued with fines. However, it does mean that you could run into problems with your insurer and should things go wrong, an investigation might determine that you failed to properly take guidance into account when planning and risk assessing, this could be classed as a breach of health and safety law. Similarly, we might expect there to be further guidance issued on singing, social distancing and mask wearing in gatherings such as church services and we will need to take this into account when planning ahead.

Therefore, I would encourage churches to plan ahead carefully remembering that leaders and trustees will be both morally and legally accountable for what happens on the church premises. There are therefore 4 things to consider when putting together your risk assessment.

  1. What are the objective risks in terms of your church service leading to a super spread incident causing local case rates to rise and even leading to hospitalisations and deaths?
  2. What responsibilities do you have legally and towards insurers, property owners (if hiring) etc?
  3. What will be the response of the congregation to how you plan and organise things?  Will you be showing appropriate pastoral care or will you ne putting stumbling blocks in the way of weaker brothers and sisters (however you choose to categorise those)
  4. What will be the perception of the local community to how you plan and organise things? Will your actions act as a good and honourable witness which commends the Gospel?

With that in mind let’s consider the example of singing in church.  Should you proceed with a return to normal congregational worship on the 25th July? Well, whilst we await updated guidance for England, it is worth remembering that the Welsh Government have already issued guidance. The wording is as follows:

The risks of singing, chanting and playing of instruments are then significant. However, scientific advice has concluded these risks are manageable where the community transmission rate is low. For this reason singing and the playing of instruments as part of worship practise can take place where a risk assessment and appropriate mitigations have been put in place. This would include both indoors and outdoors, as well as both performance and congregational singing. However, it is emphasised that extreme caution should be exercised, especially in relation to large groups indoors .[1]

The wording talks about “manageable risks where the community transmission rate is low” but doesn’t in the immediate context define what is meant by low transmission. However, elsewhere, it has been suggested that low transmission counts as under 50 cases per 100,000.  To give you a feel for where we are on that, here are the actual community transmission rates for the postcodes of three churches, Bearwood Chapel, West Midlands, Beacon Community Church, Buttershaw, Bradford and Rochester Baptist Church, Kent.[2]

Bearwood:  231.4 cases per 100,000

Buttershaw: 264.9 cases per 100,000

Rochester: 106.2 cases per 100,000

The national case prevalence is 286.3 cases per 100,000 meaning that all three of our examples are significantly below the national rate. That’s based on the main Government COVID data site figures which look at cases over the past seven days. The ONS estimate for in community cases is higher at 1 in 160 or 625 cases per 100,000 which means that there may well be more cases in the community than those identified through testing and that people may have COVID longer than seven days. Though also remember that a higher proportion of those will be symptomatic and therefore self isolating.

However, all three examples are significantly above 50 cases per 100,000. Although at the same time, at that prevalence rate, the probability of having 1 person with COVID in a congregation of 150 or less remains low. 

The other factor we have to take into account at this stage is the direction of travel in terms of cases.  As these two charts show, the rate of growth in COVID infections is slowing.

Weekly no of cases
Weekly increase in cases
Weekly % increase in cases

This offers the hope that we may be seeing the current wave reach its peak. However, we still don’t know quite when that peak will come, or whether the relaxation of measures on the 19th July will give renewed energy to the wave leading to further exponential growth or whether this will be counter balanced by the arrival of school holidays, ending of the Euros and progress with vaccination.  It is likely that by the 25th July case prevalence will be equal if not higher than now but it is possible that it could be lower by mid-August.

On this basis, I would assume that there is some risk to reintroducing indoor singing at least for the first few weeks after the 19th July. It is possible that the risk could be mitigated if members are willing to  participate in lateral flow testing prior to attending indoor church services where singing happens.  My inclination in all three examples here would be to go slowly in reintroducing indoor singing at the moment.

Options that might help with the reintroduction of singing include:

  • Singing a few songs together outside the building before and/or after the indoor elements of the service.
  • Inviting people to take in turns to sing as small groups within the congregation (which would be similar to having small choirs singing.  Whilst this is not the same as having everyone joni in together in unison, it does allow everyone to participate in singing and certainly fits with the instruction in Ephesians 5:19 to sing to one another.

As well as considering the objective risks of spreading disease and the legal requirements, we also need to consider the impact of our decisions on congregations too. There’s no point pushing ahead with a full removal of restrictions if the result is that people are more wary about attending.  With that in mind, I did a brief series of straw polls on twitter the other day. Here are the results of the questions I asked.

Now, note that these polls involved very small numbers and further that there may well be bias reflecting the disposition of people I tend to interact with.[3] So, I’m less interested in the % of people choosing each option than in the fact that there are people out there who do choose those options.

So among my followers on twitter are people who:

  • Are not yet meeting together and are wary of meeting when case numbers are high
  • Will be put off attending by the lifting of social distancing, the singing ban and the requirement for face masks.
  • Any requirement to socially distance and/or where face masks.

There also seems to be a level of willingness to participate in ongoing test and trace if it helps us to open up churches safely, although there are some who would not participate even if the data was only used by the church and not shared wider or with secular authorities.

This shows how tricky it is to get the right decision and reminds us that we probably won’t be able to please everyone. There’s real potential for falling out in churches and we are going to need a lot of grace, forbearance and patience with each other.

What I would encourage you to do is to do a similar survey with your own congregation as it will help inform you with decision making as you put together your own risk management plan.

The known risks associated with full re-opening with no masks, no social distancing and the reintroduction of full congregational singing are:

  1. Actual risk of becoming a source of infection spread: Moderate
  2. Risk of invalidating insurance:  High
  3. Risk of being found in breach of Health and Safety Law High
  4. Risk of increased anxiety and reluctance to participate from congregation: High
  5. Risk of creating a bad witness in the community High

Of course those risks have to be weighed against other risks. Our highest concern is to be obedient to the Lord and different churches will come to different conclusions as to how best to do this. It is my view that we should make every effort to meet as close to in person as possible but that this can include taking precautions in the context of a pandemic (hence I’ve willingly participated in online church gatherings). 

My view is that the risk assessment at the moment requires mitigation so that we should not be expecting a full return to in normal in person gatherings on the 25th July but I am confident that we can move towards that through August. I would advise:

  • Singing should be limited to outdoor singing for the next few weeks. However, the possibility of having congregation members participate by taking it in turns to sing in small groups should be investigated.
  • Congregation members should be encouraged to wear face masks if and where possible. This should not be a compulsory requirement but it may be wise to indicate areas in the building/worship area where face masks are compulsory. This will give people the option of sitting in face mask only areas.
  • I would continue to manage seating to allow for some space between bubbles.  This would mean a reduced seating capacity in many church contexts. As mentioned before, I would prefer to add another service than rely on increased seating capacity in one meeting.
  • Congregation members should be encourage to participate in the mass testing programme for as long as it lasts, to stay home if they or someone in their household has symptoms or tests positive
  • To operate a voluntary in house signing in system to enable people to be contacted if they are likely to have been in proximity to someone who subsequently tests positively for COVID
  • To continue to provide online options.

Whilst we want COVID-19 to be over soon, it isn’t over yet and it is better to proceed cautiously now than to quickly re-open and then experience a set back such as a local outbreak within the congregation.


[1] Guidance on reopening places of worship: coronavirus [HTML] | GOV.WALES

[2] I’ve chosen these based on two criteria, they are places where I’ve lived and they represent a range of different contexts.

[3] I think that most people engaging with me are often core participants in their churches and so are more likely to be already attending in person worship.

As mentioned in the article, I understand that there are differences of opinion about how Christians should relate to pandemic guidance and regulations. This is because most Evangelical Christians would agree that God’s Word commands believers to gather for worship and not to forsake this. There are however differences of opinion.

  1. Some Christians insist that this must be a physical gathering and must include singing as well as prayer, Bible readings and preaching
  2. Some Christians agree that the gathering should be a physical one but that there are permitted exemptions such as in the context of a pandemic. This is because Christians are also commanded to love their neighbour and to honour/respect the law of the land
  3. Some Christians argue that the gathering does not need to be physical or include all the elements described above so that an online event counts as a church gathering.

My view is that we should make best efforts to gather as close to in person as possible. Whilst the ideal gathering is fully in person with singing, Bible reading, prayer, preaching and communion, it may not always be possible to do all of that. We should get as close to that possible. So for example a Zoom meeting with interaction is better than just watching a service on line. A meeting with face masks where God’s Word is read and prayer happens is better than Zoom and so on.

I think the absence of specific legal offences means that we are in a slightly grey area in terms of submitting to authorities. However we need to look at the guidance and advice as well as legislation to understand what authorities are asking. Authorities include local public health directors. We also need to check carefully at all times to ensure that the authorities are not asking us do things which are in conflict with God’s Word.

How you approach these questions means will affect how you approach risk assessments. I would suggest that whilst we all might land at different places on the spectrum that.

  1. The Bible’s injunctions on being good neighbours and loving each other mean that we cannot simply ignore the responsibility involved in carrying out a risk assessment and making decisions to mitigate risk. This is about being good stewards and loving pastors.
  2. The call to love, enjoy and glorify God means that we cannot simply be driven by numbers on a risk chart. There has to be faith and obedience to God.