by Dumitru Loredana-Marlen, Junior Associate Lawyer – CA Luca Mihai-Cătălin
After almost three months from the cessation of traditional gambling activities throughout the country, occurred as a result of the implementation of measures to prevent and combat the spread of SARS-CoV-2 coronavirus and as a result of industry efforts to identify solutions compatible with the activity in the context of the current epidemiological crisis, we have some good news regarding the moment from which the activity of gambling in locations can be resumed, as well as regarding the specific measures according to which the activity will be carried out.
In the context of the gradual relaxation of the restrictions on the activity, the possibility of resuming traditional gambling activities starting with June 15 increases, if the evolution of the pandemic will be favorable to support such a measure.
Whereas, in the current context, the resumption of the gambling activity in locations requires compliance with certain rules and certain specific health and safety measures, the activity can be resumed only in compliance with the Plan of sanitary measures for preventing and combating the spread of SARS-CoV-2 coronavirus, agreed by the representative professional organizations and raised to Government of Romania to be integrated in the Joint Order of the Ministry of Health and the Ministry of Economy, in accordance with the provisions of art. 71 para. 2 of Law 55/2020 on some measures to prevent and combat the effects of the COVID-19 pandemic.
As the measures differ depending on the specifics of the activity, the size of the locations where the economic activity is carried out and other specific conditions, certain rules have been proposed regarding the activity in the locations dedicated to gambling, but also regarding employees and participants in the gambling activity.
- With regard to the rules for activity in gambling venues, sanitary measures have been proposed both in terms of the organization of venues in accordance with the rules of social distance and in terms of the number of participants admitted simultaneously to the venue; and the hygiene measures required in the context of resuming the activity.
- The organization of the locations will be done in compliance with the norms of social distancing, as follows:
Electronic devices or gambling tables will not operate or will be moved to allow a distance of at least 1.5 meters between participants or, depending on the situation, separate panels will be installed.
Any area which involves long-term activity of one person will be clearly marked for adequate physical distance (for example: next to the cashier, behind the machines supposed to be occupied or at the entrance).
The staff, the participants in the game and any other person who enters the location should maintain the minimum 1.5 m distance or separating panels should be installed.
The person who does not intend to start or has already finished a game session is not allowed to stay inside the location.
Any coffee machine, other products and/or water dispenser may only be handled by employees of the work points.
Disposable containers will be used for serving drinks and food;
Where possible, customers will use their own pens. If the client uses a pen provided by employees of specialized locations, it will be placed in a separate box for subsequent disinfection.
For the casino game, the distance between the customers around the gaming tables will be at least 1.5 m, ensured by the appropriate arrangement of the tables. If the recommended distance cannot be respected, separating panels between customers or tables can be installed.
These measures apply to all organizers of land-based gambling, with the exception of bingo games, which has specific measures.
Organizing bingo locations:
The distance between the customers around the gaming tables will be at least 1.5 m, ensured by the appropriate arrangement of the tables. If the recommended distance cannot be respected, separating panels between customers or tables can be installed.
At the fixed stations of the installation control center, the same minimum distance of 1.5 m will be kept between the members of the operating staff or, depending on the situation, separators will be installed between the stations.
The mobile staff serving the players with playing cards will distribute and collect the cards at the tables in the designed area so as to respect the minimum prevention distance. This stage of the game will be performed minimizing customer interaction.
- The number of participants in a location
The maximum number of participants admitted simultaneously to the location will be 1 person/every 4 sqm.
Only one customer is allowed per electronic gambling machine.
Employees will make sure that players/customers do not gather around the game machines.
- Sanitation protocols
Disinfection of work and play areas and surfaces will be performed at intervals of up to 12 hours. Sanitizing biocides will be used according to specific instructions.
The ventures staff should carry out periodic disinfection of frequently touched surfaces (eg: door handles, elevator buttons).
The employees will sanitize gambling machines before and after periods of heavy use, as well as at each shift.
- Sanitation materials and products
Hand sanitization spots will be made available to gambling participants, employees, other people, at the entrance and inside all locations.
Signs will be installed to remind game participants to sanitize their hands before participating in the game.
- Ensuring adequate and regular ventilation of work rooms
Where appropriate, interior doors without security impact shall be locked in the open position to ensure ventilation and avoid the use/touching of handles.
Where possible, rooms should be ventilated every 4 hours by opening doors and windows.
- With regard to the Requirements applicable to employees, companies will have the obligation to inform and train employees about the applicable risks and measures, the need to perform their daily triage, the obligation to wear masks and personal protective equipment, as well as the procedure for managing cases of COVID-19.
- The informing of employees
The managers/persons responsible for the specialized locations will adopt the Prevention and protection measures plan, will sign for being informed and will have the obligation to ensure that all subordinate employees have been trained and informed, have received the necessary materials and use them properly.
For the entire period in which the Plan of Prevention and Protection Measures is to be applied, regular training of employees will take place.
Informative materials will be displayed at work, in visible areas (eg entrance, reception, toilets – eg display of the correct hand washing technique, display of the correct wearing of the mask, dining rooms).
- The triage
The daily measurement of the employees’ temperature at the beginning of their shift will be performed, with the recommendation of consulting the family doctor, for those with a temperature higher than 37.3°C. People with symptoms of respiratory infection (cough, sneezing, rhinorrhea, fever, altered general condition) will not be allowed to enter/attend the workplace.
- Personal protective equipment – use of masks
It is mandatory that all the employees and customers of the working points wear protective masks throughout their activity in that location. The masks will be changed at an interval of 4 hours or whenever they get wet/damaged. After use they should be thrown in the trash can – preferably in one with a lid.
- The individual hygiene
All employees will be instructed to wash their hands or use disinfectant when a sink is not available, every 60 minutes (for 20 seconds).
Hand hygiene will be performed before putting on the mask and after any of the following activities: using the toilet, sneezing, touching the face, nose-blowing, removing the mask, cleaning, sweeping, washing, smoking, consuming, drinking, entering and leaving gambling locations, work interruption both before and after the start of the shift.
- COVID-19 case management
In the event that the symptoms appear before the going to work, the employee in question will remain at home and will notify his manager/person responsible for location/direct superior. It is also recommended that the employee notify their family doctor.
If a person is at work and shows symptoms of COVID-19, he/she will be isolated immediately. The situation will be managed by the manager/person responsible for location.
If the person has the following symptoms: temperature higher than 37,3°C, difficulty breathing, frequent cough, fatigue, altered general condition will be announced at 112 and the public health directorate will be notified, in order to carry out the epidemiological investigation.
It is necessary to contract professional space disinfection services in the event that an employee is positively confirmed with SARS-CoV-2;
- Regarding the Measures applicable to gambling participants, they take into account the need to ensure a safe organization and operation of gambling for all participants, proposing some rules on the right of access, social distance, the obligation to wear a mask and triage, as follows:
- Customer responsibilities
The clients who have been in contact with people infected with SARS-Cov2 or who come from risk areas is prohibited are not allowed to access the location. The interdiction will be communicated at the entrance to the halls, using information materials (posters) .
Access to the location is not allowed for the person who has symptoms such as: temperature higher than 37,3°C, difficulty breathing, frequent cough, fatigue, altered general condition.
The client’s access inside the locations will be made, mandatorily, using a mask that should be worn throughout the client’s visit to the location. This obligation will be permanently displayed as long as the measures to control and prevent the spread of SARS-Cov2 coronavirus established by the authorities are required.
Customers have the obligation to properly sanitize their hands (at location entrance and later at the gambling areas), either by washing with soap and water, or by using alcohol-based hand sanitizers, where there are no toilets.
The participants in the game have the obligation to keep a distance of 1.5 m from other people inside the location.
- The triage
Customers will have their temperature measured at the entrance of specialized gambling locations, except for fixed odds betting locations (betting agencies) and lotto games (lottery agencies).
- Personal protective equipment – use of masks
It is mandatory that all the visitors and customers of the working points wear protective masks throughout their activity in that location. The masks will be changed at an interval of 4 hours or whenever they get wet/damaged. After use they should be thrown in the trash can – preferably in one with a lid.
- The individual hygiene
Hand hygiene will be performed before putting on the mask and after any of the following activities: using the toilet, sneezing, touching the face, nose-blowing, removing the mask, cleaning, sweeping, washing, smoking, consuming, drinking, entering and leaving gambling locations.
- COVID-19 case management
If a person is at work and shows symptoms of COVID-19, he/she will be isolated immediately. The situation will be managed by the manager/person responsible for location. If the person has the following symptoms: temperature higher than 37,3°C, difficulty breathing, frequent cough, fatigue, altered general condition) will be announced at 112 and the public health directorate will be notified, in order to carry out the epidemiological investigation.
- The informing of customers
Indicator markings or warning messages regarding the minimum permitted distance of at least 1.5 m shall be displayed in a visible place.
Hand hygiene messages will be displayed in a visible place (eg area of directly operated gambling machines, access areas, toilets).
The customer information regarding the obligations to adopt the sanitary protection measures will be performed as follows:
- Posting outside the location an information poster on the mandatory measures to be followed inside the location (respecting the minimum safety distance between people, respecting the distance markings and mandatory use of the mask.
- An information poster will be posted in the gambling area regarding the obligatory social distancing measures, the obligatory use of the mask, the rules of conduct on the premises and the adoption of a responsible behavior;
- An information poster on the correct hand washing technique must be displayed in the toilets.
- Showing how to correctly wear a mask.
- The number of people present simultaneously in smoking areas will be limited, depending on the space available (floor markings, increasing the number of ashtrays), where possible.
The measures presented represent the draft set of rules, estimated to be applied in the field of gambling at the time of resumption of activity.
Once adopted, each gambling organizer will issue its own health safety procedures for its working points based on the general recommendations of the authorities, taking into account, of course, the gambling-specific action plan.
Although it involves a number of important financial and human endeavors, especially in the context of the long-term shortage of revenue companies the sanitary measures imposed on the gambling organizers correspond to the general line of preventive measures, meant to remove the danger of COVID-19 spreading.