COVID-19 Update #13

Dear all,

Easing of restrictions in NSW from Monday 1 June 2020

We give thanks and praise to God that Australia has not experienced the rates of infection or deaths from COVID-19 as in other countries.  We give thanks that we can return to fellowship together, or at least that a number of our church communities will be able to return to their local church.

But, we also pray that God will keep safe all those who come together in fellowship, and encourage all our readers to be sensitive to the concerns of others as you do so.  This is particularly so for elderly and vulnerable members who gain great comfort in the saving grace of our Lord Jesus through their local church services and community.

While it is encouraging that we are starting to step out in growing confidence, it is too early to assess whether there will be a second wave about which most health professionals are concerned.  Accordingly, we outline below the mandated restrictions by the NSW Government on Places of public worship and offer our suggestions to ministers and pastoral leaders as you discuss the opening of your churches to religious services.

The Legislation – extracts relating to places of public worship

Due to some inconsistencies in the new legislation, we provide the following extracts of the legislation for your information:

Restricted premises (Schedule 1)

PremisesLimitation on number of persons on premisesRestrictions or conditions
column 1column 2column 3
18. Places of public worship  For a wedding, funeral, memorial or religious service – as per clause 11(1) For private worship, the lesser of (a) 50 persons, or (b) the total number of persons calculated by allowing 4 square metres of space for each person on the premises(a) may be open to the public only for a wedding, funeral, memorial or religious service or for private worship (b) for a wedding, funeral, memorial or religious service – as per clause 11(2)  

11. Directions of Minister about gatherings for weddings, funerals, memorial services and religious services

(1)    The Minister directs that a person must not participate in—

(a)    a gathering for a wedding service, or a gathering immediately after a wedding service, at which there are more than 20 persons, excluding – (i) the persons being married, and (ii) the persons necessary for the conduct of, or assisting in the conduct of, the service or gathering, and (iii) one photographer and one videographer,

(b)    a gathering for a funeral service or memorial service, or a gathering immediately after a funeral or memorial service, at which there are more than 50 persons, excluding the persons necessary for the conduct of, or assisting in the conduct of, the service or gathering, including, for example – (i) the funeral celebrant or minister of religion, and (ii) the funeral directors,

(c)    a gathering for a religious service at which there are more than 50 persons, excluding the persons necessary for the conduct of, or assisting in the conduct of, the service.

(2)    The Minister directs that—

(a)    a person at a wedding, funeral, memorial or religious service, or a gathering immediately after a wedding, funeral or memorial service, must provide the person’s name and contact details, including a telephone number or email address, to the relevant person for the service, and

(b)    the relevant person for the service or gathering must record the names and contact details, including telephone numbers and email addresses, of all persons at the service.

(3)    In this clause – relevant person, for a wedding, funeral, memorial or religious service, or a gathering immediately after a wedding, funeral or memorial service, means – (a) for a service or gathering held in an indoor space—the occupier or operator of the premises, or (b) for a service or gathering held in an outdoor space—the person conducting the service.

5. Directions of Minister concerning restricted use of certain premises

(1)    The Minister directs that premises referred in column 1 of Schedule 1 are subject to—

(a)    the limitation on the number of persons that may be on the premises at any time set out opposite the premises in column 2 of the Schedule, and

(b)    the condition that no person may be on the premises as part of an individual group of more than 10 persons, and

(c)    any other restrictions or conditions set out opposite the premises in column 3 of the Schedule.

(2)    Subclause (1)(b) does not apply to persons –

(a)    engaging in work on the premises,

(b)    participating in a gathering for a wedding, funeral, memorial or religious service, or a gathering immediately after a wedding, funeral or memorial service, at which no more than the number of persons permitted at the service or gathering under clause 11 are on the premises.

(3)    If it is a condition that there must be a COVID-19 safety plan for the premises, the occupier or operator of the premises must—

(a)    develop and comply with a safety plan for the premises that addresses the matters required by the COVID-19 safety checklist approved by the Chief Health Officer in relation to the type of premises and published on an appropriate Government website, and

(b)    keep a copy of the COVID-19 safety plan on the premises and make it available for inspection by an authorised officer as requested.

Summary of restrictions from 1 June 2020 and recommendations

1.     Church services:

  • Religious services of up to 50 people are allowed, which excludes the persons necessary for “the conduct of, or assisting in the conduct of, the service”. 
  • Persons excluded from the 50 worshippers.  The minister and those working on the production of a livestream are excluded from the maximum of 50 worshippers.  These would include, for example, the worship leader, the sound desk operator, the data operator, musicians who provided the music throughout the service.  That is, all those “necessary“ for the conduct of the service. 
  • Persons included in the 50 worshippers.  Worshippers who have been asked to undertake certain tasks such as reading from the bible, lead prayers, making an announcement, or a soloist who provides a musical item.
  • Children are also included in the maximum number of 50 persons on the church premises at the same time.
  • Children’s and youth ministries.  We believe that children’s and youth ministries can be run at the same time as the church service, so long as they are part of or associated with the religious service (for example, ministries being conducted for children or young people of families attending the church service) and the total number of persons on the church premises is no more than 50.
  • 4sqm per person.  Although the new legislation in NSW appears not to mandate that the maximum number of persons in any one space needs to be limited to 4sqm per person, we caution ministers and pastoral leaders about increasing the number of worshippers in any space, halls or room above the 4sqm rule.
  • Please measure the size of all rooms.  We recommend that the church space and any rooms or halls that may be used during the church service be measured and a sign be produced that shows the maximum number of persons able to meet in that space or room.
  • Maximum number of persons per space.  So long as the maximum number of persons in any one room does not exceed the maximum capacity for that room based on the 4sqm rule, we believe that the maximum number of persons on the premises at any time cannot exceed 50 (plus the minister and any livestreaming persons).
  • Vulnerable members should be discouraged from attending church services for the time being.
  • Singing during religious services.  Although there is no mandate against singing, the Safety Plan prepared by the NSW Government for Places of Worship asks churches to “Avoid group singing or chanting and wind instruments (such as flute, oboe or clarinet).  Solo singers should maintain at least 3 metres physical distance from other people.”  We ask ministers and pastoral leaders to consider how best this may be achieved to protect the health of all worshippers attending the church service.  In asking this, we acknowledge that we are being asked to temporarily give up something very significant and it is appropriate for us to grieve this loss, and indeed other sacrifices that have been made during the COVID-19 health crisis.  We strongly recommend choirs not operate during this period – please wait for the restrictions to be fully lifted before your choir comes together in person.
  • Morning tea and supper.  Unfortunately, the legislation does not provide for worshippers to meet together for morning tea or supper after the service.
  • COVID-19 Safety Plan for Places of Worship. Although not clearly mandated, we recommend that before opening the Church to services involving up to 50 worshippers, the Minister and Elders develop a COVID-19 Safety Plan using the template appended.  The Plan can also be found at: https://www.nsw.gov.au/covid-19/industry-guidelines/places-of-worship.

It steps through all requirements for Places of Worship and is very helpful in tailoring actions specific to your local circumstances.  The Plan can be completed and approved by the minister or pastoral leader of the religious service.

  • Please keep below 50 persons. As the responsibility for upholding COVID-19 restrictions rests with the Church, if a minister or pastoral leader is concerned that opening the church for worship services may lead to more than 50 people arriving to attend, we ask you not to open the church until restrictions are further lifted.
  • Record keeping. Please remember that in opening your church for religious services, you need to keep a record of name and mobile number or email address for all staff, volunteers, visitors and contractors for a period of at least 28 days.
  • Funerals and weddings are subject to specific restrictions, and we ask ministers and pastoral leaders to refer to them or to contact the General Office for information or advice.

2.     Use of church premises by outside individuals or groups.  Unfortunately, Church premises (as they are defined as Places of Worship under the legislation) cannot be opened to external users of the facilities, other than in the following specific circumstances:

  • to provide a service to assist vulnerable members of the public, including, for example, a food bank or a service providing for the needs of homeless persons, or
  • for counselling and support group services, or
  • as an early education and care facility.

We are sorry that external users cannot use our premises at the present time, and we are approaching Government to remove this restriction.

3.     Meetings of Session and Committee of Management Session can be held on church premises as we believe they satisfy the requirement that they are held “for the purposes of work”, that is, for the work of church administration.

We believe that, as they would be for the purpose of work, more than 10 elders and COM members can meet together, subject to:

  • such meetings not being “reasonably practicable” to be held by video-conferencing.
  • such meetings being restricted to only the minister(s), pastoral leaders, elders and members of the committee of management.
  • at all times ensuring the maximum number of people in the meeting room complies with the 4sqm rule and maintaining social distancing of 1.5 metres.
  • the meeting room is cleaned after the meeting.
  • keeping a record of the name and mobile number or email address for everyone in the meeting for a period of at least 28 days.

3.     Bible studies and Prayer times are “private worship” and are allowable subject to no more than 50 people participating and the church premises being cleaned after each study or prayer time.  Private worship is also subject to the 4sqm rule, social distancing, cleaning and keeping a record of the names and contact details of all those attending.

4.     Youth groups thatgather for bible study and prayer are allowable on church premises as outlined above for “private worship”. 

5.     Meetings of a Congregation involving no more than 10 people are allowed (“being a gathering of up to 10 people”), but subject to:

  • such meetings not being “reasonably practicable” to be held by video-conferencing.
  • at all times ensuring the maximum number of people in the meeting room complies with the 4sqm rule.
  • members comply with 1.5m social distancing.
  • the meeting room is cleaned after the meeting.
  • keeping a record of the names and contact details for all those attending.

6.     Meetings of a Congregation with more than 10 people would not be regarded as meetings for the purposes of work, therefore, are not allowed and would need to continue to be held by video-conferencing.

7.     Cleaning.  We have received many questions about the frequency and type of cleaning to be undertaken following meetings and church services.  We refer you to the COVID-19 Safety Plan template appended, which outlines several requirements for churches to consider.  Safe Work Australia also provides clear guidelines for cleaning, at: https://www.safeworkaustralia.gov.au/doc/how-clean-and-disinfect-your-workplace-covid-19.  The NSW government requires continued practicing of physical distancing and good handwashing hygiene.  If church members or guests present even the mildest symptoms, they unfortunately need to be asked not to attend.

We trust you will find these guidelines helpful as you prepare to return to worship in your Church.  Please do not hesitate to email Jeof Falls on jfalls@pcnsw.org.au or Peter Merrick on pmerrick@pcnsw.org.au should you have any questions.

Grace and peace,

Grace and peace,
Rev Richard Keith, NSW Moderator
Jeoffrey R Falls, General Manager, Chief Executive Officer