Disclaimer: This information is being provided for informational purposes only and does not constitute legal advice. FAA members are encouraged to contact their legal counsel regarding any landlord/tenant law matters. The industry is in uncharted territory at this time and legal interpretations surrounding this topic may vary. Please note the guidance below consists of highlights from various resources; click on the links provided for more in-depth information.
As FAA members determine the best process for reopening amenities and common areas, there are several important factors to consider. Below is a list of best practices and additional background information from the CDC, NAA, and the State of Florida to assist FAA members in developing re-opening procedures.
This information is provided for informational purposes only. Please consult your corporate office team for company-specific guidance.
Review Florida-specific guidance regarding pool operations and fitness center requirements. Per the governor's most recent executive order, fitness centers may operate at 50 percent capacity and must comply with specific DBPR requirements.
Review FAA's Local Government COVID-19 Reopening Policies Tracker to view regulations that may be specific to the city or county in which your property is located. NOTE: This resource also includes information regarding vacation rental operations.
Ensure your company has cleaning procedures in place that are compliance with CDC guidelines and an adequate stock of cleaning supplies to ensure the safe operation of amenities and common areas.
Consider how your property will maintain social distancing in amenity spaces and common areas.
Determine how you will communicate new rules or guidelines for amenities to your residents.
Consult your corporate legal counsel or risk management team for guidance.
The CDC recommends first reviewing the guidance and directives from state and local officials and state and localexternal icon health departments. If there is not specific guidance, then consider following CDC guidance.
The CDC recommends for housing providers to maintain 6 feet of social (physical) distance between yourself and everyone that you do not live with. This may mean there will be alternatives to activities, cancelled activities, or closed areas.
Consider how you can use multiple strategies to maintain social (physical) distance between everyone in common spaces of the facility. Offer alternative methods for activities and social interaction such as participation by phone, online, or through recorded sessions. Make sure that shared rooms in the facility have good air flow from an air conditioner or an opened window. Consider working with building maintenance staff to determine if the building ventilation system can be modified to increase ventilation rates or the percentage of outdoor air that circulates into the system. Clean and disinfect shared areas (laundry facilities, elevators, shared kitchens, exercise rooms, dining rooms) and frequently touched surfaces using EPA-registered disinfectantsexternal icon more than once a day if possible.
Consider closing or restricting the number of people allowed in at one time to ensure everyone can stay at least 6 feet apart. While proper operation, maintenance, and disinfection (with chlorine or bromine) should kill COVID-19 in pools and hot tubs, they may become crowded and could easily exceed recommended guidance for gatherings (no more than 10). It can also be challenging to keep surfaces clean and disinfected. Considerations for shared spaces (maintaining physical distance and cleaning and disinfecting surfaces) should be addressed for the pool and hot tub area and in locker rooms if they remain open.
Public aquatic venues can consider different strategies to encourage healthy hygiene, including encouraging all staff, patrons, and swimmers to wash their hands often and cover their coughs and sneezes. Housing providers should encourage the use of cloth face coverings as feasible. Face coverings are most essential in times when physical distancing is difficult. Do not advise those wearing face coverings to wear them in the water. Cloth face coverings can be difficult to breathe through when they’re wet.
Cleaning and disinfecting frequently touched surfaces at least daily and shared objects each time they are used. For example:
- Handrails, slides, and structures for climbing or playing
- Lounge chairs, tabletops, pool noodles, and kickboards
- Door handles and surfaces of restrooms, and handwashing stations.
Consider providing physical cues or guides (for example, lane lines in the water or chairs and tables on the deck) and visual cues (for example, tape on the decks, floors, or sidewalks) and signs to ensure that staff, patrons, and swimmers stay at least 6 feet apart from those they don’t live with, both in and out of the water.
Consider closing activity rooms or restricting the number of people allowed in at one time to ensure everyone can stay at least 6 feet (2 meters) apart. Consider closing exercise rooms. Activities and sports (e.g., ping pong, basketball, chess) that require close contact are not recommended.
Accepting New Residents
First, review and follow the guidance and directives from your state and local officials.
If your situation is not restricted by their guidance and directives, then consider the following guidance:
- At check-in, provide any new or potential resident with a clean cloth face covering and keep them isolated from others.
- Medical evaluation may be necessary depending on the symptoms.
Reopening Office and Amenity Spaces
NAA has provided a document that outlines best practices for reopening your office and amenity spaces. It is important to first refer to your state and local government for specific guidance in these areas, then refer to NAA's best practices.
Consider reducing hours so proper cleaning can take place. In addition, limit the number of persons congregating in one amenity space in alignment with applicable federal, state, and local recommendations (the federal recommendation is fewer than 10).
Florida Department of Health Guidance
Public Swimming Pools
If the pool is closed, see the department's best practices guidance: Voluntary Pool Closures for information on keeping the pool water safe and sanitary, and on how to drain the spa to keep it sanitary during extended periods.
The COVID-19 virus is deactivated quickly using Florida rule-compliant chlorine or bromine concentrations in pools and spas, and there is no evidence it can be spread by treated water per the World Health Organization and the CDC. The Department of Health advises against mass gatherings as they can expose people to others' respiratory aerosols, and for this reason, the White House and the CDC reduced social gatherings to no more than 10 people especially for populations at higher risk. Additional guidance can be found on DOH COVID-19 and CDC Pool Guidance.
Florida Department of Business and Professional Regulation Guidance
Gyms and Fitness Centers
Pursuant to Executive Order 20-123 issued by the governor on May 15, gyms and fitness centers must follow safety measures outlined by the Department of Business and Professional Regulation (DBPR).
The mandatory measures are outlined below:
- Monitor building occupancy and restrict customer access to no more than 50 percent of the building’s occupancy. Offer readily-available dispensers of a disinfectant included on the EPA List N: Disinfectants for Use Against SARS-CoV-2. Instruct patrons to clean touched surfaces upon each use of fitness equipment.
- Thoroughly clean and disinfect all seating, counters, weights, weight bars, mats, machines, and other fitness equipment upon closing the facility each day.
- During daily operation, routinely clean and disinfect surfaces, particularly high-touch surfaces such as faucets, toilets, doorknobs, and light switches.
- Maintain restrooms that remain open with functional toilets, clean and disinfected surfaces, and handwashing supplies, including soap and materials for drying hands or hand sanitizer with at least 60% alcohol.
- Employees who appear to have symptoms upon arrival at work or who become sick during the day must immediately be separated from other employees, customers, and visitors, and sent home.
The following are best practices recommended for gyms and fitness centers by DBPR:
- Display posters and signs throughout the facility to remind visitors to take steps to prevent the spread of COVID-19, including the wiping and sanitation of touched surfaces upon each use of fitness equipment.
- Open doors between separate fitness areas or rooms of the facility to reduce surface touching by multiple people. Open windows where feasible to improve ventilation in the facility.
- Remove all unnecessary, frequently touched items like magazines, newspapers, service menus and any other unnecessary paper products and décor from customer waiting areas and locker rooms.
Local Government Guidance
In an effort to help FAA members navigate the patchwork of regulations that are being enacted by local governments across the state, FAA has created a Local Government COVID-19 Reopening Policies Tracker for members.
Please note that many local governments are in the early stages of evaluating reopening procedures, and FAA anticipates that more local-specific restrictions will be enacted by cities and counties in the coming days. Therefore, it is important for members to check this spreadsheet often and remain in close contact with their local FAA affiliate to stay up-to-date on local regulations.
Below are some other resources that may be helpful as you determine how to approach reopening your amenity spaces.
- OSHA Guidance on Preparing Workplaces for COVID-19
- 12 Steps to Reopen your Fitness Center with Success
- Florida Department of Health's Guidance on Pools
- CDC Guidance
- CDC Guidance for Aquatic Venues
- NAA Next Steps: What Owners and Operators Should Consider
- NMHC Guidance
- Will Your Pool be Ready for the Summer? Ways Your Club Can Get Ready
- Multifamily Housing News FAQ
- Florida Department of Health COVID-19 Toolkit
- Six Feet of Separation: Apartments Prepare for Life After Quarantine