How to Write a Water Safety Plan

In this guide, written by the Authorising Engineering team at Legionella Control International, we review the rising popularity and use of Water Safety Plans in healthcare, public and commercial premises, focussing on how to write one that will work to keep people safe at all stages of the water distribution network.

The guide covers lots of ground, explaining what a water safety plan is, its origins and what it seeks to achieve. It goes on to consider the essential components required to write such plans and who should be involved in developing them.

A version of this guide to writing a water safety plan first appeared in Legionella Control International’s newsletter. To get it in your inbox, sign up for free here.

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Why write a water safety plan?

Water safety plans were originally proposed by the World Health Organization (WHO) and are still used extensively today. As water safety issues move up the health and safety agenda, those in charge of both healthcare premises and commercial buildings throughout the UK are increasingly tasked with the development of credible water safety plans for both individual premises and larger, multi-site estates.

In this guide, we’ll examine the nature of a water safety plan (WSP) in such scenarios, touching on all the important topics relating to it.

What is a water safety plan?

A water safety plan is intended to ensure that a supply of water used in a building or business is safe for use. It achieves this by using a comprehensive risk assessment and risk management approach to the water distribution network. It should cover the entire water system, from the point where it enters the building to the point where it reaches the user. This will involve drinking water supplies, but it should also cover other water sources and how they are used.

For example, it may need to cover showers, taps, other water outlets, processes and equipment that use water including hot tubs, decorative fountains, cooling towers and manufacturing equipment. It should also consider all sources of risk, including those posed by the people who encounter the water sources.

Two of the most important elements of a water safety plan are hazards and risks. For example, both Legionella bacteria and Pseudomonas aeruginosa can be present in a water system and are known hazards. They can cause illness and infections in humans. The risk aspect looks at how likely it could be for either of these to cause illness or infection. The risk factor would rise if nothing was done to combat their presence or acknowledge them as hazards.

What does a water safety plan do?

A water safety plan identifies all the hazards that are present at any stage of the water system, from supply to the various points of use. It should also cover the management of each of those hazards, the reduction of risks, and all control measures implemented to keep the risks at a reasonably practical, safe minimum. It is, literally, a plan to maintain the safety of the water system in question.

There are three main areas of interest that a water safety plan should cover.

1. Firstly, it should identify how to manage the point at which the water supply comes into the building, to ensure this is not contaminated at that early stage.

2. Secondly, it should identify ways in which any contaminants in the water, i.e., bacteria, debris, and other elements such as biofilms, can be removed or at least reduced.

3. Finally, once the water has been treated, it should be protected from any contamination prior to being used. For instance, there should be no risk of it becoming contaminated before it reaches a tap, shower head, or other outlet. This may occur in a situation where an outlet is irregularly used, and so the pipework has time to collect stagnant water and to encourage the growth of bacteria.

Who needs a water risk assessment?

All water systems should be assessed to identify the level of risk or risks associated with that system. Of course, no two buildings are identical, and some may be private dwellings rented to tenants. In this case, the landlord must still carry out a legionella risk assessment to identify the risks that might be present with that water system. However, it is likely that a domestic water system won’t pose any specific risks and certainly will not require a Water Safety Group to come up with a water safety plan.

A water risk assessment will look at whether waterborne bacteria such as Legionella and Pseudomonas aeruginosa are present, pose a risk to those using the water system, and how to reduce those risks if so.

It is merely a matter of looking at how complex the water risk assessment might be. The more complex and larger the water system is, the more likely it is that a more detailed water safety plan and risk assessment are required.

What is Legionella bacteria?

Legionella is a type of bacterium that can cause Legionnaires’ disease. This is a severe type of pneumonia that can develop when someone inhales water vapour or mist that contains Legionella bacteria. It can also cause the less serious condition known as Pontiac fever. This typically resolves on its own and does not cause symptoms as serious as those that are often experienced with Legionnaires’ disease.

What is Pseudomonas aeruginosa?

Pseudomonas is a gram-negative germ that can contaminate natural and manmade water sources. It is known for causing infections in healthcare settings. It can cause infections of the ear, urinary tract, and skin, among other things. Those in healthcare settings are particularly at risk because they may already be ill or recovering from treatment or surgery. This may mean they have a compromised immune system.

How often is a legionella or water risk assessment required?

The baseline to bear in mind is for a legionella or water risk assessment to take place every two years. However, this should be the absolute maximum time between assessments. In some cases, where the risk is deemed higher, the risk assessment should be performed much more frequently than this.

For example, if the assessment involves healthcare premises, where residents or inpatients present a much higher risk factor, the assessment should be performed more often.

Even when the two-year period is valid for a business or other premises, it is still wise to redo the assessment sooner if something changes within the water system, use of the building or the water management team. For example, if an extension is built that extends the water system as well, a fresh risk assessment would be required.

Another example would be if testing revealed elevated levels of Legionella bacteria or a case of Legionnaires’ disease was associated with the premises. This could mean the Water Safety Plan is potentially not covering as many areas as it should or has missed a risk factor and allowed legionella to develop and spread.

What should be in a water safety plan?

The focus of a water safety plan is to ensure water safety throughout the building the plan has been created for. This means each WSP will vary from others, since it must consider and be specific to all the elements in the building being examined.

The legionella or water risk assessment must come first, as this provides crucial information that will be required when compiling the water safety plan. It identifies the risks with the water system, so that the WSP can lay out steps for controlling those risks. These risks will cover Legionella, Pseudomonas aeruginosa, and other any other waterborne pathogens deemed to be a risk. The plan should also consider whether there are any risks for chemical contamination of the water, which may be a risk factor for certain businesses.

Risk factors may vary depending on the size of the water system and how it is used. There could also be different risk factors according to who uses the system. For instance, in a healthcare setting, those who are elderly or who are receiving extensive treatment could be at greater risk of exposure to waterborne bacteria than those using other parts of the system. As we can see, it’s not just a case of the system but who is exposed to it as well. This means that risk factors can be external as well as internal, i.e., outside the water system and not just within it.

Another risk factor to note involves using various treatment chemicals and processes to manage the presence of bacteria in the water system. With multiple products available to resort to, it is imperative that those compiling the water safety plan note which methods make the most sense for the water system.

It is prudent to include a diagram of the water supply system to help understand it and compile the water safety plan. This should include all components, including the source of the water, the system in and around the building, and the points at which it is available for use by those in the building. This should be regularly reviewed to make sure it is up to date and that there are no alterations anywhere. If there are, these should be altered on the diagram.

It is also wise to conduct a new water risk assessment at this point, as there may be risks associated with the changes. A simple example would be to highlight the need to maintain and clean the new area or to test the water periodically if required.

What are the three components of a water safety plan?

Depending on the source you read, and how the components are listed, there are usually more than three in play. Firstly, you need a team of experts who will be responsible for compiling the water safety plan. This team is known as the Water Safety Group (WSG). The WSG will have people on board with experience in water systems and safety, along with those who have experience of various parts of the business.

For example, a hospital Water Safety Group may have people from various hospital departments. They would have specialist knowledge of the people in that department and whether they would be at greater risk of certain waterborne illnesses caused by Legionella or Pseudomonas aeruginosa.

The next component is to have a plan of the water system and how it operates. This can then help those who conduct the risk assessment. This in turn helps to identify the risks and how to control each of them.

There should be monitoring processes in place to ensure those risks are managed or mitigated where possible. The ideal scenario is to remove all risks, but this is rarely reasonable. All controls should be monitored, with regular maintenance to support the water system and keep it in good working order. Information on control measures used to support a healthy and safe water system should also be included in the plan.

Finally, documentation of all steps and processes should be kept. This is required to prove what has been done and when.

What is the NHS Water Safety Plan?

A healthcare specific Water Safety Plan runs along similar lines to any other water safety plan, yet it focuses on the specific risks seen in a healthcare setting. For example, hospitals will have people on the premises who are likely to be immune-suppressed or compromised. They will therefore be at greater risk of illness and infection.

The UK’s Department of Health produce guidance in their HTM 04-01 Safe water in healthcare premises document. This is comprised of three parts, covering both Legionella and Pseudomonas aeruginosa as key risk factors. There is also a supplement going into detail on thermostatic mixing valves or TMVs.

This HTM document is designed to help create a water safety plan for a healthcare premises. It works alongside the Approved Code of Practice L8 (ACoP L8), issued by the Health and Safety Executive (HSE) and BS 8680:2020, Water quality – Water safety plans – Code of Practice. Additionally, the HSG274 Part 2 document provides guidance on controlling Legionella in water systems. These four documents provide all the information required to be able to compile an effective water safety plan.

Who can create a water safety plan?

The plan should be compiled by the Water Safety Group, as we have already seen. It is important that those selected for the task have relevant experience and knowledge of what is required.

The more complex the water system, and the larger the premises it works for, the more likely it is that expert insight will be required. This will help to ensure everything is covered and that risks from Legionella, Pseudomonas aeruginosa, and other waterborne pathogens (and indeed other risk factors) are mitigated.

In many cases, an independent water expert who is outside the business will be hired to come in and take a role on the Water Safety Group. This expert is often referred to as a Authorising Engineer (Water) and can advise on risk assessments, required steps to ensure a safe and treated water system, and other elements. Even here, though, it is the responsibility of the group to ensure the person hired for this role has the required knowledge and experience to perform it.

In short, a water safety plan identifies potential risks within a water system, providing information on how to reduce those risks to an acceptable level. It is the remit of the Water Safety Group to produce this plan and to make sure it is up to date.

It is always better to prevent outbreaks of disease and illness. A proactive approach to a solid water safety plan should make sure this is the outcome for every business, whether it is a healthcare setting, a factory, or any other venue.

Legionella and water safety specialists

Legionella Control Internationals expert teams of water safety specialists support business owners and those responsible for health and safety in the workplace. Our risk management solutions support duty holders, the responsible person and others with responsibility for the control of waterborne pathogens and other water safety risks, helping them to protect their staff, customers and others and so meet their responsibilities in this specialist area.

We deliver specialist Authorising Engineer (Water) services, legionella risk assessments, water testing, independent compliance auditing, City & Guilds training, expert witness support and other environmental risk management services that help keep people safe.

To speak with one of our water safety specialists call us today on 0330 223 36 86 or contact us here …