Legionella Management: The Basics of Getting it Right
Legionnaires’ disease is a serious lung infection similar to pneumonia, that can develop from inhaling very fine water droplets contaminated with Legionella bacteria. Fortunately, with proper management of manmade water systems, it is preventable.
In the UK every business owner, landlord or duty holder is legally responsible for making sure all the necessary steps are followed to maintain the safety of the hot and cold water systems within premises under their control. In the rest of this article we’re going to cover the basics.
A version of this beginners’ guide to legionella management appeared in Legionella Control International’s newsletter. To get it in your inbox, sign up for free here.
Tackling legionella training and competency
It’s essential to mention training and competency first because it underpins everything else. A business owner or other person in charge of a building or facility may not have the required skills to manage all the tasks that revolve around legionella management.
In this case, an external water safety specialist may be the best option to handle everything required. Even then, though, the person in charge, the responsible person must make sure they hire a reputable and experienced company who can do the job properly. Check for membership of the Legionella Control Association (LCA) and the registered membership categories, as this provides a benchmark for excellent service standards. Any company hired to assist in this manner should possess appropriate training and competency levels to handle the duties required of them.
The size and type of your business can sometimes influence the necessary individuals who need to be involved. For example, a small business with just a few employees won’t require a Water Safety Group with various people possessing different training, experiences, and relevant subject areas of information. However, a hospital building certainly will.
The competent or responsible person
The competent or responsible person – whether this is a third party, the business owner or building manager – must possess the necessary skills, competence, and experience to handle the role correctly. Hence why some people decide to call in an outside company to do this on their behalf. It is always necessary to be fully aware of and to understand documents such as the Health and Safety Executives ACOP L8 and HSG274. There may be other relevant documentation to adhere to depending on the nature of the venue, particularly in the case of healthcare premises where HTM 04-01 is highly relevant.
The bottom line is that the individual responsible for hiring a reputable and qualified person or company to handle their legionella safety requirements will remain responsible. If the hired individual or person does not do their job properly, responsibility will still ultimately come down to the person who hired them.
Conducting a legionella risk assessment
Before an approach can be taken to managing legionella in the workplace, there should be an understanding of where potential legionella risks are located, what the level of risk is, how the water systems work and how they are laid out. This is best done by carrying out a detailed legionella risk assessment. This assessment then provides guidance to the maintenance and treatment that is required, and when each should be completed. The idea is to determine how the scheme of control will be approached – an element included in the business’ Water Safety Plan.
Regular reviews of any legionella risk assessment is essential. It should always be reviewed whenever any change has been made to the water system.
Keeping appropriate water safety records
It’s not enough to conduct all relevant risk assessments, checks, maintenance tasks, and water treatments. These must also be recorded, and records kept. These records then support the processes that have been covered. Should there be any investigation or request from the relevant health and safety regulators to find out what measures have been taken, they will provide evidence of this.
A copy of the legionella risk assessment is the first document to keep. This should be followed by a water safety plan, covering the measures selected to maintain water safety. A written scheme of control further supports this.
Regular sampling and monitoring of the water systems should also take place. Appropriate records of any sampling and the results should be kept. If someone from outside the business handles the sampling and monitoring, they should provide relevant information and documentation to support this.
Management structure – the duty holder, responsible person and external contractors
It is also necessary to keep details covering which individuals have been appointed to which roles. Again, if an external company is handling all the roles, relevant details should be kept indicating this. If one or more individuals within the business are performing one or more roles, records should be kept indicating this as well.
In all cases, evidence of the suitability of any individual should be noted. Competency levels of both internal and external staff should be checked and confirmed, with supporting documents to prove any training or assessments have indeed taken place.
All the records should be kept – both paper copies and computer records – for however long they remain relevant. You also need to add two years where legionella risk assessments are concerned, along with another five years wherever paperwork relates to monitoring and to dates of inspections.
Exploring legionella problems relating to non-compliance
The Health and Safety Executives ACOP L8 covers the process of controlling Legionella bacteria in water systems, so anything that occurs that does not support this will be deemed non-compliant, unless what’s in place can be shown to be as good or better. The same applies to HSG274 Parts 1, 2, and 3 for the control of Legionella bacteria.
For instance, the risk assessment might have identified an action that must take place to maintain safety in the water system. If this action has not occurred, this would be deemed to be non-compliant. Similarly, if water samples have been taken and have shown a raised level of Legionella bacteria, this would be non-compliant. Actions must immediately be taken to rectify such issues.
Again, records should be kept of the issues, what has been done to rectify them, and how long it has taken to do so. Of course, if you hire an external company to handle water safety for your business, they can cover the entire process from start to finish. They can make sure compliance with all necessary legislation is always achieved.
Auditing legionella records
Water safety or legionella compliance audits are an important final step of the record-keeping process. Checking through all paperwork is essential as it helps to ensure no errors have been made and nothing has been missed.
For instance, if remedial action has been identified as necessary and it has not been completed, an audit may reveal this when it would otherwise have been missed. If hiring an external company to take this on, it’s ideal to check whether this will be part of their duties.
World leading legionella management specialists
The water safety specialists at Legionella Control International help business owners and those responsible for the control of legionella and other waterborne pathogens manage their workplace risks to maintain regulatory compliance and keep people safe.
We are experienced water safety specialists and deliver full range of services including risk assessments for legionella, pseudomonas and other waterborne pathogens. We also offer Authorising Engineer support, compliance auditing, water quality testing, City & Guilds training and other health and safety risk management services that help keep staff and others safe.
If you would like to speak with one of our legionella specialists about improving your water safety management processes call us today on 0330 223 36 86 or contact us here …
