Legionnaires’ disease is a debilitating illness that can be prevented by managing the risks correctly but that means paying attention to detail.
It starts with having the right team in place and ensuring they are properly trained. This means the Duty Holder (for example an owner or a Director of the business) needs to appoint a person who will manage the risks and processes on a day-to-day basis, this person is called the Responsible Person (in the UK). You may also need to have in place a Deputy especially if the site is complex and there is complexity involved.
Once you have the team in place then you need to have a “suitable and sufficient” risk assessment in place. There are several documents that will help you decide on what is suitable and sufficient, one is the HSE document “indg163” (Risk assessment A brief guide to controlling risks in the workplace), another is BS8580 (Water quality – Risk assessments for Legionella control – Code of practice) which is specific to Legionella risk assessments. It is also worth reading a HSE research document called “Good practice and pitfalls in risk assessment” with the reference rr151.
A good risk assessment will provide you with a view of foreseeable risks and then logical control measures to help you manage those risks. Some of these risks and control measures are described in the 3 documents in the HSG 274 series. There may be other documents needed, for example HSG 282 (The control of Legionella and other infectious agents in spa-pool systems) if you have a spa pool or even “Managing the Risk of Legionnaires’ disease in Vehicle Wash Systems” from the Water Management Society.
Once the risk assessment has identified the risks you then need to create a Written Scheme which will explain how you will manage the risks on your site, what the control methods will be and what records you will keep. The Written scheme is described in detail in the appendices in the HSG 274 series of documents. If you are a Healthcare site then you will need to create a Water Safety Plan which contains the same information plus more which is relevant to the special needs of the healthcare environment.
It is important to ensure all staff that work with the Legionella risk are suitably trained but this may not mean a highly involved course if the task they carry out is only taking temperatures, the training should be relevant to the role undertaken. Likewise it is unlikely a one day introduction course will be suitable for a Responsible Person. The competence of sub-contractors is also key so you should always ensure you check the competence of your chosen plumber, water treatment company or any other staff who work on your water systems. You could consider looking at the Legionella Control Association and WIAPS as appropriate tools to judge your sub-contractors though these are not compulsory nor the only way to measure competence.
Your site up-to-date schematics, or if you have them as fitted drawings, are a key tool to understanding what you have on site, these along with the risk assessment will help you create an asset register so you can ensure you have created a complete list of control measures you will carry out. These control measures will generate a lot of information so what records you keep and for how long needs to be understood. Again L8, HSG 274, and if you are a healthcare site HTM0401, will explain what tasks should be carried out, what records to keep and for how long. Don’t be afraid to consider electronic record systems as you will need to understand what is happening on your site and electronic systems can help you by providing overviews and graphical representations that aid understanding.
Interpreting and reacting to results is a key task of the Responsible Person. This will ensure you are managing the risk and not allowing issues to run away from you. Understanding what is happening will mean you can carry out the correct remediation in a timely way so reducing the risks to employees and visitors to your site, it may also mean that the wider public are protected from the effects of your workplace. It is therefore important to take time to regularly review your results and consider if you could do things differently.
This short description of managing your site needs to be made specific to your site so is necessarily only an overview. A more detailed discussion and review will help you understand where your risk gaps exist (if any) so that you can identify what actions need to be taken on your site.
If you need help identifying this risk gap and having a discussion on how to bridge those gaps then why not arrange for an initial discussion with us, you can contact us via: general@collatonconsultancy.com or phone on +44 (0)7958 124563.
Simplifying the complex from Collaton Consultancy Limited.
Legionella Risk Management 