The Health and Safety Executive’s Business Plan for 2018/19 has been released and it spotlights legionella as a high-consequence risk. The business plan states that HSE inspectors will be focusing much more on the control and management of legionella with an extensive programme of inspections starting in Q4 of 2018/19 – around 20,000 proactive inspections are to be delivered in this period.
The HSE have also said they will be focussing on water treatment companies so are you prepared for what they might look for?
Fortunately, some clues can be gleaned from a 2017 report from the HSE entitled “Legionella control in evaporative cooling systems; underlying causes of breaches in health and safety compliance”.
“HSE inspected 1,906 premises with evaporative cooling systems between 1 April 2013 and 31 August 2014. While the majority of sites required no enforcement, material breaches were found at 625 sites (33% of those inspected), including 409 Improvement Notices (INs) and 12 Prohibition Notices (PNs) served at 229 sites (12.0% of those inspected). Underlying causes of breaches of health and safety compliance were analysed. The main ones were lack of training, failure to maintain the cleanliness of cooling towers and the water within them, absence of, or inadequate, risk assessments, and absence of, or insufficiently detailed, written control schemes. Further analysis looked into the reasons why cooling towers were not cleaned properly.”
Cooling towers not being cleaned was seen to be mainly due to a lack of pack inspection or a lack of pack removal for cleaning (or enhanced in situ cleaning methods where pack removal was not reasonably practicable).
Implementation of Control Scheme’ was the cause of more than half of all the Improvement Notices (INs) issued, with ‘Risk Assessment’ and ‘Written Control Scheme’ each being the cause for issue of just under a quarter of all INs.
The majority of INs issued were for the ‘lack of effective implementation of a written control scheme’, with 53% of all INs being served in this topic area.
A detailed breakdown of the reasons for failings leading to INs showed the following
By analysing the above table you can see the major failings identified by the HSE and so it would be a reasonable assumption that when the HSE start looking at water treatment companies they may well use the above analysis as pointers for what to look out for.
As the HSE have said they will be carrying out inspections of third parties providing services to control legionella risks, including water treatment contractors, legionella risk assessors and cleaning contractors in Q4 2018/2019 this means you have the rest of this year to make sure all is in order.
If you need any help checking your systems and processes, or the quality of your risk assessments then contact Collaton Consultancy Limited for independent help and support. Having acted as Expert Witness in many cases involving compliance we are ideally placed to help you prepare for the HSE intervention program.
Contact us firstname.lastname@example.org or phone on +44 (0)7958 124563