The Health & Safety Executive (HSE) have recently published three new guidance documents to support the existing Approved Code of Practice for the control of legionella bacteria in water systems. The suite of guidance considers evaporative cooling systems, hot and cold water systems and other risk systems.
For many of our clients, a written scheme of work will already be in place for the control of legionella. However, there is a requirement to review your legionella risk assessment and the scheme of work and we suggest that this is a timely opportunity to do so.
You should ask yourself the question, ‘do we still have a nominated Responsible Person?’ This ‘competent person’ is appointed to take day-to-day responsibility for managing legionella risks in your workplace. They need to understand the water system and all its constituent parts. They should be able to identify if the water systems are likely to create a risk from exposure to legionella bacteria. Of course, in many cases they need to be supported and advised by external service providers with requisite technical expertise.
The legionella risk assessment should be reviewed regularly and specifically when there is reason to suspect it is no longer valid. An indication of when to review the assessment may result from:
i. a change to the water system or its use;
ii. a change to the use of the building where the system is installed;
iii. new information available about risks or control measures (e.g. the new guidance documents recently published);
iv. the results of checks indicating that control measures are no longer effective;
v. changes to key personnel;
vi. a case of legionnaires’ disease/legionellosis associated with the system.
The assessment of risk is an ongoing process and not merely a paper exercise. The risk needs to be identified and communicated to management to allow them to prioritise remedial actions to control it.
Records must be retained for the period they remain current and for at least two years afterwards, with the exception of records kept for monitoring and inspection, which should be kept for at least five years. It may be helpful to keep training records of employees; and records of the work of external service providers, such as water treatment specialists.
Part 2 ‘Hot and Cold Water Systems’ contains a useful checklist for the periodic checks to be made on water systems.