Published in Lexis Nexis Facilities Management magazine / July 2013
Cost-effective Legionella control starts with risk assessment
When Legionella prevention measures fail and a positive result is returned from the lab, there is an imperative to act fast to stamp infection out, but taking the right action is never going to be easy. Andrew Steel, managing director of air and water treatment specialists Airmec, explains.
All property owners, as well as the individual company directors of a property owning company, have a responsibility to manage the Legionella risks arising from their property. An initial risk assessment is a statutory requirement and this should include an assessment of hot or cold water systems. This means anywhere where water may be stored at a temperature between 20 and 45 Celsius.
If a water sample returns a legionella positive result swift and effective action is required to resolve the situation. This will usually mean both major disruption and significant expenditure. Shutting down operational areas of a building is a substantial logistical exercise and expensive in itself, before you even factor in the cost of disinfection and possible remedial work. Advance contingency planning is the best way to manage risks and mitigate costs.
Even though a Legionella positive result does not always mean that immediate shut down of all operations is essential, there is never going to be much time for delay in whatever action is necessary; and institutional checks and balances can make it difficult to authorise significant expenditure quickly enough. There may simply be no time for competitive tendering or normal due process. It’s the finance director’s nightmare – one that having a good risk assessment in place can help to avoid.
As a business with significant experience of working with large and complex facilities and estates, Airmec has first-hand knowledge of working with building managers who have been faced with the dreaded combination of Legionella-positive lab results, no budget for the remedial works necessary and no time for the due process that ought to be followed before commissioning works of such necessity.
We know full well that our duty to advise building managers and financial chiefs of the consequences of infection can be a thankless task. We’re not bringing good news, but please don’t shoot the messenger! Independent lab tests speak for themselves, and the seriousness of the predicament usually sinks in fairly quickly. After all, the law will hold responsible persons to account for failure to deal with the situation.
While newer buildings may have the advantage of zoned water systems and built-in flushing valves, systems in older buildings are often a mystery even to the people who manage them. There will likely be a history of refurbishments and minor works such that no-one really knows the system, or could locate every pipe, outlet and potential risk area. Again, having a good, current and legally compliant risk assessment would mean that all this investigative trace-and-access work is in the bag.
If there is a Legionella positive result then getting rid of infection and avoiding a major incident in a sizeable estate will typically involve several stages and potentially six figure sums. This may include:
Cost-effective Legionella control starts with risk assessment
When Legionella prevention measures fail and a positive result is returned from the lab, there is an imperative to act fast to stamp infection out, but taking the right action is never going to be easy. Andrew Steel, managing director of air and water treatment specialists Airmec, explains.
All property owners, as well as the individual company directors of a property owning company, have a responsibility to manage the Legionella risks arising from their property. An initial risk assessment is a statutory requirement and this should include an assessment of hot or cold water systems. This means anywhere where water may be stored at a temperature between 20 and 45 Celsius.
If a water sample returns a legionella positive result swift and effective action is required to resolve the situation. This will usually mean both major disruption and significant expenditure. Shutting down operational areas of a building is a substantial logistical exercise and expensive in itself, before you even factor in the cost of disinfection and possible remedial work. Advance contingency planning is the best way to manage risks and mitigate costs.
Even though a Legionella positive result does not always mean that immediate shut down of all operations is essential, there is never going to be much time for delay in whatever action is necessary; and institutional checks and balances can make it difficult to authorise significant expenditure quickly enough. There may simply be no time for competitive tendering or normal due process. It’s the finance director’s nightmare – one that having a good risk assessment in place can help to avoid.
As a business with significant experience of working with large and complex facilities and estates, Airmec has first-hand knowledge of working with building managers who have been faced with the dreaded combination of Legionella-positive lab results, no budget for the remedial works necessary and no time for the due process that ought to be followed before commissioning works of such necessity.
We know full well that our duty to advise building managers and financial chiefs of the consequences of infection can be a thankless task. We’re not bringing good news, but please don’t shoot the messenger! Independent lab tests speak for themselves, and the seriousness of the predicament usually sinks in fairly quickly. After all, the law will hold responsible persons to account for failure to deal with the situation.
While newer buildings may have the advantage of zoned water systems and built-in flushing valves, systems in older buildings are often a mystery even to the people who manage them. There will likely be a history of refurbishments and minor works such that no-one really knows the system, or could locate every pipe, outlet and potential risk area. Again, having a good, current and legally compliant risk assessment would mean that all this investigative trace-and-access work is in the bag.
If there is a Legionella positive result then getting rid of infection and avoiding a major incident in a sizeable estate will typically involve several stages and potentially six figure sums. This may include:
- Risk assessment to identify where the danger lies (dead legs, redundant piping etc).
- An initial disinfection to get the current outbreak under control (but will often not remove the root cause).
- Remedial work to remove major risks and likely causes of the current positive test results.
- Further disinfection and ongoing sampling, because remedial work such as the removal of system dead legs is very likely to disturb bacterial colonies and cause them to be distributed around the piping circuits.
The chart shows how the costs were broken down in a recent £200,000 project we undertook.
The full risk assessment is highly significant here because in this recent example it should not have been necessary since it should already have been in place. By law, risk assessments should include schematic diagrams and reviews and be undertaken as a minimum every two years, and more often if there have been changes to the system or indications that controls are failing. All too frequently such risk assessments and accurate schematic diagrams are completely absent.
The legal and regulatory framework
The requirement for detailed schematics , and other, requirements for risk assessment are laid out quite clearly in the UK Health and Safety Executive’s (HSE) Approved Code of Practice and Guidance (ACOP) "Legionnaires' disease: Control of legionella bacteria in water systems" (L8) . L8 has special legal status and is legally binding..
British Standard BS 8580:2010 Water quality – Risk assessments for Legionella control – Code of practice clearly lays out the best practice for risk assessments, but takes the form of guidance and recommendations, rather than being a definitive specification.
A risk assessment identifies any reasonably foreseeable risks to health, and advises on the necessary precautionary measures that need to be taken to prevent, or adequately control, the risk. It also enables the person on whom the statutory duty falls to show that all the steps needed to prevent or control foreseeable risk have been considered.
The full risk assessment is highly significant here because in this recent example it should not have been necessary since it should already have been in place. By law, risk assessments should include schematic diagrams and reviews and be undertaken as a minimum every two years, and more often if there have been changes to the system or indications that controls are failing. All too frequently such risk assessments and accurate schematic diagrams are completely absent.
The legal and regulatory framework
The requirement for detailed schematics , and other, requirements for risk assessment are laid out quite clearly in the UK Health and Safety Executive’s (HSE) Approved Code of Practice and Guidance (ACOP) "Legionnaires' disease: Control of legionella bacteria in water systems" (L8) . L8 has special legal status and is legally binding..
British Standard BS 8580:2010 Water quality – Risk assessments for Legionella control – Code of practice clearly lays out the best practice for risk assessments, but takes the form of guidance and recommendations, rather than being a definitive specification.
A risk assessment identifies any reasonably foreseeable risks to health, and advises on the necessary precautionary measures that need to be taken to prevent, or adequately control, the risk. It also enables the person on whom the statutory duty falls to show that all the steps needed to prevent or control foreseeable risk have been considered.