HSE spotlight on spas and manufacturers a wake up call for FMs
First published in Water & Wastewater Treatment magazine/ Jan 2013
First published in Water & Wastewater Treatment magazine/ Jan 2013
Poor risk assessment is the weak link in Legionella control
Andrew STEEL, Managing Director, Airmec Ltd.
Leisure centres with spa facilities are among the businesses being urged to do more to protect workers and members of the public from Legionella risks – yet few are aware of the standards of care that are required or of the actual risks that their premises present. This has become apparent since air and water treatment company Airmec has been contacting firms about the latest HSE guidance on the subject.
Earlier this year, the Health and Safety Executive issued a safety notice* targeting companies and organisations that use hot and cold water systems for bathing and washing or in manufacturing processes. This comes after a review of a decade’s worth of data identifying the most common causes of significant Legionella outbreaks. It follows the publication of a separate notice in July aimed at companies with cooling towers and evaporative condensers.
The latest notice stresses the need for measures to be in place to control identified Legionella risks and that these are reviewed regularly. In the case of spas, it can even mean the need to check water quality as regularly as every two hours! Few operators are aware of this, even though they do have a legal responsibility to ensure they're doing all they can to protect workers and the public.
Where risks have been properly assessed and control measures are in place, there may be no need for changes in processes. However we often find that risk assessments are inadequate and, in the light of this increased focus from HSE, now would be a good time for managers to review their processes.
The inadequacy of many risk assessments is quite staggering, according to Airmec. By law, risk assessments should include schematic diagrams and be undertaken every two years, more often if there have been changes to the system or indications that controls are failing.
These, and other, requirements for risk assessment are laid out quite clearly in the UK’s Health and Safety Executives (HSE) Approved Code of Practice and Guidance (ACoP) "Legionnaires' disease: Control of legionella bacteria in water systems" (L8) . L8 has special legal status and legally binding: if designated responsible people within an organisation do not comply with its recommendations the
Courts may hold them personally responsible for the consequences . So it is all the more surprising that good risk assessments are nowhere near ubiquitous.
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. Of course, prevention is always going to be better – and cheaper – than cure.
The risk assessment 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.
Ideally, risk assessments should be undertaken before a maintenance regime is put in place – or as soon as possible afterwards. This is especially important with more organisations now preferring to manage routine inspection and flushing work internally, rather than pay third parties to come in and perform these routine tasks. It’s a logical approach that offers significant cost savings, but these will quickly be wiped out if the regime fails to address the risks and there is an outbreak. So it’s still worth calling in the professionals to set up the maintenance regime. Aligning inspection and flushing schedules with the asset register and schematic in the risk assessment is undoubtedly a good investment and one that will add further value to the risk assessment as a valuable tool for preventing outbreaks in the first place.
When there is a breakout
Even though -immediate shut down is not always essential, there is never going to be much time for delay once you have a Legionella positive result of a routine sample from an Independent UKAS (United Kingdom Accreditation Service) testing laboratory
If there is a Legionella positive result then eliminating the sources of infection and avoiding a major incident will typically involve several stages:
So the bottom line is: check your risk assessment now and if in any doubt, pick up the ‘phone and ask for advice.
*The safety notice Management of the risks from Legionella in water systems can be read in full at: http://www.hse.gov.uk/safetybulletins/legionella2.htm
Andrew STEEL, Managing Director, Airmec Ltd.
Leisure centres with spa facilities are among the businesses being urged to do more to protect workers and members of the public from Legionella risks – yet few are aware of the standards of care that are required or of the actual risks that their premises present. This has become apparent since air and water treatment company Airmec has been contacting firms about the latest HSE guidance on the subject.
Earlier this year, the Health and Safety Executive issued a safety notice* targeting companies and organisations that use hot and cold water systems for bathing and washing or in manufacturing processes. This comes after a review of a decade’s worth of data identifying the most common causes of significant Legionella outbreaks. It follows the publication of a separate notice in July aimed at companies with cooling towers and evaporative condensers.
The latest notice stresses the need for measures to be in place to control identified Legionella risks and that these are reviewed regularly. In the case of spas, it can even mean the need to check water quality as regularly as every two hours! Few operators are aware of this, even though they do have a legal responsibility to ensure they're doing all they can to protect workers and the public.
Where risks have been properly assessed and control measures are in place, there may be no need for changes in processes. However we often find that risk assessments are inadequate and, in the light of this increased focus from HSE, now would be a good time for managers to review their processes.
The inadequacy of many risk assessments is quite staggering, according to Airmec. By law, risk assessments should include schematic diagrams and be undertaken every two years, more often if there have been changes to the system or indications that controls are failing.
These, and other, requirements for risk assessment are laid out quite clearly in the UK’s Health and Safety Executives (HSE) Approved Code of Practice and Guidance (ACoP) "Legionnaires' disease: Control of legionella bacteria in water systems" (L8) . L8 has special legal status and legally binding: if designated responsible people within an organisation do not comply with its recommendations the
Courts may hold them personally responsible for the consequences . So it is all the more surprising that good risk assessments are nowhere near ubiquitous.
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. Of course, prevention is always going to be better – and cheaper – than cure.
The risk assessment 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.
Ideally, risk assessments should be undertaken before a maintenance regime is put in place – or as soon as possible afterwards. This is especially important with more organisations now preferring to manage routine inspection and flushing work internally, rather than pay third parties to come in and perform these routine tasks. It’s a logical approach that offers significant cost savings, but these will quickly be wiped out if the regime fails to address the risks and there is an outbreak. So it’s still worth calling in the professionals to set up the maintenance regime. Aligning inspection and flushing schedules with the asset register and schematic in the risk assessment is undoubtedly a good investment and one that will add further value to the risk assessment as a valuable tool for preventing outbreaks in the first place.
When there is a breakout
Even though -immediate shut down is not always essential, there is never going to be much time for delay once you have a Legionella positive result of a routine sample from an Independent UKAS (United Kingdom Accreditation Service) testing laboratory
If there is a Legionella positive result then eliminating the sources of infection and avoiding a major incident will typically involve several stages:
- Risk assessment to identify where the danger lies (dead legs, redundant piping etc.).
- Initial disinfection to control the outbreak (but often not remove the root cause).
- Remedial work to remove major risks and cause of the current positive test results.
- Further disinfection and on-going 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.
So the bottom line is: check your risk assessment now and if in any doubt, pick up the ‘phone and ask for advice.
*The safety notice Management of the risks from Legionella in water systems can be read in full at: http://www.hse.gov.uk/safetybulletins/legionella2.htm