Water safety - who needs to know?
Ensuring water safety is expensive but the persistent news reports of Legionella and Pseudomonas outbreaks reminds us that it is not a topic for tick-box compliance. Senior managers and owners will take the rap if it goes wrong. Andrew Steel, managing director of water services company Airmec reminds us that you can outsource the work, but not the ultimate responsibility.
Any temptation to file and forget the HSE L8 Approved Code of Practice on the control of Legionella bacteria once you’ve signed a contract with a specialist services company should be quickly dismissed. It has the full force of the law (HASAW and COSHH) behind it, and is now so concise there isn’t any ‘wriggle room’ should you have to defend your position.
The document clearly identifies the role of the duty holder, the appointed person the risk assessor and the employee in implementing the control measures: rest assured that one of those caps will fit you. Yes, you can employ consultants and contractors to risk assess, clean and test your systems and to set up your flushing regimes and auditing procedures, but you simply cannot outsource the ultimate responsibility. If the service providers get it wrong, the buck stops with you!
The buck really does stop at the top…
The owner or operator of any water system accessible to the public and/or employees is the ‘duty holder’ who must comply with legislation that requires proper management, maintenance and treatment of water systems in your premises.
The ‘duty holder’ should appoint a person to take day-to-day responsibility for controlling any identified risk from Legionella bacteria. The appointed ‘responsible person’ should be a manager, director, or have similar status and sufficient authority, competence and knowledge of the installation to ensure that all operational procedures are carried out in a timely and effective manner.
So, who needs training?
The answer is not as obvious as you would think, in many cases organisations spend a lot of money training their employees with little or no consideration of what they really need. At the other end of the scale is a misapprehension that you can get away with a one-size-fits-all online course.
Under Health and Safety law, duty holders must consider the risks from Legionella that may affect staff or members of the public and ensure that suitable precautions are taken. However everyone involved in implementing control measure bears a responsibility and is answerable to the law and needs to be suitably knowledgeable.
As we all know, people who understand why they need to do something are more likely to do so effectively, so it is important to consider the training needs that exist throughout your organisation and to tailor the course to individual needs. The person charged with flushing the taps will not, for instance, need to know the ins and outs of how an evaporative condenser works – indeed information overload may distract them from the vital understanding they do need.
Equally important at management level can be an understanding of the implications of a positive test result and how the business should respond. All too often there is panic as the building management team scrabble to release the necessary budget to nip it in the bud. When asked for help with a positive sample result our first question is usually “How were these samples taken and transported to the lab?” Often we are met with blank looks, a sure sign to us that there have been gaps in training and understanding
Planned prevention
I like to think of training as planned prevention. So, when considering training I urge you to start at the top and ensure that those with the ultimate responsibility also attend a relevant Legionella Control course, to ensure they are suitably knowledgeable, not just the operational staff. Work with your training provider to develop a programme that covers everyone’s needs: from the duty holder to the employees carrying out the control tasks should have sufficient information, instruction and training.
It may do no harm to ensure that all other members of staff have at least a basic awareness of the very real risks that Legionella bacteria present. This is a requirement in the healthcare sector, and would seem to me to make sense in every other sector as well.
It is important that the decision makers and budget holders are fully cognisant of the potential liability should their water management programme fail. Those making managerial decisions should be fully aware of the need for risk assessment and best practice in the form of documents such as BS 8580:2010 Water quality. Risk assessments for Legionella control. Code of practice. I always use this and other references to explain fully the responsibilities of each group of people within a company, especially those relating to communication and record keeping.
The good news is that choosing a trainer is no longer an act of faith. Now regulated by Ofqual, training is curriculum based. You benefit from years of experience and industry best practice, not just what is in the trainer’s head. A good trainer will also develop a programme that fits your staff requirements.
The table below gives an example of how we tailored training for one of our customers in the healthcare sector, on a budget, to ensure that each person gets the information they need and the greatest likelihood of retaining and implementing the knowledge they need. Of course, the most important element of any training programme is the trainer – do they really know their topic so they can interpret it, and not just regurgitate the HSA guidance? Do they have enough knowledge and practical experience of real systems to be able to tailor the course to your specific needs and premises? Are they effective and engaging communicators?
A word of caution: if you outsource Legionella control to a third-party services company, as is usually the case, part of your due diligence in selecting them should of course be to check that their staff are adequately trained. As duty holder you should maintain a watch on that over the years to ensure those levels of competency are maintained. A safe option is to deal only with members of the Legionella Control Association which audits its members.
Don’t pay lip service to training – the risks to your employees, your visitors, your business and you are just too high. It only takes one person to fail to understand the importance of their role ….
Ensuring water safety is expensive but the persistent news reports of Legionella and Pseudomonas outbreaks reminds us that it is not a topic for tick-box compliance. Senior managers and owners will take the rap if it goes wrong. Andrew Steel, managing director of water services company Airmec reminds us that you can outsource the work, but not the ultimate responsibility.
Any temptation to file and forget the HSE L8 Approved Code of Practice on the control of Legionella bacteria once you’ve signed a contract with a specialist services company should be quickly dismissed. It has the full force of the law (HASAW and COSHH) behind it, and is now so concise there isn’t any ‘wriggle room’ should you have to defend your position.
The document clearly identifies the role of the duty holder, the appointed person the risk assessor and the employee in implementing the control measures: rest assured that one of those caps will fit you. Yes, you can employ consultants and contractors to risk assess, clean and test your systems and to set up your flushing regimes and auditing procedures, but you simply cannot outsource the ultimate responsibility. If the service providers get it wrong, the buck stops with you!
The buck really does stop at the top…
The owner or operator of any water system accessible to the public and/or employees is the ‘duty holder’ who must comply with legislation that requires proper management, maintenance and treatment of water systems in your premises.
The ‘duty holder’ should appoint a person to take day-to-day responsibility for controlling any identified risk from Legionella bacteria. The appointed ‘responsible person’ should be a manager, director, or have similar status and sufficient authority, competence and knowledge of the installation to ensure that all operational procedures are carried out in a timely and effective manner.
So, who needs training?
The answer is not as obvious as you would think, in many cases organisations spend a lot of money training their employees with little or no consideration of what they really need. At the other end of the scale is a misapprehension that you can get away with a one-size-fits-all online course.
Under Health and Safety law, duty holders must consider the risks from Legionella that may affect staff or members of the public and ensure that suitable precautions are taken. However everyone involved in implementing control measure bears a responsibility and is answerable to the law and needs to be suitably knowledgeable.
As we all know, people who understand why they need to do something are more likely to do so effectively, so it is important to consider the training needs that exist throughout your organisation and to tailor the course to individual needs. The person charged with flushing the taps will not, for instance, need to know the ins and outs of how an evaporative condenser works – indeed information overload may distract them from the vital understanding they do need.
Equally important at management level can be an understanding of the implications of a positive test result and how the business should respond. All too often there is panic as the building management team scrabble to release the necessary budget to nip it in the bud. When asked for help with a positive sample result our first question is usually “How were these samples taken and transported to the lab?” Often we are met with blank looks, a sure sign to us that there have been gaps in training and understanding
Planned prevention
I like to think of training as planned prevention. So, when considering training I urge you to start at the top and ensure that those with the ultimate responsibility also attend a relevant Legionella Control course, to ensure they are suitably knowledgeable, not just the operational staff. Work with your training provider to develop a programme that covers everyone’s needs: from the duty holder to the employees carrying out the control tasks should have sufficient information, instruction and training.
It may do no harm to ensure that all other members of staff have at least a basic awareness of the very real risks that Legionella bacteria present. This is a requirement in the healthcare sector, and would seem to me to make sense in every other sector as well.
It is important that the decision makers and budget holders are fully cognisant of the potential liability should their water management programme fail. Those making managerial decisions should be fully aware of the need for risk assessment and best practice in the form of documents such as BS 8580:2010 Water quality. Risk assessments for Legionella control. Code of practice. I always use this and other references to explain fully the responsibilities of each group of people within a company, especially those relating to communication and record keeping.
The good news is that choosing a trainer is no longer an act of faith. Now regulated by Ofqual, training is curriculum based. You benefit from years of experience and industry best practice, not just what is in the trainer’s head. A good trainer will also develop a programme that fits your staff requirements.
The table below gives an example of how we tailored training for one of our customers in the healthcare sector, on a budget, to ensure that each person gets the information they need and the greatest likelihood of retaining and implementing the knowledge they need. Of course, the most important element of any training programme is the trainer – do they really know their topic so they can interpret it, and not just regurgitate the HSA guidance? Do they have enough knowledge and practical experience of real systems to be able to tailor the course to your specific needs and premises? Are they effective and engaging communicators?
A word of caution: if you outsource Legionella control to a third-party services company, as is usually the case, part of your due diligence in selecting them should of course be to check that their staff are adequately trained. As duty holder you should maintain a watch on that over the years to ensure those levels of competency are maintained. A safe option is to deal only with members of the Legionella Control Association which audits its members.
Don’t pay lip service to training – the risks to your employees, your visitors, your business and you are just too high. It only takes one person to fail to understand the importance of their role ….