Published in Building Services & Environmental Engineer - August 2014
Legionella – back to basics?
Andrew Steel, MD of Airmec reminds us that there are no magic wands when it comes to Legionella control – but just throwing money at the problem is not the answer.
Avoiding Legionella outbreaks is a constant concern for any building or facilities manager and there is certainly no shortage of advice to be had; especially since the guidance and regulations were updated last year. The challenge is to find your way through the maze and understand what inspectors are looking for, and devise a regime that is both effective and affordable for your premises.
The guidance is written by experts with the cumulative benefit of massive amounts of experience: in other words it is good stuff. Take time to absorb it, act appropriately, make sure your staff training s up to date and you should have no problems.
Of course, budget is not the main issue here, and the potential consequences of an outbreak far outweigh the matter of the hefty intervention charges HSE inspectors can levy if they don’t like what they see. Nevertheless, signing up for the latest big and probably expensive idea will rarely provide a panacea. Do take time to ponder how you can best balance the law and code of practice guidance with your real-world budget.
The current frenzy of news about Legionella control has surrounded last year’s publication by the Health and Safety Executive of the 4th edition of what is known as “ACOP L8”, the Approved Code of Practice and Guidance on Regulations for the Control of Bacteria in Water Systems. To be clear, an ACOP is not actually a law, but it does enjoy special legal status.
In a nutshell, the latest, fourth edition of the ACOP contains revisions intended to simplify and clarify the text. In practice the main changes centered on removing the technical guidance, which is now published separately as HSG274. It only upon reading the fine print of HSG 274, Parts 1 to 3 dealing respectively with evaporative cooling systems, hot and cold water systems and other systems, that you may find that some of the intended clarity could be lost on you.
However, the way to achieve certainty and clarity is probably not to throw money at what might not be a problem after all. It may be far better to take a holistic view of the systems in your premises, review your schematics and risk assessments; and then tailor preventive measures to what you can afford and have the resources to do properly. There’s no point in fitting devices if you are unaware of their limitations. Look, for instance, at the trend towards UV sterilisation of taps and shower heads, which might seem, at first glance, to be a panacea – indeed they are a good innovation. Such devices are, however, only part of a potential solution when combined with a robust water management plan. There may be less capital intensive alternatives which will be just as effective. Can you afford to manage that risk as well as to service the capital cost and maintenance of the units? If so, all well and good, if not, perhaps a more pragmatic approach is called for?
There is, at the end of the day no magic wand: risk management always starts with a comprehensive risk assessment, which should be treated as a live working document and not something that can be filed away for two years. It might be thought that every responsible organisation already has such a live risk assessment…but surprisingly few do: there is a lot of work out there which is either outdated or just plain inaccurate. Yet the cost of dealing with a positive lab analysis or even an outbreak rises dramatically, as does the cost of business disruption, if there is not a good risk assessment to work from.
Let’s be clear this is not a criticism on the HSE’s technical guidance – producing it is a massive achievement, but there are bound to be teething troubles as it beds in. There is, however, no leeway to stand back and watch that happen because the inspectors can come knocking any day. We’ve been aware for instance, of a Health & Safety executive focus on evaporative cooling towers in recent months - after all a third of Legionnaires’ disease and Pontiac fever cases attributed to cooling towers and poor risk management.
There have been some significant “intervention fees” slapped on firms whose risk assessments do not meet requirements that only came into force in December 2013, so forget the idea of two yearly risk assessment that we are all rather used to. If it was undertaken before last Christmas, it’s probably wrong! The HSG guidance clearly states that assessment of risk is an ongoing process and not merely a paper exercise – now they are showing that they really mean it! No matter how good your risk assessment, if you thought it could sit on the shelf for two years before review, think again.
While the use of cooling towers is declining as more efficient heat exchangers gain in popularity, Legionella prevention in hot and cold water should remain high on anyone’s agenda.
The market has come up with no end of solutions, but none of them offer a complete answer. Inspectors rightly look for proof that you understand the risks in your premises and have a plan to deal with them – and they want to see documented proof that you carry out that plan.
Whether that plan involves fitting brand new hardware or flushing old taps regularly or, more likely, a combination of both is up to you. Just be sure that you have enough knowledge of your own systems to make the right management choices and never, ever take your eye off the ball. There are no fit-and-forget solutions to be had.
Avoiding Legionella outbreaks is a constant concern for any building or facilities manager and there is certainly no shortage of advice to be had; especially since the guidance and regulations were updated last year. The challenge is to find your way through the maze and understand what inspectors are looking for, and devise a regime that is both effective and affordable for your premises.
The guidance is written by experts with the cumulative benefit of massive amounts of experience: in other words it is good stuff. Take time to absorb it, act appropriately, make sure your staff training s up to date and you should have no problems.
Of course, budget is not the main issue here, and the potential consequences of an outbreak far outweigh the matter of the hefty intervention charges HSE inspectors can levy if they don’t like what they see. Nevertheless, signing up for the latest big and probably expensive idea will rarely provide a panacea. Do take time to ponder how you can best balance the law and code of practice guidance with your real-world budget.
The current frenzy of news about Legionella control has surrounded last year’s publication by the Health and Safety Executive of the 4th edition of what is known as “ACOP L8”, the Approved Code of Practice and Guidance on Regulations for the Control of Bacteria in Water Systems. To be clear, an ACOP is not actually a law, but it does enjoy special legal status.
In a nutshell, the latest, fourth edition of the ACOP contains revisions intended to simplify and clarify the text. In practice the main changes centered on removing the technical guidance, which is now published separately as HSG274. It only upon reading the fine print of HSG 274, Parts 1 to 3 dealing respectively with evaporative cooling systems, hot and cold water systems and other systems, that you may find that some of the intended clarity could be lost on you.
However, the way to achieve certainty and clarity is probably not to throw money at what might not be a problem after all. It may be far better to take a holistic view of the systems in your premises, review your schematics and risk assessments; and then tailor preventive measures to what you can afford and have the resources to do properly. There’s no point in fitting devices if you are unaware of their limitations. Look, for instance, at the trend towards UV sterilisation of taps and shower heads, which might seem, at first glance, to be a panacea – indeed they are a good innovation. Such devices are, however, only part of a potential solution when combined with a robust water management plan. There may be less capital intensive alternatives which will be just as effective. Can you afford to manage that risk as well as to service the capital cost and maintenance of the units? If so, all well and good, if not, perhaps a more pragmatic approach is called for?
There is, at the end of the day no magic wand: risk management always starts with a comprehensive risk assessment, which should be treated as a live working document and not something that can be filed away for two years. It might be thought that every responsible organisation already has such a live risk assessment…but surprisingly few do: there is a lot of work out there which is either outdated or just plain inaccurate. Yet the cost of dealing with a positive lab analysis or even an outbreak rises dramatically, as does the cost of business disruption, if there is not a good risk assessment to work from.
Let’s be clear this is not a criticism on the HSE’s technical guidance – producing it is a massive achievement, but there are bound to be teething troubles as it beds in. There is, however, no leeway to stand back and watch that happen because the inspectors can come knocking any day. We’ve been aware for instance, of a Health & Safety executive focus on evaporative cooling towers in recent months - after all a third of Legionnaires’ disease and Pontiac fever cases attributed to cooling towers and poor risk management.
There have been some significant “intervention fees” slapped on firms whose risk assessments do not meet requirements that only came into force in December 2013, so forget the idea of two yearly risk assessment that we are all rather used to. If it was undertaken before last Christmas, it’s probably wrong! The HSG guidance clearly states that assessment of risk is an ongoing process and not merely a paper exercise – now they are showing that they really mean it! No matter how good your risk assessment, if you thought it could sit on the shelf for two years before review, think again.
While the use of cooling towers is declining as more efficient heat exchangers gain in popularity, Legionella prevention in hot and cold water should remain high on anyone’s agenda.
The market has come up with no end of solutions, but none of them offer a complete answer. Inspectors rightly look for proof that you understand the risks in your premises and have a plan to deal with them – and they want to see documented proof that you carry out that plan.
Whether that plan involves fitting brand new hardware or flushing old taps regularly or, more likely, a combination of both is up to you. Just be sure that you have enough knowledge of your own systems to make the right management choices and never, ever take your eye off the ball. There are no fit-and-forget solutions to be had.