Published in Public Sector Estates Management - February 2015
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 is 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 bible for Legionella control, published by the Health and Safety Executive, is 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.
The fourth edition, published in 2013, aimed to simplify and clarify the advice. In practice the main changes it introduced centered on removing the technical guidance, which is now published separately as HSG274. It is 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.
HSE 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.
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 is 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 bible for Legionella control, published by the Health and Safety Executive, is 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.
The fourth edition, published in 2013, aimed to simplify and clarify the advice. In practice the main changes it introduced centered on removing the technical guidance, which is now published separately as HSG274. It is 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.
HSE 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.