Published in Lexis Nexis Facilities Management magazine / May 2013 2013
The Copper biocide Euro-ban: no need to panic, but time for a due diligence review?
Water treatment services company Airmec is urging estates and facilities managers to take a balanced view on the ban on the use of copper biocides in Legionella control. While the reasonable man’s interpretation of the HSE’s position is that they will not seek enforcement pending an exemption from the European Commission, you should have a contingency plan in place and can view the current situation as a prompt to review the effectiveness and financial efficiency of the processes you currently have in place.
The European ban on the use of copper as a biocide in water systems has been effective since 1st Feb, and given that the HSE has applied to the European Commission for an exemption to allow its continued use for Legionella control, there is confusion in the marketplace about what to do next.
Users who have made a capital investment in ionising electrode systems, typically using Copper/Silver electrodes, are naturally loath to write them off, especially as the widespread belief is that the granting of an exemption, sooner or later, is a foregone conclusion.
Indeed, commenting on its plans for the immediate future, the HSE has said that its and local authority inspectors will take a sensible and proportionate approach to enforcement if they come across these systems while a ban is effective. During what is generally expected to be only an interim period, the focus of any enforcement activity will be on the failure to control the risk of exposure to Legionella bacteria and the likelihood of legionnaire’s disease developing in a given situation, rather than on the means of control.
However, there are chemical alternatives to CuAg alloy electrodes and ionisation that can easily and quickly be implemented to keep you within the law – either as temporary or permanent solutions.
A number of treatments (chemical and physical) are mentioned in different sections of the ACOP L8 guidance, although chlorine dioxide and ozone are the specific biocides actually compared to ionisation and UV light, (pages 43/44/45 in L8) and are sometimes mistakenly thought to be the only options. Sodium hypochlorite and chlorine dioxide are suitable for drinking water, for instance.
Peracetic acid, hydrogen peroxide, chlorine dioxide and sodium hypochlorite can all be used as disinfectants in cleaning processes e.g. tank cleaning and will be chosen based on metallurgy of the system, water quality and industrial application. Often oxidising biocides capable of oxidising organic matter, are often used in combination with non-oxidising biocides to provide complete system control.
It is clear that the choice of agent(s), their concentration/dilution and frequency of treatment is always going to be site specific, and that the real skill in water treatment services is combining a comprehensive knowledge of the guidance with the experience that enables a consultant interpret it to find the right solution for each situation.
“Nevertheless, looking at oxidising alternatives, whether the legal spotlight is currently on the means of control or not, makes sense from a due diligence perspective,” says Peter Bowle, director at Airmec Ltd.
Legionella control is, of course, too serious a business to take chances with and it is understandable that managers will take an “If it ain’t broke, don’t fix it” approach. So it you are planning to explore the potential for swapping from ionization to oxidation, key expectations from a consultant should be that they have the skills to be able to offer advice on efficacies for different chemical actives against different organisms with cost comparisons.
They should offer costed recommendations for shot dosing (‘initial blast’), maintenance dosing and secondary biocides to minimise resistance within organisms. In addition, they should ask for sight of the site schematic and asset register that you are required to have in law, and be able to help you prepare these if necessary.
Users may be reluctant to retire the capital equipment they have invested in for ionization, but may well find that the costs of chemical biocides will compare well with what they are having to spend on consumable electrodes. Once you have done the maths, a swap to biocides might, therefore, be permanent and not just a stopgap pending an exemption on the copper ban.
“This ban is a timely prompt to review your regime and ensure you have best value for money and the most effective, safe solution. It may be that you already have the best possible solution in place, but it will cost you nothing to have a consultant offer informed advice,” says Peter Bowle.
The Copper biocide Euro-ban: no need to panic, but time for a due diligence review?
Water treatment services company Airmec is urging estates and facilities managers to take a balanced view on the ban on the use of copper biocides in Legionella control. While the reasonable man’s interpretation of the HSE’s position is that they will not seek enforcement pending an exemption from the European Commission, you should have a contingency plan in place and can view the current situation as a prompt to review the effectiveness and financial efficiency of the processes you currently have in place.
The European ban on the use of copper as a biocide in water systems has been effective since 1st Feb, and given that the HSE has applied to the European Commission for an exemption to allow its continued use for Legionella control, there is confusion in the marketplace about what to do next.
Users who have made a capital investment in ionising electrode systems, typically using Copper/Silver electrodes, are naturally loath to write them off, especially as the widespread belief is that the granting of an exemption, sooner or later, is a foregone conclusion.
Indeed, commenting on its plans for the immediate future, the HSE has said that its and local authority inspectors will take a sensible and proportionate approach to enforcement if they come across these systems while a ban is effective. During what is generally expected to be only an interim period, the focus of any enforcement activity will be on the failure to control the risk of exposure to Legionella bacteria and the likelihood of legionnaire’s disease developing in a given situation, rather than on the means of control.
However, there are chemical alternatives to CuAg alloy electrodes and ionisation that can easily and quickly be implemented to keep you within the law – either as temporary or permanent solutions.
A number of treatments (chemical and physical) are mentioned in different sections of the ACOP L8 guidance, although chlorine dioxide and ozone are the specific biocides actually compared to ionisation and UV light, (pages 43/44/45 in L8) and are sometimes mistakenly thought to be the only options. Sodium hypochlorite and chlorine dioxide are suitable for drinking water, for instance.
Peracetic acid, hydrogen peroxide, chlorine dioxide and sodium hypochlorite can all be used as disinfectants in cleaning processes e.g. tank cleaning and will be chosen based on metallurgy of the system, water quality and industrial application. Often oxidising biocides capable of oxidising organic matter, are often used in combination with non-oxidising biocides to provide complete system control.
It is clear that the choice of agent(s), their concentration/dilution and frequency of treatment is always going to be site specific, and that the real skill in water treatment services is combining a comprehensive knowledge of the guidance with the experience that enables a consultant interpret it to find the right solution for each situation.
“Nevertheless, looking at oxidising alternatives, whether the legal spotlight is currently on the means of control or not, makes sense from a due diligence perspective,” says Peter Bowle, director at Airmec Ltd.
Legionella control is, of course, too serious a business to take chances with and it is understandable that managers will take an “If it ain’t broke, don’t fix it” approach. So it you are planning to explore the potential for swapping from ionization to oxidation, key expectations from a consultant should be that they have the skills to be able to offer advice on efficacies for different chemical actives against different organisms with cost comparisons.
They should offer costed recommendations for shot dosing (‘initial blast’), maintenance dosing and secondary biocides to minimise resistance within organisms. In addition, they should ask for sight of the site schematic and asset register that you are required to have in law, and be able to help you prepare these if necessary.
Users may be reluctant to retire the capital equipment they have invested in for ionization, but may well find that the costs of chemical biocides will compare well with what they are having to spend on consumable electrodes. Once you have done the maths, a swap to biocides might, therefore, be permanent and not just a stopgap pending an exemption on the copper ban.
“This ban is a timely prompt to review your regime and ensure you have best value for money and the most effective, safe solution. It may be that you already have the best possible solution in place, but it will cost you nothing to have a consultant offer informed advice,” says Peter Bowle.