What are the key features of an effective Legionella Risk Assessment?
For many companies this will involve procuring the services of a certified water hygiene company that can provide an unbiased appraisal of the water quality risks.
So what are the essential elements of an LRA? And how can you ensure that your water hygiene services provider has ticked every box when it comes to the safety-critical issue of compliance?
This blog post provides an overview of the features that a comprehensive LRA should include to maintain best practice and keep your workplace environment safe.
Assessing the risk
In the UK, the legal requirement for a risk assessment is underpinned by the following health and safety legislation:
- The Health and Safety at Work Act 1974
- The Management of Health and Safety at Work Regulations 1999
- The Control of Substances Hazardous to Health (COSHH) regulations 2002
- The Health and Safety Executive (HSE) Approved Code of Practice ACOP L8 "Legionnaires Disease: The Control of Legionella Bacteria in Water Systems"
- The HSE's Health and Safety Guidance HSG 274 "Legionnaires Disease Technical Guidance"
What does a Legionella Risk Assessment involve?
A formal independent Legionella Risk Assessment should ideally comprise:
- An evaluation of your on-site assets
- An appraisal of the condition of water storage systems
- Temperature checks
- A photographic register of assets
- A schematic to show the inter-relationship of equipment and associated risks
- A list of recommended actions to ensure compliance and remain safe
In particular, the LRA will focus on the following key elements:
1. An assessment of risk to tenants/employees/visitors - is there anyone on site who is particularly susceptible due to age or health considerations? In the healthcare sector, for example, the compromised immune systems of some patients can increase the risks posed by Legionella bacteria.
2. Descriptions of both cold water and hot water systems - for example are they mains fed, from water storage, or a combination of the two?
3. A record of water outlet temperature - water services must be operated at temperatures that inhibit Legionella growth. For cold water systems this means a water temperature of below 20C at outlets and where water is stored, and for hot water a temperature of above 50C at the outlets. At temperatures below 20C Legionella is dormant, while at temperatures of 60C and above it cannot survive.
4. An assessment of the cold and hot water system/s - if there is a cold water tank present, is it accessible, insulated and completely enclosed to prevent ingress of vermin or foreign matter which can act as a nutrient source for bacteria?
In the case of a hot water system, what type of system is it (unvented cylinder, combi-boiler, cylinder fed etc) and are the distribution pipes adequately insulated?
6. Identification of additional areas of risk - are showers and mixing valves correctly installed and well maintained? Are there any dead legs, redundant or rarely used pipework on the property that will need to be removed or altered? If areas of the property are left unattended for periods of time, is there a schedule in place to flush water systems on a regular basis?
Choosing a LRA
While LRA's tend to follow a fairly prescribed format, there are some factors that can help you differentiate one water hygiene provider's approach from another.
The aim of an LRA is to help you identify real risks and to provide you with the steps to take in order to remedy any problems. Clarity is key - so it makes sense to look for an LRA that simply and succinctly explains the issues and that offers a clear set of actionable solutions.
To this end, an LRA that incorporates a traffic-light system can also be a useful way to help you prioritise your tasks. A red light, for example, might indicate actions that are of the highest priority and which will need to be attended to as soon as possible.
Tasks with an amber light might indicate that prompt action is recommended, perhaps within an advised time-frame; while a green light could refer to non-urgent actions that, whilst not essential, would assist in improving or streamlining your processes.
Routine LRAs are vital to safeguard the well being of occupants and visitors of any workplace where the presence of Legionella poses a potential risk.
While the law doesn't stipulate that duty holders employ the services of a qualified risk assessment assessor, the ACoP L8 regulations do specify that any person who is appointed to implement LRA control measures and strategies should be "suitably informed, instructed and trained and their suitability assessed" and that they are "properly trained to a level that ensures tasks are carried out in a safe, technically competent manner.”
It is therefore highly advisable to choose a reputable company for example, one that is a member of the UK Legionella Control Association.
Selecting a water hygiene company that operates as part of a larger group can also offer additional reassurance and a greater breadth of experience, to ensure that your company's risk assessment and Legionella control procedures are conducted in an efficient and compliant manner.
Topics: Legionella Control
Written by Jon Greaves
Jon has progressively worked through operational roles, account management, technical management, and senior management roles over the last 16 years within one of the group companies before moving into the role of Water and Air Managing Director. Jon has experience across multiple sectors of water and air compliance, including district energy networks; data centres; healthcare; food and beverage and facilities management. Jon acted as a corresponding steering committee member on CIBSE CP1 – Heat Networks Code of Practice for the UK released in 2020.