Water Hygiene Auditing

As part of any water hygiene risk assessment a full and thorough audit will be carried out of all activities relevant to water hygiene and Legionella control on site. This will include an audit of all sub-contractors’ activities and of the management programme and record keeping of the incumbent site/facilities manager.

Excluding high-risk sites, the basic requirement is to review a Legionella risk assessment every two years or in the event of significant changes on site.  For added peace of mind and control, many sites prefer to carry out an additional audit at a frequency greater than every two years to ensure that everything is still running smoothly; that actions are being implemented according to relevant timeframes and to ensure water hygiene and Legionella control standards are being maintained.

In addition, an audit is often carried out in lieu of another external visit, from perhaps an Environmental Health Officer or possibly a Health and Safety Representative from one’s own company. Regular audits can act like a ‘pre-MOT’ to highlight where minor issues require attention, before they manifest into greater problems further down the line.

What are the benefits?

Employing the S2 Partnership to carry out regular water hygiene/Legionella audits on site has the following benefits:

  • provides site managers peace of mind that tasks are being carried out to a timely and competent fashion by all sub-contractors used;
  • highlights and addresses minor non-compliances before they manifest as greater problems further down the line;
  • keeps all sub-contractors ‘on their toes’ in maintaining water hygiene standards; and
  • ensures that external visits, for example by Environmental Health Officers, run as smoothly as possible.
How can the S2 Partnership help?

The S2 Partnership can provide expertly trained water hygiene/Legionella control consultants to attend site to carry out the following:

  • check that all sub-contractors are carrying out their tasks to agreed timeframes and that all works are carried out by suitably trained and competent persons;
  • scrutinise method statements to ascertain that they are site-specific and fit for purpose;
  • act as the ‘eyes and ears’ of an Environmental Health Officer, to pre-empt and rectify any potential problems ahead of potential visits; and
  • drill down into the minutiae detail of all policies and procedures to check that they are valid, relevant and adequately cover all activities carried out on site with regard to water hygiene and Legionella control.

S2 Partnership provides a comprehensive service to audit and manage the level of Legionella compliance/control on any site, which involves the following:

  • site survey of all relevant assets and plant to include a detailed condition survey outlining all faults and listing all necessary remedial actions required to ensure the water services on-site comply with the requirements of not only ACOP L8, but also other guidance documents and regulations, such as the Water Supply (Water Fittings) Regulations 1999;
  • audit of all Legionella control activities on-site, including all tasks carried out by sub-contractors and to include an assessment of the competency of all people involved in the management and control of Legionella bacteria;
  • provision of all documentation relevant to Legionella control, including policies and procedures method statements, emergency procedures, log books, log sheets and risk assessments;
  • designing and delivering specific training programmes aimed at ensuring competency of on-site maintenance staff, managers and Responsible Persons/Duty Holders; and
  • carrying out sampling to prove the effectiveness of control regimes.

As part of your obligations to comply with current legislation and codes of practice governing the control and management of legionella (COSHH, RIDDOR, HSWA, MHSWA, Notification of Cooling Towers and Evaporative Condensers Regulations, ACOP L8). The following is required from clients for water systems that they manage:

  1. The need to carry out a suitable and sufficient risk assessment
  2. The need to prepare a scheme for preventing or controlling the risk
  3. The need to implement, manage and monitor precautions
  4. The need to keep records of the precautions
  5. The need to appoint a person to managerial responsibility

It is the client’s responsibility to maintain all records pertinent to the control of legionella on site and to determine where these records will be kept. Records are to be maintained for a period of five years.

S2 Partnership assists in the production of a written scheme, but this will also require input from the client and their appointed M+E contractors and water treatment contractors. The elements of the written scheme as outlined below are assessed and audited at the time of the risk assessment and where necessary actions raised in the risk assessment to indicate where improvements need to be made to achieve compliance. ACOP L8/HSG 274 outline a suitable and sufficient written scheme as having:

a) an up-to-date plan showing the layout of the plant or water system, including parts temporarily out of use (a schematic diagram is sufficient);
b) a description of the correct and safe operation of the system;
c) the precautions to take;
d) checks to carry out to ensure the written scheme is effective and the frequency of such checks;
e) the remedial action to take if the written scheme is shown to be not effective.

The written scheme should give details on how to use and carry out the various control measures and water treatment regimes, including:

a) the physical treatment programme  – e.g. using temperature control for hot and cold water systems;
b) the chemical treatment programme, including a description of the manufacturer’s data on effectiveness, the concentrations and contact time required;
c) health and safety information for storage, handling, use and disposal of chemicals;
d) system control parameters (together with allowable tolerances); physical, chemical and biological parameters, together with measurement methods and sampling locations, test frequencies and procedures for maintaining consistency;
e) remedial measures to take in case the control limits are exceeded, including lines of communication;
f) cleaning and disinfection procedures;
g) emergency procedures.

The written scheme should also describe the correct operation of the water system plant, including:

a) commissioning and recommissioning procedures;
b) shutdown procedures;
c) checks of warning systems and diagnostic systems in case of system malfunctions;
d) maintenance requirements and frequencies;
e) operating cycles – including when the system plant is in use or idle.

Our team of dedicated and professionally trained staff ensure the ability to deliver a comprehensive and effective water management service. The S2 Partnership is a member of the Legionella Control Association, delivering key services including risk assessments, consultancy, training and analytical services.

The S2 Partnership Registration Certificate can be viewed here.
To see a current copy of the Legionella Control Association Code of Conduct which S2 Partnership comply with click here.

For clients subscribing to RiskWise, reports (including any logsheets and actions) are uploaded directly to RiskWise, prompting an email notification to the site representative of the new report being available.

For clients without RiskWise, reports are issued directly by email to the client representative with the option of hard copies being posted on request.

Please contact us for more information.