Water Hygiene Cooling Tower Assessment
A cooling tower risk assessment is legally required for all premises with cooling towers and evaporative condensers. The requirement to carry out a risk assessment is laid down in section 6 of the Control of Substances Hazardous to Health Regulations 2002, and section 3 of the Management of Health and Safety at Work Regulations (1999).
In order to give clear guidance and instruction on how to comply with the regulations, the Health and Safety Executive has issued an approved code of practice ACOP L8, which details all the specific tasks, checks, policies and procedures which need to be in place for any organisation to fully comply with the legislation.
A cooling tower risk assessment carried out by the S2 Partnership will detail all the relevant assets, plant and systems on site which have the potential to create a risk with regard the growth and dissemination of Legionella bacteria. A condition survey of all relevant plant/assets will summarise the remedial actions required in order to reduce the risk to a manageable level. In addition, the S2 Partnership will audit all current activities on-site with regard to Legionella control as per ACOP L8 and set up a comprehensive management plan and The growth of bacteria in water systems is a common cause of potentially-fatal Legionnaires’ disease. Recent outbreaks of Legionella have highlighted the need for stringent water hygiene risk mana... More log book system to include detailed policies, procedures and method statements in order to ensure the site fully complies with all guidance and legislation.
What are the benefits?
A water hygiene risk assessment carried out by the S2 Partnership provides a number of benefits including:
- compliance with relevant legislation – specifically HSWA (1974), COSHH (1992), MHSWR 1999, The Notification of Cooling Towers and Evaporative Condensers Regulations 1992;
- prevention of an occurrence/outbreak of Legionnaires’ disease. Legionnaires’ disease can be fatal and as such if negligence is proved, a prosecution under the Corporate Manslaughter and Corporate Homicide Act 2007 is a distinct possibility. Cooling Towers have been associated with all of the largest outbreaks of Legionnaires’ disease;
- maintaining the company’s reputation. Following recent outbreaks of Legionnaires’ disease, public awareness and media involvement continues to gain momentum; and; and
- the control of Legionella bacteria on sites is closely scrutinised by both the HSE and the Local Authority. These agencies have the power to issue Improvement Notices and Prohibition Notices. Following all of the guidance outlined in an S2 Partnership risk assessment will ensure that audits by the HSE and Local Authority run smoothly and avoid the detrimental effects of having either a Prohibition or Improvement Notice served.
How can the S2 Partnership help?
Work will be undertaken by our specialist water hygiene assessor and will involve an examination of the cooling towers. Risk assessments will be undertaken and site-specific documentation compiled. This will include monitoring logs as appropriate and recommendations for action supplemented by digital photographs.
The 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 and 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.
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:
- 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);
- a description of the correct and safe operation of the system;
- the precautions to take;
- checks to carry out to ensure the written scheme is effective and the frequency of such checks;
- 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:
- the physical treatment programme – e.g. using temperature control for hot and cold water systems;
- the chemical treatment programme, including a description of the manufacturer’s data on effectiveness, the concentrations and contact time required;
- health and safety information for storage, handling, use and disposal of chemicals;
- 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;
- remedial measures to take in case the control limits are exceeded, including lines of communication;
- cleaning and disinfection procedures;
- emergency procedures.
The written scheme should also describe the correct operation of the water system plant, including:
- commissioning and recommissioning procedures;
- shutdown procedures;
- checks of warning systems and diagnostic systems in case of system malfunctions;
- maintenance requirements and frequencies;
- operating cycles – including when the system plant is in use or idle.
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.
Note: In order for our consultant to gain safe access to the cooling tower, your site engineer must be present at the time of the assessment so that the tower can be shut down for inspection.
The S2 Partnership is a member of the Legionella Control Association, delivering key services including risk assessments, consultancy, training and analytical services.
Please contact us for more information.