Water Hygiene Risk Assessment: Domestic Systems
A 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 risk assessment is legally required for all premises with water, where there is the potential to create a spray or aerosol and where there is the potential for the water on
site to exceed 20°C.
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 (HSE) has issued an approved code of practice
ACOP L8, which details all the specific tasks, checks and policies/procedures
which need to be in place for any organisation to fully comply with the legislation.
A water hygiene 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 to the growth and dissemination of Legionella bacteria.
A condition survey of all relevant plant/assets will summarise those 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/water hygiene log book system to include detailed policies and 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 (2002), and MHSWR 1999;
- 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;
- protection of reputation. Following recent outbreaks of Legionnaires’ disease, public awareness and media involvement continues to gain momentum; 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 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?
The water hygiene risk assessment survey of domestic water systems on site to identify
hazards, assess risks and recommend risk controls that minimise the potential for legionella bacteria. If no schematic drawings are available on site, these can be produced for an
additional fee. As part of the water hygiene risk assessment, water log sheets will
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:
- The need to carry out a suitable and sufficient risk assessment
- The need to prepare a scheme for preventing or controlling the risk
- The need to implement, manage and monitor precautions
- The need to keep records of the precautions
- 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.
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.