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INFECTION CONTROL Paul Sear – Technical Manager, Environmental Scientifics Group

Clearing up the confusion on Legionellaguidance

This article looks at the recent changes to the Legionellarisk management guidance and explains what they mean for healthcare estates and facilities managers.

Late in 2013, the Health and Safety Executive (HSE) in the UK published a revision to its Legionella management guidance – the first since 2000. This review has resulted in two new documents – the updated Approved Code of Practice (ACoP) Legionnaires’ disease: The control of legionella bacteria in water systems (L8), and the new Technical Guidance HSG 274 Parts 1-3. In general, the revised L8 and

HSG 274 guidance takes a number of recommendations, specific to healthcare environments, from existing documents, of which healthcare estates and facilities managers will already be aware. These include Water Systems Health Technical Memorandum 04-01: The control, legionella, hygiene, ‘safe’ hot water, cold water and drinking water systems Parts A and B, and Water Systems Health Technical Memorandum 04-01: Addendum, Pseudomonas aeruginosa – advice for augmented care units. As such, the principles of Legionella management and control in the healthcare environment have not changed significantly, as many of the updates would have already been implemented from previous guidance. However, with the Health Technical Memorandum 04-01 now more than seven years old and due to be revised in the next 12 months, it is important for healthcare estates and facilities managers to understand the key changes the new L8 and HSG 274 guidance and what this guidance means for the buildings they manage.

‘The greatest difference in the new documents is the language used, which makes the guidance clearer and easier to understand.’


Clear and concise The greatest difference in the new documents is the language used, which makes the guidance clearer and easier to understand. Given the ACOP’s special legal status, this clarity makes the practical advice easier to follow for building managers – both in the healthcare arena and elsewhere – and enables them to facilitate compliance with the law surrounding Legionella management and control. As part of this drive for clarity, the old

ACOP L8 Part 2 technical guidance has been separated into an independent document Technical Guidance HSG 274. This is further sub-divided into three clear and easy-to- digest sections: Part 1, The Control of legionella bacteria in evaporative cooling systems; Part 2, The control of legionella bacteria in hot and cold water systems and Part 3, The control of legionella bacteria in other risk systems.

Responsibility Throughout the new ACOP L8 document, greater emphasis is placed on the duty holder, regardless of the purpose of the building being managed. The enhanced clarity of the documents should assist those following them to clearly understand their role and responsibilities with regards to Legionella risk management and control. It should also ensure they have sufficient knowledge of the issue and help improve their communications with maintenance teams and other stakeholders to maintain

better control of risk both internally and externally. Under the new guidelines, it is also no

longer the case that a single individual has to be in charge of ‘competency’. Sharing responsibility helps to minimise the risk of errors from having one person in sole control and is especially important in large and complex organisations. The pool of competent people does not have to draw solely from directors or managers, but those chosen must demonstrate knowledge and authority, and training should be provided so that everyone is aware of their responsibilities. In addition, the HSE is now allowing appointments from outside an organisation, providing the responsible person and duty holder maintain sufficient authority for day-to-day control.

Advice for healthcare systems The updated L8 document does not, in itself, contain anything specific to healthcare, but nevertheless it provides good guidance on the management and control of Legionella in water systems that duty holders for hospitals, care homes and other high-risk environments need to follow. The risk assessment remains the starting

point for Legionella control, as it always determines the most appropriate control measures. No longer is there guidance to undertake risk assessments every two years; it should now be considered a living

Paul Sear

Paul Sear is a Technical Manager at ESG with responsibility for providing consultancy services for clients, including risk assessments, training, auditing and writing policies and procedures.

He is an experienced consultant working in health, safety and environment consultancy, specialising in the field of legionella management and control. He has expert knowledge of ACoP L8, HSG274, HTM04-01, BS8580 and other

Legionella management, legal and best practice guidance and legislation, as well as a BSc (Hons) in Environmental Science.

He is a member of the Water Management Society. IFHE DIGEST 2015

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