WATER HYGIENE AND SAFETY
generally involves a paid subscription, and gives little reassurance of the competence of the member companies, or the individuals registered by them. Professional bodies vary greatly. Some will require evidence of training, CPD, and references, to allow an individual to join, while others will have an element of peer-to-peer review; in some cases this may not have much value. Very little of this scrutiny focuses on the individuals that will be delivering services on your site – don’t forget, these are the people you need to be making those ‘reasonable enquiries’ about.
Matt Morse undertaking an ‘infield’ competence assessment.
course materials; others will look at the course material in detail and the delivery quality – ‘buyer beware’.
Employing contractors or consultants ACoP L82
has a statement in paragraph
57 that says ‘employing contractors or consultants does not absolve the duty- holder of responsibility for ensuring that control procedures are carried out to the standard required to prevent the proliferation of legionella bacteria. Duty- holders should make reasonable enquiries to satisfy themselves of the competence of contractors in the area of work before they enter into contracts for the treatment, monitoring, and cleaning of the water system, and other aspects of water treatment and control. An illustration of the levels of service to expect from Service Providers can be found in the Code of Conduct administered by the Legionella Control Association (LCA)’. There are three important points in this
paragraph: n The legal duty remains with the duty- holder regardless of the employment of
Provide training and skills
development
a specialist, so you remain responsible for the actions of your RP, AE, and contractors.
n Duty-holders should make ‘reasonable’ enquiries on competence, so possibly not that onerous, but certainly an interpretable term.
n Levels of service to expect can be found in the LCA Code of Conduct3 seems like an easy way forward?
– this
Making ‘reasonable’ enquiries Since you, as the duty-holder, are going to retain that responsibility, then the reasonable enquiries on competence are going to need to be made. Ask yourself, why do you believe that your AE, RP, consultant, risk assessor, clean and disinfection company, monitoring contractor, water treater, and so on, are competent. How do they prove it to you? There are registrations with professional bodies that might give you some comfort – or do they? That may depend on the entry criteria, and how these are assessed and policed.
Membership of trade associations
Accreditation What about accreditation and memberships that are often treated like accreditation, e.g. UKAS or the LCA? Does selecting a contractor that has this tick in the box get you off the hook for those ‘reasonable enquiries’? It may seem unlikely from reading L8? UKAS4
accreditation to national standards. In the Legionella world it accredits laboratories to ISO standards for laboratory practices/ methods, and it accredits inspection bodies for Legionella risk assessment to the inspection standard, ISO 17020. Does this guarantee that every individual and every piece of work that a UKAS- accredited company delivers is to the relevant standard? No – UKAS undertakes a sampling exercise of a company’s output, and cannot act as the QA department for the companies it accredits. The LCA is a standards organisation
that grants membership to companies that operate appropriate management systems, and can demonstrate this with evidence at audit. The LCA requires members to comply with a Code of Conduct and Service Delivery Standards. The Service Delivery Standards5
is the UK body for
are about No
Assess competence in field, is the operative competent?
Yes
the technical delivery of Legionella control services, and are not the subject of this article, but the Code of Conduct has several clauses specific to competence of individuals that are very relevant. Does this guarantee that every individual and every piece of work that an LCA member company delivers is to the relevant standard? No – the LCA undertakes a sampling exercise of a company’s output, and cannot act as the QA department for member companies. This may seem like UKAS accreditation, except that the LCA has Service Delivery Standards covering all aspects of Legionella control services, not just risk assessment (ISO 17020) and analysis (ISO 17025), as UKAS does.
Record Yes
operative as competent
Key questions in the LCA competence assessment guidance. 58 Health Estate Journal August 2022 Is there any reason
to doubt competence? • Complaints • Role changed? • Procedures changed?
Management system requirement The LCA code section 2 (training and competence) requires member companies to operate a management system to identify what training is required to deliver the Legionella control work they do, and to make sure that their employees have that training, assess their competence to deliver
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