WATER HYGIENE AND SAFETY ‘‘
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
that work, and to keep records of all of those. When the LCA audits a member company, we examine the structure around those elements to assess its capability. We then audit an LCA-selected sample of output that demonstrates that the system works, and is used in practice. Identifying what you need to know to be able to do something sounds simple, but what if ‘you don’t know what you don’t know’? The LCA publishes a knowledge and skills matrix6
to illustrate the
knowledge and skills areas that members are likely to need for delivery of specific Legionella control tasks. Once the required knowledge is identified, looking at the staff to identify any gaps in their knowledge leads to the delivery of additional training to fill any gaps. Before working unsupervised, every member of staff must be assessed for their competence via an infield competence assessment. The LCA publishes guidance7
on how to carry this
out, and requires that records of these assessments and annual reviews are kept for all staff. What does all that mean for the user of the LCA member wanting to make those ‘reasonable enquires’?
An assurance of competence Both UKAS accreditation and LCA membership mean that the company has to have in place management procedures that should lead to competent people being used on your site, job, or contract. Is the use of one of these accredited or member companies enough to discharge your legal duty to make those ‘reasonable enquiries’? By itself, not really. There is a bit more for the duty-holder to do: request the competence assessments for the staff that will be used on your
work and review them. Take a look at examples of the individual’s previous work. Make a judgement based on that reasonable enquiry – you may not have the technical depth of knowledge to judge the individual; that is why you access this competent help in the first place. You can, however, request the backing detail for the company’s assertions that its staff are competent. Competence in your contractors
and staff is vital to avoiding breaches of the law, illness, and deaths. Use the tools available to make the necessary ‘reasonable enquiries’, and be wary of the huge variability in training quality that exists in the marketplace.
References 1 COGWT11: Carrying out legionella risk assessments. National Occupational Standards.
https://tinyurl.com/yc524j34
2 Legionnaires’ disease. The control of legionella bacteria in water systems. L8 Approved Code of Practice and guidance on regulations. Health & Safety Executive, 2013.
https://tinyurl.com/yxdukpec
3 LCA Code of Conduct for LCA Members. Legionella Control Association. https://
tinyurl.com/4v4pcduz
4 ‘Frequently Asked Questions’. UKAS.
https://www.ukas.com/faqs/
5 LCA Standards. Legionella Control Association.
https://tinyurl.com/ y5u8devm
6 LCA Guidance. Suggested Knowledge & Skills Matrix for Legionella Control Service Delivery. Legionella Control Association.
https://tinyurl.com/53zbrtne
7 Competence Guidance. Legionella Control Association. https://tinyurl. com/58yv68w6
Matt Morse
Matt Morse has worked in Legionella control and water treatment for over 20 years for service-providers and as an independent consultant, whose role includes including acting as a subject matter expert. He also works part-time as the Manager of the Legionella Control Association. He has contributed to industry work including representation for industry bodies, and the development of guidance and standards. A past- chairman of the Legionella Control Association, he is a Member of the British Association of Chemical Specialities Water Treatment Group, a BSI committee member, and was a contributor to both the Health & Safety Executive’s HSG274 guidance on Legionella, and the HSE Approved Code of Practice ACOP L8 (2013), Legionnaire’s disease: the control of Legionella in water systems. He is a member of the Working Groups for the latest revision of BS 8580-1:2019: Risk Assessments for Legionella Control, for BS8680:2020: Water Safety Planning, and a current Working Group member for BS7592:2022: Legionella sampling, and BS 8580-2:2022: Risk assessments for Pseudomonas aeruginosa and other waterborne pathogens.
+44 (0) 161 627 7947
www.safelocking.co.uk
THE KEY TO THE WHEELS TURNING Practically Stored - Securely Managed
FLEET KEY AUDIT TRAIL ENABLE ACCESS TO CERTAIN USERS ACCESS TO BOOKED KEYS ONLY ENSURE MILEAGE & DAMAGED REPORTED
August 2022 Health Estate Journal 59
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