WATER SYSTEM HYGIENE AND SAFETY
Ensure external Legionella risk assessors can do the job
IHEEM-registered AEs (Water), Steve Mount and Harry Evans, warn that it is imperative to make a judicious choice of risk assessor and water hygiene contractor as part of concerted strategy to combat Legionella in healthcare water systems. Taking on individuals without demonstrable evidence of the necessary competence and expertise is fraught with danger, and – should a serious incident occur – leaves the client organisation, such as an NHS Trust, open to serious consequences – in the worst case facing prosecution.
After an outbreak of Legionnaires’ disease in 1976 in Philadelphia, the UK’s Health and Safety Executive (HSE) produced a guidance note (EH48), while in 1991, the Health and Safety Commission published the Approved Code and Practice for the Prevention of Legionellosis; the second edition was published in 1995. In 1998, there was specific guidance issued for hot and cold water systems. In 2001, everything was combined into one guidance document, the first edition of the HSE’s Approved Code of Practice and Guidance, L8, within this there were various levels of document: laws, regulations, approved codes of practice, and technical guidance. In 2013/14, the HSE published the latest ACOP L8 and HSG274 Legionnaire’s disease Technical guidance, which provide more detailed guidance on Legionella risk assessment, control measures, and managing potential contamination sources.
A response to a series of outbreaks In May 2016 the Department of Health produced the first edition of Health Technical Memorandum HTM 04-01:
Safe water in healthcare premises, as a response to a series of Legionnaires’ disease outbreaks in the 1990s, both in the UK and other countries. These led to increased public awareness of the risks associated with Legionella, and prompted calls for tighter regulations and enforcement. There were subsequent updates to this HTM in 2013 and 2016 to reflect advances in knowledge and technology. It is an important guidance document in the UK for the management of Legionella bacteria in healthcare facilities’ water systems.
An evolving picture Legionella risk assessment in the UK has evolved over time, with a focus on risk identification, management, and prevention. The regulations and guidance have been regularly updated to reflect new scientific evidence and best practice, and the responsibility for managing the risk of Legionella contamination has been firmly placed on building owners and managers. Against this backdrop, the UK Government has launched several initiatives aimed at improving
Legionella risk management – including the development of a national register of cooling towers and evaporative condensers, and the establishment of the HSE in January 1975 – as an independent body to enforce health and safety legislation in all workplaces, including the Legionella regulations. Overall, Legionella risk assessment and management continue to be a priority for public health and safety in the UK.
A history of Legionella risk assessments The first Legionella risk assessments in the UK were produced in the late 1980s by a combination of different organisations – including the HSE and various private consulting firms. The HSE developed guidance for risk assessment and management following the enactment of legislation (the COSHH Regulations) in 1989, requiring employers and building owners to assess and manage the risk of Legionella in their buildings. This scenario has continued without regulation ever since. Now, we have numerous organisations providing ‘the most
Figures 1 (above left) and 2 (above right): Two of the photos taken by the ‘non-competent’ water safety contractor referred to in the article, of one of the cold water storage tanks they were asked to inspect. Based on the photos, the individual claimed no disinfection was required, but seemingly failed to spot substantial corrosion to the tank upper braces and bolts – see Figure 2.
August 2023 Health Estate Journal 41
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