WATER SYSTEM HYGIENE AND SAFETY
water supplies to work on TMVs, should this person not at least have water hygiene training, as stipulated within HTM 04- 01? If not, there is a much higher risk of them infecting your water supply. If such an individual is undertaking works within augmented care areas housing very vulnerable patients, would they be aware that they should not be doing so – particularly if working on drinking water systems – if, for example, they are suffering from one of the many illnesses that cause diarrhoea? These are among the reasons that a water hygiene course is now recommended in HTM 04-01. Historically, water treatment
contractors undertook tank cleaning and disinfections along with system disinfections, and installation of secondary water treatment systems etc. This, however, has changed, with such companies now undertaking everything from TMV in-service testing to AE(W) services, and everything in between. While water treatment companies now appear to be synonymous with all things water-related, how many of you check the competencies of the individuals working for them?
Examples of questionable works carried out To show what can happen if the water treatment company’s personnel lack the necessary expertise and competence, let us take as an example one such individual being asked to inspect a pair of cold water storage tanks (CWSTs). The contractor promptly arrived and undertook an inspection; the resulting report stated that the tanks showed signs of light sediment to the tank bases, with no biofilm growth. The company recommended a disinfection, and a further inspection the following year. Within the accompanying report was the customary single picture of the base of the CWST (see Figure 1). Based on the picture, the contractor said a disinfection was not required, but seemingly failed to spot substantial corrosion to the tank upper braces and bolts, which really needs to be attended to well within the next 12 months (see Figure 2). Did the Responsible Person check the operative’s qualifications before employing them to undertake the work, and indeed was the operative competent to inform the RP that the tanks were fine to leave for a further year? This contractor has membership of the LCA, and the RP has paid for a report which is of no real value. Worse still, the report and
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Figure 4: Another image from the risk assessor. In addition to the redundant branch pipes (see previous photo), an infrequently used washhand basin with equipment piled on top of it, and a ‘redundant sink’, were also missed.
recommendations have given the RP a false sense of security that these tanks are in good condition, when clearly they are not.
Importance of impartiality The issue of using a water hygiene company that provides risk assessment and remedial work services has been well documented in BS 8580-1:2019. Water quality – Risk assessments for Legionella control – Code of practice, where it is stated: ‘The risk assessor should be able to demonstrate impartiality and independence when carrying out Legionella risk assessments. The risk assessor or assessing organisation should not allow commercial, financial, or other pressures to compromise impartiality, and should be able to demonstrate valid reasons for any proposed course of action. It should be clear, for example, why a recommendation has been made to clean cold water storage tanks.’
Dirty utility area experience Another risk assessor we came across was working in a hospital’s dirty utility area, measuring the blended hot water temperature from a washhand basin, which he had designated as a sentinel point. He did not select an unblended sluice outlet located nearby. Without disclosing my position as the Trust AE
If contractor staff are all in-house trained, then you need to look at the business’s in-house certificates
44 Health Estate Journal August 2023
(Water), I asked why he was doing this, rather than measuring the inlet temperature to the associated TMV. He said he had been told to take the hot water temperature from an outlet. I asked if there were any other issues of note in the area, and was told ‘no’. He had failed to notice three redundant branch pipes under a sink (see Figure 3), an infrequently used washhand basin with equipment piled on top of it, and a redundant sink (Figure 4).
Assessment of contractors So, how do we assess the competence of such contractors? Good quality training is a good start on the road to competence, and certified training such as from City & Guilds or ILM may give you some assurance that training is adequate. Training is only the start of this journey, however; the operative must then gain experience through working with other experienced operatives, thus building up competence over time – by being corrected and allowed to slowly undertake more work on their own, until finally being deemed competent by their superior, and from this point on being allowed to work unsupervised, with only occasional checks made on the quality of their work. This should all be logged on a competency matrix, and available on request.
Contractor training What about in-house training? It has been a long-standing issue that water treatment specialists provide their own training for their operatives, either as additional support for accredited training, or quite often entirely in-house training.
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