WATER SYSTEM HYGIENE AND SAFETY


We have seen one-hour courses written by contractor staff with very limited competence. Often courses are not tested, which leaves candidates unenthusiastic, checking their phones, or looking out the window. We regularly see in-house certificates that any of us could knock up on a PC in 10 minutes. The main reason for this potentially


poor training is a) cost – such external training courses are expensive, and the operative is not working while attending such courses, so a substantial investment in the operative is required, and b) box ticking – to show that training has been provided.


In-house training should not be


dismissed out of hand; as previously stated, some specialist companies do have some very competent staff, but if you are willing to accept such training, you must ensure you are complying with the duty you have under L8 to ensure that the staff you are employing are competent.


Scrutinise ‘in-house’ certificates If contractor staff are all in-house trained, then you need to look at the business’s in-house certificates. It is not unusual to receive a PDF that incorporates the person’s name, date of the training, and the trainer’s name, or the MD’s name, and usually a list of Legionella-related headings such as ‘Cleaning and disinfection of CWSTs and systems’, ‘CWST inspections’, ‘TMV maintenance’, ‘Temperature monitoring’, and ‘Shower clean and disinfection etc’. In some cases these training courses have all been completed on the same day, which may indicate the quality of training provided. Take one of these headings – ‘TMV


maintenance’, and you might be shown an in-house certificate with a raft of other training listed, alongside the date, and the name of the trainer. This training could be a 15-minute ‘toolbox talk’ undertaken by an unqualified operative. Would you be satisfied with this certificate – indicating that this is the only training this operative has had on TMVs? What information is it providing you that gives you the confidence that this operative is competent to undertake this task?


Sufficient data to make a judgment call?


When reviewing in-house training you need a little more information to make any kind of judgment call. Remaining with TMVs, and what was the duration of the individual’s training – a day, half a day, or 30 minutes? Each timeframe gives you a different level of comfort. Who undertook the training, and what qualifications does this person possess to give such training? Again, the information provided gives you a different level of comfort. Was this training tested at the end of the course? Was this a practical test, including a strip-


‘‘


Training is only the start of this journey, however; the operative must then gain experience through working with other experienced operatives…


down and service of a valve which was cleaned, disinfected, and reassembled, or was the training simply via a PowerPoint presentation with a multiple choice question set? Or, in fact, was there no test at all, and did the trainer have to wake the operative at the end of the course to give them their certificate? The latter example may seem a bit flippant, but with the in-house certificate you receive, some of these eventualities are entirely possible. We would much sooner you asked these questions of the water treatment specialist, than answered them in court subsequently.


Competence takes time Here we are referring just to the necessary training; the required competence levels, are, however, only achieved over time. By physically undertaking the work and being corrected by an experienced, competent


Steve Mount


Steve Mount provides consultancy advice, risk assessments, auditing, and training, to a wide variety of clients, including NHS primary care Trusts, other healthcare organisations, and facilities management companies. He is a Fellow of IHEEM, an IHEEM-registered Authorising Engineer (Water), a member of the IHEEM Water Technical Platform, and a Clinical and Professional Advisor for the Care Quality Commission (CQC). Working for several NHS Trusts and healthcare organisations has given him experience and insight into the requirements for compliance of large establishments. He regularly delivers City & Guilds-accredited training, and lectures to a wide range of organisations, with the emphasis on Legionella awareness and compliance. He formed Steve Mount Associates in January 2006 following a 25- year career in microbiology and UKAS-accredited Legionella analysis. The company provides a range of professional Legionella management, training, and consultancy services, and is fully independent, with no links to any water treatment company or chemical supplier.


Harry Evans


Harry Evans BSc (Hons), MRICS, MRSPH, MIHEEM, MCABE, is an IHEEM-registered AE (W), chairman of the NHS Estates Training Advisory Group (TAG), and an Authorising Engineer (Water) for HDE Authorising Engineers. He is a chartered professional with over 40 years’ experience incorporating the design and maintenance of commercial, industrial, and healthcare premises. Over the years he has gained qualifications, expertise, and experience of a wide range of building and engineering services. He started his NHS career in 2000, initially in a Capital Design role at Salford Royal NHS Foundation Trust, before taking on the role of head of Operational Estates for Salford, a position he held for over 12 years. He was appointed as AE Water for Equans in 2015, and now divides his time between Equans and his own private consultancy practice, HDE Authorising Engineers, where he provides AE services to the NHS and other organisations throughout the UK.


August 2023 Health Estate Journal 45


person, the operative should receive a competency matrix. This should state that – after training – the operative has worked supervised, with their work corrected for a set number of weeks, before being upgraded to work unsupervised. At this point they should require only minimal checks to ensure they are not taking short cuts, or developing poor habits. Finally, the date that the operative was deemed competent to work on their own for external customers should be clearly stated.


It should be remembered that if the


contractors you use undertake inadequate works on your behalf, the liability will remain with you. The ACOP L8 states that ‘the duty-holder should take all reasonable steps to ensure the competence of those carrying out work who are not under their direct control’, so, our advice is: ‘be careful’.


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