WATER QUALITY AND SAFETY


Safe water in healthcare premises 2016 documents do discuss risk assessments, but guidance on how to assess the risks from Legionella is limited.


BSRIA guidance BSRIA has produced two documents, Guidance and the standard specification for water services risk assessment (FMS 4/99) – which describes the standard specification for water services risk assessment, and Legionnaires’ Disease - Risk Assessment (BG 57/2015) – which provides a framework for a Legionella risk assessment to take account of standards and guidance documents, including the ACOP and associated HSG 274 guidance. The main guidance encapsulating the aforementioned statutes and guidance is provided by the British Standards Institution (BSI), the UK’s national standards body, which produces technical standards on a wide range of products and services, and supplies certification and standards-related services to businesses. The BS 8580-1:2019 Water quality – Risk assessments for Legionella control – Code of practice is a revised version of the now withdrawn BS 8580:2010 referenced in HSG274 and HTM 04-01 as the main ‘go to’ document for further information. As a code of practice, this British Standard takes the form of guidance and recommendations. It is not a specification (and clearly states that it cannot be used as one), and particular care should be taken to ensure that claims of compliance are not misleading. BS 8580-1 will not tell you how to carry out a Legionella risk assessment.


Justifying their course of action Any user claiming compliance with this British Standard is expected to be able to justify any course of action that deviates from its recommendations. Compliance with a British Standard cannot confer immunity from legal obligations. An LRA is a particularly important legal document, especially in healthcare, as it should form the basis of the organisation’s Legionella management, and provide bespoke recommendations that enable control of the risks of exposure to Legionella bacteria or reduce the risk of them occurring. IHEEM Water Technical Platform (WTP) members and registered Authorising Engineers (Water) review and audit healthcare LRAs regularly, and we have raised concerns about the suitability


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The BS 8580-1:2019 Water quality – Risk assessments for Legionella control – Code of practice is a revised version of the now withdrawn BS8580:2010 referenced in HSG274 and HTM 04-01.


(Permission to reproduce extracts from British Standards is granted by BSI Standards Limited (BSI). No other use of this material is permitted.)


and quality of many of the LRAs we observe. So, let us look at some key points from the guidance, and the related issues we find.


Competence of the risk assessor BS 8580-1 makes clear that the competence of the assessor is paramount, and should be matched to the complexity of the system and the risk being assessed. If the assessor is not competent, the assessment is unlikely to be ‘suitable or sufficient’. Firstly, there is no mandatory qualification to become a risk assessor; anyone can decide they are capable of performing the task. An assessment of competence in healthcare is usually the responsibility of the Water Safety Group (WSG), or the duty-holder via the Responsible Person (RP). Individuals commissioning risk assessments must establish the relevant competence of an assessor. If you employ someone to conduct a LRA on your behalf, you must be satisfied they can demonstrate their experience and competence in assessing the specific risks that may be faced by a healthcare population – but does this happen in practice?


The competence of the assessor is paramount, and should be matched to the complexity of the system and the risk being assessed. If the assessor is not competent, the assessment is unlikely to be ‘suitable or sufficient’


38 Health Estate Journal February 2022


Need for record-keeping If things go wrong, and the regulators come in, they will want to see these records. Records detailing competence should be assessed before employment and kept. Each assessor should provide this information, but many do not. Feedback from WTP members indicates that, on many occasions, poor, or a complete lack of competence, are evident. One said: “One risk assessor I checked had undertaken a two-day course five years ago, and offered no other training or competences.” Is this really adequate for a large, complex hospital? BS 8580-1 states that assessors should have their competence formally assessed, and there are organisations/ documents that require employees of service-providers to have undergone this via an internal process. IHEEM, as one of the UK’s professional engineering institutes, puts considerable store on the competence, expertise, and knowledge of those providing such specialist services, and has recently strengthened its Terms of Reference to reflect the importance it places on such professional expertise and wider good governance. As CEO, Pete Sellars, explained in an article in last August’s HEJ, one of the major drivers for this strengthening of IHEEM’s Terms of Reference – alongside the need to meet licencing requirements set out by the Engineering Council UK in its 2019 review – was ‘to create confidence across the system that all IHEEM activity is underpinned by robust governance and assurance, and operates within agreed standards and by appropriate codes of conduct’. Those harnessing the expertise of, for example, IHEEM-registered AEs, or the Institute’s Technical Platforms, can thus be confident that the individuals concerned possess the appropriate levels of competence, qualifications, and experience, to provide the specialist guidance, advice, and input healthcare provider organisations require to ensure that their operations are compliant.


Required levels of competence UKAS-accredited inspection bodies undertaking Legionella risk assessment activities should apply the specifications itemised in the UKAS RG 9 Sept 2017 document, Accreditation of Bodies Undertaking Legionella Risk Assessment Activities, which details the levels of competence required, and how to demonstrate competence. Monitoring the performance of the risk assessors is conducted internally by the 13 accredited organisations, which are audited by UKAS. The concerns raised regarding


competency, and the consequences of lack of it, have been highlighted in audit comments from the WTP members and registered Authorising Engineers (Water), and include:


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