WATER QUALITY AND SAFETY


n Incorrect temperature references have been made for healthcare premises.


n Water heater temperature ranges stated are incorrect.


n Clarification/training is required to distinguish between deadlegs and dead ends.


n Identification and definition of sentinel outlets was confusing and possibly incorrect.


n Inaccurate statements have been made which do not concur with documented guidance.


n Several recommendations made will not control the proliferation of Legionella bacteria.


n The document quotes incorrect flushing and temperature requirements.


Risk assessor independence BS 8580-1 states that the risk assessor should be able to demonstrate impartiality and independence when carrying out Legionella risk assessments. We have seen misleading statements stating that cold water storage tanks (CWSTs) (clean or unclean) should be cleaned and disinfected every year, contrary to guidance, by the same company that conducted the assessment – a clear conflict of interest. Some risk assessors also recommend frequent TVC sampling and analysis when it is not required – again, contrary to guidance. Comments and issues we have seen


from auditors include: n Risks are often overstated to create fear or promote additional services from the assessment organisation.


n Trying to sell ‘extras’ during a LRA. n Too many risk assessors are still undertaking LRAs and picking up the water treatment works – a clear conflict of interest.


n Most risk assessors still want the CWST cleaned annually. Many risk assessors work for companies


who provide monitoring and remedial work services. How can they credibly demonstrate impartiality? If you use your maintenance or water treatment contractor to conduct the risk assessment,


you will be asking the people to whom you have given specific control tasks to report formally on their effectiveness.


Desktop appraisal of the current scheme of control BS 8580-1 states that the risk assessor should undertake a detailed appraisal and audit of the scheme and report on its adequacy. These checks are detailed in: n 6.2: Appraisal of the current scheme of control.


n 6.2.2: Appraisal of the maintenance and testing records within the scheme of control.


n 6.2.3: Appraisal of management responsibilities.


n 6.2.4: Appraisal of training records and competence checks of site and service- provider personnel.


n 6.2.5: Appraisal of the safe operation of the systems.


n 6.2.6: Appraisal of the monitoring and inspection records. These appraisals comprise a total of 32 checks to be made. This is unworkable when assessing large sites. A competent appraisal of documentation does not often occur, and, when it does, usually a ‘tick box’ exercise is conducted – which provides no real value. Performing these checks is important, but should this be the role of the assessor, who may require audit training?


Site survey – Measurements BS 8580-1 states that measurements routinely taken on site, such as temperature, should be checked for accuracy and reliability, and validated. Measurements of various types (e.g., temperature, biocide, pH) therefore should usually be undertaken and evidenced by the assessor as part of the risk assessment. Many find this statement vague and confusing. Risk assessors will interpret it in different ways; some take all temperatures, others some, others few. Should we, in fact, temperature test all hot and cold water outlets? This is unclear until we look at the following extracts from BS 8580-1:


n 3.10. Hazard – Water conditions with the potential to cause adverse health or safety-related effects.


n 8. Evaluation of the risk – Where the risk assessor identifies a hazardous situation, they should record each situation and assess the risk arising from it.


n 8.1 General – Each risk should be analysed appropriately, considering its consequences and the likelihood of them arising, to derive a measure of the severity, and set priorities for action. Note 3: if the system contains water at a temperature greater than 20 °C, and less than 50 °C, and an aerosol can be generated under any foreseeable circumstance, then it is a system at risk of causing legionellosis.


n Annex B5 – The commonly accepted method to control Legionella in hot and cold water systems is by temperature.


Temperature assess all hazards From the above we see water conditions are a hazard presenting a risk, and each risk should be analysed. Temperature is used to measure the risk, so we should temperature assess all hazards (hot and cold water outlets, cisterns, heaters etc). Comments on this topic we have seen


from auditors include: n No hot and cold water outlets detailed in the asset list have been temperature tested.


n From the information detailed in the asset list, the auditor is confident that over 350 temperatures from hot and cold water outlets have not been recorded. All hot and cold water outlet temperatures should be recorded and assessed.


n Only 21% of the 418 available hot and cold water outlets were temperature tested.


n The site outlet register provided very poor coverage (22%) of available temperature assessment from hazards (water outlets) identified.


Evaluation of the risk – risk rating systems Legionella risk assessments should


February 2022 Health Estate Journal 39


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