WATER QUALITY AND SAFETY
Examples of a clean (left) and an unclean (right) cold water storge tank.
contain a risk rating system to allow for prioritisation of the risks and remedial action. When assigning a risk rating, individual water systems and individual levels of relative risk should be appropriately reflected within the final report.
‘Risk scoring systems’, or ‘risk algorithms’, are used to help understand the relative risk of the systems assessed, but they require care in use, as they can mask important issues. Risk evaluation is often not understood,
and rating systems are regularly not included in risk assessment reports. When they are, frequently they do not allow the reader to understand how the risk has been evaluated. The guidance is clear that a rating system should be based on the C.A.T.E.S. principles as documented in BS 8580-1; however, the difference in assessor knowledge and experience can have a huge effect, potentially resulting in varying risk interpretation.
Repeatability of the system For the implementation of a risk rating system to be of value, the repeatability of the system should be assured by clear guidance on the application of such a system to all risk assessors undertaking such evaluations, with each risk given a score. Many risk assessors have not used the guidance, and continue to use outdated risk scoring systems, not endorsed by current guidance, that may mask important issues. Many clients receive reports with risks identified without an explanation of why or how they have been rated. The report should clearly highlight the
status of any key risks identified (e.g., low, medium or high risk), and indicate: n the underlying cause/source of risk(s), e.g., a particular activity or process, or source of water.
n whether the risk can be eliminated, e.g. ‘Removal of the little-used shower and associated pipework and fittings in Room XX’.
40 Health Estate Journal February 2022
Auditor comments we have seen include: n The Executive Summary describes the building water system as a ‘low-medium’ risk. This is inappropriate, as each risk identified should be allocated a risk rating.
n The risk assessment companies do not adopt the BS 8558-1 guidance in practice, only ‘copying and pasting’ the relevant text into the RA’s documents.
n No risk rating system has been documented. The auditor would suggest that the assessor has scored Legionella risks on a ‘plucked out of the air’ basis.
n Risk ratings were inappropriate, and scored with no reference to standard risk scoring matrixes.
Risk assessment reporting This is often a prominent issue seen by auditors. We have seen reports of over 250 pages, when in fact the LRA covering a small site could have been documented in 20-30. It appears the risk assessor was trying to ‘blind the reader with science’, and referencing/cross- referencing a multitude of documents and texts. This left the auditor trying to understand the LRA ‘worn out’, while the RP who commissioned the report said it was unreadable. The importance of conciseness and clarity is recognised in BS 8580-1, which stipulates that the report should avoid the use of jargon or abbreviations not explained clearly, to enable it to be readily understood by the target users. The report should be concise, and
unnecessary repetition and/or the inclusion of superfluous content avoided
‘‘
– for example, issues that may be a health and safety risk, but are not relevant to risks posed by Legionella. LRAs should not involve the preparation of the written scheme of control, but should provide information critical to its preparation, improvement, and review. Many LRAs audited do, in fact, contain a written scheme of control. We also regularly see sizeable extracts cut and pasted from the ACOP L8, HSG 274, and HTM 04-01 which are often not necessary.
Don’t lose sight of the primary goal It should be remembered that the principal purpose of the report is to convey the findings of the assessment in an efficient, effective manner. It should be sufficiently detailed to give owners of the risk an appropriate understanding of the key issues and actions required to control risks from exposure to Legionella. Most importantly, the LRA should be clear and unambiguous in its findings and recommendations. Comments we have seen from auditors here include: n The document structure is too complex and lengthy, and hard to navigate.
n I have seen data returned in Excel spreadsheets that I cannot make head nor tail of.
n Risk assessors tend to quote sections of HSG and HTMs by ‘cut and paste’, rather than giving the site the bespoke information it needs.
n I find LRAs very large documents, with significant repetition, and very little bespoke advice – they quote the guidance, but don’t explain how it relates to the site.
n The document does not explain what a
Risk evaluation is often not understood, and rating systems are regularly not included in risk assessment reports. When they are, frequently they do not allow the reader to understand how the risk has been evaluated
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