WATER QUALITY AND SAFETY


providers have made misleading claims, such as ‘Accredited by the LCA’, and/or try to sell ‘add- on’ services such as remote risk monitoring systems.


Confidence before the regulator The key is to be confident you can demonstrate the competence of your chosen assessors to the regulator; a few course certificates are not enough. If the assessor is not competent, then their assessment may not be ‘suitable or sufficient’. Consequently, it may be necessary to interview the prospective assessor, check their CV, verify any claims of courses completed, request documented evidence of experience, and review example LRAs they have undertaken to be sure they are competent. Should we, though, not have a standard set of competency requirements that must be obtained and evidenced, including a tested industry standard LRA course, that all assessors take before being deemed competent to operate?


A comprehensive evaluation The British Occupational Hygiene Society (BOHS) has recognised the issue of securing competent LRAs, and has an interest in developing all skills, knowledge, and competency for Legionella risk assessors working in the field. Currently the BOHS suite of Legionella courses, which can lead to the Certificate of Competence in Legionella, provides a comprehensive evaluation focussing on all aspects of Legionella and its control. Candidates need to demonstrate their experience and training, and submit reports detailing their technical knowledge, to include basic engineering and plumbing ability, which is assessed prior to an oral examination. This approach could be adapted to cater specifically for Legionella risk assessors. The current ACOP L8 paragraph 57 discusses levels of service to expect from service-providers. Would it not be a positive move for guidance such as L8, HSG 274, and HTM 04-01, to include reference to organisations who can offer an independent and impartial service to improve competence in the field?


You ‘get what you pay for’ It is also worth remembering that you usually ‘get what you pay for’. There are many companies offering very cheap risk assessments, but the quality of the assessment and subsequent report are likely to reflect the cost. While many healthcare provider organisations will face cost constraints, choosing low cost over quality is rarely beneficial. The price will often reflect the risk assessor’s expertise, and the time required to conduct the assessment and analyse the findings.


42 Health Estate Journal February 2022


Procuring risk assessments Most Legionella risk assessments are obtained via a tender process or recommendation. It is up to the Procurement team to produce robust detailed tenders which specify exactly what is required. This can be achieved by reading BS 8580-1, and creating your own specification for an LRA. Organisations stating that the LRA must be as described within BS 8580-1 have not understood the standard’s basic principles; it is a guidance document on how to develop a Legionella risk assessment, and cannot be used as specification. Those procuring risk assessment


services need to take advice from experts before selecting a competent risk assessor to ensure they can do a competent job on their behalf. Detail what you require


A typical ‘dead end’ – a length of pipe closed at one end, through which no water passes.


Investing in a low-cost risk assessment may mean receiving a substandard report, which may be unlikely to convince the enforcement agencies that the risks in your buildings have been identified and suitably assessed. This could leave you liable, and result in another assessment being completed before your compliance can be assured. Paying for expert advice, and securing


a competent service, can often be a lot cheaper in the long run, especially if the LRAs are deemed ‘unsuitable’ or ‘insufficient’. We have seen some larger service-providers reducing costs to secure work, which can often cut out smaller providers, who may provide a better quality assessment, as they have a lot more to lose in terms of reputation.


Steve Mount


Steve Mount provides consultancy advice, risk assessments, 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 of, and insight into, the requirements for compliance of large establishments. He established Immerse Training, which 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, ‘having no links to any water treatment company or chemical supplier’.


from the LRA, and request examples to ensure that their assessment is easy to read, easily comprehensible, and that you can act upon its recommendations. Tender documents should clearly state


what is expected from the LRA and the risk assessor. To summarise, LRAs are especially important to help protect vulnerable people and patients, and – going forward – we need to ensure that risk assessor competence is raised, maintained, and measured. Risk assessors need to read and


understand the HTM 04-01 and HSG274 guidance to better interpret BS 8580- 1. They need to produce valuable and reproduceable risk rating systems based on C.A.T.E.S principles, and remove confusing and unnecessary information. This should allow the construction of easily understandable, clear-cut, risk assessment reports.


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