WATER SYSTEM SAFETY
with, water – e.g. ice machines, water dispensers, vending machines, dialysis machines, and nebulisers. Risk assessments form the core of the
development and implementation of a Water Safety Plan (WSP), and should be undertaken in addition to the Legionella risk assessment where relevant. PA risk assessments are particularly applicable in healthcare premises, and especially in areas designated as ‘augmented care’, and/or those providing specialist services where there is exposure to water for treatment/diagnostics.
Pre-assessment actions Before the site visit, pre-assessment actions should be undertaken by the risk assessors, i.e.: n Appraisal of the WSP, supporting documentation, and gap analysis.
n Define the scope of the PA risk assessment.
n Appraisal of training records and competence.
n Appraisal of the maintenance, remedial actions, and testing records, for the water system.
n Appraisal of monitoring and inspection records (PA).
Key issues for WSP appraisal Assessors should review and appraise the WSP and supporting documentation, and carry out a gap analysis to check there are sufficient processes in place to minimise the risk associated with the individual hazards, e.g. Pseudomonas aeruginosa, non-tuberculous mycobacteria etc. The WSP appraisal should cover all the issues below: n Governance arrangements, so that the lines of responsibility, accountability, and communication, are in place and kept under review.
n Processes for ensuring that asset registers are kept up to date, and include data on all relevant systems, equipment, and associated plant, including equipment which might result in cross- contamination from wastewater as a result of backflow, e.g. from macerators and other fittings / equipment.
n A description of the correct operation and maintenance of systems, plant, and/or equipment, with any necessary precautions to minimise risk.
n Details of any start-up/shutdown procedures, plant and equipment rotation, disinfection, temperature control, and flushing requirements.
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The frequency of microbiological sampling, where there are high-risk patients, should be sufficient for trend analysis to establish evidence-based confidence that control measures remain effective.
n Processes for logging, risk assessments, and management plans, for any plant / equipment brought onto site by third parties which could pose an infection risk.
n Reference to general method statements; for example, standard operating procedures (SOPs)/risk assessment and method statements (RAMS) for tasks such as cleaning, disinfection, calibration, maintenance, and monitoring operations.
n Processes for any validation, monitoring, sampling, and tests on the systems, along with the required frequency, and the acceptable control parameters.
n Details on who is responsible (including lines of communication) for appropriately addressing defects or out- of-parameter results.
n Processes for prioritisation, identification, signing off, and logging of, corrective actions.
n Previous risk assessment findings and actions taken.
n Appropriate surveillance and information for users/visitors to minimise the risk from waterborne infections.
n Processes in place to verify WSG
There are many potential infection routes in healthcare settings, including directly from person to person, and indirect transmission from person to water system components, and then onwards to other people
26 Health Estate Journal June 2022
approval of the design, specification, installation, commissioning, handover, operation, and maintenance, of new systems and equipment, and suitable assignment and review of augmented care areas and high risk patients.
n Review of the governance, accountability, systems, equipment, and activities, covered by the Legionella risk assessment, to verify their applicability to the effective management of risks from other waterborne infections.
n Take account of all relevant microbial hazards (other than Legionella), all water uses, potential hazardous events, potential exposure modes, and the susceptibility of those who might be exposed.
n Consider specialised water uses to be accessed by different groups of users with different susceptibilities – for example hydrotherapy pools.
n The effectiveness of existing controls, and any actions needed to improve control for all relevant microbial hazards and users.
n An asset register which includes all assets which could pose a risk of waterborne infection, in addition to those identified in the Legionella risk assessment.
Verification of staff competence Verification of staff competence and effective risk assessments should be undertaken – including for Legionella and PA and other relevant hazards, and appropriate schemes of control and supporting programmes should be in place. Assessors should verify that the WSP defines or references the required processes so that Legionella risk assessments are undertaken in a competent and timely manner, in accordance with BS 8580-1, and these can be used as the basis of the PA risk assessment. The Legionella risk assessment should have identified any engineering defects affecting the system’s ability to deliver water at a temperature or biocide concentration that minimises legionellosis risk. If the RP/WSG are satisfied that the Legionella risk assessments are up to date and valid, these should be used as a starting point. If, however, a WSP and/or Legionella risk assessment is not in place, or there are unaddressed gaps identified in the WSP or previous risk assessments, assessors should advise the identified RP. The assessors should check the
accuracy of records and drawings – including monitoring and surveillance records – and verify that any remedial actions and control measures identified within the Legionella risk assessment have been implemented, and that there have been no significant changes since that assessment which could adversely affect water safety.
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