WATER SYSTEM SAFETY
healthcare settings. Annex B (informative) provides an
example of risk assessment pre-survey preparation by detailing a 15-point checklist in Table B.1 to indicate typical information which might be expected and of use. This will provide the risk assessor with some base information on equipment, processes, and procedures that utilise water within each department under assessment. Any information gathered can be reinforced or clarified with observations, risk ratings, recommendations, and review dates, during the site survey. Annex C (informative) gives an example of risk assessment for healthcare premises, covering: 1: General overview – Patients; 2: General overview – Clinical surveillance; 3: Equipment risk; 4: Equipment risk – Water dispensers/mobile handwashing stations; 5: Equipment risk – Sensory tubes; 6: Equipment risk – Assisted baths, foot baths, birthing pools, wash and dry toilets (in addition to the assessment in Section 3.0 of the table); 7: Specialist equipment risk; 8: Cleaning equipment risk; 9: Kitchen equipment risk; 10: Staff on-call and changing rooms, parent craft rooms, visitor accommodation, and 11: Clean and dirty preparation rooms. Risk rating systems, if used, should
follow the general principles advocated in BS 8580-1, i.e. CATES principles. For the implementation of a risk rating system to be of value, its repeatability should be assured via clear guidance on its application in all circumstances where risk assessments are undertaken. The standard provides some useful explanatory information, and some example formats for risk scoring purposes Risk assessment reporting, and review
of an existing risk assessment report, should be done in accordance with BS 8580-1, and reports appraised by the RP/ WSG to verify their fitness for purpose, and that recommendations are prioritised and implemented to verify that all risks are kept As Low As Reasonably Practicable (ALARP).
Summary The Cambridge dictionary defines a code of practice as ‘a set of standards agreed on by a group of people who do a particular job’. I have concerns that the ‘group of people who do a particular job’ largely comprises very knowledgeable people who know and understand the subject matter, but don’t necessarily understand the issues
‘‘
An old tap showing dried biofilm.
and pressures faced by those in the field actually performing risk assessments. With the level of risk assessor competence we see in the field, and the requirement for healthcare staff to gain the necessary competence to carry out the onerous tasks detailed in the standard, I don’t think effective management in this area is likely. In non-healthcare environments, I think this will be very unlikely. Many risk assessors may struggle to carry out the tasks recommended, such as desktop appraisals and the numerous checks required. Almost every day we see the NHS on the news struggling to cope with a whole range of issues required of the service, and the gathering, training, appointment, and retention of competent, already busy personnel, to act as a multidisciplinary team may also be challenging. We must also not forget that risk assessment and management of Pseudomonas is a live entity which requires regular review.
Further training To effectively manage the recommendations and guidance within BS 8580-2 will require a team of competent individuals who may need further training outside of their normal remit to improve/expand their skills and
As part of the site survey, assessors should speak to management and staff to determine whether the organisation’s management culture and work practices are adding to, or reducing, the risk
competencies. From experience, on a practical level there are several issues which need addressing, including: n Cleaning, disinfection, or replacement/ removal of flow straighteners.
n Poor use and siting of clinical washhand basins.
n Excessive use of TMVs where they may not be appropriate.
n Cross-contamination from splashing. n Correct timing and sampling of samples (notably pre-flush).
n Correct sample labelling, storage, and delivery to the laboratory.
Legal requirements and governance standards It should be remembered that the quality and fitness for purpose of the healthcare estate is assessed against a set of legal requirements and governance standards. Adhering to guidance documents will be considered as evidence towards compliance with these. The use of the guidance and recommendations outlined in BS 8580-2 is not legally binding, and should be used to supplement legal requirements and governance standards. BS 8580-2 states that risk assessments in healthcare premises are to be undertaken as recommended within national guidance within healthcare settings (HTM 04-01 Part C), and where clinical surveillance and/or the WSG indicate a need. HSG274 Part 2 refers to the HTM 04-
01 Part C guidance when it states ‘the addendum focuses on specific additional measures to control or minimise the risk of Pseudomonas aeruginosa in augmented care units, but it also has relevance to other waterborne pathogens,
June 2022 Health Estate Journal 29
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