WATER SYSTEM SAFETY ‘‘


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


including Legionella. While not statutory under health and safety legislation, the formation of a WSG, and implementation of a WSP, complement the requirements in the Approved Code of Practice on Legionnaires’ disease for the control of Legionella bacteria in water systems for an adequate assessment of risk, and the formulation and implementation of an effective written control scheme to minimise the risks from exposure to legionellosis. This should be applied proportionately depending on the setting’.


Not for quoting as a specification As a code of practice, BS 8580-2 takes the form of guidance and recommendations, but should not be quoted as if it were a specification, with particular care needed to ensure that claims of compliance are not misleading. Any user claiming compliance with the British Standard is expected to be able to justify any action that deviates from the recommendations. This information is useful to note. However, BS 8580-2 and HTM 04-01 give recommendations and guidance on what to consider in risk assessments, but do not tell those concerned how to conduct them. The result is many risk assessors – with a variety of experience, knowledge, and competency – focusing on areas that they can manage sufficiently, in turn frequently resulting in a range of risk assessment reports which differ in content and quality. It would be great if risk assessor competency was good across the industry, but I would suggest this is not the case.


A ‘reworded’ risk assessment Unless the risk assessor is fully ‘vetted’, chosen carefully, and fully supported by the correct members of the WSG, what you are likely to receive is a re-worded Legionella risk assessment with many of the retrograde contamination routes of Pseudomonas aeruginosa overlooked or missed. Many PA risk assessments are nothing more than expanded Legionella risk assessments, when PA risk assessments need to be so much broader. If this risk assessment is left to Estates and Facilities, it is highly likely to be totally ineffective; to ensure a good outcome, the WSG Infection Control team needs to take control and ensure members are fully involved in every aspect. BS 8580-2 references BS 8580-1 and


BS 8680 on several occasions, and producing a PA report may be challenging if these documents have not been studied,


30 Health Estate Journal June 2022


understood, and used to produce a PA risk assessment and WSP respectively.


The COSHH regulations Finally, the Control of Substances Hazardous to Health Regulations 2002 refer to an ‘approved classification of a biological agent’, which refers to the classification of that agent approved by the Health and Safety Executive (HSE). The Approved List of biological agents is approved by HSE for that purpose. The Advisory Committee on Dangerous


Pathogens (ACDP) has terms of reference, which are: ‘To provide as requested independent scientific advice to the Health and Safety Executive, and to Ministers through the Department of Health, on all aspects of hazards and risks to workers and others from exposure to pathogens’. ACDP prepares the approved list and advises HSE and Ministers at the Department of Health and Social Care on all aspects of hazards and risks to workers and others from exposure to pathogens. The latest update of the approved list came into effect on 12 July 2021. The classifications in the approved list


assign each biological agent listed to a hazard group according to its level of risk of infection to humans, where Hazard Group 1 agents are not considered to pose a risk to human health, and Hazard Group 4 agents present the greatest risk. Legionella pneumophila and Pseudomonas aeruginosa are both classed as Hazard Group 2 organisms which can cause human disease, and may be a hazard to employees; they are unlikely to spread to the community, and there is usually effective prophylaxis or treatment available.


Associated with buildings’ water systems Both organisms are found in the healthcare environment, are associated with buildings’ water systems, can be transmitted in water and or via aerosols, and cause nosocomial infections, which has been well documented, with many papers describing Pseudomonas infections as being more prevalent. Let’s not forget that other waterborne pathogens are classed in Hazard Group 2; these include Burkholderia cepacian, Elizabethkingia meningoseptica, Klebsiella pneumoniae, and Mycobacterium avium, and these organisms are known waterborne microbial hazards within healthcare. Legionella has an associated HSE


Approved Code of Practice (ACOP) and guidance (L8 and HSG274), so why haven’t the ACDP and HSE produced an ACOP for Pseudomonas aeruginosa and other waterborne pathogens (see text box, page 28)? Having worked in the healthcare field for over 15 years as a risk assessor, trainer, and IHEEM-registered Authorising Engineer (Water), my experience tells me that the BS 8580-2 document is a great theoretical document, but that in practice, incorporating its recommendations within a busy and pressured healthcare environment will be extremely challenging if one considers the associated competency, time, management, and costs.


Steve Mount


Steve Mount BSc (Hons), CBiol, MRSB, FIHEEM, MWMSoc, provides consultancy advice, risk assessments, and training, to clients including NHS primary care Trusts, other healthcare organisations, and FM 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 compliance requirements 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’.


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