HEALTHCARE WATER SYSTEMS
Priorities for water safety in private healthcare
Peter Gunn, a Senior consultant at the Water Hygiene Centre, discuses the priorities for those working in engineering and estate management and clinical roles in private sector healthcare settings whose role includes responsibility for keeping their facility’s water system in a safe and compliant condition. He focuses particularly on the key steps to minimise the chances of Legionella growth and proliferation – as set out in HSE and Department of Health and Social Care guidance.
Below: A sink and toilet that are clearly not being used for their intended purpose, in a room that appears to being used primarily for storage. The outlets shown would be classed as ‘infrequently used’, and – despite being difficult to access here – would thus require regular flushing to reduce the risk of Legionella.
Right: A tap with limescale, which in turn is an ideal breeding ground for Legionella.
The private or independent healthcare sector is largely made up of hospitals and clinics run independently of the NHS. These healthcare facilities are normally run by a commercial company, although some are also run by charities or other non-profit organisations. Private healthcare sites may also include mental healthcare facilities, rehabilitation centres, care homes, and many other types of site-specific facilities. Although Pseudomonas aeruginosa, Nontuberculous mycobacteria (NTM), and other waterborne pathogens continue to come to the fore, Legionnaires’ Disease and Legionellosis prevention must remain a key concern for private healthcare providers. As applies equally to all healthcare businesses, private
healthcare operators have a duty of care to protect their residents, staff, visitors, and anybody else who
may be affected by their day-to-day risk management undertakings, from foreseeable risks to their health, safety, and wellbeing. All healthcare estates are assessed against a set of legal requirements and governance standards – and the associated principles of health and safety are enshrined within the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and specifically Regulations 12[2][h] and 15 of the Act. Failure to comply with the aforementioned ‘Regulation’ or ‘Act’ is an offence, and as such the Care Quality Commission has ‘enforcement powers’ to ensure compliance with accepted standards. Such enforcement powers include: issuing time-defined warning notices, prosecution, and cancelling a provider’s registration to provide healthcare services – removing its ability to provide regulated activities.
Extensive guidance on offer Despite Legionella risks being ever-present for providers, extensive guidance is available. The Department of Health’s Health Technical Memorandum 04-01 sets out the standards for water safety within health estates by acknowledging within its three parts – A, B and C – the regulatory requirements of the Health and Social Care Act, as well as the role of the Health and Safety Executive (HSE) for the safe management of healthcare estates. There are many commercially run private healthcare sites, and the skills and competencies of staff within these varying sites may well be adequately specialised and relevant to ensure that good water hygiene management practices are implemented. Alternatively, staff may also have a more general managerial skillset, and be unlikely to possess the requisite knowledge in water system safety.
A checklist to provide assurance So, can we simply identify the measures within a checklist to provide assurance both individually at site level, and at a more strategic level? Regardless of the level of care or the standards to be applied, the key to managing Legionella risk is the implementation of the following five steps, as advocated under the HSE’s Approved Code of Practice (ACoP) L8: 1. Appoint a manager to be responsible for others; 2. Identify and assess sources of risk (i.e. carry out Legionella risk assessments];
3. Prepare a scheme to prevent or control risk (i.e. a Water Safety Plan);
4. Implement, manage, and monitor, the scheme of precautions;
42 Health Estate Journal May 2025
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