WATER MANAGEMENT
“The note on Page 53 states ‘If a permanently installed standby pump is considered to be essential, the control system should automatically change over operation every three hours’, and yet this is no longer mentioned in Part B. Part B, Page 9, section 2.2-2.3 states: ‘To ensure governance with regard to water safety, the Duty Holder will: appoint a Competent Person with sufficient authority and knowledge of the installation to help take the measures needed to comply with the law’, and yet it does not specifically reference HSE ACoP L8, which states that the Duty Holder must appoint a ‘Responsible Person’.
Careful consideration and interpretation
“There are many other areas that require careful consideration and interpretation in respect of pressure and expansion vessels, point-of-use filters, and thermostatic mixing taps – here D08 is silent on these devices. Then there is ‘the infrequently used outlet’. What is this? It is not described in the glossary of terms, and yet there is, by inference, a potential definition within Table 1 on page 48, which suggests that infrequently used equipment within a water system is an outlet which ‘is not used for a period equal to or greater than seven days’. Is this the definition used by your Water Safety Group and adopted into your Water Safety Plan?
“The recent publication of a
Memorandum of Understanding between the Care Quality Commission and the Health and Safety Executive sets out how the CQC and HSE will ensure that there is effective, coordinated, and comprehensive regulation of health and
n Risk assessment n Scheme of control n Cleaning and disinfection n Training and competence
Figure 1: Legionella outbreaks by attributed failing – 10 years to August 2011 (Courtesy of HSL data1
).
safety for patients, service-users, workers, and members of the public. Access to suitable training is key to understanding the challenges involved in managing the safety of water systems in healthcare buildings, the focus of the training provision being the required outcome – sufficient knowledge and understanding of the risks associated with water systems in healthcare environments. It should not simply be a ‘tick box’ exercise that provides nothing more than a training certificate at the cheapest price and within the shortest timeframe.”
Designated roles
HTM 04-01 does not provide clarity on designated roles for the management of safe water systems in healthcare
buildings, argues Mervyn Phipps. “HTM 00 provides guidance for establishing a suitable management structure, and also on training. HTM 04-01, meanwhile, provides detailed guidance on the requirements for training provision for all staff in respect of water hygiene and microbiological control, including the need for assessment following suitable training.”
Improving standards through competence training
There are ‘numerous sources of data illustrating common problems in the management, risk assessment, and competence, of healthcare organisations and management of water hygiene risks’, believes Alan Hambidge, Authorising Engineer and Eastwood Park trainer. He says: “The HSE has previously warned companies of the need to manage water hygiene in a robust and defensible fashion. This has resulted from a number of improvement notices and prosecutions in recent years. On 27 July 2012, the HSE issued an instruction to companies to improve the management of legionellosis risk, based on then recent research. The appointed individuals must understand all of the roles and responsibilities, and have the ability to judge if the approach taken by their organisation is ‘suitable and sufficient’ for the hazards and risks presented.
Common pitfalls
“Back in 2012,”Alan Hambidge continues, “the Health and Safety Laboratory (HSL) – an agency of the Health & Safety Executive (HSE) – published a report entitled Legionella outbreaks and HSE investigations; an analysis of contributory
August 2018 Health Estate Journal 61
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