WATER MANAGEMENT factors (HEX/12/07).1 The HSE’s Legionella
Committee in September 2011 gave the HSL the task of gathering and analysing the data from outbreaks of Legionnaires’ disease in the UK during the 10-year period up-to August 2011. The aim was to identify trends and relationships in the data. This data is very useful, as it indicates important common failures, and illustrates some of the key issues with which Responsible Persons must ensure compliance.
“The HSL used a range of information sources, including HSE records, outbreak committee reports, and press releases from HSE and others, Health Protection Agency and other disease reporting data, and national and local news reports. The review provides a broad general picture of outbreaks in the last 10 years, and principal trends.
Common failings
“Examination of the data presented by the HSL report on outbreaks by failing to which they are attributed (Fig. 1) illustrates the importance of the following – as suggested in earlier text: n Scheme of control – 63% of outbreaks were attributed to inadequate scheme of control. The appointed individuals must have the ability to adequately audit and review their own scheme of control, and establish its scope and suitability.
n Risk assessment – 25% of outbreaks were attributed to inadequate water hygiene risk assessments.
n Training and competence – 8% of outbreaks were attributed to inadequate training and competence directly.
“If we look at enforcement notices issued by failing to which they are attributed (Fig. 2) form the same HSL data, a similar picture appears: n Scheme of control – 59% of enforcement notices were attributed to inadequate scheme of control. The appointed individuals must have the ability to adequately audit
Suitable schematics AE/IA appointed Suitable training
Suitable written scheme
Suitable water safety risk assessment Water safety policy
Responsible person appointed 0 20 40 60 Figure 3: Water hygiene compliance audit summary findings, 2007-2017. 62 Health Estate Journal August 2018
that comply fully with several key requirements from the audit questions (the audit employed was in the form of a standard set of criteria in a spreadsheet, based on the HSE model audit). The audits covered all elements of water management, but the data on which Figure 3 is based indicates the percentage of healthcare organisations in the audit sample that comply with several fundamental competence elements in the audit. The following trends were observed in the audited sample: n The formal appointment of all relevant designated persons was lacking in approximately 30%.
n Risk assessment n Scheme of control n Responsible person n Cleaning and disinfection n Training and competence
Figure 2: Legionella enforcement cases by attributed failing – 10 years to August 2011 (Courtesy of HSL data1
).
and review their own scheme of control and establish its scope and suitability.
n Risk assessment – 31% of enforcement notices identified in the data were attributed to inadequate water hygiene risk assessments.
n Training and competence and Responsible Person (combined) – These two sectors combined account for 9% of enforcement notices identified in the data.
Importance of adequate training “This data clearly illustrates the need for appointed staff to receive adequate training,” says Alan Hambidge. “The appointed individuals must be able to evaluate their organisation’s level of compliance, know how and when to seek specialist assistance, and be able to provide assurance evidence to the Board. Having been involved in examining data from 20 water safety audits during a 10-year period (2007-2017), I obtained similar data. Figure 3 summarises the proportion of organisations audited
47 87 67 47 67 60 73 80 Organisations in sample compliant (%) 100
n Suitable water safety risk assessments were lacking in over 33%.
n AEs/IAs were not appointed in approximately 13%.
n A suitable written scheme was absent in over 53%.
n Suitable schematics were lacking in over 50%.
Focused training
“The need to control the hazards and risks associated with water hygiene is critical. To be able to achieve such control it is essential that trained competent staff are appointed to the roles identified in L8, HSG274, HTM 04-01, and HTM 00. These individuals must understand fully their roles and responsibilities. It is important that staff members possess the ability to clearly identify and discharge their roles and responsibilities. Any training should be focused on specific roles and responsibilities and tasks. “To this end Eastwood Park has reviewed and revised its suite of water hygiene training courses, and has developed courses focused on the particular roles and responsibilities of the principal appointed individuals. The courses have an enhanced interactive element, with numerous course activities. The courses aim to enable estates staff to gain an understanding of the importance of managing water hygiene-related risks, their roles and responsibility and potential liabilities, and the use of important techniques such as development of an adequate risk assessment, risk minimisation schemes, monitoring, and audit, in order to achieve compliance.” Eastwood Park is an accredited City & Guilds training centre, and all training is delivered to the specified City and Guilds-accredited standards. Residential and day courses can be delivered, along with delivery on hospital or ‘agreed suitable sites’.
Reference 1 Legionella outbreaks and HSE investigations; an analysis of contributory factors (HEX/12/07). Health & Safety Laboratory, July 2017 [
www.tinyurl.com/989hc5t].
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