Compliance


3. To prevent bathing and wastewater contaminating drinking water supplies, install the correct level of backflow protection.’3


Back-flow Bathing equipment in care homes is categorised as a fluid category 5 risk – a serious health hazard. To protect residents and staff the supplies to all tap and shower outlets must be protected by a backflow arrangement rated as providing fluid


Non-compliant appliances are still being marketed, sold, and installed


category 5 protection.4 An example of where back-flow can occur is when taps and shower handsets are dipped or left submerged in bathwater and the water supply pressure drops. This action causes a vacuum in the appliance’s


Case study: ensuring compliance in assisted bath installation The Local Authority, despite the


Reval was recently approached by a private client seeking to replace an assisted bath for her son. The previous appliance was removed due to its age and non-compliance with UK water by-laws. During a random inspection by the local water provider, it was found that compliance could not be provided by the manufacturer, necessitating the removal of the old system.


The compliance challenge Non-compliant assisted bathing systems and manufacturers are surprisingly common in the UK healthcare market. As of 30 May, only two manufacturers (including Reval) are listed as compliant on the Water Regs UK approved product and materials register. This implies that nearly 80 per cent of assisted bath manufacturers selling and installing products in the UK are non-compliant, making them unsuitable for connection to the mains water systems.


Client’s dilemma Our client requested our product specifications and compliance certification as per the 2024 Water Regs UK guidelines. Approval from the local water provider is required at least 10 days before installation to avoid serious practical and financial consequences. We provided the necessary compliance proof and a quote for our appliance. The client, concerned about compliance, asked us to verify the compliance of the other manufacturer and model. We found that neither the company nor the model was registered or certified under category 5 / BS 6920. We communicated this to the client and provided evidence from the Water Regs UK register.


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evidence, insisted that the non-compliant manufacturer assured them of their compliance, based on their past usage without issues. This stance placed our client in a difficult moral and legal position. After further discussion, the Local Authority agreed to part-fund our compliant appliance, although they disappointingly valued it at the same rate as the non-compliant option. Thankfully, the client chose to proceed with our product, ensuring long-term compliance and safety for her son.


This case is not unique in our


experience with local authority social care departments. Historically, assisted bathing compliance has not been well-publicised by regulators and water providers. There is also a lack of enforcement and awareness by organisations like Trading Standards, the Medicines and Healthcare products Regulatory Agency (MHRA), and CQC. Compliance with standards such as BS 6920 is legally required, but responsibility also falls on owners, operators, and those involved in the construction and specification of healthcare facilities to ensure compliance. In contrast, NHS Estates Departments


have stringent compliance controls, ensuring only approved appliances are used in NHS hospital facilities. This is likely due to the critical nature of care and the need to maintain high internal standards to protect those at greatest risk. The 2024 Water Regs UK guidelines


provide clear directions for owner- operators and community-based care providers. Enforcement of these guidelines is crucial to protect vulnerable individuals and ensure the safety of facilities.


pipework. The vacuum action will then back-syphon the bathwater along with any of the bathers’ pathogens, bacteria, soaps, and emollients transferred during bathing, into the building’s freshwater ring main. If safety devices are not installed, these pathogens can potentially find their way through an entire building plumbing system and can potentially be discharged anywhere in your building, such as a wash basin or a kitchen sink where food and drink is being prepared. This level of contamination risk also threatens and potentially extends to adjacent buildings connected to the same mains water supply, potentially causing downstream contamination and health and safety hazards to others. In the event an operator is found to be the source of the contamination, cost and fines can be imposed based on the level of contamination clean-up and impact to health and safety caused etc. The typical cost of a contaminated zone clean-up is likely to be considerable – not including the reputational damage. Non-compliance might also have potential insurance implications in respect to owners and operators found to be responsible for contamination caused by a non-compliant appliance.


To ensure peace of mind and compliance,


care providers should request evidence that bathing appliances are compliant and tested against all appropriate standards as previously highlighted. A possible and effective solution could be for the CQC to incorporate compliance via category 5 / BS 6920 certification into its inspection process.


There are three specific things you should bear in mind: n Understand the regulations and guidance. n Comply with the regulations. n Uphold your duty of care to residents and staff by being aware of the compliance.


Due to the inherent vulnerabilities in care home settings, the likelihood of contamination and infection outbreaks is increased. Those who are cared for should expect to be safe from exposure to infections. So how can that be achieved in an environment where multiple individuals may use the same bathing facilities? Those operating in healthcare premises


have a duty to comply with the regulations and to ensure that medical appliances are procured to assure the higher level of fluid category 5 backflow protection. Fluid category 5 represents a serious health


www.thecarehomeenvironment.com July 2024


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