Director of Market Development, Assurity Consulting
4th June 2020
In the national press (for example: Independent 19th May 2020, Daily Express 19th May 2020, The Mirror 20th May 2020 and The Times 22nd May 2020), Legionella has been highlighted as an issue with “potentially deadly outbreaks of Legionnaires’ disease are expected after lockdown,”. As a result, advice from a range of organisations has been to focus on disinfection as the course of action to take.
Both however do our industry a significant disservice because:
- Many of the facilities and heath and safety professionals we are working with were not only reviewing and managing their premises responsibly during lockdown, but planning for what re-occupation would look like long before the middle of May 2020; and
- For those who have been responsibly managing their water systems, disinfection is an unnecessary and expensive action, where they are already demonstrating compliance and control.
Of course, there will be those who haven’t considered the risks, either during or post lockdown, they will be in a different situation, similarly with all areas of health, safety and environmental management. Taking the guidance from the two major enforcement bodies in the UK, the Health and Safety Executive (HSE) and local authorities through the Chartered Institute of Environmental Health (CIEH).
The HSE are reminding us that:
“Employers, the self-employed and people in control of premises, such as landlords, have a duty to protect people by identifying and controlling risks associated with legionella. If your building was closed or has reduced occupancy during the coronavirus (COVID-19) outbreak, water system stagnation can occur due to lack of use, increasing the risks of Legionnaires’ disease.”
They also, as we have been doing for some time now, remind dutyholders to:
- “Review risk assessments and controls;
- Maintain the appropriate measures to prevent Legionella growth if the water system is still used regularly;
- Manage the Legionella risks when you:
- Reinstate a water system or start using it again;
- Restart evaporative cooling systems.”
While, unfortunately a lot of advice and guidance from others has had cleaning and disinfection as almost a default position.
The Chartered Institute of Environmental Health in their document “Legionnaires’ disease: lockdown risks and reopening safety”, under the section “Advice for reopening” identify:
“If you have already reviewed your risk assessment and implemented additional control measures, then it is unlikely you will need to take any further steps prior to reopening. A building is more likely to be safe to reopen without additional measures if:
- Flushing of the water systems has been undertaken weekly;
- Water temperatures at outlets have been checked and are consistently in line with the recommendations in HSG274 Part 2 – The Control of Legionella Bacteria in Hot and Cold Water Systems; and
- Any microbiological sampling undertaken over the course of the lockdown indicates no significant change in the total viable count (TVC) and Legionella bacteria samples have returned as not detected or satisfactory.
Note – there is no legal requirement to undertake microbiological sampling, but where it has been undertaken then it may provide assurance and confirmation that control measures have been effective.
Where no additional action has been taken, or you are concerned about the effectiveness of controls implemented, you must take reasonable steps to ensure the safety of the water system prior to reopening. It is foreseeable that some increase in bacterial levels will have occurred. Such water systems should not simply be put straight back into use and a plan should be formulated to allow safe start-up prior to reopening the building.
Any plan should consider the competency and health and safety of individuals carrying out the work. The hazards from Legionella bacteria will likely be greater than expected under normal conditions so measures such as limiting the production of water droplets (aerosol), minimising exposure to those droplets and even use of respiratory protective equipment should be considered.
Where you have concerns, for example if you have previously experienced problems with Legionella in your water system, external advice should be sought from a competent person who may be able to assist remotely or through attendance on site.”
The section goes on to look at what the “Additional steps to take prior to reopening” could include.
We are already seeing how effective many of our customers have been in their ongoing compliance management including Legionella, after all it is what would be expected from workplace management professionals.
You can view the HSE guidance here
You can view the CIEH guidance here