This white paper outlines:
1. Risk assessment and schemes of control
Legionella risk assessments are fundamental to the success of your wider water management system too. While Legionella risk assessments identify and evaluate potential hazards and the particular means by which exposure to the bacteria can be prevented or controlled, your written scheme details the procedures and actions that will be implemented to control and mitigate risk – where prevention is not practical. The risks identified during the Legionella risk assessment provide the backbone of the written scheme of control to demonstrate that the water system will be managed, monitored, and maintained effectively to make sure proactive and suitable Legionella control.
The written scheme will dictate the roles and responsibilities of Legionella management and the implementation of the control measures. For example, the statutory duty holder holds the legal responsibilities to make sure that Legionella control is managed effectively, working
with the appointed and deputy responsible people and those tasked with delivering the controls to implement your written scheme.
Emergency contingency procedures should also be produced to clearly detail the proceedings for out of parameter results or the isolation of Legionella from any relevant system, including follow up actions and remedials to be taken. Recording such information acts as demonstrable evidence that control has been regained of the water system, which is vital to for traceability to illustrate legal compliance keeps your management visible and reduces the likelihood of outbreaks occurring.
2. Nuancing your management
In recent EHO inspections, there has been an increasing trend in scrutinising how automated systems are captured in the written schemes. Assets such as bleed solenoids, automated flushing, pump systems, and BMS run systems are extremely useful in increasing operational efficiency and control. However, when the automated systems experience a fault, it is vital to have a method of identifying these faults before they give rise to issues. Capturing manual checks of the automated systems in the written scheme demonstrates robust control of the system without relying solely on the BMS operation to identify faults, or not, as the case may be.
Written schemes of control are a key component in demonstrating compliance with Approved Code of Practice L8 (ACoP L8) and the supporting technical guidance within the HSG274 series of documents. Having a comprehensive and detailed Legionella risk assessment is crucial to capturing all areas of the water systems to be covered by your written scheme and mitigating potential risks as far as reasonably practicable. Assurity Consulting’s Legionella risk assessments are ‘suitable and sufficient’ as determined by our Primary Authority Partnership, an Assured Advice Scheme run through the Office for Product Safety and Standards (OPSS).
The relevant assets captured during the Legionella risk assessments feed into the written scheme of control to determine maintenance and monitoring regimes and frequencies. Our Legionella risk assessments also include schematic diagrams of the hot and cold water systems, as is required for a scheme of control outlined in BS8580 -1:2019 Water quality - Risk assessments for Legionella control - Code of Practice (BS8580-1:2019) - for which we also hold accreditation through UKAS.
Once a suitable written scheme has been established, evidence of implementation is needed to demonstrate that the necessary requirements for Legionella control have been fulfilled. Diligent record keeping using logbooks or online systems acts as evidence of implementation of the written scheme, demonstrating compliance with the requirements of Legionella control legislation. Records that are organised and easily interpreted are critical to show that the required responsibilities have been satisfied by the statutory dutyholders and appointed responsible people during inspections from Environmental Health Officers (EHOs) or indeed the Health and Safety Executive (HSE).
3. It’s what you record and the way you record it
The single biggest issue we find with Legionella management documentation however is its visibility. All too often it too infrequently reviewed or too difficult to see a clear picture of performance – good, bad or indifferent. This in turn creates risk as duty holders are either reacting to old/historic events after the fact, or worst case, not reacting at all. So how can this be changed without a much greater investment of time and resources, especially for large portfolios of buildings?
Our new Assurity Plus 2.0 Water Management software works with our Legionella risk assessments to produce a cohesive online management tool covering all assets, corresponding tasks, jobs, and equipment, chemicals, training, management information and documents. By importing the asset register from the Legionella risk assessment, process mapping, task allocation, responsibilities and activity frequencies are all produced, along with follow up and reactive tasks procedures. A site-specific written scheme with everything in one place and easily accessible.
In addition, user-specific jobs - with corresponding equipment and chemicals - are created, and associated calibration certificates and COSHH risk assessments can be uploaded too. Your records have a required retention period of at least 2 years for the management documents, and 5 years for monitoring records. These are your evidence of proactive management or, if required, in the case of enforcement investigations or civil claims.
With often, hundreds, if not thousands of pieces of data being gathered for each of your buildings, it can quickly become overwhelming with physical logbooks and paper records building up. The Assurity Plus 2.0 Water Management software helps to avoid reams of paper and physical storage requirements, with all records kept online in organised and easily accessible formats.
BS8580-1:2019 states that “risk assessment is an ongoing process”, and should be regularly reviewed in anticipation of, rather than in response to changes. Demonstrable data from maintenance and monitoring records can be used by responsible persons to identify trends in water system microbiological and functional activity, providing key insights to allow for the anticipation of changes in the system. Using the data input from your records, the Assurity Plus 2.0 Water Management software transforms this into clear, actionable insights to support your overall management and compliance performance.
Data is compiled across the tasks, jobs, assets, and users to shed light on specific risks or understand the overall performance of a property, portfolio, or user group. With paper copy records, documentation can often go long periods of time without full review. When responsible people manage multiple properties over large portfolios, the physical location of the records can make review difficult.
Held online, results can be interrogated and performance monitored by responsible people or third-party contractors, quickly and from the same location, making management reviews much more convenient and accurate. By incorporating benchmarking, trend analysis, and predictive patterns, the Assurity Plus 2.0 Water Management software helps to proactively anticipate developing risks before issues materialise. Reports can be customised to the tailored requirements needed for operational teams, senior management, board reporting, or audit preparation. Notifications appear to indicate tasks or documents that are due or close to expiration, or review, to ensure that the approach to management is proactive and efficient, rather that reactive.
In summary, 21st century compliance needs a 21st century solution and for your water management, Assurity Consulting has the answer.
Assurity Consulting is the UK’s leading independent consultancy specialising in workplace health, safety and environmental solutions. As your partner in compliance management you will reap the benefit of our more than 40 years’ experience of helping customers across a range of different sectors – manage their compliance responsibilities as effectively as possible. If you need any help with your health, safety or environmental compliance, or if you would like more information on the services Assurity Consulting offer, please get in touch.