Record keeping is a key element of successful Legionella management and forms a specific part of the Approved Code of Practice & Guidance on regulations (L8): “Legionnaires’ disease: The control of Legionella bacteria in water systems” (paragraphs 70 to 74).
Your existing risk assessment should identify the systems susceptible to colonisation by Legionella bacteria that incorporate a potential means for creating and disseminating water droplets. However, your risk assessment alone will not ensure you have effective management systems in place to control these risks. Neither will a 3rd party log book containing record forms provide the whole solution. The requirements in L8 state:
“70 An assessment of the risk must be carried out and those appointed under paragraph 48 must record the significant findings and ensure appropriate records are kept. This should include any groups of employees identified as being particularly at risk and the steps taken to prevent or control risks. If the employer has less than five employees there is no statutory duty to write anything down, but it may be useful to keep a written record of what has been done.
71 Records should include details about:
(a) the appointed responsible person(s) for conducting the risk assessment, managing, and implementing the written scheme;
(b) any significant findings of the risk assessment;
(c) the written scheme and its implementation;
(d) details about the state of operation of the water system, ie in use/not in use;
(e) the results of any monitoring inspection, test or check carried out, and the dates.
72 These records should be retained throughout the period they are current and for at least two years afterwards. Retain records of any monitoring inspection, test or check carried out, and the dates, for at least five years.”
The water management systems we develop are based on demonstrating compliance. This is because unlike many other systems, we design it with you – not just provide it for you. As well as the operational controls it will reflect your policies, objectives, clear management responsibilities as well as the scheme of control and remedial actions (as needed). The following interlinked components will form the structure of your document:
- Responsibilities for implementing the policy defined for named individuals;
- Record of training and competence for responsible persons;
- Description of the water services present;
- Your existing legionellosis risk assessment;
- Written scheme to identify the measures required to control risk;
- Clear references to maintenance and water treatment contractor procedures;
- Emergency and out of parameter contingency procedures;
- Water management record system; and
- Water management archive system.
Once completed, you will have a comprehensive water management system that provides you with the tools to adequately control the Legionella risk in your water systems. As it is your system too, it provides the information needed for your contractors to work to rather than the other way around.