Defining the responsible person who will take your legionella risk assessment should be the very first step that you take when carrying out this process. By carrying out a comprehensive risk assessment you will be able to understand your water system, establish legionella risks and define action that should be taken to prevent the spread of legionella bacteria.
The risk assessment should include:
- Management responsibilities, including the name of the competent person and a description of your system(s)
- Any potential risk sources
- Any controls currently in place to control risks
- Monitoring, inspection and maintenance procedures
- Records of result monitoring, inspection and checks carried out
- Review date
If not, further steps must be taken to manage the risks and limit the exposure of staff/those you are responsible for from potentially contaminated water.
Managing the Risk
A competent person or persons must be designated as being responsible for implementing compliance with health and safety regulations.
This person must have the necessary skills, knowledge and experience to manage health and safety, including implementing and managing control measures.
The competent person can either be yourself, one or more workers or can also be someone from outside the business (e.g. a health and safety contractor).
In areas where there is regular shift work, responsible people should always be on hand and know their role within the organisation.
Prevention and Controlling of a Risk
Your first step is to consider if you actually need the water system you’re using, or whether you could use a viable alternative. Such examples include replacing a wet cooling tower with a dry air-cooled system and steps should be taken to ensure that the growth of legionella and other types of bacteria is limited as far as is practicable.
Limiting the exposure of staff to Legionella-infected water is also essential, and steps can be taken to do so. To prevent and control legionella risks, duty holders and competent person(s) should:
- Ensure that the release of water spray is properly controlled
- Avoid water temperatures and conditions that favour the growth of bacteria
- Ensure that water can’t stagnate anywhere in the system by keeping pipe lengths short or by removing redundant pipework
- Avoid materials that might encourage the growth of legionella such as sludge, organic matter and other materials that encourage bacterial growth
- Keep the system clean and the water inside it clean
- Treat the water regularly to either kill legionella and other bacteria or limit their ability to grow
If during your risk assessment you define a risk that simply can’t be controlled, you should introduced controls that should limit the risk of legionella. You should introduce a course of action that will help you to control any risks from legionella by identifying:
- Your system, e.g. developing a written schematic
- Who is responsible for carrying out the assessment and managing its implementation
- The safe and correct operation of your system
- What control methods and other precautions you will be using
- What checks will be carried out to ensure risks are being managed and how often
Keeping Records
Keeping records about Legionella depends on the size of your company. If you have less than five employees, it isn’t necessary but is still recommended. If you have more than five, any significant findings and how they affect employees, as well as information on prevention and controlling risks must be recorded and reported to relevant regulatory bodies.
Records should indicate:
- The person or people responsible for conducting the risk assessment, managing and implementing the written scheme
- Any significant findings of the risk assessments
- The written control scheme and its implementation
- The results of any inspection, test or check carried out and the dates
Further information on the state of the operation of the system, and whether it is used/not used, must be stated. These records should be retained throughout the period in which they remain current and for at least two years after that period. The records kept in accordance with the last bullet point above must be kept for five years.