Without an effective written scheme of control no water system can be claimed to be under effective control.
The written scheme of control forms an essential risk management document that should be developed as a practical tool to be used by all stakeholders involved in the legionella control process.
The written scheme is separate to the legionella risk assessment and is a legal requirement identified by the Health & Safety Executive in their Approved Code of Practice and guidance ACOP L8 “Legionnaires’ disease. The control of legionella bacteria in water systems”.
The HSE advises, If you are an employer, or someone in control of premises, including landlords, you must understand the health risks associated with legionella. The following legislation outline your responsibilities
- Health and Safety at Work etc Act 1974
- The Management of Health and Safety at Work Regulations
- Control of Substances Hazardous to Health Regulations 2002
- The Approved Code of Practice: Legionnaires’ disease: The control of Legionella bacteria in water systems (L8)
As an employer, or a person in control of the premises, you are responsible for health and safety and need to take the right precautions to reduce the risks of exposure to legionella. You must understand how to:
- identify and assess sources of risk
- manage any risks
- prevent or control any risks
- keep and maintain the correct records
- carry out any other duties you may have
Identify and assess sources of risk
Carrying out a risk assessment is your responsibility. You may be competent to carry out the assessment yourself but, if not, you should call on help and advice from either within your own organisation or from outside sources, e.g. consultancies.
You or the person responsible for managing risks, need to understand your water systems, the equipment associated with the system such as pumps, heat exchangers, showers etc, and its constituent parts. You should also Identify whether they are likely to create a risk from exposure to legionella.
Managing the risk
As an employer, or person in control of premises, you must appoint someone competent to help you meet your health and safety duties and to take responsibility for controlling any identified risk from exposure to legionella bacteria.
If you decide to employ contractors to carry out water treatment or other work, it is still the responsibility of the competent person to ensure that the treatment is carried out to the required standards.
Preventing or controlling the risk
The key point is to design, maintain and operate your water services under conditions that prevent or adequately control the growth and multiplication of legionella.
If you identify a risk that you are unable to prevent, you must introduce a course of action ie a written control scheme, that will help you to manage the risk from legionella by implementing effective control measures, by describing:
- your system, e.g. develop a schematic diagram
- 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, and how often will they be carried out, to ensure the controls remain effective
Keeping records
If you have five or more employees you have to record any significant findings, including those identified as being particularly at risk and the steps taken to prevent or control risks. Records should include details of the:
a. person or persons responsible for conducting the risk assessment, managing, and implementing the written scheme
b. significant findings of the risk assessment
c. written control scheme and details of its implementation
d. details of the state of operation of the system, i.e. in use/not in use
e. results of any monitoring inspection, test or check carried out, and the dates
These records should be retained throughout the period for which they remain current and for at least two years after that period. Records kept in accordance with (e) should be retained for at least five years.
APC Compliance can help you in a number of ways to ensure you meet your Health and Safety requirements and sufficiently manage the risk of exposure to Legionella bacteria. We offer the following services
- Legionella Risk Assessments of domestic water services
- Production of a Written Scheme to ensure that any identified risk is controlled and managed
- Completion of logbook audits to ensure your chosen water treatment provider is competent and carrying out tasks on your behalf
- Independent consultancy services.
