Every company has the legal requirement to ensure that their water systems are managed to ensure that Legionella bacteria are controlled in a way that achieves a safe environment.
Legionella Companies – who/what are they?
They are companies that support those identified in Health and Safety Law as being responsible for the control of Legionella bacteria in all water systems subject to the Control of Substances Hazardous to Health Regulations (COSHH).
The reference to Duty Holder and Responsible Person in ACoP L8 can be quite narrow but it can be much further reaching to those involved in this subject matter. The Duty Holder must ensure that competent persons, who have sufficient authority, competence and knowledge, are appointed to fulfil the required duties. These maybe from outside of their organisation and can include: –
- Principal Designers,
- Principal Contractors,
- Designers,
- Contractors,
- Facilities and Operational Teams.
The HSE Approved Code of Practice L8 (ACoP L8) is the recognised approach to achieving compliance in controlling Legionella bacteria in water systems. Legionella companies can support you with your responsibility as they can provide one or more of the following services: –
- Consultancy services – design, installation and O&M reviews, role of the Authorising Engineer, Water Regulations compliance.
- Legionella Risk assessments – for all building water systems and other systems e.g. irrigation systems, water features, spa pools, cooling towers and evaporative coolers.
- Legionella Written Scheme of Control – the written document that identifies your control measures and who is responsible plus their competency.
- Legionella Training – this can include governance requirements to basic monitoring activities.
- Disinfections – where new installations / modifications have taken place or if the control measures identified in the legionella written scheme of control have not been achieved.
- Remedial work – aspects of a water system that support the growth of bacteria identified through management surveys or risk assessments.
- PPM activities – e.g. Cold / Hot water storage vessel inspection / cleaning, TMV/TMT servicing, temperature monitoring.
- Sampling and testing.
- Record keeping and Auditing.
Why use Legionella Companies and what to be mindful of?
Industry continues to learn that compliance is not just limited to the role of facilities management / maintenance teams and Legionella companies can help identify the wider requirement. Compliance includes all aspects from governance, through design phases of projects leading to the operational phases. Caution should be taken if appointing a single company to fulfil multiple requirements as independent reviews help to avoid teams ‘marking their own homework’ or generating work that is not required.
Differences for large or small Client organisations / companies
Your legionella risk assessment will advise what is required to be done and will vary depending on the complexity of your water systems. Large organisations with multiple facilities that could include water features, leisure, manufacturing, residential, or hospitality will need multiple robust Legionella written schemes of control, whereas a retail outlet with only a staff room and toilet facilities will need a less onerous management regime due to the level of risk. However, the regulations still apply, and Legionella companies can support with specialist knowledge and resources.
Accreditations and Competency.
Accreditation / affiliation to or membership of an industry organisation is a good benchmark for demonstrating competency, but organisations can differ somewhat on entry requirements. Some only require a Company to apply and pay a fee whereas others focus on the individual, offering different levels of membership based on qualifications and experience. It is still a requirement for the individual’s specific competency to be checked because there are many types and variations to water systems and roles to be fulfilled. Membership needs to be supported by individuals having sound knowledge of their area of work gained through experience and a wealth of supporting industry technical standards. Some recognised organisations are: –
- Legionella Control Association (LCA)
- Water Management Society (WMSoc)
- Institute of Leadership and Management (ILM)
- United Kingdom Accreditation Service (UKAS)
- International Standard for Organization (ISO)
- Chartered Institute of Building Services Engineers (CIBSE)
- Building Engineering Services Association (BESA)
- Institute of Healthcare Engineering and Estate Management (IHEEM)
- WaterSafe
Demonstration your Legionella Company and individuals are competent in the work that they are appointed to complete will give assurance that you are fulfilling your legal responsibility as a Client, Duty Holder or Responsible Person.
