The Importance of Legionella Control

Legionnaire’s Disease is not new, it is a disease which first came to light in 1976 when a group of attendees of an American Legion Conference in Philadelphia developed a serious but mysterious illness following exposure to the potentially harmful legionella bacteria. Of the 221 men affected, 34 sadly died. Legionnaire’s disease is still recognised as a serious and potentially life-threatening disease and that is why health authorities throughout the world consider this with the severity it deserves. Despite the focus and awareness that now exists around legionella, this is not an illness that we have been able to eradicate and in 2018 UK Government statistics reported that 469 cases were recorded in England and Wales. It is not the responsibility of Government, Councils or Public Health Bodies to investigate the presence of legionella bacteria. It is the responsibility of employers or people in control of buildings to ensure that employees and tenants can work or live in those buildings free from the risk of being exposed to legionella. For that reason, employers and landlords are responsible for carrying out Legionella Risk Assessments and managing and mitigating any risks which arise from those results.

Legislation is in place to guide the process by which legionella control should follow. Whether you intend to manage and control this internally in your organisation or appoint a water management company to handle these activities, you do need to be aware of your responsibilities with regard to implementing a legionella management and control programme. This isn’t something that is a one-off tick box exercise which can be filed and not revisited. A legionella risk assessment programme must be a living document or process which is revisited and updated regularly to continually demonstrate compliance.

Demonstrate Compliance and Your Responsibilities

To demonstrate compliance to any standard, you first need to understand what your responsibilities are and how that should be tested, measured and results shared. The approach taken to the control regimes put in place needs to follow the guidelines laid out in the legislation for the control of legionella.

The standard in the UK to which all legionella risk assessments should follow and adhere to is the Approved Code of Practice L8 (ACOP L8).
This was updated in 2014 to implement HSG274 parts one, two and three.

The British Standards Institute also produce guidance in the legislation, the latest version of which is titled: British Standard 8580-1:2019 Water Quality Risk Assessments for Legionella Control Code of Practice. If followed, the guidance should lead to the production by competent individuals of brief, clear, user-friendly reports lacking in superfluous information.

How to Demonstrate Compliance

The legislation and guidance for legionella risk assessment, control and management are clear and available for all those responsible to follow and implement. Let’s look at the 5 key areas to highlight the work that can be done to demonstrate that you have done all you can to be compliant and mitigate the risk of legionella to as low as possible.

1. Identify and assess any potential sources of risk

For the building you are responsible for, you need to be able to identify all asset types that may pose a risk or threat of containing the legionella bacteria

2. Prepare a scheme to prevent or control the risk

Once identified, parameters need to be assigned to each individual asset which will mitigate the risk. For example, stating that a tap needs to remain within set parameters to minimise the risk of legionella bacteria forming.

3. Implement, manage and monitor precautions and controls which have been put in place

Once assets are listed as potential sources of risk and the controls are identified to help mitigate the risk, you need to implement a regime which monitors those controls and raises an issue when the control criteria are not met. This programme of control needs to include frequency of testing. Failure to meet the compliance laid out in the legislation can prove costly.

4. Keep records or precautions

It isn’t enough to plan the programme of control – you need to be able to show on demand any records of tests, non-compliances raised and the resulting actions where applicable. Also, that any actions resulting from a non-compliance are complete and the results are back within the control parameters. Basically, there needs to be a record of all inspections and work done as part of the legionella control programme.

5. Appoint a responsible person

Regardless of size of organisation, someone needs to have overall responsibility for the management and control of legionella.

A Digital Approach

The best way to consider the reasons that a digital approach to legionella testing is better than a paper-based system is to look again at the five steps required from the legislation.

1. Identify and assess any potential sources of risk

In using software, you can identify all assets in your building which may present a risk of legionella and store them centrally in a system. In doing so, you have a record of all areas of risk and can easily move onto preparing the plan to prevent or control the risk

2. Prepare a scheme to prevent or control the risk

With all potential for risk identified and stored on a system, it makes planning for control measures much easier. You can easily take each asset in turn and set control parameters on the system to plan for an inspection regime. Without doing this digitally, the identification and control process becomes a lot more laborious as you work through each asset and record on paper what the controls should be.

3. Implement, manage and monitor precautions and controls which have been put in place

A legionella testing regime will take the assets and control parameters set out and test for meeting those criteria. This test is a lot quicker and easier to complete if it is digitally based, an inspector is able to pull up each job and work through the test programme. Further, any actions from the result of tests can be implemented swiftly.

4. Keep records of precautions

Record keeping is key in being able to demonstrate compliance. In a world where information is at our fingertips, the record keeping of legionella testing should be as well. A digitally based system ensures test results are available in real time.

5. Appoint a responsible person

Regardless of size of organisation, someone needs to have overall responsibility for the management and control of legionella.

Legionella Risk Assessment

Within a software system for legionella testing and control there will be three key areas

1. Forms for ease of testing

An electronic form enables all field staff to capture test results quickly and easily. It also ensures the information captured is only within the boundaries of the testing criteria and doesn’t contain information that will not be required. Thereby, meeting the recommendations of the standard stating reports should be “lacking in superfluous information”.

2. Compliance to manage issues

To maintain compliance when it comes to legionella testing, actions need to be raised and actioned swiftly. In an electronic system, this can be done. A non-compliance is raised, the resulting action is quickly assigned and can be worked on to fix the issue as quickly as possible. Without an electronic system, this process is a lot slower.

3. Visibility for all stakeholders

For a compliance system to be effective, communication and transparency for all stakeholders is key. Anyone can see results of tests and corrective action plans at any given time and don’t need to wait for reports to be sent to them. Visibility and transparency leads to an open and honest culture that becomes embedded throughout the organisation.

Benefits of a Digital System

The main benefits of a digital approach to legionella risk assessment, management and control are:

Saved Time

If using a paper-based system for legionella control and testing, the likelihood is that tests are done and the results are not known until the field worker carrying out the test has returned to the office to submit a report, issues will be highlighted and dealt with. However, to assign and action the issues will require someone to read the report and assign the job to the appropriate person. All of which takes time and can become a laborious process. In the digital format outlined in our guide, test results are instant and issues can be highlighted and actioned quickly.

Improved Efficiency

A laborious paper based process has the potential for mistakes and misinterpretation of data. Therefore, the saved time and costs associated with an electronic format system all contribute to improved efficiencies and an all-round better way of working.