Control of Legionella

Health and Safety Executive

Control of Legionella

Howard WhittakerPrincipal InspectorFOD Leeds

Risk Systems

Spa Pool Guidance

Health Technical Memorandum

Notification to LA of operational cooling tower

• Notification of Cooling Towers and Evaporative Condensers Regulations 1992

• Regulation 3

Approved Code of Practice (L8)

• Identify and assess sources of risk

• Prepare a scheme for preventing or controlling the risk

• Implement and manage the scheme

• Keep records and check that what has been done is effective

• Practical advice

Risk Assessment should include:

• the management responsibilities and name of the responsible person;

• population exposed and risk from water systems;

• an assessment & adequate schematic of the system;

• details of precautions taken including:

- the control method/s – inspection / monitoring and maintenance programme (eg checking the system is kept clean);

• records of operation, monitoring and remedial work;

Responsible person

• Take managerial responsibility – change management

• Supervise

• Working knowledge of– Risks– Controls– Target levels– Action levels

Management questions

• Has a ‘responsible person’ been

identified?

• Is there a deputy?

• Are there contact details?

• Are roles and responsibilities clearly

defined?

Roles and responsibilities

• Responsible person

• Water treatment company

• System operators

• Contractors

• Subcontractors

THE MAR OF POPMAR

I THINK I KNOW

I HOPE I KNOW

I KNOW I KNOW

No Legionella risk assessment

No Responsible person for Legionella

No water treatment chemicals

No monitoring of water treatment

Poor communication

Unclear lines of responsibility

Failure to act on advice/raised concerns

Poor management of contractors

Inadequate training/knowledge base

Individual failings

What went wrong?

• Previous cntract terminated in spring 01

• Failures in the procurement of the replacement contract

• Water management scheme excluded from contract

• Little/no documentation in existence

• Concerns brought to the attention of Design Services Group Manager

• No legionella risk assessment in place

• No/poor control of contractors

• Biocide drums empty since Dec 01

• Lack of/poor health & safety management by the council

Manchester Blitz

• 18 sites visited (31 towers)

• 15 water treatment companies

• 3 towers condemned by the client

• 1 no drift eliminator

• 1 No risk assessment

• Roles and responsibilities between company and WT company

• 3 Companies, No schematics (2 needed updating)

• 4 Companies, Deadlegs

Common Issues 1)

• Poor provision for access to towers in general.

• Routine physical checks not being carried out.

• 6 monthly cleaning & disinfection not carried out (no supporting evidence / justification for less frequent cleaning.

• Packing not removed (no evidence to support quality of pack cleaning).

• Towers found in poor physical condition.

• Poor communication between operator & WTC in terms of roles and responsibilities.

• No documented close-out on remedial actions.

• Generic method statements for cleaning

Common Issues 2)

• HSE Safety Notice July 2012 after review of outbreak causes.

• 90% failure to identify risk or have effective control scheme.

• Departures from planned maintenance and cleaning schedules.

• Changes in the process.

• Staff / contractor changes.

• Intermittent use of plant.

• Unusual weather conditions.

Advice for senior managers

• Seek assurance that effective controls in place.

• Ensure MAR.

• Ensure training and competence.

• Roles and responsibilities defined.

• Adequate control of contractors.

• Act on information.

The audit checklist