Primary Water Solutions – Practical Advice on How to Manage Water Systems in Current Climate

Primary Water Solutions can offer a reasonably practicable approach via Desk Based Risk Assessment with a competent person to outline current risks, with sensible solutions to cover both answers to the following:

How do I review my Legionella Risk Assessment and manage my current compliance obligations?

What does safely commission prior to re-occupation, really mean for me?

To follow up on our previous communications, Primary Water Solutions would like to take this opportunity to assist and advise of some options that are currently available to you via Primary Water Solutions in order to manage the exposure to Legionnaires’ disease during these unprecedented times. The advice will be as reasonably practicable as possible to the organisation.

One of the many problems facing DutyHolders at present is:

Water usage is currently not being used in its as designed manner and flushing of outlets is not simulating normal usage potentially creating Legionella and other waterborne pathogens.

Problem:  Reduction in building use: In particular low water use and its associated risks

Due to a building closed down for the foreseeable or a building that has reduced members of staff present – or where staff are working on skeleton staffing levels to maintain building function whilst ensuring social distancing and safety is maintained or buildings where Key Critical Functions/Equipment are being manufactured on lower levels of workforce for example – not an exhaustive list of reasons but some to think about:

Solution:  Risk assessment should be reviewed due to a significant change: see also articles below

• Importance of a Written Scheme
• What is a Significant Change?

Subsequent Problem:  Legislation (Health & Safety at Work Act) and Regulations (COSHH) are still in force.

The building is currently unsafe to access or access cannot be permitted due to COVID-19 restrictions.

So, what can we do: What is the next best practicable option we can offer:

Practicable Solution:  Desk Based Appraisal of Current Risk Assessment – Completed by a competent person

Result:  Yes; the desk based assessment will identify and raise elevated risks, however, will also recommend and detail appropriate and site specific control measures to take immediately, short term and post COVID-19 lock down.

Identification of possible but not an exhaustive list of scenarios are below:

Scenario 1:  Minimal outlets or supplied off the mains cold water and instantaneous water heaters.  Building totally empty

Scenario 2:  Minimal storage of water however building part occupied.

Scenario 3:  Building empty but has numerous stored water systems.

Scenario 4:  Building part occupied but has numerous stored water systems.

Scenario 5:  Building operates a Cooling tower / Evaporative condenser / Adiabatic Cooler.

What is apparent is there are numerous different water systems, with differing operational levels and therefore differing risk levels making it difficult to advise on a specific control strategy without having appraised the sites water systems.

What could a Desk Based Assessment involve?

• Collaborative approach with the Water Safety Consultant / Duty Holder / Responsible Person / Site Competent Person and Water Hygiene Contractors if relevant
• Access to previous risk assessment and schematics (or as fitted drawings).
• Access to records (temperature, sampling, cleaning records etc)
• Video Conference / Telecommunication to review current previous risk assessment (if present)
• Identification of system changes / building changes / operational changes / user changes
• Once building use is confirmed, appropriate control measures can be discussed and formerly presented by the water Safety Consultant in writing and as part of the desk assessment report.
• Confirm who is going to complete all the actions and agree on reasonable timescales for completion.

Primary Water Solutions have completed this bulletin in order to pro-actively advise of any strategies that could be put in place at this point in time to ensure the on-going management of water systems.

An extract below from BS8580 ref Desk Top Appraisal of Documentation

Appraisal of the safe operation of the systems, the risk assessor should check that there is a scheme for the safe operation and maintenance of all risk systems within the scope of the assessment which:

• includes a description of the correct operation of the plant and any precautions to be taken;
• details any start-up and shutdown procedures, and plant rotation and flushing requirements for little‑used outlets;
• includes details of any plant or equipment brought onto site by third parties;
• includes, where appropriate, method statements, e.g. for major tasks such as cleaning operations;
• outlines any tests that are to be completed on the systems, along with the required frequency of the tests and the acceptable control parameters
• details defects or out‑of‑parameter results; and
• logs appropriate corrective actions

Desktop appraisal of documentation

Preparation of an existing risk assessment report is available, it should be appraised by the risk assessor to determine if it is still valid and to identify any changes since the last assessment.

NOTE 1  Appraising the current risk assessment can give the assessor valuable information about the water systems being assessed and the attitude of the management on site as demonstrated by their responsiveness to previous risk control recommendations made.

NOTE 2  The appraisal of the validity of the existing risk assessment cannot be performed adequately without a site survey (see Clause 7). An appraisal should be carried out to determine whether the system is under control and the risk is continuing to be adequately managed.

If the current controls, etc., are found to be insufficient or not to have been fully implemented where there have been adverse monitoring results, or if there has been a change in process or management, then the risk assessor should request/obtain and appraise the following:

• current risk assessment;
• current logbooks, asset register and schematic diagram(s) of the water system(s). This will allow the assessor to determine inherent risk arising from design and construction;

NOTE 3  In the absence of an up-to-date asset register or schematic diagram, the risk assessor has to make a value judgement as to whether they have sufficient information to complete and issue a risk assessment report.

• any recent Legionella control audits;
• the current written scheme of control, including:
• the maintenance history of the water system(s) to be assessed;
• training records of, and records of competence checks on, site personnel and contractors;
• monitoring and inspection records;
• the scheme for the safe operation of the systems;
• timely and appropriate reactions to lapses of control;
• any substantive changes in the at‑risk population; and
• any substantive changes to relevant personnel

Primary Water Solutions have produced the above advice to assist building owners/occupiers as to the options available to them and to avoid being in an unprecedented position of losing managerial and system control of their Legionella Compliance programme.

For any further advice – please contact Primary Water Systems on 01454 501818