The Simple Guide to Legionella Risk Assessments and Primary Water Services
What the law says you MUST do to protect your business
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
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?
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:
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:
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.
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