In environments where there is a duty of care, such as healthcare facilities, residential homes and commercial buildings, it is a legal requirement to conduct a legionella risk assessment for water systems.
The Health and Safety Executive’s (HSE’s) Approved Code of Practice L8 (2013) stipulates that legionella risk assessments should be reviewed ‘regularly’ to ensure any changes in the water system or its use are identified, and that the risk assessment remains valid. Previously, the HSE recommended a two-year frequency for these assessments. In 2013, however, this was revised to align with other legislative documents, promoting assessments that are current, relevant, and proportionate to the identified risks. BS 8580-1:2019 outlines that a legionella risk assessment should be a continuous process rather than a one-off task, supporting the notion of a ‘live document’ that anticipates changes rather than merely reacting to them.
The Health and Social Care Act 2008: Code of Practice on the prevention and control of infections and related guidance requires the duty holder of a building to set up a water safety group (WSG) to manage and monitor the prevention and control of infection. According to the Department of Health’s document HTM 04-01, the WSG should be consulted at the earliest opportunity when planning new healthcare premises or refurbishing existing ones, to ensure risk assessments are integral to all projects.
Commercial offices are at particular risk after the Covid-19 pandemic altered usage pattern.
‘Legionella
Using a review tool can highlight changes that might invalidate your current risk assessment. While some changes, such as a case of legionellosis, are obvious, others – such as modifications to the water system – require careful consideration. Significant changes, such as ward refurbishments or removing a cold-water tank, clearly necessitate a reassessment, while minor changes might warrant a reassessment if they alter the overall risk profile.
Review criteria are designed to predict changes in risk assessment findings impacting the written scheme of control, monitoring and maintenance tasks. Best practice suggests timely completion of risk assessments, especially after system installations or refurbishments. Identifying risks early allows for necessary adjustments, minimising users’ exposure and avoiding costly fixes after the building is operational. During commissioning, well-documented risks often emerge that could have been addressed beforehand. Examples include:
- Flexible hose connections fitted to clinical wash basins behind integrated panel systems (IPS)
- Hot water tertiary loops not circulating
- Insufficient pipework insulation
- Over-storage of cold water
- Inadequate disinfection and water sampling records
- Inaccessible assets behind IPSs.
Addressing these can prevent unnecessary risks and interruptions once the building is in use, with contractors typically bearing the cost of rectifications before handover.
Failing to update a risk assessment can lead to several problems. New or altered risk systems may necessitate updates to the water safety plan or written scheme, requiring revised regimes of checks and inspections. Missed checks can cause irreparable damage or require costly remediation.
Changes in water storage requirements or usage can impact turnover times and increase biofilm growth risks, and different users with different susceptibilities, such as in healthcare, may require more frequent checks than public buildings.
Outdated risk assessments can result in HSE improvement notices, so regular reviews are crucial for maintaining up-to-date compliance and ensuring the right control measures are in place