Health and Safety - Legionella and Water Hygiene Policy

 

1. Introduction

The Society Water Hygiene policy sets out the aims and objectives of The Midcounties Co-operative Society (hereby referred to as “the Society”) to control water quality at all the Society’s sites. It is to be read in conjunction with the Written Scheme for each building. These documents provide the specific detail of how this policy should be implemented on a building by building basis.

The Society as employers have a general duty under The Health and Safety at Work Act 1974 to ensure so far as is reasonably practicable, the health, safety and welfare of all their Colleagues. Colleagues have a duty to take reasonable care for their own health and safety and of that of others who may be affected by their acts or omissions at work.

It is the responsibility of any person employed by the Society to comply with this Policy.

1.1 Scope

This Policy applies to the design, operation and maintenance of all water systems where there is the potential for legionella to grow and become dispersed as a respirable aerosol, whether systems include those owned or managed by the Society, or brought onto the Society’s sites by colleagues, or those visiting or working at any given site.

T sources include, but are not limited to, the following systems:

• Cold Water Services – Storage and Distribution

• Hot Water Services – Calorifiers, Direct water heaters and others

• Taps, showers, bib taps, etc.

• Thermostatic Mixing Valves (TMV)/Thermostatic Mixing Taps (TMT)

• Car wash systems

• All other systems identified by risk assessment as posing a risk

2. Policy Statement for Legionella Control

Water quality can represent a significant risk to health as highlighted by regular outbreaks of Legionnaires’ disease. The responsibility of the Society to achieve control within accepted parameters is formally recognised by this policy.

The Society accepts their responsibilities to take every reasonable precaution necessary to protect the welfare of people occupying and visiting their properties, as well as those passing by their buildings. To ensure that the highest reasonably practicable standards are maintained, guidance relating to the prevention of legionella, issued by authorities such as the Health & Safety Executive and the British Standards Institution, relating to the prevention of legionella will be adopted where relevant.

2.1  Policy Review

This Policy will be reviewed every two years, or whenever there is reason to believe that it is no longer relevant. The review will be completed by the Legionella Advisory Lead.

Changes to nominated roles within the Policy version are noted in section 9 of this Policy

Further details on the content of this review can be found in the Society’s Water Hygiene Written Schemes.

3. Arrangements

The foundation to the Society’s approach to water quality control is:

• Identify and assess sources of risk through completing risk assessments

• Prepare written schemes for preventing, reducing or controlling the risk; including actions to be taken in the event of loss of control

• Implement, manage and monitor measures to control the risk

• Appoint appropriate persons to be managerially responsible for the Policy implementation

• Keep records of the precautions implemented

3.1 Risk Assessment

The Society will ensure risk assessments are undertaken, and a risk based approach to water system management is implemented and recorded.

Risk Assessments will be saved to the Society’s electronic compliance system and all actions will be monitored on a period basis for completion.

All Colleagues have a role in protecting health and safety for all and water quality is part of this, as such basic information will be provided to all Colleagues, and specific training and instruction will be given to all those directly involved with water safety management, to ensure competency levels are suitably maintained at all times.

3.1a Changes to use of building

New Risk Assessments will be undertaken whenever significant changes are made to the existing building water system or building use.

In addition, where the use of a building changes considerably, total cold water consumption over a typical day will be assessed to confirm there is reasonable of flow and that water is not stagnating

3.2 New Builds and developments

Typically new sites opened by the Society would be considered as small developments and as such, prior to, and as close as reasonably practical to opening and occupation, the water system will be thoroughly flushed and disinfected.

“Mothballed” sites will be drained down until re-occupation.

3.3 Written Schemes

The Society will prepare Written Schemes for all sites owned and managed by the Society, aimed at clearly identifying the measures required to control the risks from exposure to Legionella bacteria, and
how those measures are to be implemented and managed so that control over water systems is achieved and remains effective. 

To access the Legionella Written Scheme, please click here

 

4. Key Roles for Policy Implementation

General

Management has the overall responsibility for the implementation of this Policy to ensure a safe, reliable hot and cold water supply, within all the Society’s sites. In addition, management has a statutory duty to ensure that compliance with this Policy is continual and not notional.

The Society has identified the following responsible positions to implement and maintain its water hygiene policy. For full details of duties involved, refer to the Management Arrangement section of the Society’s Water Hygiene Written Scheme

Statutory Duty Holder - Secretary & Head of Governance

The Statutory Duty Holder has the overall responsibility for ensuring compliance with all statutory regulations and therefore this Policy.

Legionella Advisory Lead (LAL) – Health and Safety Manager
The Legionella Advisory Lead has overall responsibility to provide advice and guidance on effective management of Legionella in the Society

Appointed Responsible Person (Legionella) (LRP)– Head of Facilities Management

The Appointed Responsible Person has overall responsibility for the day to day management of water quality in Society sites

Additional Roles and Responsibilities

Legionella Operations Lead - Chief Operating Officer (“COO”) for each Trading Group

The Legionella Operations Lead has overall responsibility for the successful implementation of all site-based control measures identified in this policy to ensure colleague and contractor safety on site

Facility Management Department

The Society’s Facilities Management Services Team is responsible for the handling and suitable instruction of any required works requests in relation to a sites water systems including new developments.

Calls relating to non-compliance of Water Hygiene controls will be handled as a Priority 1 call, and appropriate SLA observed

Managing Agents

Where the Society is identified as the landlord for any residential or commercial properties, a competent managing agent will be appointed and will be responsible for implementing suitable controls to mitigate the risk of legionella in such water systems.

They will also be responsible for maintaining communication with the tenants ensuring they are aware of the potential risk of exposure to legionella

Health & Safety Department

The Society’s Health & Safety Team will monitor effective completion of site-based activities, during internal Health & Safety Audits and implement measures to correct non-conformity.

Property Compliance Department

The Society’s Property Compliance Team is responsible for maintaining records, and periodically auditing compliance via Society’s C365 electronic compliance system. Records of monitoring and inspection will be kept for 5 years.

The Water Hygiene Contractor will provide the Compliance Team with all monitoring, inspection & test results and certificate produced on site, for the purpose of record keeping.

Site Management Team

The Society’s Site Management teams are responsible for completing control measures and tasks as allocated in the Society’s Written Scheme.

Records of control task completion will be maintained electronically. Where the electronic task platform is unavailable for task completion, a manual record of the check and result must be made and the records kept for 5 years.

To access the site manager Legionella Control Document, please click here

Water Hygiene Contractor

The selected Water Hygiene Contractor is responsible for delivering tasks as allocated in the Society’s Written Schemes. Duties will include:
• Monitoring and sampling, reporting & logging

• Hot and cold water system management

• Ad-hoc training – on site

• Risk Assessment completion

A full list of tasks identified for completion are included in Appendix 1, but will include:

• Descaling of water systems

• Chlorination

The Water Hygiene Contractor will notify the Appointed Responsible Person, or the Deputy, of any situation that they deem to be of a high risk.

Consultants

At the time of this Policy the responsibilities for Legionella Consultancy Services lies with Bradley Environmental.

5. Training and Competence

The Society recognises that effective implementation of this Policy will rely on all those involved in water system management being suitably informed, instructed and trained and their suitability assessed.

Legionella awareness and responsible person training will be undertaken to a recognised standard such as City & Guilds. More specific training against this policy and site-specific written schemes may also be undertaken.

Training will be reviewed periodically, and refreshed at least every 3 years or when there is reason to believe that training is no longer suitable, such as poor performance against compliance criteria, or updates to guidance and legislation

A training needs analysis will be completed to ensure that any potential changes in key personnel/job roles are reviewed to ensure compliance to recognised roles and responsibilities.

Records of all training will be kept in line with the Society’s internal policy

All service providers should be LCA approved and training certificates and competency statements for their site operatives quality are to be maintained and made available on request.

6.  Notification of Outbreaks of Legionella

In England and Wales, legionnaires’ disease is notifiable under the Health Protection (Notification) Regulations 2010. Under these Regulations, human diagnostic laboratories must notify Public Health Departments of microbiologically confirmed cases of legionnaires’ disease.

An outbreak is defined as two or more cases where the onset of illness is closely linked in time (weeks rather than months) and where there is epidemiological evidence of a common source of infection, with or without microbiological evidence.

In such an event, the Society will fully comply with the local Authority and Proper Officer in their investigations.

In the event of a confirmed case of Legionella on a Society site, the Appointed Responsible Person, or the Deputy, will follow the Society’s Major Incident Plan in relation to Legionella and advise the Health and Safety Manager

Any confirmed cases (e.g. a doctor notifies the Society as the employer) will be reported under RIDDOR guidelines.

7. New and Refurbishment Works

The Appointed Responsible Person will be responsible for ensuring that the Society mitigates the risks from Legionella when undertaking any refurbishment or replacements of water infrastructure. This will include a programme for the removal of dead legs.

For new builds the plans for any water distribution system should be reviewed by the Society’s Consultants as part of the planning and construction project. This will ensure that in new build and refurbishment projects the water distribution systems are optimised in terms of Legionella control.

7.1 Remedial Works

Historic remedial works required on a site will be reviewed as part of the initial Annual Review visit by the Water Hygiene Contractor and a program implemented to address critical items.

8. Verification and Measures

 

 To access the Appendix 1, please click here