Health and Safety Executive Control of Legionella Howard Whittaker Principal Inspector FOD 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; • details of precautions taken including: an assessment & adequate schematic of the system; - 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 • • • • No legionella risk assessment in place 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/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) • • 3 Companies, No schematics (2 needed updating) 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 4 Companies, Deadlegs Common Issues 1) • • • Poor provision for access to towers in general. • Packing not removed (no evidence to support quality of pack cleaning). • • Towers found in poor physical condition. • • No documented close-out on remedial actions. Routine physical checks not being carried out. 6 monthly cleaning & disinfection not carried out (no supporting evidence / justification for less frequent cleaning. Poor communication between operator & WTC in terms of roles and responsibilities. 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