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