Legionnaires’ guidance leaves uncertainty
Members of BEAMA’s water safety and hygiene group are concerned that updated guidance on Legionnaires’ Disease is lacking in technical guidance. Terry Rowbury explains.
The Health & Safety Executive (HSE) recently revised the Legionnaires’ Disease Approved Code of Practice (ACOP) L8, updating and clarifying the health and safety information on managing and controlling legionella bacteria in water systems, while also making the technical guidance separately available. However, because the technical guidance relating to hot- and cold-water systems hasn’t yet been finalised and published, members of BEAMA’s water safety and hygiene group are concerned that the advice might not be clear enough to ensure compliance.
Legionnaires’ Disease is a potentially fatal form of pneumonia. It can affect anybody, but some people are more susceptible because of age, illness or immunosuppression*. The disease is caused by the bacterium Legionella pneumophila and related bacteria being inhaled deep into the lungs.
Each year, on average, 200 to 250 cases of Legionnaires’ Disease are reported in the UK. It can be treated effectively with appropriate antibiotics, but infection with legionella bacteria can be fatal (in approximately 12% of reported cases).
Legionella bacteria are common, and can be found naturally in water sources such as rivers, lakes and reservoirs. They can colonise in manufactured water systems and can be found in cooling tower systems, hot and cold water systems and other plant and equipment which uses or stores water. Legionella bacteria can survive under a wide variety of environmental conditions, but the ideal growth range is 20 to 45°C.
Although infections originating in the UK are often sporadic, for which no source of infection is traced, some outbreaks have been associated with hot- and cold-water systems in buildings such as factories, hotels and hospitals.
To reduce the risk, it is important to introduce measures which do not allow proliferation of the bacteria, and to reduce, so far as is reasonably practical, exposure to water droplets (aerosols), suspended in the air containing the bacteria.
Practical advice on how to comply with UK health and safety law with regards to the control of legionella bacteria is available from the HSE — and the ACOP and guidance document ‘Legionnaires' Disease: The control of legionella bacteria in water systems L8’ has recently been revised.
It provides guidance on how to comply with the requirements of the Health & Safety at Work etc. Act 1974 and the Control of Substance Hazardous to Health 2002 (COSHH), and is aimed at dutyholders, including employers, those in control of premises and those with health and safety responsibilities for others.
It includes information on identifying and assessing sources of risk; preparing a scheme to prevent or control risk; implementing, managing and monitoring precautions; keeping records of precautions; and appointing a competent person with sufficient authority and knowledge of an installation to help take the measures needed to comply with the law.
The code and guidance also set out the responsibilities of suppliers of services such as water treatment and maintenance, manufacturers, importers, suppliers and installers.
The revised ACOP is intended to provide greater clarity for dutyholders on what constitutes legal requirements and what is guidance; where possible the terminology has been simplified.
As part of the update, the technical guidance has been removed, and is published separately online in HSG274. However, the revised version of Part 2 of HSG274, ‘The control of legionella bacteria in hot and cold water systems’, is still under review and needs to be updated, so hasn’t yet been published. Only interim guidance is currently available, which is an extract from the previous ACOP L8.
Members of BEAMA’S water safety and hygiene group believe that the revised ACOP needs to be viewed in association with updated technical guidance. Until the two documents can be viewed together, we are concerned that potentially there isn’t enough information available to provide clarity and ensure compliance.
In addition, we are aware that the ACOP is a guide that leaves the responsibility of legionella control with an appropriate person, rather than providing a definitive list of instructions. Throughout the ACOP there is reference to ‘competence’ and ‘suitable experience’, which needs further clarification.
Furthermore, chemical treatment is referred to throughout the ACOP document, but there is no clear explanation of what constitutes an appropriate chemical-treatment programme. This is an important point, as the inappropriate use of chemicals has been found to have a significantly detrimental effect on water storage and distribution systems.
BEAMA’s water safety and hygiene group welcomes any update that leads to an improvement in legionella control, but we are keen for the HSG274 technical guidance to be finalised as soon as possible. Members provided a collective response to the ACOP L8 consultation, and expect to be called upon for the group’s expertise during the consultation for the technical guidance.
Terry Rowbury is association director at the BEAMA water safety and hygiene group.
*Certain groups of people are known to be at higher risk of contracting Legionnaires’ Disease; for example, people over 45 years of age, smokers, heavy drinkers, people suffering from chronic respiratory or kidney disease, people with diabetes or lung and heart disease and anyone with an impaired immune system.
