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Posted By Monty
Having had a visit from the factory inspector I was informed that I don't need a risk assessment for Legionella. My water treatment company advised me that I had to have one and they were insistent that it is a legal requirement to meet the HSWA and COSHH regulations. They have always given good service and thoughtful advice. We employ about 120 people and have many water systems, process and domestic, on site.
Who's right? Does anybody know?
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Posted By Jerry Lucey
Hi Monty,
I do seem to remember, from working in the UK that cooling towers have to be registered with the local authority.
The risk of Legionairres Disease occurs where there is the possibility of stagnant water in air conditioning systems being converted to spray/ droplets. If this risk exists, as it does with many air conditioning systems, particularly older ones you will need to risk assess.
In your case I would err on the side of caution and conduct a risk assessment as it sounds as though your maintenance company have proved themselves to be competent and helpful in the past.
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Posted By Jeff Manion
Of course if you have cooling towers must be registered with local authority. You must have risk assessment.
If you have other "wet" services you still have to risk assess, but dependant on what services it could be simple,
i.e. direct main fed equipment low risk not much to do.
lots of water tanks varios voids no cover or lids, poor water temperature control you have to do more, this should then bring you to a managed arrangement to deal with the potential problems.
JM
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Posted By Dave Wilson
Ask the water company that if there is a risk of the water which THEY SUPPLY to you can have Legionella in it then please stop supplying in that condition as you will hold them responsible for any injury as a result!
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Posted By Jerry Lucey
Monty - it is not the water being supplied which contains the risk, it is where it is allowed to sit and stagnate at a suitable temperature and then be converted to droplets in a form where it can be inhaled. One of the measures to prevent the outbreak of Legionnaires Disease would be to clorinate the system with 3 - 5 parts per million chlorine.
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Posted By col
The legislation prior to 2001 was that any water system under 300litres was exempt from a risk assessment in relation to legionella. After 2001 the legislation stated that any water system which has the potential to create an aerosol was covered under the ACOP L8. If you have a cooling tower then you definately fall under the ACOP L8 and do require a risk assessment.
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Posted By Adrian Watson
Dear All,
There appears some confusion here! To carry out a legionella risk assessment you need to answer the following questions:
1. Can legionella enter the hot or cold water systems?
2. Has the legionella the time and the right environmental conditions to grow?
3. Can the legionella be aerosolised?
4. Are there susceptible people present, who can inhale the legionella?
The answer through to all of the above questions must be yes for there to be a risk of from legionella. The factory inspector has most probably concluded that the answer is no to one or more of the above questions.
The legislation has not changed; what did change was the guidance contained in L8. The majority of water treatment companies do not carry out risk assessments. They carry out an inspection of the water system and make money doing so! Most people can answer questions 1,2 and 4. If the answer to these is yes then you'll need somebody to inspect the water system.
Regards Adrian Watson
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Posted By col
Scope and application of the Approved Code of Practice.
para 18. This approved code of practice applies to the control of legionella bacteria in any undertaking involving a work activity and to the premises controlled in connection with a trade, business or other undertaking where water is used or stored and where there is a means of creating and transmitting water droplets which may be inhaled, thereby causing a reasonably foreseeable risk of exposure to legionella bacteria.
para 19. A reasonably foreeable risk of exposure to legionella bacteria exists in:
a) water systems incorporating a cooling tower.
b) water systems incorporating an evaporative condenser
c) hot and cold water systems and
d) other plant and systems containing water which is likely to exceed 20C and which may release a spray or aerosol during operation or when being maintained.
Therefore the risk of exposure to legionella may exist in all water systems. A hotel was fined recently when guests caught legionella from a fine mist from a salad bar. Women tend to put the toilet seat down when they have finished on the toilet. a fine spray which can be inhaled may come from any quarters and so an assessment is required even if the risk is low. It is worth remembering that although failure to comply to any part of the ACOP is not in itself an offence, that offence can be construed as being in contradiction to the HSWA 1974, MHSWA 1999, & COSHH 2002.
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Posted By Monty Smith-Hart
Many thanks to all the responses to what I thought was a simple query.
I have had a good look into this and have spoken to the HSE at some length. It seems that any industrial or commercial business (with more than 5 employees) must have a Legionella Risk Assessment to ensure compliance with COSHH and the HSWA. Even if the water systems are no, or low, risk they still have to be assessed, and then they become part of a written scheme. It may be that the systems present no risk but they must be assessed as such and documented. As we have domestic cold water and hot water tanks, showers, taps and process water systems there is an obligation to assess, document, manage, monitor and keep any results or actions in a control system document or logbook.
The water treatment company (Hydro~Flo Water Systems Ltd), in this instance, are correct and, after checking their credentials, I will be ordering a risk assessment from them.
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Posted By col
Any body who wishes to have a risk assessment or management of the water systems cannot go far wrong if they use a company who are associated with the code of conduct. please find their web attached. Oh and I work for Dakro Environmental ltd.( just thought I would plug it)
www.conduct.org.uk
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Posted By John Webster
Perhaps we need to ask just what is meant by risk assessment. Even if you have answered No to all 4 of Adrian's questions, you will have conducted a risk assessment! In that case, your assessment will conclude that there is no significant risk and so no further action is required, but you will still have done a risk assessment.
Many of the legionella questions on this forum come from people who appear to have fairly straightforward water systems but have been made to worry by others. If the only water system you have is similar to a domestic set-up, ie mains feed to a few taps and/or a small covered storage tank, a hot water cylinder or combi boiler with direct feed to a few hot water taps, and WC cisterns off either the mains or the small header tank, and if there are no significant dead legs and all the outlets are in regular use then there is no significant risk. If you have showers on such a system, clean the heads at least annually, and if there are any hoses attached to water outlets ensure that proper precautions are taken to prevent backflow of dirty water.
Water filled central heating systems carry no risk. Air conditioning systems only carry risk if they have re-humidification and/or open water cooling towers.
So unless you have these, or more complex or non-mains water systems, the risk is not significant.
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