Control of Legionella

1. Control of Legionella Howard Whittaker Principal Inspector FOD Leeds

2. Risk Systems

3. Spa Pool Guidance

4. Health Technical Memorandum

5. Notification to LA of operational cooling tower • Notification of Cooling Towers and Evaporative Condensers Regulations 1992 • Regulation 3

6. 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

7. Risk Assessment should include: • the management responsibilities and name of the responsible person; • population exposed and risk from water systems; • an assessment & adequate schematic of the system; • details of precautions taken including: - the control method/s – inspection / monitoring and maintenance programme (eg checking the system is kept clean); • records of operation, monitoring and remedial work;

8. Responsible person • Take managerial responsibility – change management • Supervise • Working knowledge of • Risks • Controls • Target levels • Action levels

9. Management questions • Has a ‘responsible person’ been identified? • Is there a deputy? • Are there contact details? • Are roles and responsibilities clearly defined?

10. Roles and responsibilities • Responsible person • Water treatment company • System operators • Contractors • Subcontractors

12. THE MAR OF POPMAR I THINK I KNOW I HOPE I KNOW I KNOW I KNOW

14. 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

15. What went wrong? • Previous cntract terminated in spring 01 • 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 legionella risk assessment in place • No/poor control of contractors • Biocide drums empty since Dec 01 • Lack of/poor health & safety management by the council

16. Manchester Blitz • 18 sites visited (31 towers) • 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 • 3 Companies, No schematics (2 needed updating) • 4 Companies, Deadlegs

17. Common Issues 1) • Poor provision for access to towers in general. • Routine physical checks not being carried out. • 6 monthly cleaning & disinfection not carried out (no supporting evidence / justification for less frequent cleaning. • Packing not removed (no evidence to support quality of pack cleaning). • Towers found in poor physical condition. • Poor communication between operator & WTC in terms of roles and responsibilities. • No documented close-out on remedial actions. • Generic method statements for cleaning

18. 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.

19. 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.

20. The audit checklist