Legionella Monitoring
Legionella and Water Monitoring
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Legionella Compliance
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HSE Guidelines
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Legionella and Water Monitoring - Legionella Compliance - HSE Guidelines -
Legionella Monitoring and your legal Requirements as an employer or someone in control of premises (including Landlords).
If you are an employer, or someone in control of premises, including landlords, you must understand the health risks associated with legionella and take suitable precautions to prevent, manage, and control the risk of exposure to legionella to meet the following regulations. Failure to address these issues could leave you liable for enforcement action by the HSE Legionella Control Association/ Local Authority Environmental Health Department.
Duties under The Health & Safety at Work Act 1974 (HSWA) extend to risks from Legionella arising from work activities. A broad framework for the controlling health and safety at work can be found in the Management of Health and Safety at Work Regulations (MHSWR). In addition the Control of Substances Hazardous to Health Regulations 2002 (COSHH) provide a framework of actions designed to assess, prevent or control the risk from bacteria like Legionella and take suitable precautions.
A list of the hierarchy of legal, guidance and British Standard documents are outlined below:
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Sections 2, 3, 4 and 6 are defined within ACoP L8 as applicable to legionella control. The first 2 sections cover the primary requirements for legionella control: -
(2) It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.
(3) It shall be the duty of every employer to conduct his undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his employment who may be affected thereby are not thereby exposed to risks to their health or safety.
http://www.legislation.gov.uk/ukpga/1974/37/pdfs/ukpga_19740037_en.pdf
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These regulations provide a broad framework for controlling health and safety at work. As well as requiring risk assessments, they also require employers to have access to competent help in applying the provisions of health and safety law; to establish procedures to be followed by any working if situations presenting serious and imminent danger were to arise; and for co-operation and co-ordination where two or more employers or self-employed persons share a workplace.
http://www.legislation.gov.uk/uksi/1999/3242/pdfs/uksi_19993242_en.pdf
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This regulation requires the notification of evaporative cooling devices.
3. (1) Subject to this regulation and the regulation 4. It shall be the duty of each person who has, to any extent, control of premises to ensure that no notifiable device is situated on these premises unless the information set out in the Schedule to these Regulations has been notified in writing, on a form approved for the time being for the purposes of these Regulations by the Health and Safety Executive, to the local authority in whose area the premises are situated.
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Approved Code of Practice
This Code has been approved by the Health and Safety Executive, with the consent of the Secretary of State. It gives practical advice on how to comply with the law. If you follow the advice you will be doing enough to comply with the law in respect of those specific matters on which the Code gives advice. You may use alternative methods to those set out in the Code in order to comply with the law.
However, the Code has a special legal status. If you are prosecuted for breach of health and safety law, and it is proved that you did not follow the relevant provisions of the Code, you will need to show that you have compiled with the the law in some other way or a Court will find you at fault.
Guidance Published in L8
This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory, unless specifically stated, and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and Safety inspectors seek to secure compliance with the law and may refer to this guidance.
Downloadable as a PDF Free of charge from the HSE website -
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The guidance in each part of HSG274 gives practical advice and examples of good practice in how to achieve what is required under L8. HSG274 is published in three parts:
HSG274 Part 1
This document gives specific guidance for evaporative cooling systems. Appendix 1 and 2 give useful practical advice on what should be found in a legionella risk assessment and in a written scheme of control.
Downloadable as a PDF free of charge from the HSE website -
http://www.hse.gov.uk/pubns/priced/hsg274part1.pdf
HSG274 Part 2
This document gives specific guidance for hot and cold water systems. Appendix 2.1 and 2.2 give useful practical advice on what should be found in a legionella risk assessment and in a written scheme of control.
Downloadable as a PDF free of charge from the HSE website -
http://www.hse.gov.uk/pubns/priced/hsg274part2.pdf
HSG274 Part 3
This document gives some basic guidance for other risk systems that are not covered in Part 1 or Part 2. For other risk systems, assessment and control of risk must be from first principles of legionella control. These systems require the most competent and knowledgeable assessors and contractors.
Downloadable as a PDF free of charge from the HSE website -
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This British Standard gives recommendations and guidance on Legionella risk assessment relevant to water systems. It is applicable to any undertaking involving a work activity or premises controlled in connection with a trade, business or other undertaking where there is potential for exposure to water or when water is used or stored in circumstances that could cause a reasonably foreseeable risk of infection by Legionella and contracting legionellosis.
This standard is also available with tracked changes from the 2010 version.
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This Health Technical Memorandum (HTM) gives guidance on the legal requirements, design applications, maintenance and operation of hot and cold water supply, storage and distribution systems in all types of healthcare premises.
The guidance is for:
-> healthcare management
-> water safety groups
-> design engineers
-> estate managers
-> operations managers
-> contractors
-> supply chain businesses
It also provides advice and guidance on the control and management of the risk posed by Legionella, Pseudomonas aeruginosa and other water borne pathogens within a healthcare setting.
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HTM 01-05 is intended to raise the quality of decontamination work in primary care dental services by covering the decontamination of reusable instruments within dental facilities.
https://www.gov.uk/government/publications/decontamination-in-primary-care-dental-practices
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This guidance is intended to help those providing and managing care homes - to give them a better understanding of the real risks and how to manage the effectively. It has been extensively rewritten, with a number of new topics, and brings together key messages on risks to both workers and residents. It will also be of interest to others working in social care.
This new edition was published during a period of change. At the time of publication (June 2014), HSE and local authorities investigate serious worker and resident incidents. Under the Enforcing Authority Regulations, HSE regulates homes with nursing and local authority owned or run care homes. Other homes and regulated bt local authorities.
However, from 1st April 2015 the Care Quality Commission (CQC) in England became the lead investigator of incidents where residents have been harmed because of unsafe of poor quality care.
How do I meet Legionella Compliance?
As an employer, or person in control of premises, you are responsible for health and safety and must therefore ensure to take the right precautions to reduce the risks of exposure to Legionella. In order to help understand the requirements the process can essentially be broken down into 3 phases.
Legionella Risk Assessment
The first requirement is to undertake a legionella risk assessment that will identify and assess potential sources of risk Legionella posed by your water systems.
Legionella Remedial Works
Once these risks have been identified remedial works should be undertaken as soon as possible to ensure they are either removed, substituted or managed.
Legionella Monitoring
The final phase is to control and manage the ongoing risk of Legionella exposure from your water system by carrying out continued Legionella monitoring.
Legionella Monitoring to meet HSE guidelines
See below for a full list of the legionella monitoring services that you may need depending on your water system to meet HSE’s Legionella Compliance.
Weekly Flushing
Quarterly Return Loop
Annual Review
Annual CWH Inspection
Annual Water Softener Service
Monthly Temperatures
Six Monthly Expansion Flushing
Annual Tank Inspection
Annual TMV Servicing
Annual Water Testing
Quarterly Descaling
Six Monthly Filter Servicing
Annual Cylinder Inspection
Annual Representative Temp
Other Risk Systems
Do I need to do water monitoring?
Under the Health and Safety at Work Act 1974 and in compliance with the Approved Code of Practice (ACoP L8, HSG 274), duty holders, including employers and those in control of premises, must ensure the health and safety of their employees or others who may be affected by their undertaking. This includes taking suitable precautions to prevent, manage and control the risk of exposure to legionella and legionnaires disease. This can be achieved by undertaking the following control measures:
legionella risk assessment
actioning all identified legionella risks within the simple risk assessment with legionella remedial works
sampling the water quality to confirm bacterial presence with legionella testing
carrying out ongoing record-keeping also known as legionella monitoring or water monitoring
When and how often do I need legionella monitoring?
Once the legionella risk assessment has been completed, a water logbook should be produced to assist with your legionella monitoring and record keeping.
As every water system is different it is advised that a bespoke water monitoring plan is developed and implemented to control legionella levels and any potential exposure to legionnaires disease. This should include a plan of tasks to be undertaken weekly, monthly, quarterly, six-monthly and annually.
How much does water monitoring cost?
The cost of water monitoring can vary greatly depending on various factors including the number of water outlets, cold water storage tanks, hot water cylinders, combi boilers and other water assets that may be present. The number and types of assets within your water system will of course determine the amount of time required on-site and how long it will take to carry out all legionella monitoring tasks.
Prices vary enormously across the industry, often depending on the size of the company you use and their processes, speed of work and professionalism.
At C&M Water we carry out regular price comparisons and service reviews to ensure we are always competitive with all services that we offer.
How long does a water monitoring visit take
As mentioned above depending on the type of water monitoring visit it is and the size of the water system will determine how long a water hygiene engineer is required on-site.
For monthly temperature monitoring, you can expect the engineer to be on-site for a period of 30-60 minutes on average. If however a descale is required which is undertaken quarterly then visit might take 1-4 hours.
Some tasks such as TMV servicing and inspections can take considerably longer.
How long are water monitoring contracts?
Legionella monitoring contracts at C&M Water range from 2 to 5 years. We can under certain circumstances offer 12-month contracts, but in essence the longer the contract the better price we can offer you.
What if I choose not to do Legionella monitoring
Should you choose not to undertake water monitoring, you run the risk of allowing harmful bacteria to grow within your water system which may lead to illness and prosecution under the HSE ACOP L8 (HSG 274) .
FAQs
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Consideration should be given to removing infrequently used showers and taps and where removed, the redundant supply pipework should be cut back, as close as possible, to a common supply, eg to the recirculating pipework or the pipework supplying a more frequently used upstream fitting.
The risk from legionella growing in peripheral parts of the domestic water system, such as dead legs off the recirculating hot water system, may be minimised by regular use of these outlets. When outlets are not in regular use, weekly flushing of these devices for several minutes can significantly reduce the risk of legionella proliferation in the system. Once started, this procedure has to be sustained and logged, as lapses can result in a critical increase in legionella at the outlet. Where there are high-risk populations, eg healthcare and care homes, more frequent flushing may be required as indicated by the risk assessment.
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Temperature plays an important role in controlling and managing legionella bacteria. The legionella bacteria can proliferate between 20-50°C and has even been known to grow at 54°C—with its most favoured temperature being 37°C (body temperature), which is why it can be dangerous to humans once contracted causing illness such as legionnaires disease, pneumonia, Pontiac fever, and the common cold and flu.
Temperatures must be reached within a specific timeframe, to ensure consistency in testing. This allows us to determine the frequency of use of the outlet, as well as those areas at a higher risk of stagnation.
Temperature readings should be taken from all sources of heat and from the nearest and furthest outlets of a water system. The sentinel points are monthly temperature points at the closest and farthest outlets, for example, taking temperatures for cold-water storage tanks would be taken from the nearest tap to the tank and from the furthest tap away. For heat sources, this means taking temperatures nearest and farthest from all heat sources such as cylinders, electric water heaters, boilers or other types of instant water heaters with single outlets such as showers.
Temperature timeframes
Hot temperature – 1 minute
Cold temperature – 2 minutes
Temperature guidelines
Hot outlet – 50°C (55°C in healthcare)
Cold outlet – <20°C
TMV* outlet – 38-43°C (ranges vary for showers/baths)
Scalding – 44°C
Heat sources
Cylinder and flow – 60-65°C
Cylinder return – 50°C (55°C in healthcare)
Combination water heater – 60-65°C
Boiler – 50-60°C (55°C minimum in healthcare)
Electric water heater – 50-60°C (55°C minimum in healthcare)
Instant water heater – 50-60°C (55°C minimum in healthcare)
*TMV – thermostatic mixing valve, blends hot and cold to create a reduced, non-scalding temperature. Often required for vulnerable persons and in healthcare.
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Limescale, a source of nutrients for Legionella pneumophila, can be found in hard-water systems. The UK suffers from hard water due to the chalk limestone earth below the ground that finds its way into our reservoirs that supplies our mains water. Therefore, all outlets should be dismantled, cleaned, and descaled to remove limescale. This includes taps, spray heads, tank cleaning, showerheads and hoses.
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Taking the temperature from the re-circulating return loop quarterly for subordinate temperatures.
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An expansion vessel is a small white, blue, grey, or red tank. The white, blue, and grey vessel colours are to identify water system expansion vessels and the red is to identify heating system expansion vessels. Each vessel includes a rubber diaphragm that goes across the middle, where the bottom half of the vessel is filled with water and the top half with pressurised air. When water is heated at the heat source (like a cylinder) it may expand as much as 4%. The expansion vessel allows this expanded water (increase in water size) from the heat source (cylinder) to flow into the expansion vessel where the bottom half of the vessel (water) may push the diaphragm up into the top hair (airside) to allow for the expansion in water.
So why do we need to flush an expansion vessel? Well, there are 2 primary reasons. One the expansion vessel is a dead end, and as such does not allow water out of it and therefore encourages stagnation both inside the vessel and all the pipework leading to it from the feeding tee (branch of pipe that leads to it). Secondly, the diaphragm is made of rubber, which is a great source of nutrients for legionella.
The guidelines outline that we must flush the expansion vessel for six months to remove stagnant water from the vessel and relevant pipework.
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A filters job is to cleanse the water impurities and allow for good quality water to pass by and therefore provides us with good quality water free from bacteria’s and the like. And in doing so the filter will become dirty itself. You will often see an internal filter that initially looks like a clear white tube that eventually turns brown/black with impurities over time.
Most manufacturers have given this timeframe 6 months before a filter is needed to be replaced or cleaned.
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An annual review is an important part of your legionella testing and control. At this stage, your risk assessments, logbook, schematic, and other records will be reviewed by an engineer to confirm the status of your legionella control and management.
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Coldwater storage tanks overall as a design will not change from year to year but the condition of the tank internally certainly can. Coldwater storage tanks are subject to poor temperatures (too hot or freeze), foreign bodies (bugs, animals), sediment (from mains), biofilm (from stagnation), wall spores (bacteria), and so on. Therefore, it is important to inspect both the internal and external conditions of a tank annually as a minimum.
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Hot water cylinders are subject to continual heat changes that may increase the risk of legionella through non-compliant temperatures. They also require temperature gauges, pipe insulation, and should be purged periodically to remove any internal limescale, debris, or sediment. Cylinders are prone to limescale build-up and an inspection and drain down (purge) of the cylinder will help to remove unwanted items within the cylinder.
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A combination water heater consists of a cold-water storage tank on top feeding the hot water cylinder below, hence the name combination water heater. Therefore, both the tank and cylinder inspections and servicing must take place on a combination water heater.
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TMV or thermostatic mixing valves are blending valves that mix the hot and cold water to reduce the risk of scalding where temperatures are often set to 41°C, 3°C lower than the scalding starting temperature for vulnerable persons at 44°C.
TMVs are fitted with filters that protect the valve, where these filters are prone to blocking with limescale, sediment, and other matter. Therefore, a TMV should be serviced at least annually as recommended by most manufacturers. TMV servicing will often include temperature calibration, failsafe testing, and clean and disinfection of TMV parts amongst other actions where required.
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Whilst you are required to undertake monthly temperature monitoring throughout the year at your sentinel points. You are also required to take the representative temperature at other points in the system to gather information on the rest of the water system. This could be made up of 10% of outlets in the system from areas you do not normally take the temperature from when undertaking monthly temperatures.
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Manufacturers recommend that water softeners should be serviced annually. This often includes a regeneration process where backflow is created to remove any bacteria or otherwise within the water softener system. Additionally, a review of the brine (salt) tank and other elements will be reviewed to ensure a safe and suitable working condition.
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t is recommended that legionella sampling or a legionella risk assessment is undertaken periodically or at least annually. The number of samples required will depend entirely on your water system. For example, samples should be taken from dead legs or areas of stagnation, cold water storage tanks, and all sentinel points to provide an accurate overview of the water systems condition.
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There is a range of other risk systems that require more bespoke management. For more information please contact our team. Below we have a list of water systems that commonly require regular legionella risk assessments:
Ultrasonic humidifiers/ foggers
Spray humidifiers
Air washers
Emergency showers
Sprinkler and hose systems
Swimming pools/ whirlpools/ jacuzzis
Horticultural misting systems
Dental chair
Vehicle wash systems
Fountains and water features
Industrial processing water systems
Reverse osmosis
Water dispensers
Evaporative cooling systems