The Control of Legionella Bacteria in Water Systems. The Approved Code of Practice & Guidance L8.

Transcription

1 The Control of Legionella Bacteria in Water Systems The Approved Code of Practice & Guidance L8.

2 Contents 1. Background to Legionnaires Disease & Risk Systems 2. Requirements of The Approved Code of Practice and Guidance L8 3. Monitoring of Hot and Cold water services.

3 Where and when did it all start Legionnaires Disease was first identified at the Bellevue Hotel in Philadelphia in A previously unrecognised bacterium was isolated from lung tissue samples which was subsequently named Legionella pneumophila. Positive results from retained tissue samples back to people caught the disease. Thirty four people died

4 Here are just a few outbreaks: Kingston upon Thames Hospital Stafford General Hospital /28 B.B.C /2 University Hospital Nottingham Barrow - in - Furness, Local Authority Building /7 Bulmers Cider, Hereford /2 Basildon Hospital 2007/2010 8/2 Edinburgh /4

5 HSE Prosecutions. Science Museum Cooling Towers No outbreak, No legionella detected. Found guilty of a breach of HASAW etc Act 1974, as no documented evidence of compliance could be provided.

6 HSE Prosecutions. Barrow - in - Furness. Cooling Towers Senior Local Government Officer charged with breaches of the HASAW etc ACT and as there were 7 deaths during the outbreak 7 charges of manslaughter were brought against the defendant. Found guilty of the breaches of the HASAW etc ACT but not guilty of manslaughter at a re-trial personal fine for breaches of HASAW etc Act 1974.

7 HSE Prosecutions Bulmers Cider, Hereford in 2003 Cooling Towers 28 Cases of Legionnaires Disease 2 Deaths. Age range - 36 to 91 years of age 1 Male & 1 Female death 21 of the 28 cases were male Bulmers fined 300, ,000 costs Water treatment provider same penalty

8 HSE Prosecutions Basildon & Thurrock University Hospital Trust in 2013 Hot and Cold water services 8 Cases of Legionnaires Disease 2 Deaths. 74 year old man died in 2007 and a 54 year old man in 2010 The hospital pleaded guilty to a breach of Section 3 of the Health & Safety at Work Act over failing to protect visitors and patients adequately from legionella. The court was told that the hospital trust had been prosecuted before and fined 25,000 in 2007 over the death of a man from Legionnaire's disease. Magistrates were told the starting fine for just one death from legionella was in the region of 100,000. Hospital Trust fined 350,000

9 Legionellosis What is it? Legionellosis is a generic term to cover: Legionnaires Disease Non - pneumonic Legionnaires disease Pontiac Fever - Lochgoilhead Fever

10 CAUSATIVE ORGANISM Legionella pneumophila Serogroup 1 is the only member of the legionella family to cause Legionnaires Disease. Other Legionella Species are pathogenic eg Legionella pneumophila SG 4 & 6, Legionella micdadei, Legionella longbeachae - but no fatalities have been recorded.

11 Legionella bacteria

12 How many Legionella species are there & where do they come from? There were over 40 species of Legionella at the last count, fortunately only a few are pathogenic. They are most likely to arrive via your water supply in a dormant state. Legionella is widespread in nature being found in: Rivers Lakes Reservoirs Soil

13 What type of environment supports Legionella growth? Temperatures in the range 20 C to 45 C The presence of sediments, scale & sludge from poor system hygiene or control of water chemistry. The presence of Ferrous Oxide (rust) from poor corrosion control. The presence of algae, amoebae and biofilms from poor microbiological control.

14 An amoeba

15 Biofilm - A community of bacteria, slime & debris

16 What is Legionnaires Disease and who does it affect most? Legionnaires Disease is a type of pneumonia. It affects the lungs primarily but other major organs can be affected. The incubation period is in the range of 3 to 10 days. Normally 6 days. All persons are at risk but the higher risk categories are:

17 What is Legionnaires Disease and who does it affect most? The age group of 40 to 70 Males more at risk than females. (Ratio: 3:1) Smokers Alcoholics Diabetics Patients with heart, kidney and liver disorders Patients on chemotherapy Patients with low immunity due to disease or drugs APPROXIMATELY 12% OF CASES ARE FATAL, EVEN WITH MEDICAL CARE

18 What are the symptoms of Legionnaires Disease The symptoms vary but generally include: High Fever Muscle Pains Headaches Chills Difficulty in Breathing Dry Cough Some patients become delirious and suffer from diarrhoea and/or vomiting.

19 Healthy Lungs

20 Lungs showing progression of infection

21 Lungs, after treatment,showing recovery over a number of years

22 22 Cases of legionellosis

23 Which establishments are most at risk? All establishments are at risk but the highest risk is in: Hospitals, Care Homes & Nursing Homes This is mainly due to the susceptibility of the population. Hotels There are several hundred cases of outbreaks of Legionnaires Disease reported each year world wide associated with Hotels.

24 Public Health Laboratory Services Survey An environmental survey, carried out by the Public Health Laboratory Service, of 180 establishments found Legionella to be present, as follows:

25 Building Systems Number Sampled % Positive Hotels Cooling Towers H&C Water 9 67 Hospitals Cooling Towers 3 33 H&C Water Business Cooling Towers H&C Water Residential H&C Water 3 67

26 What systems are likely to pose a risk? Any system that can produce airborne droplets that may contain viable Legionella bacteria, such as: Evaporative Cooling Towers Open & Closed Evaporative Condensers Hot & Cold Water Services Humidifiers, Spray Washers Spa Baths & Pools

27 27

28 28 Summary of UK outbreaks Sept 2001 Aug 2011

29 Where do we start? The Relevant Legislation is: The Health And Safety At Work Act, 1974 The COSHH Regulations, 2002 The Management of Health and Safety at Work Regulations RIDDOR 1995 The ACOP (L8)

30 Summary of HSW Act, sections 2,3 and 4 Section 2 places a duty on employers to ensure the health, safety and welfare of employees as far as is reasonably practicable. It also requires employers to consult with trade union safety representatives on matters affecting health and safety in the workplace. Moreover, employers of more than five people must prepare a written health and safety policy and bring it to the attention of employees Section 3 requires employers to ensure that non-employees who may be affected by work activities are not exposed to risks to their health and safety. Section 4 places a duty on anyone responsible for the workplace to ensure that the premises, plant and machinery do not endanger the people using them.

31 Summary of COSHH reg 6 & MHSWR reg 3 These regulations require employers to make a suitable and sufficient assessment of the risks from any work which is liable to expose any employees to any substance hazardous to health before that work is carried out. Employers are also required to make an assessment of the risks to other persons not in their employment who may be affected by the work activity. They are also required to regularly review the risk assessment, and make any necessary changes as a result of that review.

32 Summary of RIDDOR Cases of legionellosis are reportable under RIDDOR if: a doctor notifies the employer; and the employee's current job involves work on or near cooling systems which are located in the workplace and use water; or work on hot water service systems located in the workplace which are likely to be a source of contamination.

33 Approved Code of Practice (ACOP) L8 The Approved Code of Practice (ACOP) gives advice on the requirements of the Health and Safety at Work etc Act 1974 (the HSW Act) and the Control of Substances Hazardous to Health Regulations 2002 (COSHH) and applies to the risk from exposure to legionella bacteria (the causative agent of legionellosis including Legionnaires' disease). In particular it gives guidance on sections 2, 3, 4 and 6 (as amended by the Consumer Protection Act 1987) of the HSW Act and regulations 6,7,8,9 and 12 of COSHH. The Code also gives guidance on compliance with the relevant parts of the Management of Health and Safety at Work Regulations 1999 (MHSWR).

34 The ACOP & Guidance L8

35 The requirements of The Approved Code of Practice and Guidance L8 1) Identification and assessment of risk. 2) Managing the risk: management responsibilities, training & competence. 3) Preventing or controlling the risk from exposure to Legionella bacteria. 4) Record keeping. 5) Responsibilities of manufacturer, importers, suppliers and installers.

36 Identification and Assessment of Risk The statutory duty holder must ensure that: A suitable and sufficient assessment is carried out to identify and assess the risk of exposure to Legionella bacteria. They have access to competent help to assess the risk of exposure to Legionella bacteria and identify the necessary control measures. The Assessment must include: Identification and evaluation of potential sources of risk. The means by which exposure to Legionella bacteria can be prevented. OR The means by which the risk from exposure to legionella bacteria can be controlled if prevention is not reasonably practicable.

37 Risk Assessment Outcomes An initial risk assessment will either establish if there is a risk or not IF THERE IS NO RISK NO FURTHER ACTION IS REQUIRED

38 What if there is a risk? If a risk is identified then there is a requirement to (so far as is reasonably practicable) take measures to minimise or if possible eliminate the risk. If the risk can be eliminated by removing the system or source of spray then no further action is required. If the risk cannot be eliminated then the next best course of action must be taken to minimise risk.

39 Note! The assessment needs to be reviewed regularly and specifically when there is reason to believe that the original risk assessment may no longer be valid. Management and communication procedures should also be reviewed as appropriate. An indication of when to review the assessment and what needs to be reviewed should be recorded. If a landlord retains responsibilities for a building s maintenance the landlord is the statutory duty holder.

40 Managing the risk: management responsibilities; training & competence The person upon whom the statutory duty falls must appoint a person (or persons) to take managerial responsibility to provide supervision for the implementation of control measures, ie:- The Responsible Person The statutory duty holder may appoint themselves if they are competent to carry that responsibility. Persons who carry out the assessment and design/implement the control measures must have the necessary ability, experience, information, training and resources to carry out their tasks efficiently.

41 Managing the risk: management responsibilities; training & competence (cont.). If the appointed Responsible Person does not have the required expertise, then competent assistance should be enlisted from outside the organisation. In these circumstances the Statutory Duty Holder is required to ensure the competence of any external assistance. Responsibilities and lines of communication should clearly defined. Water treatment service providers should be Category 1 members of the Legionella Control Association. They should also be accredited for the appropriate areas in which they are offering a service. Details of a company s current status can be found on under Directory of Companies

42 The Responsible Person must :- Be a Manager, a Director, or have a similar status and sufficient authority. Have the necessary competence and knowledge of the installation to ensure all operational procedures are carried out in a timely and effective manner. Appoint deputies to act on their behalf in their absence. Ensure that both they and their appointed deputies have sufficient knowledge, information and training to carry out their tasks effectively. Ensure that regular refresher training takes place.

43 The Responsible Person must:- Ensure that the Statutory Duty Holder is kept informed of the status of the systems under their control, particularly if control measures are known to have failed. Ensure that either they, or an appointed deputy, can be contacted at all times.

44 The Deputies The appointed deputies should have: Adequate knowledge of the systems for which they are responsible. Adequate training to ensure they can carry out their tasks effectively. Sufficient information to ensure that they can carry out their tasks effectively. Regular refresher training. Direct access to Responsible Persons to ensure they are kept informed of the status of the systems under their control.

45 Preventing or controlling the risk from exposure to Legionella bacteria If reasonably practicable risk systems should be taken out of use. Where this is not possible there should be a written scheme for controlling the risk. This scheme must be implemented and properly managed and should include: 1) An up to date schematic drawing of the system(s). 2) Written correct and safe operating procedures. 3) The control measures. 4) Checks to be carried out to demonstrate efficacy of the scheme. 5) Remedial actions to be taken should the scheme be shown to be not effective.

46 Preventing or controlling the risk from exposure to Legionella bacteria The risk from exposure will normally be controlled by conditions which do not allow the proliferation of Legionella Bacteria and reduce exposure to droplets, droplet nuclei or aerosols Control measures should include the following: Control the release of droplets, droplet nuclei or aerosols. Where possible, avoid temperatures and conditions that favour growth of Legionella and other micro-organisms. Avoid the use of materials that harbour the growth of bacteria or provide nutrients for microbial growth. Maintain the system and water in clean condition. Use of water treatment techniques. Actions which ensure the correct and safe operation of the system(s).

47 Review and monitoring of control measures If the control measures are to remain effective the condition and performance of the system must be monitored. This should be responsibility of The Responsible Person, where appropriate with assistance from others, and should include: Checking systems performance and that of its component parts. Inspecting accessible parts of the system for signs of damage and/or contamination. Monitoring to ensure that the treatment regime continues to be effective. Frequency and extent of monitoring will depend upon the system but should be at least weekly.

48 Record keeping The responsible person shall ensure that appropriate records are kept. These records must include: The person(s) responsible for carrying out the risk assessment. The person(s) responsible for managing and implementing the written scheme. The significant findings of the risk assessment. Details of the implementation of the written scheme. Results of any monitoring, inspection, tests or checks carried out with the relevant dates. Details of the state of operation of the system i.e. in use/not in use, with the relevant dates.

49 Record keeping The records should be retained throughout the period for which they remain current and at least 2 years after that period. Results of monitoring, inspection, tests and checks along with details of the state of operation of the system should be retained for at least 5 years. These records will be examined by a Health & Safety Inspector or Environmental Health Officer to assess your compliance with the ACOP & Guidance L8

50 Responsibilities of manufacturers, importers, suppliers and installers Whoever designs, manufacturers, imports or supplies water systems that may create a risk of exposure to Legionella bacteria should, so far as is reasonably practicable: a) Ensure that the water system is so designed and constructed that it will be safe and without risks to health when used at work and b) Provide adequate information for the user about the risk and measures to ensure that the water systems will be safe and without risks to health when used at work. This should be updated in the light of any new information about significant risks to health and safety that becomes available.

51 Responsibilities of manufacturers, importers, suppliers and installers Suppliers of products and services, including consultancy and water treatment services, aimed at preventing or controlling the risk of exposure to Legionella bacteria, should so far as is reasonably practicable: Ensure that measures intended to control the risk of exposure to Legionella bacteria are so designed and implemented that they will be effective, safe and without risks to health when used at work. Provide adequate information on the correct and safe use of products taking into account the circumstances and conditions of their use. Ensure that any limitations on their expertise or on the products or services they offer are clearly defined and made known to the person upon whom the statutory duty falls or the person(s) appointed to take managerial responsibility. Ensure that any deficiencies or limitations which they identify within the occupiers systems or written scheme to control the risk of exposure to Legionella bacteria are made to the person upon whom the statutory duty falls or the persons appointed to take managerial responsibility and Ensure that their staff have the necessary ability, experience, instruction, information, training and resources to carryout their tasks competently and safely.

52 Regular Monitoring Frequency Action Responsibility 1. Weekly Flush little-used outlets to drain without release of aerosols. Record. Occupier 52

53 Regular Monitoring Frequency Action Responsibility 2. Monthly Check water temperatures at Sentinel taps Hot water > 50 C after 1 minute Cold water < 20 C after 2 minutes Record. Occupier, Maintenance Contractor 3. Monthly Check Calorifier temperatures. Flow 60 C, Return > 50 C. Record. Occupier, Maintenance Contractor 53

54 Regular Monitoring Frequency Action Responsibility 4. Quarterly or as necessary Dismantle, clean and descale Shower heads and hoses. Record. Occupier, Maintenance Contractor 54

55 Regular Monitoring Frequency Action Responsibility 5. Six Monthly eg. January and July Measure incoming water temperature to cold water cisterns and water temperature remote from float valve. Should be below 20 C. Record. Maintenance Contractor 6. Six monthly Measure cold water temperature rise between incoming main and most distant outlet. Should be less than 2-3 C. Record. Occupier, Maintenance Contractor 55

56 Regular Monitoring Frequency Action Responsibility 7. Annually Take sample and record condition of water from HWS calorifier drains. Water from calorifier drains should be clean and free from visible debris Maintenance Contractor 8. Annually Open and inspect internal surfaces of HWS calorifiers for scale and sludge and clean or descale as necessary. Calorifiers should be clean internally and free from sludge or heavy scaling. Record. Maintenance Contractor 56

57 Regular Monitoring Frequency Action Responsibility 9. Annually Check and record temperatures at a representative number of taps throughout the system on a rotational basis. Occupier, Maintenance Contractor 10. Annually Inspect Cold Water Cisterns and carry out remedial work as necessary. Record work done and report outstanding defects. Maintenance Contractor 57

58 Regular Monitoring Frequency Action Responsibility 11. Annually Physically inspect the hot and cold water systems and check accuracy of Schematic drawings. Note changes. Check for underused fittings and report recommendations. Specialist Contractor 58