The Health and Safety at Work Act still applies in the current situation and as such an employer or those in control of premises must continue to manage any risk arising from their activity and this includes Legionella control. Dutyholders implicated in an outbreak of Legionnaires’ disease resulting from actions taken for COVID-19 precautions are not likely to have any exemption from prosecution.
While controls in place may need to be adapted to changing circumstances, Dutyholders must still be able to demonstrate control of risk to a reasonably practicable level. Many Legionella control activities are monitoring measures rather than interventions and there may be some flexibility in how these are maintained during the COVID-19 situation. Other systems may require interventions by service providers to remain safe and these should not be neglected. Each system should be considered individually.
Our recommendation is to always follow the latest government advice available at www.gov.uk on measures to take and how to work.
Each Dutyholder must make their own determination for each circumstance, but the following principles should be considered when making decisions on what to do to control Legionella during the COVID-19 outbreak:
Decommissioning of water systems within buildings should be undertaken by a specialist as it’s not as simple as draining down the systems. Systems are normally left filled with water for mothballing and not drained down, as moisture will remain within the system enabling biofilm to develop where there are pockets of water or high humidity. The water in the system also helps to avoid other problems associated with systems drying out, including failure of tank joints and corrosion in metal pipework.
Recommissioning of water systems within buildings should be undertaken by people who are trained and competent to do so, due to the potential increased levels of biological activity. RPE should be worn and specialist measures undertaken to ensure the system is brought back online safely.
Sampling to BS7592 should be considered to ensure the system is fit to be placed back in service, these samples should be taken 2-7 days post commissioning and analysed at a UKAS registered laboratory which is accredited to undertake the sample type required. Follow up samples may need to be considered as part of the recommissioning plan.
As a leading environmental consultancy, Franks Portlock can assist with all the above and we train our staff in personal hygiene and hand washing, reducing the risk of infection and contamination, with the use of alcoholic wipes and hand sanitisers. Site work must be kept to an absolute minimum, however where this is unavoidable, Franks Portlock staff follow the government guidelines to reduce the risks of contamination and have a wealth of experience in avoiding cross contamination due to years of working with hazardous and carcinogenic substances.
At Franks Portlock we have over 100 years of combined experience in environmental matters, including the disinfection and control of pathogens. During these unprecedented times, we offer, in addition to the Water Hygiene work, infection control, by the implementation of high traffic area disinfection.
For Franks Portlock Consulting Limited
Sean Green, Head of Business Operations (Water Hygiene)
If you need any further advice or assistance, please do not hesitate to contact us.