Legionella bacteria can pose a significant health risk when they proliferate in water systems, leading to potentially fatal illnesses such as Legionnaires' disease. To prevent outbreaks, it is crucial to implement effective control measures and strategies, one of the most important being a Written Scheme of Control. This document is a key part of ensuring that the necessary procedures are followed to keep water systems safe and free from Legionella.
What is a Written Scheme of Control for Legionella?
A Written Scheme of Control for Legionella is a comprehensive risk management document that clearly identifies the measures required to control the risks from exposure to Legionella bacteria. It specifies how these measures are to be implemented, managed, and maintained to ensure that control over water systems remains effective. The scheme must be practical, actionable, and relevant for all stakeholders or responsible persons involved in the management of water systems, such as building owners, employers, and maintenance personnel.
It is important to note that the Written Scheme of Control is separate from the Legionella risk assessment. While the risk assessment identifies potential hazards and assesses the risk of Legionella, the written scheme focuses on the specific actions to control and mitigate those risks.
The Legal Requirement for a Written Scheme of Control
According to the Health & Safety Executive's (HSE) Approved Code of Practice (ACOP) L8, which governs the control of Legionella bacteria in water systems, a written scheme must be developed and followed when there is a foreseeable risk of exposure to Legionella bacteria.
You can identify if there will be a foreseeable risk if you have water systems such as water tanks and showers.
The HSE guidance (paragraph 58) states:
"Where the [risk] assessment shows that there is a reasonably foreseeable risk of exposure to Legionella bacteria, the use of water systems, parts of water systems or systems of work that lead to exposure must be avoided so far as is reasonably practicable. Where this is not reasonably practicable, there should be a written scheme for controlling the risk from exposure that should be properly implemented and managed."
Without an effective written scheme in place, it is impossible to claim that a water system is under proper control.
What Should a Written Scheme of Control Include?
A well-structured Written Scheme of Control provides a clear outline of the specific actions required to manage and mitigate the risks associated with Legionella bacteria. Key components of the scheme include:
Risk Assessment: The scheme should begin with a summary of the findings of the Legionella risk assessment, which identifies the risk points and vulnerable areas within the water system.
Control Measures: Detailed steps must be outlined to prevent Legionella growth, such as maintaining the correct water temperature, ensuring proper water treatment, and implementing regular cleaning and disinfection of water systems.
Monitoring Procedures and any control measures: The written scheme should specify how to monitor the effectiveness of control measures, including temperature checks, water sampling, and testing for Legionella bacteria.
Maintenance and Inspection Schedules: The document should provide guidelines for regular maintenance, cleaning, and inspection of systems like cooling towers, hot water tanks, and plumbing systems to prevent Legionella colonization.
Responsibilities: It should clearly define who is responsible for the implementation and ongoing management of the control measures, including monitoring, testing, and addressing any issues that arise.
Corrective Actions: If monitoring reveals that control measures are failing or Legionella bacteria are detected, the written scheme should outline the corrective actions required to address the issue promptly.
The Role of Written Schemes in Preventing Legionella
A Written Scheme of Control serves several critical functions in the prevention and management of Legionella risk:
Ensures Compliance: In many countries, particularly in the UK, a written scheme is legally required for all premises with water systems that could support Legionella growth. It ensures compliance with regulations, such as the Health & Safety Executive’s ACOP L8.
Protects Public Health: By clearly outlining the steps needed to control Legionella, the scheme helps prevent outbreaks of Legionnaires’ disease and protects the health and well-being of staff, customers, and residents.
Demonstrates Due Diligence: Having a documented written scheme provides proof that an organisation is taking all necessary precautions to mitigate the risks of Legionella. This can be crucial in the event of an audit, inspection, or legal challenge.
Ongoing Risk Management: The written scheme provides a framework for continuous management of Legionella risks, ensuring that water systems are properly maintained and that risks are regularly reviewed and controlled.
What is included in a written scheme from Absolute Water Compliance?
Introduction & Policy Statement
Systems Register
Key Personnel & Contact Details
Communications Chart
Control Scheme
Description of Safe Operation
Method Statement & Guidance
Task Planner & Responsibility Register
Risk Assessment Implementation & Review
Management of non-conformance
Additional Control Measures
Procedure in the event of persons contracting Legionnaires’ disease
Procedure in the Event of Positive Legionella Samples
Training Implementation & Review
Shut Down & Start Up Procedures
Schematic Drawing
Expert Legionella Risk Management Support
For organisations seeking assistance in developing or reviewing their Written Scheme of Control for Legionella, expert advice is available. Absolute Water Compliance are leading experts in Legionella compliance and will provide an unrivalled service offering professional services, including risk assessments, water testing, compliance audits, and the development of written schemes of control.
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