After a risk assessment is completed, a written scheme of control must be prepared and implemented to control the risk of legionella in your water systems.
A key element in the legionella risk management programme involves keeping and maintaining records. Having an effective monitoring programme and keeping records is essential to demonstrate that your water systems are well managed and everything is in control.
However, not everyone is clear on how this should be done, what should be recorded and how long the records should be kept?
In this blog, we discuss everything about legionella record keeping and how your organization can stay compliant with legislation.
Why are records needed?
It isn’t enough to prepare a legionella control plan – you need to be able to show on-demand any records of tests, non-compliances raised and the resulting actions where applicable.
Also, that any actions resulting from a non-compliance are complete and the results are back within the control parameters.
Record keeping is not just ‘paperwork’, but has many purposes and benefits.
- It ensures key information is easily retrievable and can be passed on from one person to another, ensuring consistency and continuity. (e.g. Appointed responsible person changes)
- It ensures that the organization can demonstrate compliance with their legal duties under health and safety law.
- It provides a starting point for future decision making.
- It enables senior managers to monitor water safety.
Keeping records of the assessments, results and actions taken will also prove very handy in an event of a safety audit. When auditors audit an organization, they will try to find as many loopholes and fallbacks. The records can provide a comprehensive paper trail, proving to auditors that the right approach has been taken to keep risks under control.
Are you legally required to keep records?
Maintaining & retaining vital records is no longer just a good business practice – it’s a necessity. Clear, consistent, and organized records are important for maintaining compliance and avoiding future issues.
HPSC’s Guidelines for Control of Legionellosis in Ireland, 2009 states “The responsible person(s) appointed must ensure that appropriate up-to-date records relating to the control scheme are kept.”
The records being maintained form documented evidence to the HSE about the effectiveness of the monitoring programme being carried out.
What should be recorded?
As part of the Legionella risk management plan, organizations should be recording everything which includes monitoring, inspections, and maintenance tasks.
Anything of significance discovered during the risk assessment should be noted, along with all inspection dates, tests, and other similar incidents.
Precautionary measures and treatments, monitoring results and remedial work should be logged and signed or initialled by the person who has carried out the work. Sufficient information should be recorded to show what measures have been taken and how they have been monitored. The detailed information required in the log will depend on the type and complexity of the system or water service to which it applies.
The records should include the following details:
- Names and positions of person(s) responsible for carrying out the various tasks under the written scheme i.e. responsible for risk assessment, managing and implementation of the control scheme
- Plans and schematic drawings of the systems
- Details showing the current state of operation of the system e.g. when the system or plant is in use and if not in use whether it was drained down or not
- The significant findings of the risk assessment
- The written scheme of actions and control measures required and details of their implementation
- The results of any monitoring, inspection, test or check carried out, and the dates
- A log detailing visits by contractors, consultants, and other personnel. The remedial work required and carried out and the date of completion
- The signature of the person carrying out the work or other form of authentication where appropriate i.e. contract specification
- Copies of contractor’s method statements
- Cleaning and disinfection procedures and associated reports and certificates
- Results of the chemical and microbiological analysis of the water
- Information on other hazards e.g. treatment chemicals
- Personnel training records
- Review meeting notes and actions
- Product information and chemical/biocide safety data sheets.
The risk can change as the water systems are added or removed, so it is critical that the organization’s approach to managing risk is dynamic and this can be evidenced by suitable record keeping.
How long should the records be kept for?
Records should be retained for the period in which they remain current and for two years following review. All monitoring and maintenance records need to be for a minimum of five years
All records should be signed by those persons performing the various tasks assigned to them.
Making the leap to digital record keeping
Most companies have their own method of keeping records. Records can be kept electronically or as hard copies – as long as the information is there and readily available, it does not matter how it is kept.
However, it is generally recommended to manage records electronically using a software. A laborious paper-based process has the potential for mistakes and misinterpretation of data. Therefore, the saved time and costs associated with an electronic format system all contribute to improved efficiencies and a better way of working.
Once an electronic record keeping system is established, all the historic records can be retrieved with just a few clicks.
Are You Compliant?
Keeping records is the only way to stay on the right side of the law. Organizations must ensure all their records are legible, complete and up to date.
Records form documented evidence to relevant authorities that you are managing risks present in your water systems effectively. Failure to demonstrate compliance could land you in trouble and result in heavy fines.
Celtic Water Solutions works is a leading water hygiene service provider in Ireland offering a comprehensive range of water safety risk management solutions. Our experts can provide advice and support to help you identify the most appropriate strategies for the ongoing management of water systems in your facility.
If you need more information about our water safety risk management and record keeping, feel free to speak to one of our consultants. We would be happy to guide you and offer the best possible solution based on your unique requirements.
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