Under Ireland’s health and safety laws, business owners and those controlling premises must understand and manage the risk of Legionella within their workplace. A risk assessment is the best and most effective way to achieve this.
A Legionella Risk Assessment (LRA) is an essential water hygiene management procedure to identify potential risks and ensure the safety and compliance of engineered water systems in the workplace.
The UK HSE’s ACOP L8 states that legionella risk assessments should be reviewed regularly and especially if there’s reason to suspect it’s no longer valid.
In this blog, we will discuss how often should a risk assessment be reviewed and situations that require more frequent reviews.
HPSC’s National Guidelines for the Control of Legionellosis in Ireland, 2009 clearly states that once the risk assessment is completed and documented, it should be reviewed regularly i.e. at least annually. In addition, it will need to be repeated more frequently in situations where the original assessment is considered to be no longer valid.
ACOP L8 originally recommended carrying out legionella risk assessments every two years but later removed a set timeframe from the guidance. However, ACOP L8 says the legionella risk assessment should be seen as a living document that must be reviewed regularly to make sure it remains up to date.
In our experience, the frequency of the update will depend on the risks associated with any given system defined in the risk assessment document and changes that affect it over time.
The risk assessment must be updated when the Duty holder reviews it and believes it is no longer current or valid. Depending on the risks associated with the system this could be years for a low-risk property where nothing has changed to much more regular updates for a high-risk system.
Based on the risk factors identified in your facility, a risk assessment would suggest a review date, but should any of the following changes occur in the meantime the risk assessment must be immediately updated.
If there are significant changes to the water system, a fresh risk assessment should then be undertaken. Changes to water systems could include installation of a new cooling tower, addition or removal of cold storage tanks, installation of new fountains etc.
The risk assessment must also be updated if there is any new construction work that affects the water system.
Changes to any given water system can result in dead legs being created, which can provide a thriving environment for legionella bacteria to grow and multiply. Changes in pipework or the layout of the system will also need to be assessed and included in an update.
This is the reason why up to date schematic drawings showing the layout of the system within a building must be included within a legionella risk assessment. Should the layout change or any of the assets identified on the schematic change then the drawing must be updated to reflect these alterations.
A change of use may indicate people are now using the building that could fall into an age group that is at greater risk of contracting Legionnaires’ disease if exposed to contaminated water or spray.
Alternatively if the use of the water in the building changes, for example; fewer people are using the building so the water in the system stagnates and little-used outlets are effectively created. A building can have an oversized amount of stored water if the use changes from residential to commercial for example.
In larger buildings with complex water systems, established control measures may stop working. With many more potential issues that could arise, regular testing may reveal legionella levels have risen beyond acceptable safe levels.
If the monitoring results indicate the control measures are not working or are ineffective then it is crucial to review the legionella risk assessment to make alterations to the regime or recommend an alternative method of controlling the risk of legionella bacteria growing within the system.
Identifying why existing control measures no longer work as they previously did should help to identify where the issue has come from, allowing targeted remedial action to be taken along with further validation testing.
Employers have a requirement to appoint individuals to take responsibility for managing the risk from legionella bacteria on their sites.
A legionella assessment report should also be reviewed if key personnel, such as the responsible person or key contractors have changed
If regular water testing reveals the presence of legionella in your water systems – or even if there are new grounds to suspect that legionella is present – legionella risk assessment must be reviewed without delay to highlight areas of concern and where remedial action may be required.
Occasionally the HSE will issue new guidance regarding the control and prevention of legionella. If this happens, you may need to review your risk assessment to ensure that it complies with the new rules and implement new recommendations into the control scheme.
There is no hard and fast rule to say how often you should undertake a legionella risk assessment review. At the very minimum, you need to complete one at least every year, but in many cases, it is wiser – and may be a legal duty – to undertake them more frequently.
The risk assessment frequency should be determined by the level of risk and referencing review criteria.
By keeping your risk assessment up to date and you can be sure you are taking all the preventive actions to prevent and control the risk of legionnaires disease within the properties you are responsible for.
It is best to hire the services of an expert company that can provide qualified and experienced specialists to undertake a comprehensive risk assessment.
If you are in any doubt about the safety of your building call us today and speak to one of our legionella experts.
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