Author: Paul Limbrick, Senior Consultant, Water Hygiene Centre Ltd
Good water hygiene management within school properties can be distilled into the following areas:
1 – Establishing the level of water hygiene risk;
2 – Devising an action plan proportionate to risk;
3 – Evidencing how risk has been suitably managed.
ACoP L8 and HSG 274 Part 2 provide practical advice and guidance on how this can be achieved – to help ensure compliance with health and safety laws.
Establishing the level of risk within school properties can be further compartmentalised into two main areas:
1 – Management policy;
2 – Operations.
Starting with management policy; it’s important to identify a hierarchy of authority (communications pathway/organogram) for water hygiene management ensuring that those responsible are demonstrably competent to undertake their role. Doing so will help the organisation to suitably delineate between management and operational water hygiene responsibilities. Moreover, estates, facilities and/or caretaking staff will invariably accept responsibility for planned preventative and reactive maintenance tasks (as ‘authorised’ or ‘competent’ persons), whereas staff members with a strategic water hygiene responsibility (often estates) may accept responsibility for managing the organisational written scheme of control (sometimes referred to as the water safety plan).
The responsibility to manage and deliver the organisational written scheme of control typically falls within the role of the ‘responsible person’ (RP). Nominating a demonstrably competent person (known as the RP) for water hygiene is a legal requirement and is a role of significant responsibility as the duty holder, or ‘directing mind’ of the organisation – often the Chancellor or Principal, may be the head teacher of a school (depending on the type of school) and may not necessarily possess the technical knowledge, qualifications, water hygiene experience or expertise to adequately execute the duties of the RP and therefore authority may be delegated by the duty holder to an RP. This may help to ensure that the estate is managed in accordance with accepted practices and that assurances are provided to occupiers of the estate (teaching staff, students) regarding protection from waterborne pathogens such as Legionella and associated infection and disease.
Whilst many of the operational and managerial water hygiene responsibilities may be delegated, it is noteworthy that the duty holder will retain accountability for ‘water and Legionella risk’. It may be prudent to consider this when planning the resources and budget required to ensure that all health and safety concerns are adequately addressed. The threat from Legionnaires’ Disease is considered ‘preventable’ and when contracted from an estate, invariably there will be legal ramifications…
Once the management structure has been agreed and formalised within a policy document, water management considerations now become more ‘operational’. For example, a good starting point for a school, as for any organisation, would be to commission a site-specific water risk assessment with accompanying schematics. Carrying out a site-specific risk assessment is an absolute requirement under health and safety law. Provided that the risk assessment is accurate and completed in accordance with British Standard 8580-1 then the full extent of the water safety risk will be captured. The risk assessment should include a survey that includes all the systems that may contribute to or cause a risk of waterborne infection. Risks should be evaluated and quantified based on the likelihood of Legionella contamination within a given system and the consequence of infection from this bacteria, using a scoring system for example.
School water systems that could present a risk will more than likely include, but not necessarily be limited to, the following:
- Domestic cold-water systems – cold water (i.e. less than 20°C) is to be achieved at the outlet within two minutes. This should be confirmed by monthly monitoring from sentinel outlets (i.e. those nearest and farthest from the water source);
- Domestic hot-water systems – hot water should be heated to at least 60°C and be distributed to all parts of the system at 50°C or above. Hot water should achieve temperature within 1-minute of opening the outlet. This should be confirmed by monthly monitoring of sentinel outlets or, where there is pumped hot water circulation, by monitoring the temperature at the farthest point on the recirculating pipework;
- Showers – ensure that these outlets are cleaned and descaled at least quarterly and used or flushed at least once weekly. If showers are infrequently used they should be removed or flushed regularly. Flushing activities are to be captured in a documented programme with records kept as evidence;
- Wash hand basin tap outlets – ensure that all outlets are used or flushed at least once weekly. Similarly, if there are infrequently used outlets then they should be removed or captured in the aforementioned flushing programme;
- Cold water storage tanks (stored cold water) – ensure that temperature within the tank is less than 20°C and that storage capacity does not exceed 24-hours of supply;
- Hot water generators/boilers (stored hot water) – stored hot water should be no less than 60°C and therefore flow at no less than 60°C from the boiler;
- Thermostatic mixing valves (TMVs) – depending on the asset which the TMV is serving, then water temperature should be regulated to 41°C +/- 2°C in order to mitigate scald risk. However, this falls within temperature range that encourages the growth of waterborne bacteria (20-45°C ) and therefore these risk systems should be dismantled, cleaned, disinfected and functional checks at least annually.
The HSE’s HSG274 Technical Guidance, Part 2, Table 2.1 provides practical guidance on the minimum requirements for the management of these systems. Therefore, whilst it’s not mandatory to follow the guidance, bear in mind that should the guidance not be followed then an organisation will need to demonstrate that they have achieved either an equivalent or better standard.
Once the risk assessments have been completed, an assessment of perceived inherent and actual risk will be provided by the surveyor. In practice, this often generates recommendations on how water safety risk can be reduced within the estate. The risk assessment can therefore be used to inform the written scheme of control and assist with the development of an action plan that identifies the corrective action to be taken as well as realistic timescales for completion. Schools, as with all organisations, must at this stage identify what is reasonable and practicable to include within the action plan to help ensure that the water safety management approach remains sustainable for the organisation. Accepted health and safety principles in the UK encourage a balance between risk, cost and difficulty in the actions that are taken; which may necessitate the inclusion of some works and the derogation of others.
Finally, for all planned preventative maintenance works or reactive maintenance works, it is imperative that comprehensive and complete records are kept and are easily accessible. A failure to provide enough evidence to demonstrate that a system is under control could be interpreted as a failure to ensure that service users are safe.