Leisure centres with spa facilities are among businesses urged to do more to protect workers and members of the public from Legionella risks.
While most are at least aware of the PWTAG (Pool Water Treatment Advisory Group) Code of Practice which provides pool operators with a structured plan for the technical operation of their pool practice, relatively few are aware of the key importance of a comprehensive risk assessment.
HSE Guidance stresses the need for measures to be in place to control identified Legionella risks and that these are reviewed regularly. So, any management plan is only as good as your understanding of the premises-specific risks arising from the system itself (technical management) and the way it is used (operational management). In the case of spas, it can even mean the need to check water quality as regularly as every two hours depending on patterns of usage.
Only where risks have been properly assessed can you be confident that you can implement the most effective control measures and understand everyone’s role and responsibilities.
A risk assessment (backed up by an accurate schematic and asset register of your system) identifies any reasonably foreseeable risks to health, and advises on the necessary precautionary measures that need to be taken to prevent, or adequately control, the risk. The risk assessment also enables the person on whom the statutory duty falls (pool operators and managers) to show that all the steps needed to prevent or control foreseeable risk have been considered.
Ideally, risk assessments should be undertaken before a new maintenance regime is put in place – or as soon as possible afterwards. This is especially important for organisations who prefer to manage routine inspection and flushing work internally, rather than pay third parties to come in and perform these routine tasks. That can be a logical approach that offers significant cost savings, but it’s probably still worth calling in the professionals to set up the maintenance and independent laboratory sample testing regimes in the first place. This will ensure the routine is aligned with identified risks.
What if, with the best will in the world, you still return a positive lab test result?
Don’t panic, listen to your advisers and take a structured approach to disinfection and removing the root cause. Of course, already having that current risk assessment and comprehensive knowledge of your system will speed the whole process up and get you back to normal operations all the sooner.