Training

Past evidence suggests that inadequate Management, lack of Training and poor Communication have been identified as contributory factors in outbreaks of Legionnaires Disease.

The Approved Code of Practice & Guidance: Legionnaires’ Disease (L8) has emphasized the need for trained and technically competent staff involved in Risk Assessments, implementing the written scheme and Water Systems Monitoring.

In carrying out the water system Risk Assessment, the person or whom the statutory duty falls (Duty Holder), needs to have access to competent help and advice. Advice and help may not necessarily come from within the organisation but may come from a service provider. Employers are required to consult employees or their representatives about the process for getting competent help and advice.

Recent high profile Legionnaires disease outbreaks associated with corporate manslaughter charges clearly highlights that organizations need to have an understanding of their duty and care with regard to operating water systems.

The Duty Holders should appoint a person to take on managerial responsibility for controlling any identified risk of exposure from the Legionella Bacteria. The “Responsible Person” should have sufficient authority, competence and knowledge of water systems. Where help and advice is drawn from outside the organisation, all reasonable steps need to be taken to ensure competence of those not directly under their control. The use of consultants and contractors does not absolve the Responsible Person of their legal duties under Section 3 of the HSWA.

It is the duty of the Appointed “Responsible Person” within an organisation to take reasonable steps to ensure the competence and suitability of involved staff that carry out control measures. Although training is an essential part of achieving competence, it is not the only factor, experience, knowledge and other personal qualities are also needed to undertake a task safely.

Training should focus especially on the requirements of the Approved Code of Practice & Guidance: Legionnaires disease (L8), which applies to the control of legionella bacteria in any undertaking involving a work activity and to premises controlled in connection with a trade, business or other undertaking where water is used or stored and where there is a means of creating and transmitting water droplets which may be inhaled, thereby causing a reasonably foreseeable risk of exposure to legionella bacteria.

Training needs to cover areas where a reasonable foreseeable risk of exposure to legionella bacteria exists:

  • Water systems incorporating a cooling tower; evaporative condenser;
  • Hot and cold water system;
  • Other plant and systems containing water which is likely to exceed 200C and which may release a spray or aerosol (i.e. a cloud of droplets and/or droplet nuclei) during operation or when being maintained.

A suitable and sufficient assessment is required to identify and assess the risk of exposure to legionella bacteria from work activities and water systems on the premises identifying any necessary precautionary measures.

A wide range of other issues also need consideration in addition to the competence of the organisation personnel or consultants and contractors;

  • Communication and management procedures
  • Record keeping
  • What to do in the event of a control procedure lapse

Training and the ability to demonstrate a measured level of competence by assessment and ideally third party accreditation is fast becoming increasingly important to organizations wishing to demonstrate due diligence in ensuring staff, consultants and contractors are able to fulfil their duties in a safe competent manner.

Over time things can change, new information may become available which could require a change in monitoring or risk assessment. New standards may need to be implemented changing the requirements, for example of records. Refresher training is therefore necessary to ensure not only standards are maintained, but to explore new information, new methods and new technology which may help in reducing the risks from Legionnaires’ disease.

Third party accreditation is available over the diverse area of skills and knowledge needed to comply with current standards. One example is City & Guilds. Leading training companies organise a wide range of joint qualifications in Legionellosis, which include:

  • The Role of the Responsible Person,
  • Hazard and Risk Assessment of Water Systems within Buildings,
  • Hot & Cold Water Systems,
  • Cooling Towers,
  • Air Conditioning and Water Regulations for Building Services Personnel & Contractors,
  • Other forms of accreditation are available for Disinfection of Water Systems and the Monitoring of Water Systems.

Article by:
Tony Green
Develop
T: +44 (0)1347 825518
E: tony.green@develop-solutions.co.uk