Legionella Risk Assessment

[Smunt]

Richlist. I deal with what the inspectors (HSE/CQC) are looking for and interpret that for my clients in order to keep them compliant and safe. If you know what the inspectors expect in terms of competence, can demonstrate your competence with the appropriate training, knowledge and experience, produce a safe and suitable assessment in order to comply with the laws and guidance out there, then that's great and you will have nothing to worry about.

[Smunt]

Chestnut. A hazard and a risk are usually linked. The Elephant is the hazard and the likelyhood of you hitting it at 70mph in your car is the risk (which in my eyes is not negligible). This is what the HSE says:

Hazard or risk? Definition of a hazard

A hazard is something (e.g. an object, a property of a substance, a phenomenon or an activity) that can cause adverse effects. For example:

• Water on a staircase is a hazard, because you could slip on it, fall and hurt yourself.
• Loud noise is a hazard because it can cause hearing loss.
• Breathing in asbestos dust is a hazard because it can cause cancer.

Definition of a risk

A risk is the likelihood that a hazard will actually cause its adverse effects, together with a measure of the effect. It is a two-part concept and you have to have both parts to make sense of it. Likelihoods can be expressed as probabilities (e.g. “one in a thousand”), frequencies (e.g. “1000 cases per year”) or in a qualitative way (e.g. “negligible”, “significant”, etc.). The effect can be described in many different ways. For example:

• The annual risk of a worker in Great Britain experiencing a fatal accident [effect] at work [hazard] is less than one in 100,000 [likelihood];
• About 1500 workers each year [likelihood] in Great Britain suffer a non-fatal major injury [effect] from contact with moving machinery [hazard]; or

The lifetime risk of an employee developing asthma [effect] from exposure to substance X [hazard] is significant [likelihood].

[Chestnut]

Smunt:

1) I am not talking about a combi boiler - only that heat exchange principle is same. The circuit (with reversed tank) I refer to has a standard boiler piped so its primary sealed heating water fills the outer jacket of the separate heat exchanger tank (cylinder) in airing cupboard. The domestic water to be heated for the taps flows through the inner coil and when a tap is opened heat flows from jacket to coil and out to taps. A traditional heat exchanger cylinder uses the jacket and coil the other way round, that is the boiler water goes to coil and heat goes out to domestic water stored in jacket.

2) Definition of risk: You are nearly right but confusing. Risk is not Likelihood. If there is (almost) no likelihood, then there is (almost) no risk regardless of hazard level. There are various BS, EN and ISO standards that specify different mathematical ways of combining Hazard and Likelihood to calculate Risk but the principle is the same. I have studied and carried out a variety of risk assessments for many years. Let us know next time you see a loose elephant on a motorway!

[Smunt]

Chestnut. Risk is assessed from an identified hazard, so if there is no elephant there can't be a risk associated with it. If there was an elephant loose on a motorway then there will be a huge risk. I think you have confused the issue between likelihood of an elephant (hazard) being there and the risk of it being there which are very different things.

A hazard is something (e.g. an elephant) that can cause adverse effects.

A risk is the likelihood that a hazard (elephant) will actually cause its adverse effects.

The Likelihood of an elephant being there can be expressed as a probability, which as you have stated is low in this country.

[Chestnut]

Thank you Smunt. I am not confused. As you now clearly state, Likelihood and Risk are two very different things, Hazard is the third. It is the combination of Likelihood and Hazard that create the amount of Risk.

Here's a fun example of high Likelihood: Likelihood that I shall try to stand up when I get out of bed every morning is very high, about 100%. Hazard is that my centre of gravity will go well above my feet. Risk of immediately falling over is however negligible because my balance is good enough to provide adequate control over the Hazard. One day I may need a grab rail or Zimmer frame, but not yet.

It is frustrating that so many, including professionals, confuse these three different entities.

[Richlist]

Risk,hazard & likelihood....even though I've read the previous posts I'm still confused but it really doesn't matter cos I've now lost interest.....I have a short attention span.

It reminds me of the many other uninspiring, triple groups I've encountered in the past such as mean, median & mode....equally confusing and totally not needed in order to get an'A in statistics.

[chriscommodious]

The HSE have recently had an outbreak of common sense and started to produce helpful guidance. Their section on risk assessments, whilst not specifically directed at the housing sector, will give you an understanding of how an assessment should be structured.

I have worked in Legionella control for over 20 years and there has been a noticeable movement towards over complicated assessments, I guess as a way of justifying the fee - the bigger the document the better. The problem is you end up with something that is unusable which is why the HSE are trying to guide people towards simple assessments. In most cases the assessment for a house should not be more that 1 or 2 pages.

The main risks are

Stagnation during unrented periods - action flush weekly without forming an aerosol.

Showers - recommended sterilise head and hose 3 monthly (add this as a requirement to agreement for tenant to do?).

Tank fed water - make sure the tank is compliant with water regs (lagged, sized to turn over within 24 hours, rodent screen on overflow, tight fitting, vented lid and clean).

Stored hot water - check for stratification - if noticed consider fitting shunt pump to circulate water daily - purge cylinder annually from bottom to remove sediment. Make sure outlets reach >50oC within 1 minute stored water should be 60oC though in a small premises there is more likely a risk of scalding so be wary of this requirement.

Make sure there is no redundant pipework (eg removed a sink from utility room but old pipework still present).

We are a social enterprise and have all our H&S training courses including legionella, fire safety, asbestos available for free (you only pay for the exam if you want it). All RoSPA approved courses, may be useful as offer info on latest requirements. Our company is commodious, 247training.solutions

[Chestnut]

Chriscommodious: Thanks! That's a good simple list that you provide, accept they are hazards and not risks. (I will bore readers again to repeat that a hazard only becomes a risk if it has an associated likelihood. Please see my earlier comments about confusion.)

Of all five hazards you list, only one exists in my tenancy - a shower. But as this is cold fed electric and used daily, I regard its hazard low and consequent risk likewise low.

My conclusion remains as before and agreed by others. Legionella risk assessment for my situation does not justify cost of an expert assessor.

[Richlist]

You only have to look at what has happened regarding EPC certificates in the last few years. Tens of thousands of people trained as assessors.....many of them are now working elsewhere.

The law may require an EPC cert but I can guarantee that large numbers of landlords don't bother....nobody is policing the process and so they get away with it. Legionalla assessments are very likely to go the same way.

[chriscommodious]

@chestnut. Totally agree, these are hazards and like your example the one hazard is low risk. You still need to write that down to prove due diligence and that was the the point I was trying to make, you do not need a qualified assessor to tell you your property is a low risk.

With regards risk matrix - against each hazard score it for contamination, amplification, transmission, exposure, host susceptibility.

So for your shower

Risk of system being infected with legionella:

Contamination low as it is fed from potable mains supply,

Amplification low as there is no residency time within the growth temperature range 20-45oC,

Risk of infecting someone: (required for high risk systems)

Transmission is high as showers disseminate aerosols but this risk is mitigated against the previous low risks

Exposure is high but again a high exposure risk but low likelihood of exposure to a hazardous substance

Host susceptibility - unknown, immunosuppressed ? Elderly? Very young? Again irrelevant as have low risk system

And one final thing, if a professional advises that samples need to be taken tell them where to go, total waste of time and actually states in guidance not needed except when an outbreak is suspected or control methods eg temperature or biocide regime is not in place for a length of time. The presence or lack of legionella bacteria is totally irrelevant, the assessment is about the design and operation of the water system and spot analysis should not be part of that process.

I think I am going to start a blog on this subject with the aim of giving people a useable self assessment along with the training to understand hazard identification, to stick it to the H$S brigade.

[Melboy]

I think I am going to start a blog on this subject with the aim of giving people a useable self assessment along with the training to understand hazard identification, to stick it to the H$S brigade.

Well, whilst this long drawn out topic has been going on I have managed to carry out 3 legionella assessments in accordance with the guidance sheet provided by the Landlord's Association. Signed by me as the competent person and signed by the tenant with an information sheet left for the tenant on legionella and what to do keep it away.

What will be next I wonder? Hazard Safety Check requirement in rented properties? Anything that provides somebody with a non job I would suggest.

I knew of 3 people who did the HIP's assessor course at great expense for them, None of them do it anymore, ( like EPC's. ) At the height of HIP's one of them told me he never got any work anyway to make it worthwhile in carrying on.

EPC's if you can be bothered to have one, cost just £40 around here. Nobody has ever asked to see one from me.

[Grampa]

What will be next I wonder? Hazard Safety Check requirement in rented properties?

Well I can see that as a possibility. A landlord/Leaseholder of a flat in a block has recently been made liable by the high court for a trip hazard (paving slab I think) where his tenant fell and injured himself.

The Hazzard was in the communal area and normally you would think the freeholders block insurance would pick up the tab but not so in this case.

[Chestnut]

Message deleted.

[chriscommodious]

Wow, I was trying to offer some friendly advice with an example of how an assessment is done. Remember you are not the only person reading this - my comments were meant as open information / advice / opinion that may help someone. I have worked in Legionella control for 20 years so wanted to offer something to the party. The risk assessment example was to show the methodology of assessing FOR THE BENEFIT OF OTHERS.

You are clearly a very sensitive, egotistical individual.

[Melboy]

Resurrected for Solent.

[Chestnut]

Solent: To answer your question - Look at the hazards listed by various contributors to this thread and from H&SE and associated guidelines for landlords, and I hope you will conclude you can do this risk assessment adequately yourself at zero cost. I have added a check note to my 6 monthly inventory inspection and warn tenant if I suspect a concern.

A similar process would apply to tripping over a curled up front door mat - a caring landlord will be doing risk assessments automatically in his/her head for all manner of things.

[Legionellaman]

Hi guys

I received an email from our MAs last week saying a new legislation has been passed regarding legionella risk assessments, and as LLs we are required by law to carry out annual tests on each property.

I've googles but can't find any info on this. Have you guys been informed too?

They (the MAs) can do it for us at a cost of £120 per property. Expensive, much?!

Many thanks

[Legionellaman]

Hi

I am Joe from Essential Legionella Services ltd we are a scientific independent testing company for Legionella and all other bacterial problems, we work in partnership with Handy Ladies, who are a professional cleaning company that we have trained to clean to minimise bacteria and legionella, specialising in rental properties.

Please visit our website www.essentiallegionellaservices.com or call me on 07914 100925 to discuss this further.

I have noticed that you have said you will be charged £120 per property for a risk assessment which is expensive considering rental properties are low risk, but still need to comply with legislation. We have devised a full unique service for the lettings industry with Valerie Edward Jones (Ex Professor of Manchester University) and all properties that we assess will be added to our compliance register.

If you visit the HSE website you will also see what is required for landlords.

http://www.hse.gov.uk/legionnaires/

I hope this helps and I look forward to hearing from you.

Thanks

Joe

[Melboy]

The Landlord's Association provided a form with the key points requiring action regarding legionella action. to be taken by domestic landlord's.

Simple enough takes about 20 minutes. Sign and date the form after carrying out the work and hand a copy to your tenant. Job done.

My domestic properties have been done in conjunction with my gas safety check. Any qualified plumber with accreditation & training like City & Guilds is capable of undertaking this work or you could do it yourself.

[Dave A]

Melboy, could you put up a link to the above.

Cheers

Dave

[Melboy]

Melboy, could you put up a link to the above.

Cheers

Dave

I can...... but I think it was Richlist who provided the forum with an A4 size form of instructions to be carried out plus the advice of the RLA on the subject.. I'll have a look through my files.

[Richlist]

Yep Richlist already posted the link with all the details.

It's on this forum somewhere.

[Melboy]

I cannot reproduce the form for you on this forum

So you may need to go to the RLA Website to view the form.

The form is A4 size and lays out neatly a quick yes / no requirement to be carried out . The RLA says that for domestic landlord's this is all that is required of them to satisfy current HSE legistlation.

So imagine these questions and answer's neatly laid out on an A4 Page.

www.rla.org.uk I 03330 142 998 I info@rla.org.uk

V1 – Risk Assess Review – 10/2014

Legionnaires’ Disease Risk Assessment review

To be completed at least once per year.

Property address

Date of review

Review carried out by

Date of original risk assessment

Since the original risk assessment was carried out: -

Has there been a change to the water system or the way it is used by occupants?

Yes No

Has there been a change to the use of the building where the system is installed?

Yes No

Is there new information available about risks or control measures?

Yes No

When testing the temperature of the water in the system, does hot water flow from any outlets at a temperature of below 50C?

Yes No

When testing the temperature of water in the system, does cold water flow from any outlets at a temperature of above 20C?

Yes No

Are the current tenants and their visitors more susceptible due to their age, health or lifestyle?

Yes No

Has there been a case of Legionnaires’ disease associated with the system?

Yes No

If you have answered yes to any of the questions above, a new risk assessment should be carried out by a competent person.

[Chestnut]

Melboy: Thanks! That's very helpful and simple to do during routine inspection visits, as I do.

Except for one point -

How do temperature tests at outlet cope with modern pre-set or thermostatic mixing valves that control water temperature at hot outlet to safe non-scalding 38deg? Do you tick Yes and pass RA to a Competent Person (like your son..)? Or would you simply run your hand over upstream pipes to assess temperatures into mixer OK (as I would do) and tick No?

[Richlist]

1. Convert 38 deg into centigrade to ensure it is not in excess of the spec.

2. Ensure thermostats on water tanks are set at or below the hot water spec of 60 deg C

3. Use common sense to determine if water temp settings meet requirements.