Legionella Control Guidance HSG 274 Part 2 Hot & Cold Water Systems issued 7th April 2014

Important changes to the way the UK’s Health & Safety Executive deal with the control of legionella bacteria and Legionnaires' disease in HOT & COLD WATER SYSTEMS have now been published.
The formal system of legionella control in the UK now comprises the HSE's ACOP L8 (4th edition) and HSG 274 Legionella guidance, which is split into three parts:

• Part 1 - Cooling Water Systems. 2013
• Part 2 - Hot and Cold Water Systems – recently published April 2014.
• Part 3 - Other Risk Systems. 2013

Hot & Cold Water Systems

Hot and cold water systems, covered by the recently published HSG 274 Part 2, are by far the most common form of water system that can potentially create a legionella risk and so these changes are likely to affect you, your staff and your organisation. It is therefore very important that you understand the changes and adjust your legionella risk management systems to remain fully compliant with the law.

10 Items you need to know:

  1. HSG274 Part 2, the guidance covering hot and cold water systems has now increased significantly from 15 to 58 pages... a big increase by any standards.
  2. All risk assessments should now consider both the relative risks associated with legionella bacteria and scalding from hot water.
  3. There is now significantly more information covering water system engineering design, including calorifiers attached to solar heating systems, expansion vessels, point of use water heaters and combination water heaters, clarification on what is a “sentinel” outlet on large multi-loop systems and there is also a simple definition of a low risk system.
  4. New Section: “Residential accommodation: Landlords and shared premises”. This new section gives guidance on how to risk assess and control both domestic and commercial tenanted properties. It is essential that property owners, landlords and tenants understand this new section.
  5. New Section: “Special considerations for healthcare and care homes”. The guidance gives new information on those special considerations where there are susceptible individuals, including revised guidance on acceptable levels of legionella bacteria in water systems. We are already advising senior health and safety teams and facilities operators in the healthcare sector on the new rules to help them to maintain their compliance status.
  6. Commissioning of new buildings has in the past resulted in significant legionella growth. There is now a significant section devoted to this topic which includes guidance when “mothballing” water systems for times of non-use. This is an important area for builders, developers and other owners of property.
  7. Potential problems are highlighted for hot water systems with secondary and tertiary loops; systems that are prevalent in hospitals and healthcare facilities. The guidance also introduces new recommended requirements for routine monitoring.
  8. New routine monitoring recommendations are now included, including point of use heaters, combination heaters, TMV’s and others. Additional routine monitoring tasks will be required as a result.
  9. Significantly increased section on the use and control of chemical water treatments and biocide systems. We are able to advise in detail on this increased guidance.
  10. Appendices included in the new guidance define much broader requirements for the risk assessment and written control scheme including the need for incident planning.

To read this document in full click on this link /HSG-274-Part-2--7-April-2014.pdf

What is next? You need to review your Risk Asseessments so they will be in line with the new guidance.

Why? Beacause of the below (C) that is stated in the ACOP L8:

Para 47 The record of the assessment is a living document that must be reviewed to
ensure it remains up-to-date. Arrange to review the assessment regularly and
specifically whenever there is reason to suspect it is no longer valid. An indication
of when to review the assessment and what to consider should be recorded. This
may result from, eg:
(a) changes to the water system or its use;
(b) changes to the use of the building in which the water system is installed;
(c) the availability of new information about risks or control measures;
(d) the results of checks indicating that control measures are no longer effective;
(e) changes to key personnel;
(f) a case of legionnaires’ disease/legionellosis associated with the system.