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Health and Safety Executive
Control of Legionella
Howard WhittakerPrincipal InspectorFOD Leeds
Risk Systems
Spa Pool Guidance
Health Technical Memorandum
Notification to LA of operational cooling tower
• Notification of Cooling Towers and Evaporative Condensers Regulations 1992
• Regulation 3
Approved Code of Practice (L8)
• Identify and assess sources of risk
• Prepare a scheme for preventing or controlling the risk
• Implement and manage the scheme
• Keep records and check that what has been done is effective
• Practical advice
Risk Assessment should include:
• the management responsibilities and name of the responsible person;
• population exposed and risk from water systems;
• an assessment & adequate schematic of the system;
• details of precautions taken including:
- the control method/s – inspection / monitoring and maintenance programme (eg checking the system is kept clean);
• records of operation, monitoring and remedial work;
Responsible person
• Take managerial responsibility – change management
• Supervise
• Working knowledge of– Risks– Controls– Target levels– Action levels
Management questions
• Has a ‘responsible person’ been
identified?
• Is there a deputy?
• Are there contact details?
• Are roles and responsibilities clearly
defined?
Roles and responsibilities
• Responsible person
• Water treatment company
• System operators
• Contractors
• Subcontractors
THE MAR OF POPMAR
I THINK I KNOW
I HOPE I KNOW
I KNOW I KNOW
No Legionella risk assessment
No Responsible person for Legionella
No water treatment chemicals
No monitoring of water treatment
Poor communication
Unclear lines of responsibility
Failure to act on advice/raised concerns
Poor management of contractors
Inadequate training/knowledge base
Individual failings
What went wrong?
• Previous cntract terminated in spring 01
• Failures in the procurement of the replacement contract
• Water management scheme excluded from contract
• Little/no documentation in existence
• Concerns brought to the attention of Design Services Group Manager
• No legionella risk assessment in place
• No/poor control of contractors
• Biocide drums empty since Dec 01
• Lack of/poor health & safety management by the council
Manchester Blitz
• 18 sites visited (31 towers)
• 15 water treatment companies
• 3 towers condemned by the client
• 1 no drift eliminator
• 1 No risk assessment
• Roles and responsibilities between company and WT company
• 3 Companies, No schematics (2 needed updating)
• 4 Companies, Deadlegs
Common Issues 1)
• Poor provision for access to towers in general.
• Routine physical checks not being carried out.
• 6 monthly cleaning & disinfection not carried out (no supporting evidence / justification for less frequent cleaning.
• Packing not removed (no evidence to support quality of pack cleaning).
• Towers found in poor physical condition.
• Poor communication between operator & WTC in terms of roles and responsibilities.
• No documented close-out on remedial actions.
• Generic method statements for cleaning
Common Issues 2)
• HSE Safety Notice July 2012 after review of outbreak causes.
• 90% failure to identify risk or have effective control scheme.
• Departures from planned maintenance and cleaning schedules.
• Changes in the process.
• Staff / contractor changes.
• Intermittent use of plant.
• Unusual weather conditions.
Advice for senior managers
• Seek assurance that effective controls in place.
• Ensure MAR.
• Ensure training and competence.
• Roles and responsibilities defined.
• Adequate control of contractors.
• Act on information.
The audit checklist