The revised Approved Code of Practice (ACoP) and guidance Legionnaires’ disease: The control of Legionella bacteria in water systems has some important changes that could affect you as a provider of residential and commercial accommodation. This short guide will help you understand what these changes mean for you, and the action you will need to take to ensure that the risk from exposure to Legionella in the premises you are responsible for is properly controlled. To do this you will need to consult the ACoP and guidance for further detail on managing and controlling Legionella risks – Omit this sentence.
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What are the changes to the ACoP L8?
The most significant change for you, as provider of residential accommodation, is the removal of the 300 litre limit for hot and cold water services. This was an artificially chosen limit and its removal means that all premises with a water system are now within the scope of the revised ACoP. Also, recent research shows that Legionella does occur in smaller domestic systems.
Practical guidance on how to comply with your new legal responsibilities regarding control of Legionella is given in the ACoP. It is important you use the current version of the ACoP as it has been recently updated. Important changes that were made to the ACoP and guidance include:
- Keeping records for a minimum of five years;
- Water treatment companies and consultants must show their service is effective;
- Recommend guidance linked to the appropriate sections of the ACoP;
- Details on all aspects of risk assessment control; and
- Inclusion of tables which detail the monitoring requirements for cooling towers, and hot and cold water systems.
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What do I have to do to comply with the law?
Legionella bacteria can multiply in hot or cold water systems and storage tanks in commercial and residential properties, and then be spread e.g. in spray from showers and taps. Although the generally high throughput and relatively low volume of water held in smaller water systems reduces the likelihood of the bacteria reaching dangerous concentrations, you must still carry out a risk assessment to identify and assess potential sources of exposure. You must then introduce a course of action to prevent or control any risk you have identified.
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Assessing the risk
It may be possible for you to assess the risk yourself, but if you do not feel you have the right skills, you can obtain help and advice from our organisation. When we carry out a risk assessment, we consider the following:
- Are conditions right for the bacteria to multiply, e.g. is the water temperature between 20˚C and 45˚C?
- Are there areas where stagnant water occurs (deadlegs), e.g. pipes to a washing machine that is no longer used?
- Are there infrequently used outlets, e.g. showers, taps?
- Is there debris in the system, such as rust, sludge or scale (often a problem in old metal cisterns), that could provide food for growing Legionella?
- Are there thermostatic mixing valves that set a favourable outlet temperature for Legionella growth?
- Are any of your employees, residents, visitors etc vulnerable to infection, e.g. older people, those already ill?
Answering ‘yes’ to any of these questions suggests there is an increased risk of your residents being exposed to Legionella and falling ill.
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What should you do if you identify risks?
Introduce proper controls, which could include disinfection of the system – you will need to refer to the ACOP for guidance on the action you should take. As the design, maintenance and operation of the system are crucial in controlling the growth of Legionella, any action you take is likely to include the following:
- Ensuring water cannot stagnate anywhere in the system, e.g. remove redundant pipework, run taps/showers in unoccupied rooms;
- Keeping water cisterns covered, insulated, clean and free of debris;
- Insulating pipework;
- Maintaining the correct temperature at the calorifier (i.e. the hot water cylinder);
- Advising maintenance staff working on the system about the risks and the control measures you are taking and the precautions they can take, such as flushing through showers following a period of non-use.
Note: raising the temperature of your warm water is one way to control Legionella growth, but could also increase the risk of burns and scalding. You will need to consider points like this when you do your risk assessment and decide which control measures to use.
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