Managing Legionella risk and promoting good water hygiene in industrial and manufacturing premises

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Ryan Lloyd-Davies is CEO and Technical Director of ORBIS Environmental Ltd and the company’s Principal DSEAR Consultant. With around 20 years’ experience in health, safety and compliance, Ryan specialises in DSEAR, ATEX, hazardous area classification, fire and explosion risk, flammable substances and combustible dusts. He has worked across MOD, aviation, fuel, chemical, NHS, prison, manufacturing and emergency response environments. His approach is practical, technically robust and commercially aware, helping clients achieve proportionate compliance that genuinely fits their site and resources.

Effective management of legionella risk is crucial for maintaining a safe working environment in all premises and requires a considered and consistent approach in industrial and manufacturing premises where different types of water system may be present. By exploring the importance of conducting legionella risk assessments, the necessity of ongoing monitoring and sampling, and the roles and responsibilities of those who may be involved, we aim to shed some further light on the subject.

Traditionally, the operational impacts of the L8 Guidance note have focussed on Industrial Process Water Systems such as those that use water for manufacturing processes, cooling, heating, and washing. They can include closed-loop systems, cooling towers, and open evaporative cooling systems.

Much has also been published on Potable Water Systems and the risks carried in those systems. This includes all systems that supply drinking water to employees. Potable water systems must be monitored to ensure they remain free from contamination.

Additionally, we need to consider other potential sources of legionella risk, including dip slide testing and metalworking fluids, unused emergency showers, vehicle or plant wash systems and emergency water systems such as fire suppression systems that may have previously been overlooked.

The Importance of a Legionella Risk Assessment

Conducting a legionella risk assessment is the first vital step in identifying and mitigating risks associated with legionella bacteria, which can cause Legionnaires’ disease—a severe form of pneumonia. This assessment is not just a regulatory requirement but also a key component in protecting the health and safety of employees, contractors and visitors.

The legislative framework governing legionella management in the UK includes the Health and Safety at Work etc. Act 1974, the Control of Substances Hazardous to Health (COSHH) Regulations 2002, and the specific guidelines outlined in the HSE’s Approved Code of Practice (ACOP) L8. These regulations mandate employers to assess and control the risk of exposure to legionella bacteria.

The Importance of Monitoring and When to Conduct Sampling

Following the risk assessment, regular monitoring and sampling are essential to ensure that control measures are effective. Monitoring involves checking water temperatures, inspecting systems for signs of bacterial growth, and verifying the functionality of control measures.

Control measures for legionella, which may include sampling or disinfection but should crucially be based around regular monitoring, should be conducted:

  • Regularly: Depending on the complexity of the system and the risk rating of those in the premises, this may be six monthly or even an annual requirement but should be based on the outcomes of the risk assessment to ensure consistent control.

  • After System Changes: Whenever modifications or repairs are made to the water system itself or to the frequency of its usage – for example if a high usage area becomes unused for a period of time (typically after more than 7 days).

  • Following an Outbreak: If there is a case of Legionnaires’ disease associated with the premises, immediate sampling is critical to identify the source and prevent further incidents. A comprehensive treatment programme and additional sampling may then be required to ensure the eradication of the bacteria and the effectiveness of the control measures.

How Much is Legionella Risk Assessment?

Depending upon the sizer and complexity of a site, unfortunately the answer is “It Depends”. But to give an idea of costs, the most common project can be summarised as:

Legionella Risk Assessment £260 to £380 for small / simple Hot and cold-water supply sites up to £1250 for more complex sites.

Water Hygiene Monitoring including Monthly, Quarterly, 6 Monthly and Annual Visits are in the region of £90 to £180 per visit.

Tank cleaning and Sanitizing can be £75 to £350 depending on the size of the tank.

There are many other costs to consider such as TMV (Thermostatic Mixing Valve) servicing £5 to £25, Dead leg removal £60 to £220, Cooling tower Sanitisation £1250 to £1850 etc that may also be needed, which need to be considered.

Sampling costs depend on quantity. The more samples the lower cost and can be £6 to £30 per sample.

Roles and Responsibilities – Who Needs to do What?

Effective Legionella management in any premises involves a clear delineation of roles and responsibilities to ensure the safety and health of all occupants. While certain tasks can be handled internally, the complexity and risks associated with Legionella often necessitate the involvement of specialist contractors. Here’s a breakdown of the key roles and responsibilities:

In-House Personnel

Basic Checks and Monitoring:

  • Regular Inspections: where appropriately trained to do so, in-house personnel can conduct routine inspections of water systems, looking for any visible signs of contamination or maintenance issues.
  • Temperature Monitoring: Regularly check and record water temperatures in various parts of the system, looking to avoid temperatures within set ranges which could result in bacterial proliferation.
  • Flushing Systems: Periodically flush seldom-used outlets to prevent water stagnation, which can encourage Legionella growth.
  • Record Keeping: Maintain detailed logs of all inspections, temperature readings, and maintenance activities to ensure compliance and facilitate ongoing monitoring.

 

Specialist Contractors

Comprehensive Risk Assessments:

  • Systematic Evaluation: Specialist contractors perform thorough risk assessments, identifying potential Legionella risks within the entire water system. This includes evaluating the design, condition, and usage patterns of all water-related infrastructure.
  • Detailed Mapping: Create a detailed map of the water system, highlighting high-risk areas and potential points of contamination.
  • Risk Mitigation Plans: Develop tailored risk mitigation plans, recommending specific actions to reduce or eliminate identified risks.

 

Detailed Sampling and Analysis:

  • Expert Sampling: Contractors have the expertise to collect water samples correctly from various points in the system, ensuring that the samples are representative and uncontaminated.
  • Laboratory Testing: Use advanced laboratory techniques to analyse samples for the presence of Legionella bacteria, providing accurate and reliable results.
  • Trend Analysis: Conduct trend analyses based on historical data, helping to predict and prevent potential outbreaks by understanding patterns in Legionella presence.

 

Specialized Equipment and Techniques:

  • Advanced Tools: Employ specialized equipment, such as high-efficiency filtration systems and biocides, to treat and manage water systems effectively.
  • Innovative Techniques: Use cutting-edge techniques like thermal disinfection and UV treatment to control and eliminate Legionella bacteria.

 

Collaborative Efforts

  • In any premises and at any risk level, collaboration between those undertaking different roles and responsibilities is key. Orbis Environmental can help achieve this by bridging the gap between in-house and outsourced responsibilities, or by offering the full package of services. This collaborative approach ensures comprehensive coverage of all aspects of Legionella prevention, detection, and control, ultimately safeguarding the health and safety of everyone on the premises.
  1. Training and education
  2. Regular audits and reviews
  3. Establishing and providing emergency response services

Additional Water Sources to Consider

Legionella risk is not confined to common water systems like cooling towers and hot water tanks. Other potential sources must also be considered:

1. Metalworking Fluids: Used extensively in many industrial processes, these fluids can harbour legionella and other bacteria if not properly managed. Regular monitoring and maintenance are essential to prevent bacterial growth.

2. Dip Slide Testing: Particularly where metalworking fluids are in use, this method involves dipping a slide coated with a nutrient medium into the water and incubating it to check for bacterial contamination. It is useful for monitoring various water systems, including cooling towers.

3. Air Conditioning Units: Especially those using evaporative cooling, as they can generate mist that might spread legionella bacteria if contaminated.

4. Humidifiers and Sprinkler Systems: Any equipment dispersing water into the air should be regularly inspected and maintained to ensure it does not contribute to legionella risk.

5. Chemical Showers: Common in industrial settings, pharmaceutical laboratories and chemical plant for emergency decontamination, these showers can also pose a legionella risk if not regularly flushed, cleaned, and monitored for water quality.

6. Ice Machines: Ice machines used in facilities for various purposes can also be potential sources of legionella if not regularly cleaned and maintained.

7. Emergency Water System: Systems such as fire suppression systems (e.g., sprinklers, hose reels) and safety showers/eyewash stations must be considered. While these are not used regularly, they can become stagnant and support bacterial growth.

8. Vehicle Wash Systems: Automated and manual vehicle wash systems, particularly those that use recycled water can be another source of legionella if not properly managed.

9. Wastewater Treatment Systems: Systems that treat and recycle wastewater may also need to be considered, particularly if the treated water is reused within the facility.

10. Irrigation Systems: In facilities with landscaped areas, irrigation systems can also be a concern, especially if they use recycled water or if water is allowed to stagnate in the system.

Managing legionella risk in industrial and manufacturing premises requires ongoing diligence and adherence to regulatory requirements. Conducting regular risk assessments, monitoring, and sampling are crucial steps in maintaining a safe environment. By considering all potential water sources and implementing robust control measures, you can protect your employees and ensure compliance with health and safety regulations.

Stay vigilant and ensure your water systems are consistently monitored and maintained to keep legionella at bay. Ask us today for a quotation or call for a free and unbiased discussion about your requirements.