Like most important and time-critical things, it's always prudent to cement instructions, protocols, practices and schedules in the form of the written word. Documenting the pre-requisitional procedures involved with legionella control is no different in this respect, and therefore roundly advisable that the accepted 'scheme of control' is committed to print in one form or another.
A legionella written scheme of control is typically highlighted and addressed within the pages of a legionella risk assessment. This subsequently acts as a good starting point to determine how you should go about adhering to the best practices recommended at the time the above mentioned risk assessment is originally carried out.
So, Tell me What Constitutes a Sound Legionella Written Scheme of Control?
First of all we need to familiarise ourselves with what a legionella written scheme of control amounts to, and that, essentially, comes off the back of a risk assessment as previously inferred. In simplistic terms, a legionella written scheme of control takes the structured form of a risk management document, albeit a comprehensive example. Laid out within its content it seeks to identify measures which either have been adopted to assume control of a building's water storage/distribution - via outlets - systems, or should be put in place. With the view to minimising potential exposure risks to legionella bacteria.
Moreover, the written scheme of control exists as a tangible means of literally submitting any - and all - means actioned, with direct reference to the dedicated implementation of remedial works required to shore up defences against the threat posed by legionella bacteria. If, in the aftermath of a legionella risk assessment, a foreseeable possibility of exposure to legionella is flagged up, then the directives are to put into practice said written scheme setting-out how, when and where you intend to mitigate the perceived threat, from that juncture and moving forwards. This accrued documentation needs to be made accessible to all stakeholders with an active interest in the risk assessment for that business premises, and the subsequent control processes suggested.
Can You Explain What Rudimentary Information Needs to Be Included Within a Legionella Written Scheme of Control?
According to the Health & Safety Executive (HSE), evidence of a written control scheme can't be over-stressed when working together to manage risks. Pinpointing precisely what areas should be covered might change slightly depending on an individual company/business/property infrastructure, however by and large everyone tends to sing from the same hymn sheet, so to speak. The most significant and robustly highlighted control measures in these scenarios include the following;
• Schematic diagram of a particular water system
• Identification/confirmation of those employees whose responsibility it is to both routinely monitor/act on various accepted elements of risk management
• What correct operation of individual systems are
• Precautionary measures companies/property owners are taking (including chemical treatments, inspections for visible damage, signs of contamination, etc)
• Exacting details of the checks that need to be performed (and the frequency by which they will be completed)
Can You Expand on Certain Core Information Which Needs to Be Captured In Such Pivotal Documentation?
Elsewhere, a compendium of all the water systems and internal infrastructures relating to the water storage elements needs to be base-touched (tech schematics), together with all cases/episodes of risk assessment and risk assessment reviews noted. Meanwhile the name of the duty holder must be prominent (corporate entity, landlord, individual, etc), evidence of training, allocation of responsibilities and the safe and correct operation of the system are all paramount.
Other chapters which are traditionally encompassed by the written scheme include those summarised beneath;
• Precautions to be taken
• Analytical tests
• Inspections and calibrations (including frequency)
• Remedial actions to be instigated
• HSE data for chemical products used in treatment
• Incident plan
• Records of completed actions
How Does the Written Scheme of Control Differ from The Legionella Risk Assessment That is Already in Place in a Business?
The written scheme of control forms an important component of the more expansive risk management document per se, and should always evolve in the capacity of a practical resource tool, and made available to all stakeholders with a key role to play in the legionella control process. That being said, from a technical perspective the written scheme is a separate entity and is universally recognised as a legal requirement as far as the HSE is concerned. Something which is underlined in its Approved Code of Practice and Guidance ACOP L8; 'Legionnaires’ disease. The control of legionella bacteria in water systems.'
To reiterate the crux of the matter, we'd like to draw your attentions to the core elements of this legislation for one moment. Specifically paragraph 58, which emphasises the 'preventing - or controlling - of the risk from exposure to legionella bacteria.'
“Where the (risk) assessment shows that there is a reasonably foreseeable risk of exposure to legionella bacteria, the use of water systems, parts of water systems or systems of work that lead to exposure must be avoided so far as is reasonably practicable. Where this is not reasonably practicable, there should be a written scheme for controlling the risk from exposure that should be properly implemented and managed. The written scheme should specify measures to take to ensure that it remains effective.”
OK. But What Format Should My Written Scheme of Control Manifest In?
There's no hard and fast rule as to how a legionella written scheme of control should be documented, just so long as it is. Be it in the guise of an old school paper log book, online portals specifically designed for these purposes and synced to your business website or even via a smartphone-accesses app. It really doesn't matter, just as long as it exists somewhere and is viewed, acted on and revised as and when required. The crucial aspect is that it is easily accessed by anyone who needs to observe/frequent a written scheme of control in this context.
Are Employee Numbers Relevant In Terms of Scheme of Control Measures?
They are relevant in the context of maintaining records, in as much as it's - advisable, yet not mandatory - to keep written records of steps taken to assess and manage risks in the event that a business employees 5 or more people. The risk management extends to individuals responsible for each assessment, any significant findings thrown up and subsequent actions taken as a result. What's more, it's a legal requirement to keep legionella written scheme of control for at least 2 years, while documentation to prove the results of testing and inspections needs to be maintained for 5 years.
