The well-anticipated HSG282 publication has officially been released by the HSE and made available to the public. It provides essential guidance to duty holders on how to ensure safety of spa-pools, as demonstrated with a self-explanatory title: “The control of legionella and other infectious agents in spa-pool systems”.

The document is an extension of the 2006 PHE/HSE publication Management of spa pools: Controlling the risks of infection, which has now been withdrawn. Whilst the content of the new HSG282 document is largely the same, it is presented with more clarity and features a simpler structure that is easier to digest, with handy information boxes featuring additional advice throughout.

The main difference is in the approach: HSG282 discusses legionella specifically whereas its predecessor took a more general stance by referring to overall microbiological infection. This could represent that the HSE has, in the decade between the new publication, identified that the main type of microbiological risk facing spa-pool systems is as a result of legionella bacteria.

The document outlines a clear set of environmental conditions of spa-pool systems that increase the risk of bacterial infection:

• If water is stored or recirculated
• If water temperature in all or part of the system is between 20–45 °C
• If these systems can support microbial growth
• If water droplets are produced and dispersed as aerosols;
• If there is the potential for exposure to any contaminated aerosols.

Health and safety legislation

As with existing documentation, the new guidance provides an outline of the existing laws that must be complied with, including The Management of Health and Safety at Work Regulations 1999 (MHSWR) and the Control of Substances Hazardous to Health Regulations 2002 (COSHH).

However, it provides a shorter and more succinct list of practical advice on what duty holders must do to comply with each framework, such as making sure they have access to help for applying health and safety legislation, establishing procedures in situations of imminent danger and controlling exposure if prevention is impractical.

It makes note of who the enforcing bodies are: the HSE and LA, where the “majority of spa pools in a business setting will be under the enforcement of LAs”.

There is mention, but not great detail of other important health and safety legislation that must be complied with:

• Reporting of Injuries, Diseases and Dangerous Occurrences 2013 (RIDDOR);
• The Safety Representatives and Safety Committees Regulations 1977;
• And The Health and Safety (Consultation with Employees) Regulations 1996.

Microbiological hazards

The new publication states microbes are introduced from external source or even from bathers and users themselves. Not mentioned previously is the danger of Coliforms and Escherichia coli in spa systems, which are spread through vegetation and faeces. 

Not unlike the 2006 document, HSG282 goes as far as stating which groups of people are more susceptible to legionella. This list has a few key differences that reflect up-to-date findings. It includes people over the age of 45 (whereas the old document listed only those over the age of 50). It also doesn’t make any reference as to which sex is more vulnerable, as the old document indicates this to be men only. Those with respiratory diseases and certain illnesses like cancer and diabetes are also defined as being more at risk.

Identifying and assessing risk

Previously, the purpose of an assessment was thought to be mainly to help identify which control measures should be implemented, however HSG282 points out an additional factor. It states that it also allows the duty holder to decide the level of risk to health present if no precautionary action is introduced.

HSG282 includes a more exhaustive list of what a risk assessment should entail, such as the competence and level of training of key personnel at the spa pool and current operation procedures and controls in place to control the risk.

Controlling the risk

New in the document is the use of information boxes that provide additional handy guidance. In this section of the document, there is guidance on controlling the risk using a Pool Safety Operating Procedure (NSOP). This will outline to anyone how the system runs on a day-to-day basis. There should also be an Emergency Action Plan (EAP) that advises people in the building on what specific actions to take in the event of an emergency.

There’s further and up-to-date guidance on a range of topics including record-keeping, dealing with emergencies, design and manufacturing responsibilities, types of spa pools, design and commissioning as well as the operation and management of spa systems.

As always, the publication is guidance and not compulsory – however, following it will help employers, managers and anyone who is in charge of a building, comply with health and safety law.  

To quickly check whether or not you’re complying with guidelines, download our free legionella checklist. – it outlines everything you should be doing in an easy to read list.