ADVICE & OPINION
COMPLIANCE
LEGIONELLA: RISKS DURING
AND AFTER LOCKDOWN
In association with
Many workplaces have laid dormant for weeks as the Coronavirus has
taken hold of the country. This has introduced new challenges, such as
the management of legionella. www.internationalworkplace.com
Legionnaires’ disease is a type of pneumonia,
which can cause serious respiratory illness and
death. It occurs when inhaling fine drops of water,
known as aerosols, containing legionella bacteria.
“Testing regimes have been diž icult to maintain
due to lack of available services and restricted access
to closed buildings,” says Darren Holmes, Senior Vice
President at risk management firm Marsh. “These
conditions could lead to an increase in waterborne
pathogens such as legionella bacteria”.
“Aerosols could be circulated by air conditioning
units or found around taps and showers where
there is a build-up of scale restricting water flow.
It is worth highlighting that due to the COVID-19
pandemic, an increased number of people could be
more susceptible to Legionnaires’ disease due to
a compromised respiratory system during or a¤ er
infection with COVID-19.”
When buildings reopen in the (hopefully) nottoo
distant future, it is essential that water systems
are not put back into use without considering the
risks of Legionnaires’ disease. According to the
Chartered Institute of Environmental Health, there is
an increased risk of waterborne pathogens such as
legionella bacteria being present as a consequence of
the conditions that lockdown may have created.
YOUR LEGAL DUTIES
Duties under the Health and Safety at Work etc. Act
1974 (HSWA) extend to risks from legionella bacteria.
The Management of Health and Safety at Work
Regulations (MHSWR) provide a broad framework
for controlling health and safety at work. More
specifically, the Control of Substances Hazardous
to Health Regulations 2002 (COSHH) provide a
framework of actions designed to assess, prevent or
control the risk from bacteria such as legionella and
take suitable precautions.
Duty-holders must take reasonably practicable
steps to control risk from legionella throughout
this time, says Legionella Control, legionella and
pathogen control specialists.
They advise that duty-holders implicated in an
outbreak of Legionnaires’ disease resulting from
actions taken for COVID-19 precautions are not
likely to have any exemption from prosecution.
The legal responsibility for Legionella control lies
with the duty-holder, who must make their own
12 FEBRUARY 2021
determination for each circumstance.
Darren Holmes adds that you should review your
risk assessment and manage the legionella risks
when you:
Reinstate a water system and start using it again;
and/or
Restart some types of air conditioning units.
“Insurers might limit Legionnaire’s coverage amounts
or impose higher deductibles if building systems are
outdated,” he says. “Insurers may also be stepping
up their scrutiny even more due to the Coronavirus
pandemic, making it important to follow and
implement key steps when considering reopening.”
LOCKDOWN RISK FACTORS AND
CONTROL MEASURES
Ideally, changes in legionella risk will have been
considered at an early point in planning lockdown
arrangements. However, if you have not already done
so, you must consider that risk now, particularly if
it is foreseeable that buildings and water systems
may remain shut down or subject to low usage for
several weeks, advises the Chartered Institute of
Environmental Health.
Legionella Control adds that it is essential that,
when buildings reopen following the li¤ ing of
COVID-19 restrictions, any water system is not
simply put straight back into use. It advises: “During
the period of shut-down it would be sensible to
formulate a recommissioning plan for each water
system to allow safe start-up and assurance to users
that it is safe. Duty-holders are likely to be able
to access competent help from service providers
remotely during the period of restricted movement.
Any plan for recommissioning buildings must take
into account the safety of the operatives carrying out
the work.”
PREPARING FOR REOPENING
Reopening may not seem very likely in the near
future, but it’s important to prepare for when that
day does come. If you have already reviewed your
risk assessment and implemented additional control
measures, it is unlikely you will need to take any
further steps prior to reopening. Adds Holmes:
“It is reasonable to assume that where buildings
have been unoccupied for a number of weeks there
will have been an increase in bacterial growth and
as such the system will need to be managed before
it is put back into use. Where no additional action
has been taken, or you are concerned about the
ež ectiveness of controls implemented, you must take
reasonable steps to ensure the safety of the water
system prior to reopening.”
Steps to take prior to reopening could include:
Flushing through simple hot/cold water systems
with fresh mains water for several minutes.
Increasing the temperature of hot water systems
to above 60°C if possible and drawing the
heated water through to all hot water outlets (a
temperature over 60°C will kill Legionella bacteria
over time, although can result in a scalding risk.
While water should be stored at 60°C, there should
be a thermostatic mixing valve before the tap to
reduce the temperature to around 43°C).
Flushing through larger hot/cold water systems
(including those with tanks, showers, clarifiers
etc.) for a significant period of time.
Ensuring that the system is capable of delivering
water at safe temperatures by checking
temperatures ahead of reopening.
Undertaking a chemical or thermal disinfection of
the water system.
Undertaking microbiological sampling for
legionella bacteria.
In conclusion, it’s important to note that each
individual water system within a building or
workplace is likely to need some degree of individual
consideration as no two systems are entirely alike.
Additionally, some systems believed to be under
good control may now show that previous high
levels of use and turnover have masked existing
issues; these could become apparent during periods
of low use.
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