If your building has been impacted by Covid-19 related low occupancy (or parts have been mothballed) are you still compliant?
A reminder of your responsibilities
All water systems should already have a risk assessment in place for Legionella.
It is most likely that the existing assessment will now need to be reviewed where buildings have low occupancy or where buildings are empty, as this will be a significant change to risk.
Duty holders and Managing Agents need to ensure their assessment of risk is current and that includes the changing circumstances due to COVID-19.
As per the Health & Safety Executive’s Approved Code of Practice – “Legionnaires’ disease: The control of legionella bacteria in water systems (ACOP L8 – 2013), the risk assessment should be reviewed in these types of circumstances, see extracts below;
From ACOP L8, Paragraph 32:
You need to review the assessment regularly and specifically when there is reason to believe that the original risk assessment may no longer be valid.
From Paragraph 47:
The record of the assessment is a living document that must be reviewed to ensure it remains up-to-date. Arrange to review the assessment regularly and specifically whenever there is reason to suspect it is no longer valid.
An indication of when to review the assessment and what to consider should be recorded.
This may result from, eg:
(a) changes to the water system or its use;
(b) changes to the use of the building in which the water system is installed;
(c) the availability of new information about risks or control measures;
(d) the results of checks indicating that control measures are no longer effective; e.g. positive Legionella samples;
(e) changes to key personnel.
At William Martin Compliance we have a nationwide team of experts who can provide the Legionella risk assessment services as outlined above to ensure you remain compliant in this fast-changing environment.
If you require further information or advice regarding Legionella Control, please contact our Technical Manager for Water Safety, Tom de Ronde, firstname.lastname@example.org