With the news surrounding Legionnaires’ disease and its impact on hospitality businesses recently, Daniel Pitcher from Water Hygiene Centre shares his insight on what hotels and restaurants should be doing to manage the risk of infection.
The Feathers Hotel in Ludlow entered administration in August following the devastating impact of an outbreak of legionnaires’ disease last year.
Where to start… the organisation that owns the hotel/s should identify who is responsible for health and safety, typically this person is the duty holder [the owner / chief executive for the organisation]. They need to start by reading the HSE guide called ‘Legionnaires Disease – A Brief Guide for Duty Holders’.
Based on the size of the organisation the Duty Holder will need to ensure adequate processes are in place as detailed in the HSE ACOP L8 document. With a single hotel the owner will typically be the Duty Holder and may also be the Responsible Person. With small or large hotel chains the relevant hotel manager is typically the Responsible Person for each hotel.
- Appoint a Responsible Person who is competent with sufficient authority and knowledge of the installation to help take the measures needed to comply with the law.
- Risk assessment – identify and assess sources of risk. The ACOP L8 details what is required from a risk assessment. It is most likely you’ll need to commission an independent consultancy to undertake the risk assessment. The Legionella Control Association lists those members who can undertake risk assessments. A cautionary note – those organisations offering an all-inclusive service may not always be impartial. A fair few to choose from, although there are only fifteen companies that can deliver UKAS accredited risk assessment.
- Prepare a written scheme of control for managing [preventing / controlling] the risk. Essentially the written scheme of control can be a suite of documents i.e. management policy / operational control procedures / site log book records. The policy details the management arrangements for the organisation. The operational procedures details how the risk systems identified from the risk assessment will be operated, monitored and maintained. The written scheme of control must be bespoke to your organisation!
- Implementation of the written scheme of control – ensuring the management policy and the associated management tasks are undertaken. With the operational procedures ensuring the defined maintenance and regular monitoring processes are undertaken, to prove control measures remain effective. To confirm that microbiological control is being achieved sampling for legionella can be undertaken to check that a system is under control.
- Keep records! In Health & Safety law records / evidence are essential to prove proactive management is being achieved. Records can exist in paper or electronic format, which is acceptable, although records need to be accessible and understood. Where non-compliant issues have occurred then there must be evidence recorded that this has been investigated and mitigated.
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