This approach provides a means for ensuring controls
are applied which are commensurate with the level
of risk and that a process for review and continual
improvement is in place. The subcommittee agrees with
this approach.
4.2. Undertaking a risk assessment
The purpose of a risk assessment is to:
-
Identify and assess the risk of
exposure to Legionella bacteria from work activities
and water systems on a premises i.e. a workplace,
healthcare facility or leisure facility
-
Establish any necessary preventive
and control measures.
A risk assessment is usually undertaken by or on
behalf of the following persons:
-
The employer or self-employed person
in order to assess the risk to employees, themselves
or to others
-
The person in control of a premises
or systems where the risk may be present (e.g. the
CEO of the hospital)
-
The person in control of a premises
used for overnight accommodation such as hotels,
holiday apartments, campsites and cruise ships where
the risk may be present from water systems in the
building/site.
Risk assessments should consider:
-
The potential for Legionella seeding
and growth
-
The potential for aerosol generation
and exposure
-
The presence of susceptible persons
-
The adequacy of existing site management
arrangements and records
-
The efficacy of existing preventive
and control measures.
The following defines the proposed outcomes sought
from a risk assessment:
-
To identify and evaluate potential
sources of risk
-
To identify means of preventing
and controlling exposure and if prevention is not
reasonably feasible, the particular means by which
the risk from exposure to Legionella bacteria can
be controlled, and To provide direction on prioritising
actions for prevention and control.
4.3 Process of risk assessment
When undertaking a risk assessment, the individual
nature of each site must be taken into account. In complex
systems or premises, a site survey of all the water
systems should be carried out and should include an
asset register of all associated plant, pumps, strainers
and other relevant items. This should include an up-to-date
diagram/drawing showing the layout of the plant or system
including parts temporarily out of use. A schematic
diagram would be sufficient. It should then be decided
which parts of the water system, for example which specific
equipment and services, may pose a risk to those at
work or to other people.
- The following systems present a potential risk of
exposure to Legionella bacteria:
- Water systems incorporating a cooling tower
- Water systems incorporating an evaporative condenser
- Hot and cold water systems
- Spa pools
- Humidifiers
- Dental chair waterlines
- Natural thermal springs and their distribution systems
Other plants and systems containing water which is
likely to exceed 20oC and which may release a spray
or aerosol (i.e. a spray of droplets and/or droplet
nuclei) during operation or when being maintained.
A water system includes all plant/equipment and components
associated with that system e.g. all associated pipe
work, pumps, feed tanks, valves, showers, heat exchangers,
quench tanks, chillers, etc. It is important that the
system is considered as a whole and not for example
the cooling tower in isolation. Dead legs and parts
of the system used intermittently also need to be included
as they can create particular problems with microbial
growth and go unnoticed. Other systems e.g. humidifiers
and air washers, spa pools and baths, car/bus washes,
wet scrubbers, industrial water systems, fountains and
water features also need to be considered.
The following list contains some of the factors which
should be considered when undertaking a risk assessment:
- The source of the system supply water, e.g. whether
from the mains supply or not
- Possible sources of contamination of the supply
water within the premises before it reaches the cold
water storage cistern, calorifier, cooling tower or
any other system using water that may present a risk
of exposure to Legionella bacteria
- The design, location and condition of equipment
for example the position of air intakes for buildings
in relation to the location of cooling tower exhausts
- Conditions suitable for multiplication of the microorganisms
e.g. stagnant water, suitable temperature (20oC-45oC),
and a source of nutrients e.g. sludge, scale, rust,
algae and other organic matter
- A means of creating and disseminating inhalable
droplets e.g. aerosols generated by cooling towers,
showers or spa pools
- Normal equipment operating conditions and any unusual
but foreseeable conditions e.g. equipment breakdown
- The presence of vulnerable individuals e.g. immunocompromised
individuals who may be exposed to infection
The extent of exposure - the number of people who may
be exposed and the length, duration and frequency of
exposure.
Not all systems will require elaborate risk assessment
and control measures. A simple risk assessment may show
that the risks are low e.g. small domestic-type premises
where temperature and turnovers are high and where instantaneous
water heaters are used. In such cases no further action
may be required other than to review the risk assessment
on a regular basis.
Where a risk is identified, the significant findings
of the assessment should be recorded, together with
the name of the person and organisation who carried
out the assessment. It will also be necessary to record
sufficient details of the assessment to be able to show
that it has been done. It should be linked to other
relevant health and safety records
Failure to undertake a risk assessment or possession
of an inadequate risk assessment may lead to prosecution,
especially if a system or premises is implicated in
a Legionnaires disease outbreak.
4.4 Preventing or controlling the risk
The risk rating for exposure to Legionella can be categorised
as follows:
- VERY HIGH - where it is certain or near certain
that exposure will occur
- HIGH - where exposure will often occur
- MEDIUM - where exposure will sometimes occur
- LOW - where exposure will seldom occur
INSIGNIFICANT OR NOT FORESEEABLE.
Where an assessment determines that there is a potential
risk of exposure to Legionella bacteria, the use of
water systems, parts of water systems or systems of
work that lead to exposure have to be avoided as far
as is reasonably practicable. Where it is not practicable
to do so then control measures should be adopted to
minimise exposure.
Guided by the risk ratings outlined above, actions
for the prevention or control of exposure to Legionella
should be prioritised by adopting:
- Urgent corrective actions to prevent or control
exposure from water systems or activities categorised
as VERY HIGH or HIGH RISK
- Planned corrective actions to meet L8 guidance or
equivalent for medium and low risk
4.5 Implementing a control scheme
The implementation of a control scheme should be regularly
and frequently monitored and decisions should be made
on the frequency and manner of the monitoring procedures
(see Section 4.15). The effectiveness of the programme
should also be monitored including the impact of short-term
or interim measures. Regular review and updating of
risk ratings is crucial to the success of the control
scheme and the implementation programme should be updated
to take account of any changes in priorities and timescales.
All persons involved in the operational procedures
should be properly supervised. Staff roles, responsibilities
and lines of communication should be properly defined,
clearly documented in writing and understood by all
involved.
Communications and management procedures are particularly
important where several people are responsible for different
aspects of the operational procedures. Lines of communication
should be clear, unambiguous and audited regularly to
ensure that they are effective.
The above also applies to the outside companies and
consultants who may be responsible for certain parts
of the treatment regime. The employment of contractors
or consultants does not absolve the duty of the holder
of responsibility for ensuring that control measures
are in place to the highest standard to prevent the
proliferation of Legionella bacteria.
Arrangements should be made to ensure appropriate staffing
levels are maintained during all hours that water systems
are in operation. Appropriate arrangements should be
made to ensure that the responsible person or an authorised
deputy can be contacted at all times. Details of the
contact arrangements for emergency call out personnel
should be clearly displayed at access points to all
automatically or remotely controlled water systems.
A written scheme detailing measures to prevent or control
risks should be implemented and properly managed, including:
An up-to-date schematic of the plant, building or system,
including parts temporarily out of use
A description of correct and safe operation
Precautions to be taken and checks to be conducted to
ensure the efficacy of the scheme and frequency of such
checks
Remedial action to be taken if the scheme is shown not
to be effective.
Based on the above scheme, a programme should be developed
for implementation of control measures taking account
of risk ratings, site requirements, resources and short-,
medium- and long-term options for preventing and reducing
risks as far as is reasonably practicable. This will
require communication between the risk assessor, service
provider and the responsible person.
The risk from exposure will normally be controlled
by measures, which do not allow the proliferation of
Legionella bacteria in the system and reduce exposure
to water droplets and aerosol. These include engineering
controls, cleaning protocols and other control strategies
such as:
Controlling the release of water sprays
Avoidance of water temperatures and conditions which
favour the proliferation of Legionella bacteria and
other microorganisms i.e. avoiding water temperatures
between 20oC and 50oC. Water temperature is a particularly
important factor in controlling the risks and should
be either below 20oC or above 50oC.
- Avoidance of water stagnation that can encourage
the growth of biofilm (slimes that form on surfaces
in contact with water) which can harbour Legionella
bacteria and provide local conditions that encourage
growth
- Avoidance of the use of materials which harbour
bacteria and other micro-organisms or provide nutrients
for microbial growth e.g. rubber washers and hoses
- Maintenance of the cleanliness of the system and
the water in it in order to avoid the build up of
sediments which may harbour bacteria (and also provide
a nutrient source for them)
- Use of water treatment regimes/techniques where
it is appropriate and safe to do so
- Action to ensure the correct and safe operation
and maintenance of the water system.
Decisions should be made about the maintenance procedures
and intervals and where relevant on equipment used for
carrying out the control measures. Legionella bacteria
may be present in low numbers in many water systems
but careful control will prevent them from multiplying.
The scheme should give details on how to use and carry
out the various control measures and water treatment
regimes including:
The physical treatment programme e.g. the use of temperature
control for hot and cold water systems (see Section
4.15.3b)
The chemical treatment programme including a description
of the manufacturer's data on effectiveness, the concentrations
and the contact time required
Health and safety information for storage, handling,
use and disposal of chemicals
System control parameters (together with allowable
tolerables); physical, chemical and biological parameters,
together with measurement methods and sampling locations,
test frequencies and procedures for maintaining consistency
Remedial measures to be taken in case the control limits
are exceeded including lines of communication
- Cleaning and disinfection procedures.
- There should also be a description of the correct
operation of the water system plant including:
- Commissioning and recommissioning procedures
- Shutdown procedures
- Checks of warning systems and diagnostic systems
in case of system malfunctions
- Maintenance requirements and frequencies
- Operating cycles - including when the system plant
is in use or idle.
4.6 Review of control measures - monitoring and routine
inspection
If preventive measures are to be effective, the condition
and performance of the system will need to be monitored.
This should be the responsibility of the responsible
person or where appropriate an external contractor or
an independent third party should be involved.
This will involve:
- Checking the performance of the system and its component
parts
- Inspecting the accessible parts of the system for
damage and signs of contamination
- Monitoring to ensure that the treatment regime continues
to control to the required standard.
The operating characteristics of the water distribution
network e.g. pumps should be monitored at least once
weekly. The results of monitoring and testing should
be interpreted by a suitably experienced and competent
person and any remedial measures where necessary should
be carried out promptly.
Testing of water quality is an essential part of the
treatment regime, particularly in cooling towers. A
service provider e.g. a water treatment company or consultant
may undertake it provided that they are trained to do
so and properly supervised. The type of tests required
will depend on the nature of the system.
The routine monitoring of the general aerobic heterotrophic
bacterial count (total viable count) is also a very
important indicator of whether microbiological control
is being achieved. This should be routinely undertaken
for cooling towers (see Section 4.15.3 and Chapter 5,
Section 5.2.2) and spa pools (see Chapter 7, Section
7.5.9). In relation to hot and cold water systems, this
should be undertaken periodically. Depending on the
size of the water system, samples should be taken from
the following points in the system: the calorifier,
water tank, pipes midway along the system and from the
furthest point from the water tank/boiler. Sampling
twice a year and testing for the presence of Legionella
bacteria may also be appropriate as an indication that
adequate control is being achieved.
In order to ensure effective implementation of the
control programme, a compliance checklist should be
compiled which includes:
- Responsibilities allocated
- Risk assessments up-to-date
- Written control scheme implemented
- Written control scheme working
- Satisfactory closure of non-compliances
- Emergency action procedures
- Process of management review
- Records complete and up-to-date.
4.7 Frequency of risk assessment
Once the risk assessment is completed and documented,
it should be reviewed regularly i.e. at least annually.
If there are significant alterations to operational
procedures in the institution or significant changes
to the water distribution system then the risk assessment
should be reviewed and updated. There should be a written
record of this review. In addition, it will need to
be repeated more frequently in situations where the
original assessment is considered to be no longer valid.
An indication of when to review the assessment and what
needs to be reviewed should be recorded. This may result
from:
- Changes in the water system or its use
- Changes in the use of the building in which the
water system is installed
- The availability of new information about risk and
control measures
- The results of checks indicating that control measures
are no longer effective
- A case of Legionnaires disease/legionellosis associated
with the system.
4.8 Written risk assessment
A written risk assessment should include:
- The scope of the assessment
- A description of the site and water systems with
details of design, operation and maintenance
- Details of site arrangements for managing and recording
control of Legionella risks
- Assessment of risk for each system and activity
Recommendations for preventing (elimination of source
of bacteria, aerosols or exposure) or controlling (control
bacteria re-growth, aerosol release and exposure) the
risks including monitoring, remedial actions, etc.
Control measures may include:
- A regular regime of water treatment, cleaning and
disinfection, monitoring and maintenance and/or
- One-off actions such as setting up management and
record/documentation systems, plant or equipment improvements,
modifications, refurbishments and replacements.
4.9 Record keeping
The responsible person(s) appointed must ensure that
appropriate up-to-date records relating to the control
scheme are kept. These records should include the following
details:
Names and positions of person(s) responsible for carrying
out the various tasks under the written scheme i.e.
responsible for risk assessment, managing and implementation
of the control scheme
Plans and schematic drawings of the systems
Details showing the current state of operation of the
system e.g. when the system or plant is in use and if
not in use whether it was drained down or not
The significant findings of the risk assessment
The written scheme of actions and control measures
required and details of their implementation
The results of any monitoring, inspection, test or
check carried out, and the dates
A log detailing visits by contractors, consultants,
and other personnel. The remedial work required and
carried out and the date of completion
The signature of the person carrying out the work or
other form of authentication where appropriate i.e.
contract specification
- Copies of contractor's method statements
- Cleaning and disinfection procedures and associated
reports and certificates
- Results of the chemical and microbiological analysis
of the water
- Information on other hazards e.g. treatment chemicals
- Personnel training records
- Review meeting notes and actions
- Product information and chemical/biocide safety
data sheets.
Records kept in accordance with the above should be
retained throughout the period for which they remain
current. All test and inspection records must be kept
for five years from the date of the test or inspection.
All records should be signed by those persons performing
the various tasks assigned to them.
4.10 Managing the risk: responsibilities, training
and competence
It is imperative that a competent person with the relevant
skills, knowledge and experience carries out the risk
assessment. Organisations and individuals carrying out
risk assessments should ideally be members of a recognised
professional body or association e.g. the Legionella
Control Association in the UK or equivalent. If this
level of expertise is not available within the organisation,
then it should be sourced externally. Sections 8 and
19 of the 2005 Safety, Health and Welfare at Work Act
outline in detail the legal duties of the employer in
this regard and the legal requirements in relation to
hazard identification and risk assessmen).
The person on whom the corporate responsibility for
the premises/systems lies should have access to such
expertise. In order to prevent any conflicts of interest,
it is recommended that ideally, those appointed to carry
out the risk assessment are independent of those appointed
to implement the control measures and remedial actions,
including water treatment and cleaning and disinfection.
It is the duty of the employer to ensure that those
undertaking the risk assessment are competent and suitably
trained and have the necessary equipment to undertake
the risk assessment in a safe and adequate manner.
If the risk assessment identifies that there is a potential
risk and it is practicable to prevent exposure or to
control the risk from exposure, the person on whom the
corporate/statutory obligation falls e.g. CEO, employer,
etc. should appoint a responsible person to take managerial
responsibility and provide supervision for the implementation
of the precautions and for ensuring that:
- Persons involved in the implementation of the control
scheme are trained and competent
- Responsibilities and lines of communication are
properly established and clearly defined
- Management arrangements and communication procedures
are reviewed periodically.
The responsible person should be a manager or director,
or have similar status with sufficient authority, degree
of competence and knowledge of the installation and
resources to ensure control measures and systems operations
are carried out in a timely, safe and effective manner.
The competence required of the responsible person will
depend upon the risks they have to manage, i.e. the
nature, size, age, use and complexity of the water systems
for which they are responsible. For locations with medium-
to high-risk water systems the responsible person should
have attended specific training courses on the management
and control of risks of exposure to Legionella bacteria
given by a qualified training provider. They should
also attend regular refresher courses and attendance
at all courses should be recorded. They should have
a clear understanding of their duties and the overall
health and safety management structure and policy of
the organisation. This person will have day-to-day responsibility
for the prevention and control of Legionella bacteria
in the organisation.
Persons who carry out risk assessments and who devise
and implement precautionary measures should have such
ability, experience, information, training and resources
to carry out their tasks competently and safely. In
particular they should know:
- Potential sources of Legionella bacteria and the
risks they present
- Measures to be adopted, including precautions to
be taken for the protection of people concerned and
their significance
- Measures to be taken to ensure that controls remain
effective and their significance.
When the person(s) do not possess the above expertise,
it may be necessary to enlist assistance and support
from outside the organisation. In such circumstances,
the responsible person should take all reasonable steps
to ensure the competence of such organisations and the
individuals undertaking the work.
4.11 Audit
A competent person should audit the implementation
and performance of the risk management programme periodically
(at least every two years). This person should be completely
independent of the service providers responsible for
the implementation of the risk control regime and should
have no interest in the provision of such services.
4.12 Responsibilities of suppliers and service providers
Outbreaks of Legionnaires disease have been associated
with faulty installation of equipment53 and inadequate
application of water treatment and risk control regimes.
As outlined in Chapter 3 on legislation, suppliers and
service providers have duties and responsibilities under
occupational health and safety legislation and must
ensure that:
- Equipment is designed and constructed to be safe
and without risks to health when used at work
- Adequate information is provided to the user about
risk and measures necessary to ensure that water systems
will be safe and without risk to health when used.
This should be updated in the light of any new information
about significant health and safety risks that becomes
available.
- Products and services are fit for purpose and that
any limitations are clearly defined and made known
to responsible persons
- Staff have the necessary ability, experience, instruction,
training and resources to carry out tasks competently
and safely
- A written risk assessment is undertaken and a plan
of work/method statement for their work activities
is prepared so that such activities are planned, organised
and controlled.
4.13 Reducing Legionella risks in new and refurbished
buildings
Water systems should be designed, installed and commissioned
to ensure risks from Legionella bacteria are eliminated
wherever possible, or reduced as far as is reasonably
practicable. Designs should also ensure that adequate
provisions are made to facilitate safe system operation
and maintenance since a poorly designed system can be
both difficult and expensive to operate and maintain.
The 'designing out' of features that will increase
the potential for seeding, growth and aerosolisation
of Legionella should be regarded as an integral component
of an effective risk control strategy, e.g. cold and
hot water systems should be designed to preserve supply
water quality, prevent microbial growth, eliminate or
reduce formation of aerosols, minimise corrosion and
maintain internal surfaces in a clean condition. This
can be achieved by, for example:
- Utilising unvented direct mains supplied hot water
systems
- Avoiding water storage tanks supplying calorifiers
- Using point of use water heaters rather than centralised
hot water systems
- Designing hot water storage vessels, direct fired
hot water service boilers and calorifiers to ensure
adequate control of water temperatures in storage
and distribution, and with sufficient heating capacity
to enable periodic pasteurisation of their contents
- Using cold water storage tanks that optimise the
maintenance of potable water quality with a storage
capacity of no more than 24 hours average water demand
- Minimising the distance between the source of the
water supply and point of use. Zoning should be used
where appropriate in more complex systems
- Designing distribution systems to ensure regular
throughput of water by eliminating 'dead legs' and
long pipework runs
- Hot and cold water distribution pipework should
be installed to minimise the transfer of heat between
both. Appropriate insulation of pipes is essential.
- Ensuring that fittings, materials and components
are corrosion-resistant and are constructed of approved
materials which do not release nutrients into the
water to support microbiological growth
- Avoiding use of equipment such as spray taps which
generate aerosols where suitable alternatives are
available. Where it is essential (e.g. showers) then
equipment should be selected to facilitate routine
cleaning and disinfection
- Sources of aerosols or droplets should be sited
away from direct intake sites such as air vents and
open windows.
It is important that the total requirements for water
supply and quality are assessed in the planning stages,
and water systems appropriate to areas of accommodation
are allocated. Where a building project is completed
and commissioned in phases or it is anticipated that
areas of the building are likely to have different levels
of occupancy and usage then careful consideration should
be given to zoning of the water services to enable floors
and areas of the building to be isolated and operated
independently.
Installation and commissioning also require careful
planning and execution to ensure designs are properly
implemented and the necessary pre-commissioning cleaning
and disinfection are carried out in accordance with
industry standards and completed in time for hand-over.
Long delays between completing the system disinfection
and operating the water system will result in a deterioration
in water quality and should be avoided.
Only competent service providers should be appointed
to design, install or modify water systems. For those
installations or modifications which could significantly
affect the risk of legionellosis from the system, the
appointed service provider should submit the following
to the appropriate responsible person:
- A detailed description of the proposed new system,
including a schematic drawing showing the layout of
all component parts and identifying changes to existing
systems
- Confirmation that its design and construction complies
with relevant legislation, guidance and standards
- A risk assessment which considers the risk of legionellosis
arising during the installation, including from any
changes to existing systems, and identifies the precautions
required to mitigate against these risks.
This information should be submitted to the responsible
person at a reasonable period in advance of commencement
of the work. The work should not proceed until it has
been approved by the responsible person or by a nominated
deputy in their absence.
On receipt of the information specified in the section
above, the responsible person, or their nominated deputy
should review the submission within 20 working days
to consider whether:
- The system design allows it to be subsequently adequately
maintained
- The assessment of risk is suitable and sufficient,
with precautions adequate to minimise the risks, for
example, from creation of dead legs and blind ends,
from possible contamination of the system, etc.
- Arrangements are in place to monitor the work and
ensure adequate commissioning of the system
- Necessary contingency measures will be put in place
to minimise potential disruption to business operations
and welfare facilities, for example, by provision
of alternative water supplies, communicating changes,
etc.
- The site can be cleared of other work and properly
prepared
- Adequate and appropriate records will be provided,
including sufficiently detailed 'as-fitted' plan or
schematic drawings, operations and maintenance manuals,
etc.
Once satisfied that all necessary safety arrangements
are in place, the responsible person should approve
the work and notify the designer/installer.
Larger and more complex projects will often benefit
from a multidisciplinary approach involving, for example,
designers, architects, manufacturers, installers, risk
assessors, water quality specialists, microbiologists,
operatives and users.
4.14 Materials for construction of water distribution
networks
As Legionella bacteria are usually associated with
bacterial biofilms and biofouling in water systems,
consideration should be given to the materials used
in the construction of water distribution networks.
Previous studies with a range of materials commonly
used in the construction of water systems showed that
some materials were very good at limiting colonisation
and biofilm formation by a wide range of bacterial species,
whereas other materials were very poor. Copper was the
best at limiting colonisation and biofilm formation,
followed by polybutylene and stainless steel, whereas
biofilm formed more readily on polyethylene, chlorinated
polyvinyl chloride (PVCc), unplasticised polyvinyl chloride
(PVCu), steel and ethylene-propylene.54;55 Distributing
hot and cold water using copper pipes may significantly
improve the microbial quality of water in water distribution
networks as copper has been shown to possess significant
antimicrobial advantages over water pipework of other
composition.
4.15 Technical guidelines for the control and prevention
of Legionella in water systems
An effective water treatment regime is essential for
Legionella control. In addition to controlling legionellae,
water treatment must also address the control of general
microbial activity, biofilm development, corrosion,
scale deposition and the retention of particulate solids.
A cooling tower for example, with an inadequate or poorly
controlled water treatment programme will be more vulnerable
to contamination with legionellae and, therefore, present
a much higher risk of exposure. Similarly, a distribution
system which is fed with water containing sediment,
minerals, organic matter and biofilm seed will always
present a high risk. Removal or control of these elements
does much to reduce the risk and also reduces the requirements
for residual disinfection.
In assessing the adequacy of water treatment, cleaning,
disinfection and maintenance regimes particular attention
should be paid to:
- Biocide type, dosage rate and frequency, and half-life
- Efficacy of corrosion/scale control
- Operation and calibration of dosing/control equipment
- Maintenance of pre-treatment and ancillary plant
- Adequacy of cleaning and disinfection.
4.15.1 Flushing
The risk of nosocomial legionellosis attributed to
the colonisation of hot and cold water systems by Legionella
bacteria is well established. In a study of ten hospitals
that were colonised by Legionella and ten that were
not colonised, Legionnaires disease was found significantly
more often in colonised than non-colonised hospitals
(p = 0.054).56 In a study of 20 Spanish hospitals, nosocomial
Legionnaires disease was found in 64.7% of the hospitals
with water cultures positive for Legionella, whereas
no nosocomial cases were found in hospitals with Legionella-negative
water cultures.
Exner et al in their review of the literature on nosocomial
infections cites a German study which investigated hospitals
and residential units and other buildings that could
be affected by the colonisation of the water system
with Legionella bacteria.58 In the study, local colonisation
of the water system was defined as colonisation of isolated
parts of the plumbing system (taps or showerheads).
Systemic colonisation was defined as colonisation of
the whole system, including the central parts of the
water supply. In the case of local colonisation it was
possible to flush out Legionella bacteria from the distal
water sites e.g. taps, showers. However, with systemic
colonisation even intensive system flushing had no effect
on the reduction of Legionella bacteria in the system.
If regular flushing is having no effect on the levels
of Legionella then all of the existing control procedures
need to be reviewed and amended if necessary.
Hot and cold water systems should be designed to aid
safe operation by preventing or controlling conditions
which permit the growth of Legionella. Flushing procedures
should be based on a risk assessment of the water systems
in the building/institution concerned. A flushing protocol
is only effective where the water system is adequate.
The following are risk factors that should be considered
in the risk assessment:
Institutional risk factors
Age and condition of the pipes
Older pipes are more prone to the growth of Legionella
because of corrosion, scaling, biofilms and sediment.
Legionella bacteria require a supply of nutrients to
multiply. Sources of these nutrients include commonly
encountered organisms within the water system such as
algae, amoebae and other bacteria. The presence of sediment,
sludge, scale and other material within the system,
together with biofilms, facilitate the growth of Legionella
and may provide protection for the Legionella bacteria
from temperatures and disinfectants that might otherwise
kill or inhibit the growth of these organisms.
Redundant pipe work and fittings
Hospitals are frequently constructed over a long period
of time and as a result often contain a considerable
amount of redundant pipework/deadlegs
in which water can stagnate which also facilitates
the growth of Legionella.59 Studies have shown that
flushing of outlets whilst reducing stagnation has little
effect on biofilm, particularly when applied to outlets
supplied from extensive pipework distribution systems.
Therefore, before the procedures are carried out, consideration
should be given to the removal of infrequently used
sanitary fixtures such as showers and taps, etc. If
they are removed then the redundant supply pipework
should be cut back as far as the main connection.52
Showers (excluding safety showers) should not be fitted
where they are likely to be used less than once per
week.
Complexity of the system
Complex, lengthy pipe systems are more at risk than
simpler, short systems.
Population at risk
In the hospital setting, patients with predisposing
risk factors are not only at higher risk of infection
but also have a higher mortality rate when infected
with Legionella. Consequently, hospitals and residential
institutions must pay particular attention to the prevention
of legionellosis. Those at higher risk include:
- Immunocompromised organ transplant patients, patients
with HIV/AIDS, and those receiving systemic steroids
- Patients with underlying chronic disease such as
diabetes mellitus, congestive heart failure, chronic
obstructive pulmonary disease, and chronic renal disease
- People over 50 years of age
- Smokers
- Those with excessive alcohol intake.
Prior history of building
History of legionellosis associated with the building
History of positive water cultures from the potable
water system and outlets or cooling towers.
When planning the construction of the water supply
system to a building it is essential to minimise the
development of biofilms. This can be done by emptying
water limbs that are not in service and by preventing
water stagnation in the distribution system. Disinfection
systems should be in place from the first moment the
water flows through the system. Once established, biofilms
are extremely difficult to eliminate. In new hot and
cold water systems, if more than seven days has elapsed
before the system is put into regular use, every outlet
should be flushed until the water temperature stabilises.
Thermostatic mixing valves
If water is maintained at 51C (124F) thermostatic mixing
valves (TMVs) can be used to prevent scalding.They should
be sited as close as possible to the point of use. Ideally,
a single TMV should not serve multiple tap outlets but
if they are used the mixed pipework should be kept as
short as possible. Self-disinfecting TMVs are now available
but their effectiveness may be compromised by the presence
of extensive sludge, scale and biofilm in the water
distribution network.
Zone protection
The risk assessment should also take into consideration
whether there is zone protection of the system i.e.
whether or not there is a possibility of cross-contamination
between different parts of the system. When buildings
are being planned or old buildings renovated, zone protection
of the water supply system should be included.
Flushing Procedure
The risk from Legionella bacteria growing in peripheral
parts of the water system such as deadlegs off the recirculating
hot water system may be minimised by regular use of
these outlets. Water within the system may stagnate
because a particular outlet is not used for more than
a week.59 In most hospitals, there are areas which may
have water outlets such as showers that are not used
for significant periods of time. These areas may change
from time to time, as wards or patient bathroom areas
are disused and reopened. Showers in such areas are
more likely to harbour Legionella than those in areas
where outlets are in regular use. Hotel accommodation
may present the same problem with bedrooms unused during
the off-peak periods.
Showers and water outlets that are in daily use do
not require flushing.
How to flush
The frequency and duration of flushing procedures should
be based on a risk assessment. Only run showers that
are intermittently used. All outlets should be flushed
at full flow (the water flow should be increased gradually
to minimise the production of aerosols) at least once
per week. However, risk assessment may indicate the
need for more frequent flushing where there is a more
susceptible population present, e.g. in hospitals, nursing
homes etc.52 High-risk areas in hospitals e.g. wards
with immunocompromised patients, renal transplant units,
may require flushing on a daily basis. The local multidisciplinary
infection control team should make these decisions.
Healthcare facilities
The duration of flushing should be based on a risk
assessment but at a minimum the procedure below should
be followed:
Showers
Run showers for four minutes weekly as follows:
Run cold for two minutes
Run hot for two minutes once water is hot.
Taps
Run individual hot and cold taps weekly as follows:
Run cold for two minutes
Run hot for two minutes once water is hot.
Mixer taps
Run with the lever in the coldest position for two
minutes weekly
Run with the lever in the hottest position for two
minutes weekly
Ensure that hot water comes out hot when in the hot
position and cold when in the cold position.
Cold water should be used to flush the cold water system
and hot water to flush the warm water system. The period
of flushing must be sufficient to remove all stagnant
water leading to the outlet. The number of outlets that
can be flushed simultaneously will depend on the capacity
of the water heater and the flow capability of the system
Where it is difficult to carry out weekly flushing,
the stagnant and potentially contaminated water from
within the shower/tap and associated deadlegs needs
to be purged to drain before the appliance is used.
It is important that this procedure is carried out with
minimum production of aerosols, e.g. additional piping
may be used to purge contaminated water to drain. Automatic
drain valves fitted to showers to drain the mixer valve
and shower hose after use, can produce conditions within
the shower that support the growth of Legionella, and
are not recommended as a method for controlling the
risk of exposure to Legionella
Where a single TMV serves several multiple showerheads,
it is important to ensure that these showers are flushed
frequently. Where an outlet is not used for more than
a week it must be flushed until the temperature of the
water at the outlet has reached the pre-determined temperature
set by the thermostatic mixing valve. Every thermostatic
mixing valve must be cleaned and maintained at least
once in every calendar year.
4.15.2 Cleaning and disinfection of showerheads
Consider replacing showerheads and hoses as an alternative
to cleaning and disinfection. Dismantle, clean and descale
showerheads and hoses quarterly or as necessary. In
high-risk areas this should be done on a monthly basis.
Disinfectants containing chlorine can be used to disinfect
showerheads.However, chlorine concentrations vary in
different products.Household bleach can lose some of
the chlorine over time so newly manufactured bleach
should be used if possible. Thick bleach solutions should
never be used for disinfection purposes as they contain
potentially poisonous additives.
Monitoring Once started, the flushing procedure has
to be sustained and logged as lapses can result in a
critical increase in Legionella bacteria density at
the outlet. A flushing protocol should be introduced
in each institution. The protocol should be incorporated
into the institution's regular cleaning contract. A
monitoring system must be put in place to monitor compliance
with the flushing protocol. Records of compliance should
be maintained and a nominated person should be accountable
for implementing the protocol and for maintaining records.
Audit
A regular audit of control and monitoring procedures
should take place. Precaution Maintenance, cleaning,
and operating procedures should be designed to control
the risks to staff and others who may be affected. Personnel
involved in flushing procedures should be adequately
trained in safety procedures including the use and maintenance
of personal protective equipment
4.15.3 Recommended inspection frequency and monitoring
guidance for risk systems
Hot and cold water systems
Temperature control
Cold water systems should be maintained at a temperature
<20C, while hot water should be stored at 60 C and
distributed so that it reaches a temperature of 50C
within one minute at the outlets. Care is needed to
avoid much higher temperatures because of the risk of
scalding. At 50C the risk of scalding is small for most
people. However, the risk particularly to young children,
people who are disabled or elderly and to those with
sensory loss will be greater. The risk of scalding also
increases rapidly with higher temperatures and for longer
exposure times. Where a significant scalding risk has
been identified the use of TMVs on baths and showers
should be considered to reduce temperature. These need
to be placed as close to the point of use as possible.52
Where buildings cannot be retrofitted with TMVs, periodically
increasing the temperature to at least 66C at the point
of use or chlorination followed by flushing should be
considered.
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