-
Those involved in risk assessment
and risk management activities at a particular location
(whether an employee of the organisation or an external
consultant)
-
Those with a role in investigating
cases of Legionnaires disease and managing outbreaks
-
The person(s) in an organisation
who have been assigned specific responsibility for
the supervision of, and implementation of, Legionella
control measures (these will often, though not always,
be the same people as in the first category above)
-
Personnel in those workplace environments
more favourable to the growth and aerosolisation
of Legionella bacteria e.g. healthcare facilities,
leisure centres, hotels.
-
Reference to training and competency
is made in Chapter 4 The aforementioned chapter
deals exclusively with the training/competency requirements
for those carrying out risk assessments and for
the responsible person designated for Legionella
control within an organisation.
Those involved in environmental investigations of
cases of Legionnaires disease and in assessment of
control measures should have, in addition to knowledge
of the epidemiology of Legionnaires disease, prior
training in both theoretical (e.g. desktop studies)
and practical Legionella risk assessments (i.e. site
visits). They should also have a basic knowledge of
building services and have received training in appropriate
sampling procedures.
Training and competence relating to 'responsible persons'
are covered in section 4.7 of Chapter 4.
It is highly desirable that all staff working in higher
risk locations such as hospitals, hotels, leisure
centres, etc. have an awareness of the Legionella
hazards associated with their work environment and
knowledge of appropriate control measures. Training
workshops should be undertaken which are tailored
to institutions/operatives following a training needs
assessment. Basic information sheets on Legionella
hazards and control should be developed for distribution
to workplaces (e.g. Appendix H 'Minimising the Risk'
could be used/adapted for this purpose). The information
sheets should also have details of relevant websites
e.g. UK - HPA, and HSC; Ireland - HPSC, and HSA. The
designated responsible person for Legionella control
in each organisation should carry out awareness sessions
with the staff at regular intervals and keep records
of these.
6.2 'Competent person' and assessment of competency
The definition of 'competent person' given in Section
2 of the Safety, Health and Welfare at Work Act 2005
has been outlined in Appendix C. It relates to the
possession of 'sufficient training, experience and
knowledge appropriate to the nature of the work to
be undertaken'. Assessment of competency therefore
falls into two broad areas:
Formal qualification(s), if any, possessed by the
person. In this regard, Section 2.(2)(b) refers to
the 'framework of qualifications referred to in the
Qualifications (Education and Training) Act 1999.
This, in practice, relates to training or qualifications
which have formal validation and recognition in the
State through validating bodies, established under
the aforementioned Act such as the Higher Education
and Training Awards Council (HETAC) (subsequently
established by the Minister in 2001). This body is
responsible for validation of higher education and
training awards and recognition of institutions (e.g.
universities, institutes of technology etc.) to which
authority to make awards may be delegated. Any third
level institution offering further education or training
can apply to the HETAC for formal recognition.
The Minister also established the Further Education
and Training Awards Council (FETAC) under the 1999
Act. The Council recognises and validates shorter
courses e.g. those run by FAS, CERT, vocational educational
committees, Teagasc etc. The formal qualification
would also be expected to address the area of the
knowledge criterion of the 'competent person' definition.
Experience would relate to evidence
of the practical application of knowledge and training
in carrying out the duties assigned. This criterion
is necessarily more difficult to assess than that of
qualifications as it will generally be a more subjective
process and, of course, the person assessing the experience
will have to be competent in order to do so.
It is suggested that a person responsible for Legionella
control in a building or facility should have the following
competencies as a minimum:
-
Have a basic knowledge of the source,
means of transmission and symptoms of legionellosis
-
Be aware of the safety, health and
welfare at work statutory provisions relating to
Legionella
-
Be able to identify and assess sources
of risk
-
Have the ability to make suitable
and appropriate recommendations on how Legionella
risk can be managed
-
Be able to monitor the effect of
any control measures implemented or to identify
the appropriate outside expertise where necessary
-
Be able to maintain records of all
risk assessments, control plans, monitoring, reviews
and all other activities associated with Legionella
control.
6.3 Training matrix
The training matrix (Table 12) is based on the recommendations
of the Legionella Control Association in the UK and
is provided as guidance to assist statutory duty holders
and site responsible persons in identifying the training
requirements for managers, supervisors and operatives
involved in administration of water management control
programmes. Where these posts do not exist in-house,
it applies to experts who are brought in.
6.4 Personal Protective Equipment
There are legal requirements under the Safety, Health
and Welfare at Work Act 2005 that require employers
to protect the health and safety of employees, and of
other people associated with their institution, company
or business. All personnel/contractors must wear suitable
personal protective equipment (PPE) identified by a
works-specific risk assessment. PPE is any clothing,
equipment or substance designed to protect the user
from injury or illness. PPE is the very last line of
defence in protecting a person's health and safety
6.4.1 PPE and Legionella
Legionellosis is transmitted primarily by inhalation
of contaminated aerosols from aqueous sources or from
aspiration of contaminated water. Personnel involved
in the inspection and maintenance of air-handling and
water systems are at risk of contracting legionellosis
and should wear appropriate PPE while performing these
tasks. Water impermeable gloves should be worn when
working with contaminated water or where there is a
possibility that the water may be contaminated, (e.g.
when taking water samples). Cuts or abrasions should
be covered with waterproof dressings at all times where
there is a risk of infection from a variety of bacteria
that can be present in contaminated water (e.g. Pseudomonas
aeruginosa). It should be noted that Legionnaires disease
is a respiratory illness and CANNOT be contracted through
cuts or abrasions.
6.4.2 Provision, training, use and maintenance of PPE
Employers must provide suitable PPE to each employee
who may be exposed to risks. It is imperative to consider
the following aspects in relation to PPE:
- Ensure that all PPE provided is compatible, and
where appropriate can be used together
- Ensure that all PPE is used and maintained in accordance
with the manufacturer's instructions
- Ensure that all PPE provided fits correctly and
is used in the proper manner at all times
Provide adequate and appropriate training to enable
employees using the PPE to be aware of the risk(s) the
PPE will avoid or limit, and the actions required by
the employee to maintain the PPE in a fit state
- Training should be provided to all new employees
who may be exposed to risk when they start work
- Training should be provided to all employees who
may be exposed to risks when new PPE is obtained or
protocols are altered
- Training should be provided periodically to refresh
employees' knowledge of the correct use and maintenance
of PPE
- Written information and protocols for PPE use should
be available in relevant languages, where appropriate
- Maintain, replace and/or clean all PPE as necessary
and provide appropriate accommodation for employees
to store PPE
- Ensure that PPE provided does not interfere with
any medical condition(s) of the user
- Ensure that written or electronic records of all
PPE training provided to employees are maintained.
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