Legionella Guidelines - An update and the consequences of getting it wrong

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Legionella bacteria can be living in your water supply, in fact anywhere in your building where water collects. It causes Legionellosis, a pneumonia like illness; the most well known form being Legionnaires' disease

The bacteria are common in water systems, such as rivers and lakes but rarely in such concentrated quantities for people to catch Legionnaires' disease.

This normally occurs when Legionella bacteria is found in purpose built water systems, such as those within your building. This is why it's essential to understand your obligations and requirements around Legionella and the L8 guidelines laid down by the HSE.

This presentation comes from the first in a series of educational seminars hosted by Acorn Maintenance, specifically to help existing clients and customers keep abreast of current legislation and best practice guidelines.

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Legionella Guidelines - An update and the consequences of getting it wrong

  1. 1. LEGIONELLALEGIONELLA AWARENESSAWARENESS Management ResponsibilitiesManagement Responsibilities Stuart R WiltonStuart R Wilton BSc(Hons);MSc;FRSPH;FWMSoc.BSc(Hons);MSc;FRSPH;FWMSoc. On behalf ofOn behalf of Acorn Maintenance LimitedAcorn Maintenance Limited 2525thth July 2013July 2013
  2. 2. Water Hygiene - LegionellaWater Hygiene - Legionella Judge Mr Justice S Burnton’s sentencing remarks:Judge Mr Justice S Burnton’s sentencing remarks:  A tragedy which never should have happened;A tragedy which never should have happened;  Numerous opportunities open to many to take stepsNumerous opportunities open to many to take steps to prevent the outbreak;to prevent the outbreak;  How serious court considers these Health & SafetyHow serious court considers these Health & Safety failures;failures;  To demonstrate to those who have responsibility forTo demonstrate to those who have responsibility for H&S that they must fulfil these otherwise they will beH&S that they must fulfil these otherwise they will be brought before court and properly punished.brought before court and properly punished.
  3. 3. Legionella AwarenessLegionella Awareness  What happened in Edinburgh – Summer 2012What happened in Edinburgh – Summer 2012  3 dead – 40/50/62 year old men, with3 dead – 40/50/62 year old men, with underlying health issues;underlying health issues;  48 confirmed cases with 95 suspected;48 confirmed cases with 95 suspected;  Cooling towers involved;Cooling towers involved;  HSE Improvement Notices issued & newHSE Improvement Notices issued & new information on HSE web site.information on HSE web site.  All towers in UK to get an HSE inspection.All towers in UK to get an HSE inspection.  HSE estimate 15,000 systems!!HSE estimate 15,000 systems!!
  4. 4. Legionella AwarenessLegionella Awareness  What's happened in Stoke?What's happened in Stoke?  2 people dead;2 people dead;  20+ infected;20+ infected;  Spa pool in JML warehouse shop;Spa pool in JML warehouse shop;  Untreated/not monitored & no riskUntreated/not monitored & no risk assessment!!assessment!!
  5. 5. Legionella AwarenessLegionella Awareness  HSE Olympic Report – Summer 2012HSE Olympic Report – Summer 2012  Internal report leaked to the Guardian;Internal report leaked to the Guardian;  Concerns over sites using FMConcerns over sites using FM companies;companies;  Poor level of compliance – 106 sitesPoor level of compliance – 106 sites visited – 15 improvement noticesvisited – 15 improvement notices issued.issued.
  6. 6. Bulmer's Outbreak 2003 Both Bulmers and Nalco Fined £300K.Guilty under Section 3(1) of the Health & Safety at Work Act 1974.
  7. 7. “THE HEADLINES” THE TRUTH, THE WHOLE TRUTH AND NOTHING BUT THE TRUTH!!
  8. 8. Legionella AwarenessLegionella Awareness  Why are we still having problems?Why are we still having problems?  Building managers are reluctant to takeBuilding managers are reluctant to take responsibility;responsibility;  Building owners unaware of how water isBuilding owners unaware of how water is “processed” in buildings;“processed” in buildings;  Confusion & misunderstanding about whatConfusion & misunderstanding about what evidence should be obtained to confirmevidence should be obtained to confirm hazard has been adequately controlled;hazard has been adequately controlled; McCoy W.F. 2012.McCoy W.F. 2012.
  9. 9. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  WHAT IS LEGIONNAIRES’ DISEASE?WHAT IS LEGIONNAIRES’ DISEASE?  HISTORY OF THE DISEASEHISTORY OF THE DISEASE  UK LEGISLATION & GUIDANCEUK LEGISLATION & GUIDANCE  ECOLOGY OF THE ORGANISMECOLOGY OF THE ORGANISM  PREVENTION AND/OR CONTROLPREVENTION AND/OR CONTROL
  10. 10. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  A severe type of pneumonia – namedA severe type of pneumonia – named after the first known large outbreakafter the first known large outbreak amongst American Legionnaires inamongst American Legionnaires in 1976;1976;  Occurs more frequently in men, overOccurs more frequently in men, over 50’s with underlying chest problems;50’s with underlying chest problems;  About 30-40% cases contracted abroadAbout 30-40% cases contracted abroad
  11. 11. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  CAUSED BY A BACTERIUM CALLED:CAUSED BY A BACTERIUM CALLED: LEGIONELLA PNEUMOPHILA  BACTERIA ENTERS BODY IN SMALLBACTERIA ENTERS BODY IN SMALL INHALABLE WATER DROPLETS;INHALABLE WATER DROPLETS;  DISEASE DOES NOT SPREAD FROMDISEASE DOES NOT SPREAD FROM PERSON TO PERSON.PERSON TO PERSON.
  12. 12. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  SYMPTOMSSYMPTOMS  HIGH TEMPERATURE/FEVER/CHILLSHIGH TEMPERATURE/FEVER/CHILLS  COUGHCOUGH  MUSCLE PAINMUSCLE PAIN  HEADACHE;LEADING ONTOHEADACHE;LEADING ONTO  PNEUMONIA, VERY OCCASIONALLYPNEUMONIA, VERY OCCASIONALLY  DIARRHOEA SIGNS OF MENTALDIARRHOEA SIGNS OF MENTAL CONFUSION.CONFUSION.
  13. 13. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  INCIDENCE IN UK?INCIDENCE IN UK?  200-300 RECORDED CASES;200-300 RECORDED CASES;  A LOT OF CASES UNDIAGNOSED;A LOT OF CASES UNDIAGNOSED;  HPA GUESTIMATE IS BETWEENHPA GUESTIMATE IS BETWEEN 5000-15,000 CASES;5000-15,000 CASES;  MAJORITY ARE CONTRACTEDMAJORITY ARE CONTRACTED FROM HOT/COLD WATERFROM HOT/COLD WATER SERVICES.SERVICES.
  14. 14. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  LEGIONELLA BACTERIA CAN BELEGIONELLA BACTERIA CAN BE FOUND IN NATURAL WATERS –FOUND IN NATURAL WATERS – REQUIRE “WARMER” WATER TOREQUIRE “WARMER” WATER TO REPRODUCE – IDEAL RANGE 20REPRODUCE – IDEAL RANGE 20°-°- 45°C;45°C;  BUILDING WATER SYSTEMS CANBUILDING WATER SYSTEMS CAN PROVIDE AN IDEAL ENVIRONMENT –PROVIDE AN IDEAL ENVIRONMENT – COOLING TOWERS & HOT/COLDCOOLING TOWERS & HOT/COLD WATER SYSTEMS.WATER SYSTEMS.
  15. 15. LEGIONELLA UPDATELEGIONELLA UPDATE  Cooling TowersCooling Towers  Whirl pool spas – JacuzzisWhirl pool spas – Jacuzzis  Domestic hot water services(cold water?)Domestic hot water services(cold water?)  Humidifiers – spray/ultrasonicHumidifiers – spray/ultrasonic  Ornamental fountainsOrnamental fountains  Car WashesCar Washes  Screen wash bottles – 20% SLIScreen wash bottles – 20% SLI  Potting compostPotting compost
  16. 16. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  BUILDING OPERATORS SHOULD:BUILDING OPERATORS SHOULD:  RISK ASSESS SYSTEMS/SERVICES;RISK ASSESS SYSTEMS/SERVICES;  PREPARE A SCHEME TOPREPARE A SCHEME TO PREVENT/CONTROL;PREVENT/CONTROL;  IMPLEMENT,MONITOR & MANAGEIMPLEMENT,MONITOR & MANAGE  KEEP RECORDSKEEP RECORDS  APPOINT A RESPONSIBLE PERSON.APPOINT A RESPONSIBLE PERSON.
  17. 17. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  STATUTORY DUTY HOLDER at your site?STATUTORY DUTY HOLDER at your site?  RESPONSIBLE PERSON at your site?RESPONSIBLE PERSON at your site?  RISK ASSESS SYSTEMS/SERVICES –RISK ASSESS SYSTEMS/SERVICES – where are assessments kept? When werewhere are assessments kept? When were they last done – are they fit for purpose?they last done – are they fit for purpose?  PREPARE A SCHEME TOPREPARE A SCHEME TO PREVENT/CONTROL;PREVENT/CONTROL;  IMPLEMENT,MONITOR & MANAGE;IMPLEMENT,MONITOR & MANAGE;  KEEP RECORDS – LOG BOOKS;KEEP RECORDS – LOG BOOKS;  APPOINT DEPUTY at your site?APPOINT DEPUTY at your site?
  18. 18. Legionella AwarenessLegionella Awareness  SDH – required to have access to competentSDH – required to have access to competent help to assess risk and what controlhelp to assess risk and what control measures maybe required;measures maybe required;  SDH appoints RP(in writing), RP needs toSDH appoints RP(in writing), RP needs to ensure that WT companies & consultants areensure that WT companies & consultants are competent & suitably trainedcompetent & suitably trained  Competence – Knowledge & experience –Competence – Knowledge & experience – can be difficult to judge.can be difficult to judge.  Use an LCA registered WT company.Use an LCA registered WT company.
  19. 19. HEALTH & SAFETY EXECUTIVE ACOP AND GUIDANCE – L8 CAME INTO FORCE 8TH JANUARY 2001. CIBSE TM13 guidance has been updated now available from CIBSE HSE consulting on L8 guidance revision – ACOP will remain as now with new guidance section with Web-updates – expected end of 2013.
  20. 20. Legionella AwarenessLegionella Awareness  Approved Code of PracticeApproved Code of Practice  Identification & assessment of risk;Identification & assessment of risk;  Managing the risk – responsibilities/training &Managing the risk – responsibilities/training & competence;competence;  Preventing or controlling the risk;Preventing or controlling the risk;  Record keeping;Record keeping;  Responsibilities ofResponsibilities of manufacturers,importers,suppliers andmanufacturers,importers,suppliers and installers.installers.
  21. 21. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  LEGAL PERSPECTIVELEGAL PERSPECTIVE  L8 – ACOPL8 – ACOP  GIVES PRACTICAL GUIDANCE WITHGIVES PRACTICAL GUIDANCE WITH RESPECT TO:RESPECT TO:  HEALTH & SAFETY AT WORK ACTHEALTH & SAFETY AT WORK ACT  COSHHCOSHH  HEALTH & SAFETY OFFENCES ACT.HEALTH & SAFETY OFFENCES ACT.
  22. 22. HEALTH & SAFETY OFFENCESHEALTH & SAFETY OFFENCES ACTACT  Enacted January 2009Enacted January 2009  Increase penalties/sentencing powersIncrease penalties/sentencing powers  Fines raised to £20,000Fines raised to £20,000  Imprisonment an option for more H&SImprisonment an option for more H&S offences(6 months – 2 years).offences(6 months – 2 years).
  23. 23. Legionella awarenessLegionella awareness New British Standard for Legionella RiskNew British Standard for Legionella Risk AssessmentAssessment BS 8580:2010 Water quality – RiskBS 8580:2010 Water quality – Risk assessments for Legionella control – Code ofassessments for Legionella control – Code of Practice.Practice. Covers:Covers:  Terms and definitionsTerms and definitions  Site visit/surveySite visit/survey  ReportingReporting  SchematicsSchematics  Reviews – updated every 2 yearsReviews – updated every 2 years
  24. 24. Legionella awarenessLegionella awareness  Systems most difficult to assess are often those with tempsSystems most difficult to assess are often those with temps between 20-30between 20-30°C with intermittent use as –°C with intermittent use as –  Significant lack of knowledge on Legionella ecology;Significant lack of knowledge on Legionella ecology;  Culture samples may help but negative results do notCulture samples may help but negative results do not necessarily mean there is no risk;necessarily mean there is no risk;  Application of novel technologies/energy conservation mayApplication of novel technologies/energy conservation may unwittingly create new risks – Solar heating,rain/grey waterunwittingly create new risks – Solar heating,rain/grey water recovery.recovery.  Perceived RISKS ARE OFTEN PROVEN – EVENTUALLY!!Perceived RISKS ARE OFTEN PROVEN – EVENTUALLY!!
  25. 25. Legionella AwarenessLegionella Awareness  WT company fined £24,000 plus £17,276 costsWT company fined £24,000 plus £17,276 costs forfor inadequate legionella assessments at Welsh careinadequate legionella assessments at Welsh care homes.homes.  Elderly nursing home residents are at greater risk;Elderly nursing home residents are at greater risk;  Clear responsibility to companies carrying out RAClear responsibility to companies carrying out RA work to provide adequate surveys and information.work to provide adequate surveys and information.
  26. 26. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  EnsureEnsure ManagementManagement Structure is robust;Structure is robust;  Should be a checkShould be a check system at all levels;system at all levels;  Regular reviewsRegular reviews
  27. 27. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  NATURAL HISTORY-ECOLOGYNATURAL HISTORY-ECOLOGY  WATER TEMPERATUREWATER TEMPERATURE  NUTRIENTSNUTRIENTS  OTHER ORGANISMS - BIOFILMOTHER ORGANISMS - BIOFILM  STAGNATIONSTAGNATION  CORROSION/SCALE/SLUDGECORROSION/SCALE/SLUDGE
  28. 28.  HPA GUIDANCE ON COLDHPA GUIDANCE ON COLD TEMPERATURESTEMPERATURESTemperatureTemperature Effect on Legionella growthEffect on Legionella growth <20°C<20°C LP survives but doesn’t grow significantly if at all.LP survives but doesn’t grow significantly if at all. 20 - 2520 - 25°C°C LP grows very slowly,easily out competed by otherLP grows very slowly,easily out competed by other bacteria and protozoa.bacteria and protozoa. 26 - 3026 - 30°C°C LP growth rate increases,coexists with protozoa,LP growth rate increases,coexists with protozoa, other bacteria grow quickly.other bacteria grow quickly. 31 - 3531 - 35°C°C LP grows well in protozoa, other bacteria alsoLP grows well in protozoa, other bacteria also growing quickly.growing quickly. 35 - 4535 - 45°C°C 46 - 50°C46 - 50°C LP grows optimally, potential to out compete otherLP grows optimally, potential to out compete other bacteria and “overcome” protozoa.bacteria and “overcome” protozoa. LP becoming inhibited and possibly dying slowly.LP becoming inhibited and possibly dying slowly.
  29. 29. COOLING TOWERSCOOLING TOWERS  LARGE OUTBREAKS GENERALLYLARGE OUTBREAKS GENERALLY CAUSED EXCLUSIVELY BY POORCAUSED EXCLUSIVELY BY POOR MAINTENANCE;MAINTENANCE;  STAFFORD HOSPITAL – 1983;STAFFORD HOSPITAL – 1983;  BBC BROADCASTING HOUSE;BBC BROADCASTING HOUSE;  BULMERS CIDER - 2003;BULMERS CIDER - 2003;  BARROW IN FURNESS – 2002;BARROW IN FURNESS – 2002;  SOUTH WALES – 2010;SOUTH WALES – 2010;  EDINBURGH – 2012.EDINBURGH – 2012.
  30. 30. COOLING TOWERSCOOLING TOWERS  WATERWATER TREATMENT TOTREATMENT TO CONTROL-CONTROL-  SCALESCALE  CORROSIONCORROSION  MICROBIALMICROBIAL GROWTHGROWTH  FOULING –FOULING – SLUDGE/SILTSLUDGE/SILT  WATER SOFTENERWATER SOFTENER  INHIBITORSINHIBITORS  BIOCIDESBIOCIDES  SIDE STREAMSIDE STREAM FILTRATION/FILTRATION/  DISPERSANTSDISPERSANTS
  31. 31. COOLING TOWERSCOOLING TOWERS  L8 LISTS SPECIFIC CHEMICAL TESTS –L8 LISTS SPECIFIC CHEMICAL TESTS – THESE NEED TO BE CARRIED OUT BYTHESE NEED TO BE CARRIED OUT BY TRAINED/COMPETENT STAFF;TRAINED/COMPETENT STAFF;  ALSO NEED TO CHECK MECHANICALALSO NEED TO CHECK MECHANICAL ITEMS INCLUDING DRIFT ELMINATORSITEMS INCLUDING DRIFT ELMINATORS AND DOSING EQUIPMENT/WATERAND DOSING EQUIPMENT/WATER SOFTENERS.SOFTENERS.  THESE ARE “INVOLVED” CHECKS WHICHTHESE ARE “INVOLVED” CHECKS WHICH CANNOT BE RUSHED!!CANNOT BE RUSHED!!
  32. 32. Cooling Tower Weekly ChecksCooling Tower Weekly Checks  phph  ConductivityConductivity  Oxidising biocide – BromineOxidising biocide – Bromine  Bacterial activity – Dipslides –Bacterial activity – Dipslides – laboratory test – biofilm monitoring?laboratory test – biofilm monitoring?  Visual Inspection – driftVisual Inspection – drift eliminators/packing/tower sump – couldeliminators/packing/tower sump – could be monthly depending on risk.be monthly depending on risk.
  33. 33. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  Barrow Outbreak.Barrow Outbreak.  7 dead,180 infected.7 dead,180 infected.  Several “awful flaws”Several “awful flaws”  Coroners’ verdict –Coroners’ verdict –  ““A Total Shambles”A Total Shambles”  Download a copy-Download a copy-  www.hse.gov.uk/legiwww.hse.gov.uk/legi onnaires/index.htmonnaires/index.htm
  34. 34. LESSONS FROM BARROWLESSONS FROM BARROW HSE Report Summary:HSE Report Summary: 1.1. POOR LINES OF COMMUNICATION ANDPOOR LINES OF COMMUNICATION AND UNCLEAR LINES OF RESPONSIBILTY;UNCLEAR LINES OF RESPONSIBILTY; 2.2. FAILURE TO ACT ON ADVICE AND CONCERNSFAILURE TO ACT ON ADVICE AND CONCERNS RAISED;RAISED; 3.3. FAILURE TO CARRY OUT RISK ASSESSMENTS;FAILURE TO CARRY OUT RISK ASSESSMENTS; 4.4. POOR MANAGEMENT OF CONTRACTORS ANDPOOR MANAGEMENT OF CONTRACTORS AND CONTRACT DOCUMENTATION;CONTRACT DOCUMENTATION; 5.5. INADEQUATE TRAINING AND RESOURCES;INADEQUATE TRAINING AND RESOURCES; 6.6. INDIVIDUAL FAILINGSINDIVIDUAL FAILINGS.. AN ABSOLUTE SHAMBLESAN ABSOLUTE SHAMBLES
  35. 35. Legionella AwarenessLegionella Awareness  What’s on the horizon?What’s on the horizon?  Water Safety Plans – WHO;Water Safety Plans – WHO;  HACCP for Water Management –(HazardHACCP for Water Management –(Hazard Analysis & Critical Control Point);Analysis & Critical Control Point);  Increased level of prosecution &Increased level of prosecution & compensation - HSE will be charging forcompensation - HSE will be charging for intervention;intervention;  Increased levels of competence will beIncreased levels of competence will be required?required?  Use of new technology for systemUse of new technology for system monitoring?monitoring?
  36. 36. LEGIONELLA AWARENESSLEGIONELLA AWARENESS  TO SUMMARISE –TO SUMMARISE –  A SERIOUS DISEASE ON THE INCREASE;A SERIOUS DISEASE ON THE INCREASE;  PREVENTABLE;PREVENTABLE;  ATTENTION TO DETAIL;ATTENTION TO DETAIL;  COMPETENT STAFF;COMPETENT STAFF;  PROACTIVE MANAGEMENT.PROACTIVE MANAGEMENT. NOT COMMON,NOT GOING AWAY ANDNOT COMMON,NOT GOING AWAY AND IS STILL KILLING PEOPLE – HPAIS STILL KILLING PEOPLE – HPA 20112011

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