In this blog we are going to consider records for water safety. When we say ‘records’ we don’t mean the round vinyl LP type (Handel’s ‘Water Music’, anyone?). No. We are focusing on records that form documented evidence to demonstrate compliance.
Let’s start by taking a step back and understand where the need for records stems from. The Management of Health and Safety at Work Regulations 1999 require employers to carry out risk assessments, make arrangements to implement necessary measures, appoint competent people and arrange for appropriate information and training. With each one of these requirements essentially there will be some form of written record to deliver, define, shape and/or explain. This is further explained in the HSE guide HSG65 Managing for Health and Safety with the Plan / Do / Check / Act principle:
- PLAN – a documented policy of implementation;
- DO – a documented assessment of risk and their associated controls;
- CHECK – documented measure of performance;
- ACT – review of the documented performance.
Moving on to the more specific requirement to manage water safety within an organisation, the same principles of Plan / Do / Check / Act will apply for duty holders to comply with their legal obligations:
- Legionella Risk Assessment – documented assessment [where greater than five employees] identifying and assessing the source of risk;
- Water Safety Plan – preparation of a WSP for preventing and controlling the risks identified in the assessments;
- Implementation – delivery of monitoring precautions and management plans to ensure systems are under control;
- KEEP RECORDS – evidence of precautions and actions;
- Appointments – written appointment of a person/s with sufficient authority and knowledge of water safety.
For each of these you’ll see that some form of record is required, some might be longer than others and the format of the document may vary.
With regard to appointments, this will start with the appointment of a Responsible Person [Water]. The RP[W] has an overarching responsibility to ensure that the written scheme or ‘Water Safety Plan’ is well managed and remains effective relative to the identified risks. Moreover, risk can change with an evolving estate, so it’s imperative that an RP’s approach to managing risk is equally dynamic and that this can be evidenced by suitable record keeping. The suitability of records and the effectiveness of the water safety plan can be determined by a process of regular reviews.
The review process should include regular Water Safety Group meetings with the key staff members who are instrumental in the provision of safe water systems. The membership will vary depending on the size and complexity of the organisation, typically members include Deputy Responsible Person, Authorised Person, Authorising Engineer, Microbiologist, Infection Control, Facilities Representatives. All these persons will be responsible for an element of the Water Safety Plan as they have a collective responsibility for water safety.
The Water Safety Group will follow a defined and relevant agenda i.e. policy (including appointments, competency, training), risk assessments, operational management and logbooks. For example:
- Training & Competency: reviewing a defined training analysis matrix for all individuals involved in water management this includes those external organisations you may have appointed. This should include the review of applied skills and knowledge, through a defined appraisal process, as evidence of competency;
- Water Hygiene Audits: reviewing the findings of periodic audits including the Authorising Engineer [Water] audits;
- Operational Records: may consist of information provided by internal competent persons but also external service providers, where is the evidence defined processes and competency of their staff.
Water Safety Group meetings will focus evidence of compliance through defined reporting processes that inform the RP whether the risk of water safety is managed [or not].
The ‘type/format’’ of records may vary between organisations based on the record management system you have in place i.e. paper records / electronic records. Paper records should be held in a defined file structure and this should be replicated on a ‘shared’ computer drive if paper records are scanned. With electronic records and data capture systems there is a reliance on pre-set parameters and establishing all the required monitoring points. Once such a system is in place it is important that all relevant staff can use the system competently and retrieve data reports.
Records should be retained for the period in which they remain current and:
- For an additional two years for risk assessments;
- For an additional five years for all monitoring and inspection data.
In summary, records are evidence. Without records it is very difficult to convince others that a task has been completed. Records are a fundamental foundation stone of successful water safety management. The opportunity exists to review each step of the water safety process and ensure there is adequate detail, information, instruction, reporting and mitigation in place. Records are your evidence, not your vinyl collection!
Editors Note: The information provided in this blog is correct at date of original publication - November 2018.
© Water Hygiene Centre 2019