Carrying out Legionella risk assessments in your hospital is vital for preventing outbreaks of Legionnaires' disease and can provide additional information about avoiding contamination of the water system.
As a result of such Legionella risk assessment, remedial (engineering) and or management actions may then be recommended to help reduce the degree of risk associated with your water systems.
Legionella Risk Assessment & Remedials
Many hospital Estate Managers continue to feel tempted to use the same company to carry out the risk assessment, the associated remedial actions and or monitoring actions too.
Though it may appear this approach streamlines your operations by employing the same company to deliver the risk assessment and deal with the associated remedial process or routine operational tasks, this may not be the best approach.
Rather, it is important to commission independent risk assessments, completed by an accredited company that is separate from those providing remedial works when managing water safety in hospitals (and other types of organisations too).
BS8580-1 2019 Water Quality - Risk assessments for Legionella control – code of practice, section 5.3 talks about Independence. The risk assessor should be able to demonstrate impartiality and independence when carrying out Legionella risk assessments. The risk assessor or assessing organisation should not allow commercial, financial or other pressures to compromise impartiality and should be able to demonstrate valid reasons for any proposed course of action.
It should be clear, for example, why a recommendation has been made to clean cold water storage tanks. Where an organisation provides risk assessment services as well as other services, for example, water treatment or cleaning and disinfection, it should have safeguards in place to ensure adequate segregation of responsibilities and accountabilities through appropriate reporting structures.
The issue of bias
As an Estates Manager, you will have agreed on a fixed cost with a company for the provision of your Legionella risk assessment. However, when it comes to the completion of remedial works, the extent of work that a company is paid for will depend on the extent of remedial work that is indicated as being required.
So, if the risk assessment indicates that no remedial works are required, then you as an Estates Manager will not need to pay a penny. That said the risk assessment you receive, will almost certainly recommend remedial work. To reduce risk and demonstrate a proactive risk management approach, you will then be required to start funding these actions to be completed by a company, whether there are a few or many recommendations.
Having the same company carry out both the risk assessment and the remedial work raises the possibility that the risk assessment may not have impartial findings or recommendations. In short, the company may make recommendations for unnecessary remedial work in your Legionella risk assessment, knowing this remedial work will be undertaken by themselves, unquestioned.
This is commonly experienced when assessing the condition of a cold water cistern, but does it require cleaning annually?
For this reason, separate companies should be commissioned by you to deliver an independent risk assessment (by an accredited company) on the one hand, and the remedial work completed by a separate company, on the other hand, ensuring impartiality and unbiased recommendations.
Being transparent about the approach of commissioning independent Legionella risk assessments from the very start of any risk assessment process, ensures all interested companies understand you as an Estates Manager can see the potential for ‘bias’ existing along with unnecessary additional costs.
In summary, the company commissioned to deliver the independent risk assessment, and has no vested interest in remedial work, will provide a balanced and more objective assessment.
Editors Note: The information provided in this blog is correct at the date of original publication - July 2022
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