Back in 2002 the largest outbreak of Legionnaires ’ disease occurred in Barrow in Furness [B-i-F]. The investigation report identified six key failures. Coupled with the fact that in the last few weeks numerous Healthcare organisations have fallen into the media spotlight for various estates issues, such as non-compliance and backlog maintenance.
This blog will aim to provide an overview to those who are responsible for ‘Water Safety’ in Healthcare organisations.
Water Safety Law, Guidance and Compliance
ACoP L8 fourth edition provides advice on how to comply with the Health and Safety at Work etc Act 1974 [HSWA] and Control of Substances Hazardous to Health Regulations 2002 [COSHH] with respect to the risk from exposure to Legionella bacteria. The ACoP L8 are approved by the HSE with the consent of the Secretary of State. It details recommended methods and advice on how to achieve compliance.
ACoP L8 and the supporting HSG274 documents are not compulsory [unless specifically stated] other action can be taken. To follow the guidance you will normally be doing enough to comply with the law.
Compliance principles related to the safety of healthcare organisation estates and facilities are ‘enshrined’ in the Health & Social Care Act 2008 [Regulated Activities] Regulations 2014. More specifically Regulation 12[2][h] states that registered healthcare providers must assess the risk of, and prevent, detect and control the spread of, infections including those that are healthcare associated.
Failure to comply with the this Act and the Care Quality Commission [Registration] Regulations [2009] is an offence.
As with the ACoP L8 and supporting HSG274 documents, the HTM04-01 documents are not compulsory. To follow HTM04-01 documents you will normally be doing enough to comply with the law.
HTM04-01 was updated in 2016. The main changes with the 2016 edition:
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Provides comprehensive guidance on measures to control waterborne pathogens;
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Aligning with the HSE revised ACoP L8 and HSG274 documents;
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The removal of the addendum and creation of Part C. With Part B outlining the remit and aims of the Water Safety Group [WSG] and Water Safety Plan [WSP];
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New guidance on the hygiene storing and install of fittings and components. Including the competency of those working on water systems;
Water Safety Plans and Water Safety Groups
One of the six failures with the B-i-F outbreak included poor lines of communication and unclear lines of responsibility. To ensure such failures do not occur, a multidisciplinary group should be established, otherwise known as the Water Safety Group [WSG].
The group should ensure appropriate expertise is available to ensure a range of competencies exist to share the responsibility and collective ownership for the identification of hazards relating to water, the assessment of risk, the necessary control measures, monitoring requirements and incident arrangements.
The Water Safety Group could include representation from Estates [operational and projects], infection control, microbiology, specialist departments & users of water [Inc. augmented care], facilities [Inc. housekeeping], an Authorising Engineer [Water]. The Water Safety Group should be chaired by a person with management responsibility for water. There should be clearly defined roles and communications pathways [lines of accountability] for all up to the duty holder.
Those healthcare organisations which have existing robust documentation for water management such as policy, risk assessments operational control procedures will have much of the integral requirements of a Water Safety Plan [WSP]
The size and complexity of the Water Safety Plan will entirely depend on the healthcare organisation and the types of buildings, types of water / risk systems and the patients they treat. Ultimately the Water Safety Plan provides the healthcare organisation with a risk-management based approach to water safety, with established practices and operational procedures based on identified and assessed hazards.
In summary, each healthcare organisation should demonstrate compliance, suitable governance, competency of those involved and finally the accountability arrangements are in place for the delivery of safe water. These parameters can be achieved through an established Water Safety Group & a robust Water Safety Plans.
Editors Note: The information provided in this blog is correct at date of original publication - July 2017.
© Water Hygiene Centre 2019
