Back in 2002 the UK’s largest outbreak of Legionnaires’ disease occurred in Barrow in Furness [B-i-F]. The investigation report identified six key failures. Continued sporadic cases and evidence of the ubiquitous presence of Legionella and other waterborne pathogens such as Pseudomonas aeruginosa, remind us of the importance of ensuring identified water systems have fallen into the media spotlight. Non-compliances and robust backlog maintenance must remain foremost in our thoughts.
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
The HSE’s ACoP L8 fourth edition 2013 provides advice on how to comply with the Health and Safety at Work etc Act 1974 [HSWA] and the Control of Substances Hazardous to Health Regulations 2002 [COSHH], with regard to the specific risks from exposure to Legionella bacteria. ACoP L8 is approved by the HSE with the consent of the Secretary of State. It details recommended methods and advice on how to achieve an adequate level of compliance.
Many parts of ACoP L8 and its supporting HSG274 documents are not compulsory [unless specifically stated] and alternative actions may be taken, assuming these are at least the equal of the published guidance and you can demonstrate this to be the case. In following this guidance and any associated regulations, you will typically be doing enough to comply with the law.
Compliance principles related to the safety of healthcare organisations 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 this Act and the Care Quality Commission [Registration] Regulations [2009] is an offence. In common with much of ACoP L8 and its supporting HSG274 documents, the Department of Health’s HTM04-01 documents [Parts A - C] are not compulsory. Again, in demonstrating you are closely following HTM04-01 documents, you will normally be doing enough to comply with the law.
HTM04-01 was updated in 2016 and broadly incorporates the following;
- Comprehensive guidance on measures to control waterborne pathogens [In addition to Legionella];
- Alignment with the HSE revised ACoP L8 and HSG274 documents;
- Removal of the previously issued addendum and creation of Part C re Pseudomonas Aeruginosa;
- Part B specifically outlines the remit and aims of the Water Safety Group [WSG] and
Water Safety Plan [WSP]; - Guidance on the hygiene, storing and installation 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 combined with 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 WSG should ensure appropriate expertise is available to ensure a range of competencies are routinely present in meetings. These individuals will then share responsibilities and ensure collective ownership for the identification of hazards relating to water, the assessment of risk, the necessary control measures, monitoring requirements and incident arrangements.
The WSG may include representation from Estates [operational maintenance and projects], Infection Prevention & Control, Microbiology, Specialist Departments & users of water [Inc. augmented care], Facilities [Inc. housekeeping] and an Authorising Engineer [Water]. The WSG should also be chaired by a person with management responsibility for water. There should be clearly defined roles and communications pathways [lines of accountability] for all present up to and including the Duty Holder.
Those healthcare organisations which already have existing robust documentation for water management such as policy, risk assessments operational control procedures will have many of the integral requirements of a Water Safety Plan [WSP] as identified within HTM04-01 and more recently within BS8680 [2020] Water Quality – Water Safety Plans – Code of Practice.
The size and complexity of the WSP will depend entirely on the healthcare organisation and the type of buildings, type of water / risk systems and the vulnerability of patients they treat. Ultimately, the WSP 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, the competency of those involved and finally that accountability arrangements are in place for the delivery of safe water. These parameters can be achieved through an established Water Safety Group [WSG] & a robust Water Safety Plans [WSP].
Editors Note: The information provided in this blog is correct at date of original publication - April 2023.
© Water Hygiene Centre 2023
