An important part of the management and control of legionnaires’ disease is having a robust management plan in place. As it says in ACoP L8: 2013
50 Inadequate management, lack of training and poor communication are all contributory factors in outbreaks of legionnaires’ disease. It is therefore important that the people involved in assessing risk and applying precautions are competent, trained and aware of their responsibilities.
This starts with having a fully detailed company policy on preventing legionella agreed and issued by the “responsible person” or someone they have appointed to do this in their place.
The policy should clearly state what the organisation will do to comply with the regulations including who created the policy, when it will be reviewed, what regualtions wil be followed, the structure of the management in place, including if possible an organogram.
This should be coupled with a detailed “Written Scheme”, this should not be confused with the written scheme of control which is a list of the control measures that need to be put in place. The “Written Scheme” as detailed in HSG 274 part 2: 2014, refers to the complete management of legionella within a site. Is is therefore not a single document but a collection of documents pulled together in one place to ensure that, as above, all those involved are aware of what is expected. It normally includes; -
- A copy of the company legionella policy or the location of where the up to date electronic copy is held.
- A management organogram showing the people that will be involved involved including lines of communication and responsibility.
- A fully detailed list of the individual role and responsibility that each position named within the organogram has in order to comply with the regulations, the company legionella policy and the remaining contents of the “Written Scheme”. The person who occupies each position must sign to show that they understand their role and if that person leaves their replacement should read and understand before signing as the replacement.
- Details of the last risk assessment carried out, how the areas of non conformance identified are being rectified and how these are signed off.
- What control measures are required, what the acceptable parameters for each test / inspection are and what is to be done if the testing / inspections find it to be outside these parameter.
- A copy of the approved method statements and task risk assessments along with a COSHH assessment if chemicals are being used.
- Lastly what, how and who will audit to ensure that all parts are being followed as prescribed and what actions should be taken if problems are found.
If producing these documents takes you way out of your comfort zone please speak to us, we would be happy to assist by pulling this together for you. We are also available to help when introducing these formal documents to those who will be involved and ensuring that they both understand and importantly sign to show they agree they understand and will follow the contents.