Water Hygiene Management Plan

The Water Hygiene Management Plan is designed to control and minimise the exposure to legionella or similar bacteria and the related health risks to anyone working, living, or visiting
Housing 21 properties.

The management plan applies to hot and cold-water services only

Management Plan Process:

  • Assess Risk
  • Management Plan 
  • Monitored regime completed for temperature measurements and  flushing 
  • Review the efficacy of the monitoring regime 
  • Water Hygiene/Legionella Risk Assessment

    The approved specialist contractor will complete the risk assessment to BS8580 in accordance with HSG274 and guidelines from the Legionella Contractors Association (LCA). The legionella risk assessment should be reviewed annually by the Housing/Local Housing Manager and every two years
    by the approved specialist contractor.

    Copies of the risk assessments are maintained electronically on the organisation’s shared drive
    here and in the Premises Log Book for each individual court.

    The legionella risk assessments are reviewed by the specialist contractor every two years or whenever there is reason to believe the original assessment is  no longer valid i.e., where there have been:
    • changes to the water system or its use.
    • changes to the use of the building.
    • new information about risks or control measures have become available.
    • monitoring indicates that control measures are no longer effective.
    • changes in key personnel.
    • any cases of legionellosis have been associated with the syst

    In any of the above circumstances the Head of Compliance must be notified to ensure that the
    legionella risk assessment, schematic diagrams, procedures, and information are updated to
    reflect the current situation.

    The Housing/Court Manager annual review should include:
    • a review of the Water Hygiene Risk Assessment.
    • confirm that regular monitoring has taken place.
    • confirm that all records in the Premises Logbook are up to date.
    • that any remedial works associated with the risk assessment have been completed*.
    • liaising with the Building Surveyor regarding any outstanding issues.

    *Managers can issue non-specialist works to a competent contractor of their choice. Specialist
    works i.e., tank cleans, and disinfections will be managed by the Compliance Team.

    When works are complete the Local Housing Manager should update the risk assessment and the water hygiene logbook to evidence that the identified risks have been removed.

  • Written Scheme

    Control of Substances Hazardous to Health (COSHH) Regulations require that measures are put in place to protect employees from the foreseeable risk of legionella. If it is not practicable to avoid exposure to legionella present in water systems, then HSE ACOP L8 requires that a Written Scheme is put in place.

    The appointed specialist contractor will provide a Written Scheme which should include:
    • A current plan showing layout of the plant or water system, including parts temporarily out of use (a schematic diagram is adequate);
    • a description of the correct and safe operation of the system.
    • the precautions to be taken including any physical treatments such as flushing the system or chemical treatments.
    • checks to be carried out to ensure the effectiveness of the scheme and the frequency of such checks; and
    • remedial actions to be taken if the scheme is shown not to be effective.

    The Written Scheme must demonstrate how the risks are to be controlled, implemented, and managed, to include:
    • the physical treatment programme such as the use of temperature control for hot and cold water systems.
    • the chemical treatment programme, including a description of the manufacturers data on effectiveness, the concentrations and contact time required.
    • health and safety information for storage, handling, use and disposal of chemicals.
    • remedial measures to take in case the control limits are exceeded, including lines of communication.
    • cleaning and disinfection procedures.
    • emergency procedures.

    Consideration must be given to ensure the safety of customer groups when cleaning and disinfection is to take place, to ensure they do not bathe in or drink the water during disinfection or cleaning regimes.

    It should also include full details of the correct operation, monitoring, and maintenance of the water system installation.

  • Schematic Diagrams

    • be simple accurate representations of the water system layout including parts out of use
    • be easy for anyone to interpret the layout without specialised knowledge or experience
    • be current
    • show the layout of the plant and equipment including positions of sentinel taps
    • include servicing and control valves within the water system e.g., isolation valves
    • include components relevant to legionella risk e.g., outlets, strainers, filters, parts out of use.

  • Premises Logbook

    The premises logbook must be always maintained on site and be available to anyone that needs
    access to the following information:
    • The current WHMP.
    • The written scheme and details of its implementation and those responsible for its implementation.
    • Current Legionella Risk Assessment including significant findings.
    • Schematic diagram of the water system.
    • Signing-in sheet/Monitoring/sampling records by the contractor.
    • Monitoring records by the Housing/Court Manager.
    • Details of any work completed on the water system.
    • Training records of those involved in managing, monitoring, and controlling the risk from legionella.

    All records shall be maintained for a minimum of five years and in accordance with HSE ACOP L8 4th Edition 2013.

  • Temperature regime control of Legionella

    General approach used by Housing 21.
    • Hot water should be stored at 60 deg C
    • Distributed so it reaches a temperature of 50 deg C within one minute at outlets.

    Hot water at 50 deg C has a lower potential risk of scalding for most people. An increased risk is
    present for vulnerable people including the elderly, those with learning difficulties or sensory loss.

    Where a significant scalding risk is present e.g., for the protection of the elderly the use of
    thermostatic mixing valves (TMV’s) on baths and basin-taps is recommended. Recommended
    temperatures are risk based depending upon the environment (assessed locally) and range up to 44 deg C.

    Water hygiene contractors should ensure the devices are installed correctly, working safely, and serviced in accordance with the manufacturers’ guidelines. They must be suitable for the water conditions of the area.

    Monitoring of water temperatures should be carried out in accordance with the regime for the

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