Legionella Compliance and Record Keeping for the Education Sector

With never-ending to-do lists and busy working hours, it’s easy for things to be overlooked in a school, university or other academic institution. However, failing to control your legionella risk could put students and pupils in danger - and expose your organisation to the severe consequences of non-compliance.

Under the Health & Safety Executive’s Approved Code of Practice ACOP L8 and the HSG274 guidance, the education sector has clearly-defined responsibilities for controlling legionella bacteria in water systems. Failing to meet these responsibilities could result in sizable fines and immediate closure.

Do you understand your responsibilities? Do you know why the education sector is especially at risk? And are you confident you are taking the appropriate steps to keep pupils safe? If you answered no to any of these questions, read on for some practical guidance.

Who is responsible for controlling legionella risk?

The HSE describes a specific individual, or dutyholder, who is responsible for legionella control in an environment. In most private sector cases, this is the property owner or employer - but academic settings are often more complicated.

In Higher Education, the dutyholder tends to be the chancellor or dean. In schools, the dutyholder could be:

• The Chief Executive of the Local Authority for council-maintained schools

• The owner or headteacher in an academy or independant school

However, in practice, the task of arranging and overseeing measures for legionella control often falls to a facilities manager on-site.

The challenges of controlling legionella in education

Legionella bacteria can grow in any hot and cold water system with the right conditions. However, educational settings often face specific challenges that increase risk levels.

In older institutions, decades of expansion and piecemeal modernisation lead to complicated plumbing with tanks and pumps distributed across a site. This makes visibility and control harder than a master-planned plumbing system.

Meanwhile, some outlets and parts of the water system may not be used all year round. Swimming pools may only be open for the warmer months, while old showers in PE changing rooms may have been untouched for years on end.

Finally, lengthy periods of disuse over the summer can lead to water stagnation - a major risk factor for increased legionella growth.

Your legionella risk responsibilities

At the most fundamental level, every educational institution needs to carry out a legionella risk assessment.

This involves examining every aspect of your hot and cold water systems, understanding how your systems are used throughout the year, and building a profile of your risk level. While this can be conducted by any qualified person, most schools and universities work with an external partner for the specialist knowledge a full risk assessment requires.

After determining your risk, you are responsible for implementing the appropriate controls, safeguards, and immediate actions to lower your risk if necessary. This could include anything from system flushing and cleaning to recommending changes to your system and how it is used.

If your risk level is low, there is no need to take further action. However, you are still responsible for recording and reporting on your compliance.

Reporting on legionella risk assessments

Initially, your records should include who is responsible for legionella control, what your legionella risk assessment found, and the results of any sampling or water tests. Then, on an ongoing basis, you must keep records of how you control risk day-to-day - this could include temperature checks, cleaning and visual inspections.

In addition, your records should establish clear policies for regular re-testing and re-assessment. We recommend reviewing your risk assessment at least every two years, but can advise a more tailored plan based on your risk level and your systems.

Working with Comfort Services, we can take charge of every aspect of controlling your legionella risk. Our DBS-checked engineers can help you meet your responsibilities faster, easier and more cost-effectively.

To find out more, download our guide to legionella compliance in education.