YOUR GUIDE TO

Legionella Risk Assessment for Commercial Property & Legionella Compliance for Duty Holders

FOR SCHOOLS, COLLEGES & UNIVERSITIES

COMFORT SERVICES GROUP IS A MEMBER OF THE LEGIONELLA CONTROL ASSOCIATION

How Comfort Services Group Supports Your Legionella Compliance & Risk Assessments

It is important to ensure that your programme of Legionella risk assessment and testing meets legal and regulatory requirements. At Comfort Services Group our highly experienced specialists are experts in legionella control can carry out comprehensive Legionella Risk Assessments to ensure that your legal obligations are met and help advise you on any steps that need to be taken to make your water system safer.

Whether your system is due for a routine assessment or changes have been made that require an up to date one be carried out, after thorough testing we will provide you with a detailed report that clearly outlines any areas that require improving as well as any recommendations for making the system safer or more efficient.

In addition to carrying out regular water system testing and legionella risk assessments, we are also able to advise on reducing high concentrations of Legionella. We will assist in setting up company procedures for water management and sampling to help ensure that all requirements are met. This includes assisting with recording and legal documentation to ensure your obligations, as an organisation, are covered.

Our team of experienced engineers have been DBS checked and, for your complete peace of mind, will always present official identification.

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What You Need To Know About Legionella Risk Assessments

Every UK business, regardless of their size or scope is legally required to conduct regular legionella risk assessments to identify potential issues and to keep employees, customers, and others safe.

Legionella risk assessments are a crucial part of legionella control that work to pinpoint possible dangers and set out the measures that should be taken in order to rectify them or in cases where levels of bacteria are too high, to reduce them back down to a safe amount.

All landlords, employers, owners, managers and operators of commercials premises such as – hotels, offices, stadiums, healthcare, education and social housing, have an obligation to understand and manage the Legionella risk within their properties.

It is their responsibility to ensure that the risk of exposure to tenants, visitors, employees and residents is properly assessed and controlled by undertaking and completing regular Legionella Risk Assessments of all water systems.

If untreated, however, the infection may continue to grow within the lungs and cause more serious symptoms including chest pains and breathing difficulties. Those affected may also suffer from a persistent cough which will increase in severity and may include the coughing-up of phlegm and, in more extreme cases, blood.

Knowing how Legionella develops, is contracted and how Legionnaire’s disease is spread is an important consideration when we undertake Legionella risk assessments. Legionnaire’s disease, unlike many illnesses, is not contagious insomuch as it cannot be transferred directly between individuals.

Legionella is so called because of the first recorded case of Legionnaire’s disease which was documented as being at a convention hosted by the American Legion. At this stage in 1976, little was known about the Legionella bacteria and about the resulting infection it could cause. Fortunately, we now know a lot more about the causes of the disease and how to prevent to multiplication of Legionella bacteria and subsequent infection.

The Legionella bacteria (primarily of the species L. pnemophila) commonly occurs in many natural bodies of water. Most rivers, lakes and ponds are liable to contain a level of Legionella bacteria but these levels are typically sufficiently low as to not present a significant risk of causing illness in humans. The risk of infection increases substantially, however, when Legionella bacteria is present in man-made water systems. Once present in man-made systems, the ideal incubation conditions allow Legionella bacteria to multiply rapidly. Infection is then caused when, from an open system such as an air conditioning system, the bacteria (which is hosted in minute droplets of water) is inhaled.

Low level water systems such as those found in private homes provide less opportunity for the rapid reproduction of bacteria. However, with significantly larger and more complex water systems, the risk increases as, not only do these systems provide more optimum incubation conditions for the Legionella bacteria, the risk of a large-scale epidemic of Legionnaire’s disease is greatly increased. It is this increased level of risk, alongside regulatory and legal risk assessment requirements, that make regular testing of water systems in schools, colleges and universities so critical.

Who Needs a Pre-Installation Assessment?

Is-your-school-at-risk-from-Legionella?

Virtually any building which operates hot and cold water systems may be at risk from Legionella. The complexity of a water system is a significant factor in determining the level of the potential hazard. Bacteria are likely to incubate and multiply at a higher rate in complex air conditioning systems and these have, historically, accounted for the majority of recorded outbreaks of Legionnaire’s Disease. Schools do not typically adopt such complex systems, however, regular testing and Legionella risk assessments are essential in all schools, colleges and universities. Asides from being a legal requirement, there are a number of other fixtures and facilities, more often found in schools and universities which present a potential legionella hazard

Legionella Bacteria

Legionella bacteria is considered to be ‘preventable’ because when reasonable precautions are taken it can be kept under control and there are stiff penalties for businesses that do not take the required steps. In the event that there is an outbreak of legionnaires disease at a property which you manage, own or are in charge of, you will need to be able to provide tangible evidence that you took every reasonable measure within your power to reduce, manage and control the risk of legionella exposure. You will be required to provide the relevant authorities with proof of the appropriate legionella control measures you have taken which will include an up to date risk assessment as well as records of all water system maintenance, monitoring and testing.

Failure to be able to provide sufficient evidence of your attempts to control the risk of legionella exposure can have severe consequences including legal action, substantial penalties and in some cases, a prison term.

What is Legionella?

Legionella comprises of a group of naturally occurring bacteria, low levels of which can typically be found in most naturally bodies of water including ponds, lakes and rivers. The levels of naturally-occurring legionella is typically too low to cause a risk to humans but when the bacteria is found in man-made water systems the risk of human infection increases significantly. The reason behind this increased risk is that the conditions found within man-made systems are often ideal for the incubation and multiplication of legionella bacteria.

Infection from Legionella bacteria occurs when aerosolised water droplets containing the bacteria are inhaled. Because of this, the highest risk comes from open systems and spray producing outlets such as taps and showers where the bacteria is contained within minute droplets of water discharged from the system.

The size and complexity of a water system will have a direct correlation with the level of risk, for example a simple, domestic water system will provide less opportunity for the reproduction of legionella compared to a complex commercial one. Because of the amount of people that can typically use, visit, work or live in larger residential and commercial properties, these systems carry a higher risk of infecting a greater number of people which can result in an outbreak/epidemic.

It is this higher level of risk, as well as the consideration of legal regulation and liabilities, which make regular testing and risk assessments in larger or commercial properties an essential consideration.

Legionella Growth

Legionella growth starts in the places most people forget exist, those lukewarm stretches of pipework where water lingers just long enough for trouble to settle in. It moves quietly, almost politely, until the conditions line up in a way that gives it room to multiply. And that’s where the responsible person really earns the title, because this isn’t just another line in a folder of substances hazardous to health.

If the bacteria drift toward a potentially fatal form, those health and safety risks become very real, very quickly. Staying ahead means noticing the small things, documenting them, and stepping in before the system decides to remind you why vigilance matters.

Is your property at risk from Legionella?

There is a risk of Legionella in almost every building which operates hot and cold water systems, but unlike other Health & Safety issues such as fire safety and asbestos, it can often be overlooked by those in charge. Underestimating the potential risks can have severe consequences for yourself and anyone who uses the building so it is important to understand what you need to do and why legionella risk assessments are a crucial to ensuring that your properties water system is safe.

At Comfort Services Group our expert engineers can carry out professional legionella risk assessments to thoroughly evaluate your properties water systems and identify any potential risks, as well as help to put in place effective measures to control, reduce or manage legionella levels.

Some of the key things that can make buildings more vulnerable or at risk of legionella include;

Complex water systems – Domestic cold water systems for example present a relatively low risk for legionella, However, properties with bigger or more complex water systems often found in large commercial buildings pose a much greater risk.

Optimum Conditions –Certain types of water systems are more likely to provide the incubation conditions needed for legionella bacteria to multiply. This includes hot and cold water systems, spa pools, vehicle wash systems, safety showers, sprinklers, fountains, water features, spray humidifiers, cooling water systems, cooling towers, evaporative condensers and any type of system that contains water within which Legionella could breed and become aerosolised.

System materials –Thequality of materials used in a system can have a significant effect on its legionella risk. Materials which are prone to deterioration can release impurities such as limescale, rust or algae into the water which can act as a nutrient for the legionella bacteria, encouraging multiplication. This is why for older systems it is important to ensure that parts which show any signs of corrosion or deterioration are renewed or replaced as quickly as possible.

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Legionella Compliance (The Law)

It is the person responsible for a commercial premises that is legally required to ensure that regular and suitable legionella risk assessments and testing are carried out. In the instance of a commercial premises, this liability typically falls to the landlord. As the landlord it is your responsibility that, asides from regular risk assessments, complete and accurate records are kept of all testing. Comfort Services Group can help to take the stress out of legionella risk assessments by ensuring that your legal obligations are met and that record keeping complies with all necessary regulations.

As landlord, the regulations state that it is your responsibility to identify any potential sources of legionella and demonstrate that all risks have been correctly managed, either through control or prevention. Failure to comply with legionella regulations (either by failing to carry out a suitable risk assessment, failure to record data correctly or failure to take appropriate action where a risk is identified) can make you liable for prosecution or a substantial fine.

According to the Health and Safety Executive: “Under general health and safety law, as an employer or person in control of a premises, you have health and safety duties and need to take suitable precautions to prevent or control the risk of exposure to legionella. Details of the specific law that applies can be found in part 1 of Legionnaires’ disease:

Carrying out a risk assessment is your responsibility and will help you to establish any potential risks and implement measures to either eliminate or control risks. You may be competent to carry out the assessment yourself but, if not, you should ask someone with the necessary skills to conduct a risk assessment. This can be done by someone from within your own organisation or from someone outside, e.g. an external consultant.”

ACOP L8 and Health Regulations

ACOP L8 and the wider health regulations ask people to look a little closer at their water systems, especially in domestic properties where things are often left to “it’s probably fine.” But Legionella doesn’t care about assumptions, and neither do cold water tanks that drift into the wrong temperature range when no one’s watching.

That’s why current control measures only work when someone actually checks them, questions them, and adjusts them when needed. Temperature monitoring becomes the quiet reassurance in all of this, the thing that tells you what’s really happening behind the walls. Follow ACOP L8 properly, and it feels less like bureaucracy and more like genuine protection.

Your Responsibilities

IDENTIFICATION OF RISK

The level of Legionella risk can vary significantly between water systems depending on their design, construction and complexity. However, regardless of the level of risk, it is essential that regular risk assessments are carried out to comply with your legal and regulatory obligations. At Comfort Services Group, we recommend that, as a minimum, legionella risk assessments are completed every two years (and more frequently for higher risk systems such as complex air conditioning systems).

Often, low risk systems will require little or no preventative or control work but must still be subject to regular assessments. Systems which have a higher risk may require immediate work to reduce levels of legionella and help prevent a potential outbreak of legionnaire’s disease. Systems most at risk of harbouring and incubating legionella bacteria include:

Systems which store water or recirculate the same water within a closed system

Systems which actively release water droplets into the atmosphere

Systems with an operating water temperature of between 20-45°C

Systems susceptible to contamination from rust or other particles

PREVENTION AND CONTROL OF RISK

The prevention of legionella may be possible without the need for control measures and systems to be put in place. The first consideration is whether it is possible to completely eliminate the risk of Legionella without the need for control measures. This will be largely dependent on the required specification and type of system needed. If the risk of Legionella cannot be completely eliminated then it is necessary for control measures to be implemented which effectively limit the risk of legionella and associated diseases.

HSE guidelines require that, where a risk of legionella is present in a system, that sufficient controls are implemented to ensure that this risk is managed. At Comfort Services Group, we assist with the whole process, from identifying areas of a system which may present a Legionella risk to advising on preventative measures. We can also carry out further testing and advise on reporting and the keeping of records to comply with necessary legislation.

As landlord and the person in charge of the premises, it is important to understand your personal responsibilities with regards the risk assessment and control of legionella. Procedures need to be put in place for the assessment and, where required, implementation of a control scheme. This can be managed by yourself, a colleague or a third-party (such as Comfort Services Group) but it is your responsibility to determine who is responsible for this. We recommend assigning a third party with the experience and system knowledge required to alleviate the burden on this responsibility.

At Comfort Services Group, we can also help you to keep accurate records which are essential to meet necessary HSE regulations. These records include the nature and frequency of testing, observations made and any reparatory work undertaken. Contact Comfort Services Group today to find out how we can help with your legionella risk assessment and control.

Legionella MANAGEMENT OF RISK

Once risk has been identified, it must be then managed (regardless of the level of risk identified through the risk assessment). Risk management may be delegated to a third party providing they have the appropriate experience, skills and system knowledge.

Comfort Services Group careries out risk management for a number of clients relieving the client and their staff of this responsibility. Why not contact Comfort Services Group today to find out how we can help identify and manage Legionella risk for your commercial property.

Legionella Control Measures and Health and Safety

Legionella control measures sit quietly in the background of safety regulations, but they’re doing far more heavy lifting than most people realise. Relevant health guidance isn’t written to fill shelves; it’s there because developing Legionnaires’ disease can happen in perfectly ordinary buildings when no one pays attention.

Safety legislation only works when someone actually follows it, not just nods at it. And those simple control measures—flushing taps, checking temperatures, logging the dull details—are what stop a manageable risk from becoming a headline. It’s unglamorous work, sometimes tedious, but it’s the thin line between a safe system and a dangerous one.

Example tasks and how often they should be carried out:

Monthly

Check calorifier flow temperatures
Take temperatures at sentinel points
Take temperatures at return legs of principal loops (sentinel points) to confirm they are at a minimum of 50 °C
Check temperatures at sentinel taps (typically those nearest to and furthest from the cold tank, but may also include other key locations on long branches to zones or floor levels).

Quarterly

Dismantle, clean and descale
Take temperatures at return legs

6 Monthly

Purge any debris in the base of the calorifier to a suitable drain
Check water temperatures to confirm the heater operates at 50–60 °C (55 °C in healthcare premises)
Flush through and purge to drain

Annually

Inspect calorifier internally by removing the inspection hatch or using a boroscope and clean by draining the vessel.
Take temperatures at a representative selection of other points
Inspect the integral cold water header tanks
Inspect cold water storage tanks
Check the tank water temperature remote from the ball valve and the incoming mains temperature
Take temperatures at a representative selection of other points to confirm they are below 20 °C
Check thermal insulation
Service and disinfect
Inspect, clean, descale and disinfect any strainers or filters associated with TMVs

The information contained on this page should be used as a general guide only. This information should not be considered a complete or exhaustive guide to Legionella risk assessment, management or control. We strongly recommend that, should you have any questions about your responsibilities or legal obligations, you contact us in the first instance. Comfort Services Group has an exceptional level of experience in Legionella risk and can assist in the identification and control of risk at your commercial property.

At Comfort Services Group, we’re impassioned about ensuring schools are aware of their legal obligations for domestic water systems, and can provide a wealth of knowledge as well as Legionella sampling.

Comfort Services Group is a proud member of the Legionella Control Association and adheres to the Code of Conduct set out by the Legionella Control Association.

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Frequently Asked Questions

How often do Legionella risk assessments need to be done?

This will typically depend on the type of property and the size and type of water systems but as standard it is recommended that a legionella risk assessment is carried out or reviewed at least every 2 years. However, if there have been significant changes or modifications made to the system in between this time then it will need to be revised.

What is the process of a Legionella risk assessment?

The process can vary depending on the type of water system, its size and complexity but a typical Legionella Risk Assessment can include:

A review of current records and previous assessments
A tour of the site, viewing all water sources
Introduction and background information on Legionella
Site details
Legionella Management Documentation audit
Condition survey reports of domestic water plant
Temperature profiling
Testing of and analysis of water systems
Taking pictures for photographic evidence
Legionella and water potability sampling
Basic schematic of plant and distribution
Asset register
Preparation of a detailed report which will include any recommendations of actions that need to be taken.
If remedial work is required, then it should be properly recorded and followed up with regular checks and maintenance

Is it a legal requirement to have a Legionella risk assessment?

Under UK health and safety law, property managers, landlords and business owners are legally required to take into account, assess and mitigate the risk of legionella within their properties or businesses.

Although there is no such thing as a ‘legionella certificate’, they must be able to provide evidence that they have carried out a risk assessment of their property and are taking every reasonable measure to control the risks and keep the employees, tenants, visitors and residents of their building safe.

Once completed, legionella risk assessment reports should be reviewed periodically and carried out again if any changes are made to the water system.

What is Legionnaires Disease?

Legionella is a slow growing bacteria which can grow and multiply in water systems and is most commonly known for being the main cause of Legionnaires’ disease as well as the spread of other illnesses such as Pontiac fever.

Legionnaires disease is a very serious, acute infection that primarily affecting the lungs, with symptoms closely resembling those of pneumonia, unfortunately in some cases it can be fatal.

During the early stages of Legionnaires’ disease, a sufferer is likely to demonstrate mild, flu-like symptoms such-as:

Aches and pains of the muscles
Fluctuations in temperature
Headaches (mild)
Feelings of confusion or fatigue

It is important that, once identified, Legionnaires’ disease is treated quickly as the bacterial infection can continue to grow, causing more serious symptoms. Sufferers of advanced Legionnaires are likely to experience difficulty in breathing, chest pains and a persistent cough which can be accompanied by the coughing up of phlegm, or in worse cases, blood. Survivors can often take over a year to recover fully but there can often be long term health problems as a result of the disease such as chronic fatigue and neurological symptoms as well as respiratory issues.

There is no doubt that Legionella can be incredibly dangerous which is why it is essential to carry out regular risk assessments and testing in order to prevent an outbreak from occurring.

What is Legionella risk assessment?

Legionella risk assessments are the legal responsibility of all landlords, employers, business owners, duty holders for commercial properties and managers of residential accommodation. They are required to assess their water systems, identify any potential issues and control the risk of exposure to legionella bacteria.

Although a risk assessment isn’t legally required to be carried out by a licensed professional, it is always a good idea to ensure that your water supply is safe.

Legionnaires disease can be deadly and in the event there is an outbreak at your property, having comprehensive, professional, verified documentation of your risk assessment will go a long way to proving that you took every reasonable step to ensure that your water was safe.