Progress Housing Group / Property Services /
Title: / Legionella Management Policy /
Ref No: / GRPOLPS15 / Reviewed: / 01/01/2018 / Version: / 3 /

POLICY DOCUMENT

Group Member: / Progress Housing Group /
Service Area: / Property Services /
Document Ref No: / GRPOLPS15 /
Subject Title: / Legionella Management Policy /
Version: / 3 /
Effective Date: / 01/01/2011 /
Last Reviewed: / 01/01/2018 /
Next Review Date: / 01/01/2021 /
Document Owner: / Compliance Manager /
Date of Board Approval: / 28/02/2018 /
  1. INTRODUCTION
  2. Progress Housing Group recognises that it has a duty of care to employees, tenants, visitors and the general public that may be affected by the operation and maintenance of premises by the organisation
  3. To ensure that the highest reasonably practical standards are maintained throughout the organisation all directives issued by the Health & safety Executive, Department of Health and the British Standards Institution relating to prevention and control of Legionella will be adopted where relevant.
  4. Progress Housing Group will therefore ensure that sufficient resource is made available to ensure that water storage and distribution systems are operated and maintained in accordance with current legislation and guidance and shall take all reasonably practical steps to ensure risk of Legionella proliferation and contamination is minimised.
  1. SCOPE OF THE POLICY
  2. This policy covers the management and control of Legionella and other contaminants in water systems in our general needs, sheltered housing, supported living schemes and supported housing properties, including all communal areas / facilities and offices Group wide.
  1. RESPONSIBILITY
  2. Progress Housing Group will appoint a responsible person (Compliance Manager ) to ensure that the commitments in this policy are carried out as well as the actions identified in the risk assessments, see Management structure below:
  3. Management Structure

Duty Holder / Operations Director Property Services
Progress Property Services
Progress House, Lancashire Business Park
Centurion Way, Leyland, PR26 6TZ
Responsible Person / Compliance Manager
Progress Property Services
Progress House, Lancashire Business Park
Centurion Way, Leyland, PR26 6TZ
Deputy Responsible Person / Compliance Surveyor and Team Leader (Gas)
Progress Property Services
Progress House, Lancashire Business Park
Centurion Way, Leyland, PR26 6TZ
Site Maintenance / Progress Property Services
Progress House, Lancashire Business Park
Centurion Way, Leyland, PR26 6TZ

3.3Where contractors carry out risk assessments, works or checks on our behalf, they will be required to meet our health and safety standards and will be appropriately qualified and accredited.

3.4PHG will publicise the policy and procedures on Legionella Management to tenants and staff in a number of ways including:

  • Tenant handbook
  • Leaflets
  • Tenant Newsletters
  • Website
  • Policy briefings
  • Training
  1. POLICY
  2. Aims & Objectives
  3. Legionnaires’ disease can prove fatal as confirmed by a number of cases, all of which could have been prevented if adequate preventative measures and contingency plans were in place. It is these preventative measures that Progress Housing Group wish to address across its portfolio of premises in order to protect staff, visitors, residents and the general public.
  4. As Legionella is a naturally occurring organism widely dispersed in nature, it must be accepted that there is a constant risk of the bacteria entering the building services of our properties. Therefore, the size and complexity of the properties under our control naturally increases the likelihood.
  5. Water services, in particular hot & cold water systems, evaporative cooling towers, humidifiers and showers are sensitive areas requiring close scrutiny with regard to maintenance methods and procedures. It is therefore essential that measures reflect current knowledge and best practice within the industry.
  6. Legionella Bacteria
  7. Legionnaires’ Disease can affect anybody but some people are at higher risk eg.Men are 3 times at risk, those over 45 years of age, smokers and heavy drinkers, those suffering from chronic respiratory or kidney disease and people whose immune system is impaired.
  8. Legionella bacteria can multiply in domestic water systems under certain conditions. In particular, water temperatures in the range 20C to 45C favour growth. The bacteria will not survive temperatures above 60C and remains dormant at temperatures below 20C.
  9. The bacteria also require a supply of nutrients to multiply such as:
  • Algae, amoebae and other bacteria within the water itself
  • Sediment, sludge, scale and other material within the water system.
  • A reasonably foreseeable risk of exposure to Legionella bacteria exists in:
  • Water systems incorporating a cooling tower or evaporative condenser
  • Hot and cold water systems
  • Other plant and systems containing water which are likely to exceed 20C and which may release a cloud of droplets and/or droplet nuclei (residue that remains when water has evaporated) during operation or when being maintained.
  • The disease is normally contracted by inhaling Legionella bacteria, either in tiny droplets of water in the form of aerosols or in droplet nuclei which are particles left after the water has evaporated and are contaminated with Legionella, deep into the lungs.
  • In accordance with the requirements of the Legislation and Guidance (L8 4th Edition and HSG274)
  • Identify and assess sources of risk
  • Prevent or control the risk where possible
  • Prepare a Legionella Management Plan (Control Scheme) for preventing or controlling the risk
  • Implement and manage the Plan (Scheme) – appointing a person to be managerially responsible
  • Keep thorough records and check that what has been done is effective
  • Where we manage properties which are not owned by a group partner we will fully co-operate with the property owner to ensure all safety requirements are fulfilled, including where this is set out in the management contract.
  • Progress Group will carry out the relevant risk assessments to ALL properties to determine any need for monthly, annual or less frequent monitoring. This applies to all Progress Group properties, however, where appropriate generic risk assessments will be carried out for general needs domestic dwellings.
  1. Risk Assessment
  2. A detailed assessment shall be undertaken at all sites where a significant risk exists, which include:
  3. Sheltered Housing Scheme
  4. Communal areas/facilities
  5. PHG offices
  6. Any establishment where volumes of water are stored and the potential for droplet formation exists.
  7. General needs domestic dwellings will have generic risk assessments carried out.
  8. All risk assessments will be undertaken by persons who are competent, experienced and have been correctly trained to carry out these duties
  9. The risk assessment should be reviewed at regular intervals or earlier if significant modifications are undertaken with regard to the system design or utilisation of the premises
  10. We will keep a record of the risk assessments undertaken as well as information regarding the maintenance, tests and remedial works carried out together with the results for a minimum of 5 years.
  11. The assessments will contain direction as to how the risk is to be eliminated, or where this is not possible, how the risk will be managed.
  12. Where the risk assessment identifies no reasonably foreseeable risk, no further measures are necessary.
  13. Prevention and Control
  14. Wherever practicable we will remove the potential source of future contamination including the removal of cold water storage tanks. Planned improvement programmes will gradually replace storage tank water systems with combination boilers, though some properties will continue to require storage tank systems to meet their requirements.
  15. On new developments, refurbishments and when carrying out planned improvements we will ‘design out’ risks where possible
  16. On letting property, we will ensure that new tenants are made aware of the risk of Legionella and provide them with relevant information and advise them to flush through the system and ensure shower heads are clean, as part of the handover.
  17. Once properties have been handed back to housing management these will be flushed as part of the accompanied viewing process or before the tenant signs for the property if the property has been empty for longer than 7 days since being handed back from the voids team.
  18. We will carry out 10% Void checks to ensure that the water tank is clean, has a lid and is adequately supported.
  19. When risk assessments identify required works to remove or reduce risks they will be carried out as responsive repairs or as part of a planned improvement programme with agreement from the budget holder
  20. Where we cannot remove the risk we will control it as far as possible in line with the Approved Code of Practice by doing the following:
  • Ensuring that the release of water spray is properly controlled
  • Avoiding water temperatures and conditions that favour the growth of Legionella and other micro-organisms
  • Ensuring water cannot stagnate anywhere in the system by keeping pipe lengths as short as possible or by removing redundant pipe work
  • Avoiding materials that will encourage the growth of Legionella
  • Keeping the system and water in it clean

4.4.8In general needs stock it is impractical for the landlord to carry out the regular weekly and monthly checks required to ensure safety from legionelliosis. We will publicise to residents the importance of carrying out such checks through our Water Hygiene leaflet and other resident communications.

4.5Monitoring

4.5.1We will monitor the percentage of properties with a risk assessment and that regular tests, required according to policy and procedure are carried out.

4.5.2Regular audit of the management processes will take place by the Group or by an External Auditor from an Accredited body

4.5.3Regular reports and up-dates will be made available to the relevant Board of Directors.

4.6Value for Money

4.6.1Legionella surveys will be procured where possible through relevant procurement framework ensuring value for money. All other works will be procured in relation to the Group’s financial regulations and competitive quotes sought. All goods and services procured will be at the best possible price and quality.

4.6.2Generating social return on investment should be maximised. PHG will ensure all existing and future procurement contracts provide social return on investment by promoting supplier assistance as part of our contract negotiations.

4.7Social Value

4.7.1Progress Housing Group takes its responsibilities very seriously under the Public Services (Social Value Act) 2012 and considers this to be an integral part of any future service offering provided to the Group. Progress Housing Group will seek opportunities to maximise social, environmental and economic value in all of its contracting opportunities.

4.8Abbreviations

4.8.1N/A

4.9Definitions

4.9.1Legionella-A naturally occurring bacteria within water sources.Inhalation or ingestion of them can cause illness

4.10References

4.10.1Health and Safety at Work Act 1974

4.10.2Workplace Regulations 1992

4.10.3Control of Substances Hazardous to Health Regulations 2002 (COSHH)

4.10.4Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR)

4.10.5The Water Supply (Water Fittings) Regulations 1999

4.10.6The Management of Health and Safety at Work regulations 1999

4.10.7The Construction (Design & Management) Regulations 2015

4.10.8Landlord and Tenant Act 1985

4.10.9Housing Acts 1985 and 1988

4.11Guidance

4.11.1.1HSG 274 parts 1,2,3

4.11.1.2HTM0401

4.11.1.3HTM0105

4.11.1.4BS8580

4.11.1.5BS7592

4.11.1.6BS8558 in conjunction with BSEN806

4.11.1.7Industry Bodies such as LCA,WMS

4.12Data Protection

4.12.1Any personal data processed as a result of legionella management will be done so in line with the PHG Data Protection Policy ensuring compliance with the Data Protection Act 1998.

  1. IMPLEMENTATION
  2. Training
  3. All appointed responsible persons will receive appropriate externally validated training every 3 years
  4. All staff responsible for carrying out Legionella Risk Assessments will receive appropriate externally validated training every 3 years to ensure competency.
  5. All staff responsible for carrying out ongoing checks of water systems will be equipped to do so.
  6. All staff will receive basic Legionella awareness training every 3 years.
  7. A record of all training completed will be kept with HR and OD see Legionella Training Plan.
  8. Procedure references
  9. Legionella Management Plan and Procedures
  10. Linked documents
  11. Legionella Management Plan and Procedures
  1. CONSULTATION
  2. This policy has been presented to the tenant forum and all relevant staff prior to seeking Board approval.
  1. REVIEW
  2. This policy will be reviewed every three years or as a result of a change in legislation to ensure it is relevant with legal and regulatory requirements and best practice.
  1. EQUALITY IMPACT ASSESSMENT
  2. We welcome feedback on this policy and the way it operates. We are interested to know any possible or actual adverse impact that this policy may have on groups in respect of gender, marital status, race, disability, sexual orientation, religion or belief, age or other characteristic.
  3. We aim to consult those who may be affected by a policy before it is formally introduced. We encourage involvement in shaping new services. We want to take account of the needs, circumstances and experience of those likely to be affected by a proposed policy and identify any possible inequalities or discrimination between different groups.
  4. To this end, we have undertaken an appropriate equality impact assessment related to services. Our approach has been developed over time and in consultation and partnership with key partners.

ISO9001:2008 – Controlled Document
Policy Document Template V3- Created by Service Development / Page 1