Performing an annual water safety audit is a crucial step to helping prevent waterborne pathogens like Legionella. Here’s how

A water safety audit is a crucial strategy for any commercial facility. But before we can discuss the uses and benefits of an independent?water safety?audit, it’s important to understand what one is and what it entails. A water safety audit?is not to be feared but to be welcomed as a measure to promote compliance within an organization.?Let’s look at four areas to focus on during a water safety audit.

1. Water Management Policy

A water safety audit will typically start with a review of the water management policy. It makes sense to first understand the management strategy and arrangements that underpin the organizational processes for the safe management of water systems.

As a rule, if concerns arise relating to compliance,?then it’s prudent to revisit the supporting processes. Conversely, should an organization not have confidence in their policy and process because it’s demonstrably flawed then it’s unreasonable to expect an improvement in compliance. Following a review of this area of compliance, the audit may be used to:

• Highlight inaccuracies within the management structure of an organization, such as the need to formally capture?roles and responsibilities?within the organizational water safety policy, as well as to formally appoint persons with a water management responsibility in writing; especially the person responsible for water safety.
• Identify?Legionella?training?requirements for all persons with responsibility for the safety of the water systems – delineating between management and operational responsibilities.
• Identify the requirement for further measures of?competency. Such assessments typically look for evidence of qualifications, experience, and knowledge appropriate to the site, role & responsibilities, and applicable legislation and guidance. Organizations should ensure that competency appraisals are completed for all persons with a water management responsibility.
• Assess an organization’s ‘attitude’ towards water safety and whether a pragmatic or reactive approach has been adopted to protect staff, occupiers, service users, and others from harmful waterborne contaminants such as?Pseudomonas?aeruginosa?and?Legionella. A pragmatic approach to water management may be evidenced by the formation of?a?water safety group?or in the way that an organization manages risk once it’s been highlighted.

This leads nicely onto the next stage of the water safety audit which is?reviewing legionella risk assessments?and schematics. The review will determine how risk assessment recommendations may be used to inform the written scheme of control and organizational action plans. A review of how much risk can be accepted and tolerated by an organization (known as risk appetite) will help to determine organizational priorities amongst these recommendations.

 2. Legionella Risk Assessments and Schematics

The completion of site-specific?legionella risk assessments?is another absolute requirement and should be completed to?current?standards. The quality of the risk assessment is of paramount importance as the information contained within it will inform the control scheme and action plans and shape how water safety is managed.

If the water safety audit identifies irregularities or doubts over the accuracy of the risk assessments or the associated schematic drawings, then this could undermine confidence in the control regime. If potential shortfalls are identified within the assessment, consideration should be given to reviewing the current assessment, or better still, carrying out a new assessment in line with current guidance to give assurance that the assessment and resultant recommendations and control regime derived from it are suitable and sufficient to manage or mitigate any risk as far as is reasonably practicable.

If we can demonstrate and accept that legionella risk assessments and schematics have been completed with accuracy and to the desired standard, then we can review recommendations that have been made and devise an action plan that supports a proportionate approach to risk management. That isn’t to say that we simply accept certain risks as derogations, but we must adopt a measured approach to managing risk. This means an approach that is underpinned by the principle of as low as reasonably practicable and that action priorities are calculated based on the associated risk, cost, and difficulty – which the annual audit supports.

Moreover, if our approach is to be truly measured, we must acknowledge the difference between inherent and residual risk, whilst evidencing the rationale for adopting either conventional, good, or best practice. In short, service users and their vulnerability always need to be considered as this will inevitably determine when conventional, good, or best practice are suitable. For example, only best practice would be considered suitable for managing areas occupied by high-risk patient groups.

3. Operational Procedures

Moving on to operational procedures, the water safety audit should also appraise control strategy using the concept of monitoring to establish control and?Legionella?sampling?for a particular reason. The traditional?primary?method of control is?temperature?for the good reason that if cold water remains cold (below 20 degrees Celsius) and hot water is kept hot (50 degrees Celsius to 60 degrees Celsius) throughout the system then it is unusual to have an issue with waterborne bacteria.

The audit will interrogate and appraise precautions taken to minimize the growth of waterborne contaminants, such as:

• Procedures to ensure the normal daily use of all outlets and for flushing programs where outlets are found to be?infrequently used;
• The identification and possible removal of flexible hoses;
• The completion of scald risk assessment to substantiate the number of?TMVs?in situ etc.
• Any?supplementary control strategies?used (e.g. chemical dosing systems).

In addition, the audit will review?microbiological?sampling practices to ensure that; the sampling strategy is supported by the?legionella risk assessment?(i.e. sampling for a particular reason) and that samples are taken following the approved technique with a chain of custody that ensures samples remain within the required stability parameters.

4. Legionella Logbooks

The water safety audit will typically conclude with a review of how all this data is?recorded. The suitability of the records management system will be defined by the completeness and accuracy of the data held on such systems at the time of audit.

Conclusion

The water safety audit?is not a piece of work to be feared but it is an invaluable tool to identify and correct inaccuracies within management and operational strategy. The audit may be seen as a strategic health check for organizations providing a means of demonstrating compliance with water safety requirements and associated health and safety laws.

Sarah Morley is brand ambassador for the Water Hygiene Centre. 

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