Legionella Guidelines - An update and the consequences of getting it wrong

LEGIONELLA LEGIONELLA AWARENESSAWARENESS

Management ResponsibilitiesManagement ResponsibilitiesStuart R WiltonStuart R Wilton

BSc(Hons);MSc;FRSPH;FWMSoc.BSc(Hons);MSc;FRSPH;FWMSoc.On behalf of On behalf of

Acorn Maintenance Limited Acorn Maintenance Limited

2525thth July 2013 July 2013

Water Hygiene - Water Hygiene - LegionellaLegionella

Judge Mr Justice S Burnton’s sentencing remarks:Judge Mr Justice S Burnton’s sentencing remarks:

A tragedy which never should have happened;A tragedy which never should have happened; Numerous opportunities open to many to take Numerous opportunities open to many to take

steps to prevent the outbreak;steps to prevent the outbreak; How serious court considers these Health & Safety How serious court considers these Health & Safety

failures;failures; To demonstrate to those who have responsibility To demonstrate to those who have responsibility

for H&S that they must fulfil these otherwise they for H&S that they must fulfil these otherwise they will be brought before court and properly will be brought before court and properly punished.punished.

Legionella AwarenessLegionella Awareness What happened in Edinburgh – Summer What happened in Edinburgh – Summer

20122012 3 dead – 40/50/62 year old men, with 3 dead – 40/50/62 year old men, with

underlying health issues;underlying health issues; 48 confirmed cases with 95 suspected;48 confirmed cases with 95 suspected; Cooling towers involved;Cooling towers involved; HSE Improvement Notices issued & new HSE Improvement Notices issued & new

information on HSE web site.information on HSE web site. All towers in UK to get an HSE inspection.All towers in UK to get an HSE inspection. HSE estimate 15,000 systems!!HSE estimate 15,000 systems!!

Legionella AwarenessLegionella Awareness

What's happened in Stoke?What's happened in Stoke? 2 people dead;2 people dead; 20+ infected;20+ infected; Spa pool in JML warehouse shop;Spa pool in JML warehouse shop; Untreated/not monitored & no risk Untreated/not monitored & no risk

assessment!!assessment!!


HSE Olympic Report – Summer 2012HSE Olympic Report – Summer 2012 Internal report leaked to the Internal report leaked to the

Guardian;Guardian; Concerns over sites using FM Concerns over sites using FM

companies;companies; Poor level of compliance – 106 sites Poor level of compliance – 106 sites

visited – 15 improvement notices visited – 15 improvement notices issued.issued.

Bulmer's Outbreak 2003Both Bulmers and NalcoFined £300K.Guilty under Section 3(1) of the Health & Safety at Work Act 1974.

“THE HEADLINES”

THE TRUTH, THE WHOLE TRUTH AND NOTHING BUT THE TRUTH!!


Why are we still having problems?Why are we still having problems? Building managers are reluctant to take Building managers are reluctant to take

responsibility;responsibility; Building owners unaware of how water Building owners unaware of how water

is “processed” in buildings;is “processed” in buildings; Confusion & misunderstanding about Confusion & misunderstanding about

what evidence should be obtained to what evidence should be obtained to confirm hazard has been adequately confirm hazard has been adequately controlled;controlled;

McCoy W.F. 2012.McCoy W.F. 2012.

LEGIONELLA AWARENESSLEGIONELLA AWARENESS

WHAT IS LEGIONNAIRES’ DISEASE?WHAT IS LEGIONNAIRES’ DISEASE? HISTORY OF THE DISEASEHISTORY OF THE DISEASE UK LEGISLATION & GUIDANCEUK LEGISLATION & GUIDANCE ECOLOGY OF THE ORGANISMECOLOGY OF THE ORGANISM PREVENTION AND/OR CONTROLPREVENTION AND/OR CONTROL


A severe type of pneumonia – A severe type of pneumonia – named after the first known large named after the first known large outbreak amongst American outbreak amongst American Legionnaires in 1976;Legionnaires in 1976;

Occurs more frequently in men, over Occurs more frequently in men, over 50’s with underlying chest problems;50’s with underlying chest problems;

About 30-40% cases contracted About 30-40% cases contracted abroadabroad


CAUSED BY A BACTERIUM CALLED: CAUSED BY A BACTERIUM CALLED: LEGIONELLA PNEUMOPHILA

BACTERIA ENTERS BODY IN SMALL BACTERIA ENTERS BODY IN SMALL INHALABLE WATER DROPLETS;INHALABLE WATER DROPLETS;

DISEASE DOES NOT SPREAD FROM DISEASE DOES NOT SPREAD FROM PERSON TO PERSON.PERSON TO PERSON.


SYMPTOMSSYMPTOMS HIGH TEMPERATURE/FEVER/CHILLSHIGH TEMPERATURE/FEVER/CHILLS COUGHCOUGH MUSCLE PAINMUSCLE PAIN HEADACHE;LEADING ONTOHEADACHE;LEADING ONTO PNEUMONIA, VERY OCCASIONALLYPNEUMONIA, VERY OCCASIONALLY DIARRHOEA SIGNS OF MENTAL DIARRHOEA SIGNS OF MENTAL

CONFUSION.CONFUSION.


INCIDENCE IN UK?INCIDENCE IN UK? 200-300 RECORDED CASES;200-300 RECORDED CASES; A LOT OF CASES UNDIAGNOSED;A LOT OF CASES UNDIAGNOSED; HPA GUESTIMATE IS BETWEEN HPA GUESTIMATE IS BETWEEN

5000-15,000 CASES;5000-15,000 CASES; MAJORITY ARE CONTRACTED FROM MAJORITY ARE CONTRACTED FROM

HOT/COLD WATER SERVICES.HOT/COLD WATER SERVICES.


LEGIONELLA BACTERIA CAN BE LEGIONELLA BACTERIA CAN BE FOUND IN NATURAL WATERS – FOUND IN NATURAL WATERS – REQUIRE “WARMER” WATER TO REQUIRE “WARMER” WATER TO REPRODUCE – IDEAL RANGE 20REPRODUCE – IDEAL RANGE 20°-°-45°C;45°C;

BUILDING WATER SYSTEMS CAN BUILDING WATER SYSTEMS CAN PROVIDE AN IDEAL ENVIRONMENT – PROVIDE AN IDEAL ENVIRONMENT – COOLING TOWERS & HOT/COLD COOLING TOWERS & HOT/COLD WATER SYSTEMS.WATER SYSTEMS.

LEGIONELLA UPDATELEGIONELLA UPDATE Cooling TowersCooling Towers Whirl pool spas – JacuzzisWhirl pool spas – Jacuzzis Domestic hot water services(cold water?)Domestic hot water services(cold water?) Humidifiers – spray/ultrasonicHumidifiers – spray/ultrasonic Ornamental fountainsOrnamental fountains Car WashesCar Washes Screen wash bottles – 20% SLIScreen wash bottles – 20% SLI Potting compostPotting compost


BUILDING OPERATORS SHOULD:BUILDING OPERATORS SHOULD: RISK ASSESS SYSTEMS/SERVICES;RISK ASSESS SYSTEMS/SERVICES; PREPARE A SCHEME TO PREPARE A SCHEME TO

PREVENT/CONTROL;PREVENT/CONTROL; IMPLEMENT,MONITOR & MANAGEIMPLEMENT,MONITOR & MANAGE KEEP RECORDSKEEP RECORDS APPOINT A RESPONSIBLE PERSON.APPOINT A RESPONSIBLE PERSON.

LEGIONELLA AWARENESSLEGIONELLA AWARENESS STATUTORY DUTY HOLDER at your site?STATUTORY DUTY HOLDER at your site? RESPONSIBLE PERSON at your site?RESPONSIBLE PERSON at your site? RISK ASSESS SYSTEMS/SERVICES – where RISK ASSESS SYSTEMS/SERVICES – where

are assessments kept? When were they are assessments kept? When were they last done – are they fit for purpose?last done – are they fit for purpose?

PREPARE A SCHEME TO PREPARE A SCHEME TO PREVENT/CONTROL;PREVENT/CONTROL;

IMPLEMENT,MONITOR & MANAGE;IMPLEMENT,MONITOR & MANAGE; KEEP RECORDS – LOG BOOKS;KEEP RECORDS – LOG BOOKS; APPOINT DEPUTY at your site?APPOINT DEPUTY at your site?


SDH – required to have access to SDH – required to have access to competent help to assess risk and what competent help to assess risk and what control measures maybe required;control measures maybe required;

SDH appoints RP(in writing), RP needs SDH appoints RP(in writing), RP needs to ensure that WT companies & to ensure that WT companies & consultants are competent & suitably consultants are competent & suitably trainedtrained

Competence – Knowledge & experience Competence – Knowledge & experience – can be difficult to judge. – can be difficult to judge.

Use an LCA registered WT company.Use an LCA registered WT company.

HEALTH & SAFETY EXECUTIVE ACOP AND GUIDANCE – L8CAME INTO FORCE8TH JANUARY 2001.

CIBSE TM13 guidance has been updated now available from CIBSE

HSE consulting on L8 guidance revision – ACOP will remain as now with new guidance section with Web-updates – expected end of 2013.


Approved Code of PracticeApproved Code of Practice Identification & assessment of risk;Identification & assessment of risk; Managing the risk – Managing the risk –

responsibilities/training & competence;responsibilities/training & competence; Preventing or controlling the risk;Preventing or controlling the risk; Record keeping;Record keeping; Responsibilities of Responsibilities of

manufacturers,importers,suppliers and manufacturers,importers,suppliers and installers.installers.


LEGAL PERSPECTIVELEGAL PERSPECTIVE L8 – ACOPL8 – ACOP GIVES PRACTICAL GUIDANCE WITH GIVES PRACTICAL GUIDANCE WITH

RESPECT TO: RESPECT TO: HEALTH & SAFETY AT WORK ACTHEALTH & SAFETY AT WORK ACT COSHH COSHH HEALTH & SAFETY OFFENCES ACT.HEALTH & SAFETY OFFENCES ACT.

HEALTH & SAFETY OFFENCES HEALTH & SAFETY OFFENCES

ACTACT

Enacted January 2009Enacted January 2009 Increase penalties/sentencing Increase penalties/sentencing

powerspowers Fines raised to £20,000Fines raised to £20,000 Imprisonment an option for more Imprisonment an option for more

H&SH&S

offences(6 months – 2 years).offences(6 months – 2 years).

Legionella awarenessLegionella awarenessNew British Standard for Legionella Risk New British Standard for Legionella Risk

Assessment Assessment

BS 8580:2010 Water quality – Risk BS 8580:2010 Water quality – Risk assessments for Legionella control – assessments for Legionella control –

Code of Practice.Code of Practice.Covers:Covers: Terms and definitionsTerms and definitions Site visit/surveySite visit/survey ReportingReporting SchematicsSchematics Reviews – updated every 2 yearsReviews – updated every 2 years

Legionella awarenessLegionella awareness Systems most difficult to assess are often those with Systems most difficult to assess are often those with

temps between 20-30temps between 20-30°C with intermittent use as – °C with intermittent use as –

Significant lack of knowledge on Legionella ecology;Significant lack of knowledge on Legionella ecology; Culture samples may help but negative results do not Culture samples may help but negative results do not

necessarily mean there is no risk;necessarily mean there is no risk; Application of novel technologies/energy conservation Application of novel technologies/energy conservation

may unwittingly create new risks – Solar may unwittingly create new risks – Solar heating,rain/grey water recovery.heating,rain/grey water recovery.

Perceived RISKS ARE OFTEN PROVEN – EVENTUALLY!!Perceived RISKS ARE OFTEN PROVEN – EVENTUALLY!!


WT company fined £24,000 plus £17,276 costsWT company fined £24,000 plus £17,276 costs for inadequate legionella assessments at for inadequate legionella assessments at Welsh care homes.Welsh care homes.

Elderly nursing home residents are at greater Elderly nursing home residents are at greater risk;risk;

Clear responsibility to companies carrying out Clear responsibility to companies carrying out RA work to provide adequate surveys and RA work to provide adequate surveys and information.information.


Ensure Ensure Management Management Structure is Structure is robust;robust;

Should be a check Should be a check system at all system at all levels;levels;

Regular reviewsRegular reviews


NATURAL HISTORY-ECOLOGY NATURAL HISTORY-ECOLOGY WATER TEMPERATUREWATER TEMPERATURE NUTRIENTSNUTRIENTS OTHER ORGANISMS - BIOFILMOTHER ORGANISMS - BIOFILM STAGNATIONSTAGNATION CORROSION/SCALE/SLUDGECORROSION/SCALE/SLUDGE

HPA GUIDANCE ON COLD TEMPERATURESHPA GUIDANCE ON COLD TEMPERATURES

TemperatureTemperature Effect on Legionella growthEffect on Legionella growth

<20°C<20°C LP survives but doesn’t grow significantly if LP survives but doesn’t grow significantly if at all.at all.

20 - 2520 - 25°C°C LP grows very slowly,easily out competed by LP grows very slowly,easily out competed by other bacteria and protozoa. other bacteria and protozoa.

26 - 3026 - 30°C°C LP growth rate increases,coexists with LP growth rate increases,coexists with protozoa, other bacteria grow quickly.protozoa, other bacteria grow quickly.

31 - 3531 - 35°C°C LP grows well in protozoa, other bacteria also LP grows well in protozoa, other bacteria also growing quickly.growing quickly.

35 - 4535 - 45°C°C

46 - 50°C46 - 50°C

LP grows optimally, potential to out compete LP grows optimally, potential to out compete other bacteria and “overcome” protozoa.other bacteria and “overcome” protozoa.

LP becoming inhibited and possibly dying LP becoming inhibited and possibly dying slowly.slowly.

COOLING TOWERSCOOLING TOWERS

LARGE OUTBREAKS GENERALLY CAUSED LARGE OUTBREAKS GENERALLY CAUSED EXCLUSIVELY BY POOR MAINTENANCE;EXCLUSIVELY BY POOR MAINTENANCE;

STAFFORD HOSPITAL – 1983;STAFFORD HOSPITAL – 1983; BBC BROADCASTING HOUSE;BBC BROADCASTING HOUSE; BULMERS CIDER - 2003;BULMERS CIDER - 2003; BARROW IN FURNESS – 2002;BARROW IN FURNESS – 2002; SOUTH WALES – 2010;SOUTH WALES – 2010; EDINBURGH – 2012.EDINBURGH – 2012.


WATER WATER TREATMENT TO TREATMENT TO CONTROL-CONTROL-

SCALESCALE CORROSIONCORROSION MICROBIAL MICROBIAL

GROWTHGROWTH FOULING – FOULING –

SLUDGE/SILTSLUDGE/SILT

WATER SOFTENERWATER SOFTENER INHIBITORSINHIBITORS BIOCIDESBIOCIDES

SIDE STREAM SIDE STREAM FILTRATION/FILTRATION/

DISPERSANTS DISPERSANTS


L8 LISTS SPECIFIC CHEMICAL TESTS – L8 LISTS SPECIFIC CHEMICAL TESTS – THESE NEED TO BE CARRIED OUT BY THESE NEED TO BE CARRIED OUT BY TRAINED/COMPETENT STAFF;TRAINED/COMPETENT STAFF;

ALSO NEED TO CHECK MECHANICAL ALSO NEED TO CHECK MECHANICAL ITEMS INCLUDING DRIFT ELMINATORS ITEMS INCLUDING DRIFT ELMINATORS AND DOSING EQUIPMENT/WATER AND DOSING EQUIPMENT/WATER SOFTENERS.SOFTENERS.

THESE ARE “INVOLVED” CHECKS WHICH THESE ARE “INVOLVED” CHECKS WHICH CANNOT BE RUSHED!!CANNOT BE RUSHED!!

Cooling Tower Weekly ChecksCooling Tower Weekly Checks

phph ConductivityConductivity Oxidising biocide – BromineOxidising biocide – Bromine Bacterial activity – Dipslides – Bacterial activity – Dipslides –

laboratory test – biofilm monitoring?laboratory test – biofilm monitoring? Visual Inspection – drift Visual Inspection – drift

eliminators/packing/tower sump – eliminators/packing/tower sump – could be monthly depending on risk.could be monthly depending on risk.

LEGIONELLA AWARENESSLEGIONELLA AWARENESS Barrow Outbreak.Barrow Outbreak. 7 dead,180 infected.7 dead,180 infected. Several “awful Several “awful

flaws”flaws” Coroners’ verdict –Coroners’ verdict – ““A Total Shambles”A Total Shambles” Download a copy-Download a copy- www.hse.gov.uk/www.hse.gov.uk/

legionnaires/legionnaires/index.htmindex.htm

LESSONS FROM BARROWLESSONS FROM BARROWHSE Report Summary:HSE Report Summary:

1.1. POOR LINES OF COMMUNICATION AND UNCLEAR POOR LINES OF COMMUNICATION AND UNCLEAR LINES OF RESPONSIBILTY;LINES OF RESPONSIBILTY;

2.2. FAILURE TO ACT ON ADVICE AND CONCERNS RAISED;FAILURE TO ACT ON ADVICE AND CONCERNS RAISED;3.3. FAILURE TO CARRY OUT RISK ASSESSMENTS;FAILURE TO CARRY OUT RISK ASSESSMENTS;4.4. POOR MANAGEMENT OF CONTRACTORS AND POOR MANAGEMENT OF CONTRACTORS AND

CONTRACT DOCUMENTATION;CONTRACT DOCUMENTATION;5.5. INADEQUATE TRAINING AND RESOURCES;INADEQUATE TRAINING AND RESOURCES;6.6. INDIVIDUAL FAILINGSINDIVIDUAL FAILINGS..

AN ABSOLUTE SHAMBLESAN ABSOLUTE SHAMBLES


What’s on the horizon?What’s on the horizon? Water Safety Plans – WHO;Water Safety Plans – WHO; HACCP for Water Management –(Hazard HACCP for Water Management –(Hazard

Analysis & Critical Control Point);Analysis & Critical Control Point); Increased level of prosecution & Increased level of prosecution &

compensation - HSE will be charging for compensation - HSE will be charging for intervention;intervention;

Increased levels of competence will be Increased levels of competence will be required?required?

Use of new technology for system Use of new technology for system monitoring?monitoring?


TO SUMMARISE –TO SUMMARISE – A SERIOUS DISEASE ON THE INCREASE;A SERIOUS DISEASE ON THE INCREASE; PREVENTABLE;PREVENTABLE; ATTENTION TO DETAIL;ATTENTION TO DETAIL; COMPETENT STAFF;COMPETENT STAFF; PROACTIVE MANAGEMENT.PROACTIVE MANAGEMENT.NOT COMMON,NOT GOING AWAY AND NOT COMMON,NOT GOING AWAY AND

IS STILL KILLING PEOPLE – HPA IS STILL KILLING PEOPLE – HPA 20112011

Legionella Guidelines - An update and the consequences of getting it wrong

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Transcript of Legionella Guidelines - An update and the consequences of getting it wrong