If you are the hotel manager, maintenance manager or property owner you have a legal responsibility and accountability to ensure that occupiers of your premises are suitably protected from water safety risk. You may have appointed, or been appointed as, the Responsible Person. This essential blog is aimed at helping you understand a little more of how a risk assessment can help you and what it must include.
A good risk assessment is a vital part of an effective strategy for the minimisation of risks associated with legionella proliferation in water systems within buildings. In this article we review what a Legionella risk assessment should include to comply with regulations and guidance.
There’s nothing new about the concept of Legionella risk assessments but the approach to completing one can vary greatly. When working with clients invariably we review the risk assessments they’ve commissioned with contractors or consultants and often we find the same failings. The list below is not exhaustive, however, for illustration purposes we’ve grouped some of the more common concerns into categories. In practice a report might fall foul of more than one of these mistakes:
Failure 1: Non-assessment – These come in three types, first we have the “subjective assessment of risk” where there is no structured method of risk evaluation, such as a risk scoring matrix. Another example is the “Flawed assessment of risk”. Often when there is a risk scoring system it can be flawed or illogical, for example many assessors fail to consider occupant susceptibility. The third example may be hard to believe but we have seen examples of so-called risk assessment reports in which there is no indication of risk at all.
Failure 2: Condition Survey – Badged as a risk assessment, condition surveys are typified by reports that focus on identifying every minor fault or defect and stipulating that all must be rectified regardless of the risk posed in each case, in some cases without a valid indication of risk at all [see Failure 1]; As a Responsible Person you may be encouraged to use the same company to carry out both the risk assessment and any associated remedial works. However, using just one company raises the possibility that the risk assessment will be partisan. For example, the assessor may suggest the need to undertake unnecessary remedial work, knowing this remedial work will result in the sale of additional services. Often these actions pass unquestioned, either due to a lack of time or knowledge on the part of the Responsible Person.
Failure 3: Asset List – Exactly what it says, this is a catalogue that lists every outlet in the building [often with photos!];
Failure 4: Wish List – Here the risk assessor places unworkable time scales on the risk minimisation actions and/or fails to properly prioritise their recommendations. BS 8580 indicates that risk assessors should be able to justify all of their actions and prioritise them according to risk, for any identified risk there might be short term actions to manage it and longer term actions to eliminate or reduce it;
Failure 5: Half-a-job – The risk assessment in which not all risk systems are included i.e. air handling units, swimming pools, spa baths and those other risk systems listed HSG 274 Part 3. It’s important that the scope of the assessment is agreed before work commences.
In this blog we have highlighted some of the common problems you may face when carrying out a risk assessment, Part 2 will follow next week and will contain advice on what a risk assessment should include to comply with current regulations.