In this blog we explore the various roles that exist within an organisations water safety team and who is the most appropriate person to fill each of these positions.
The first point of clarity being, what are these positions and are they really needed? The HSE’s Approved Code of Practice [ACOP] L8 [4th edition], identifies an absolute requirement for the duty holder to nominate, or formally appoint, a competent person known as the ‘Responsible Person’ [RP].
The ACOP L8 applies to all organisations that have a foreseeable risk of legionnaires’ disease to manage.
For healthcare organisations there is additional guidance in the form of the Health Technical Memorandum [HTM] “HTM04-01 – Safe water in healthcare premises” and the Scottish HTM “SHTM04-01 – water safety in healthcare premises”. Both SHTM04-01 and HTM04-01 include detailed guidance on ‘Operational Management’; which is contained in Part B of both publications.
SHTM04-01 Part B details a host of positions that may exist within water safety management. However, the revisions to HTM04-01 in 2016 saw the removal of most of the roles identified in the previous version. This approach was preferred by the authors on the basis that it is thought to encourage healthcare organisations to identify the specific individuals involved within water safety management within their own organisation.
When it comes to roles, organisations following the recommended ‘holistic’ approach of HTM04-01 should be identifying those involved in water safety management. This can be achieved by starting with the organisations ‘communications pathway’; a flow chart of the personnel involved in water safety management within the organisation. Once, these people have been identified then you can define their roles and responsibilities and ensure the right person is in post.
Any appointment within an organisation is very much organisation-specific in terms of ‘who’ may hold these roles. Appointments might be dependent upon:
- The size and complexity of the organisation. Smaller or less complex organisations may require fewer appointments. I.e. a flattened management structure.
- The ‘type’ of organisation. Healthcare, for example, may determine the ‘composition’ of clinical and non-clinical involvement in the management of water quality.
- How the organisation is set-up to manage water safety.
- The level of resource available so that staff members can fully invest in these positions.
Within an organisation, many positions of authority and responsibility may exist for water safety. The organisation’s Water Safety Plan [WSP] will detail the approach and strategies to be employed. The Management Policy section of the WSP is the most appropriate element to define the roles and their associated responsibilities, which will be supported by the ‘Communications Pathway’.
Let’s now start to think about these positions and who the most appropriate person might be. Remember, depending on the people identified within the Communications Pathway, these positions and titles will vary between organisations.
Responsible Person - Water [RP]:
The RP is a position of authority, competence and knowledge whose role it is to ensure that suitable and sufficient management arrangements are in place. For example, the RP will ensure that there is a Water Safety Plan [WSP] and that water systems are maintained in such a way as to mitigate the risk of ‘preventable’ waterborne disease such as Legionnaires’ Disease.
Therefore, whilst the organisation holds accountability, the RP will be someone who has holds responsibility for the water systems i.e. maintenance, monitoring, operation. The role of RP maybe delivered by a senior position within the estates management team (such as Head of Estates).
Deputy Responsible Person - Water [DRP]:
Depending on the size and complexity of the organisation, the RP may require assistance with aspects of their role. For example, the operational delivery of the maintenance programme defined in the WSP may be delegated to a deputy. The role of this DRP maybe delivered by an Estates Officer, often with a mechanical bias, and who has a responsibility for water systems safety.
The DRP might be responsible for the correct maintenance, monitoring and operation of water systems. Included in this role is the need to report the level of compliance for water systems within the estate to the RP, including the status of the risk assessment [RA]. I.e. RA in place, RA action plan deadlines being achieved, identification of when a new risk assessment is required.
Authorised Person - Water [AP]:
An AP may also be required to assist with the execution of routine operational tasks throughout the estate such as pre-planned/reactive maintenance and the management of suitable records (monitoring data). The role of the AP maybe delivered by an Estates Supervisor.
APs will invariably review monitoring / performance data retuned by the Competent Persons and identify any failures for resolution. AP’s will also typically assist with the commissioning of site specific risk assessments.
Competent Persons - Water [CP]:
Those that have the role of CP are typically tradespersons and may be employees or contractors. In either case, it’s once again important to ensure that CP’s are suitably trained and competent to complete the tasks in which they have been employed or commissioned. These tasks comprise the actual delivery of the maintenance, testing and inspections regimes, including among other tasks: flushing, temperature monitoring, water sampling, chemical testing & treatments, tank inspections, installation, repairs, alterations and other plumbing work.
Within water safety, ‘competency’ is a crucial metric which underpins the appointment of an individual or individuals to hold certain positions. An organisation should ensure suitable and sufficient training has been completed by personnel identified within the water safety management structure. Those identified should be able to demonstrate the key competencies that are required in order to fulfill the responsibilities of their role/position. Such competencies should be appraised and may be demonstrated by (but not limited to): the completion of suitable training to ensure that required skills remain up to date, the attainment of role-specific qualifications and the demonstration of job-specific knowledge and experience.
Not all organisations are the same, however, in accordance with the HSE’s ACOP L8 all organisations should appoint a Responsible Person [RP] to manage the risk. The RP may delegate duties and tasks to other individuals within the organisation and where this is the case those other individuals must be identified within the communications pathway and their role and responsibilities defined within the organisation’s management policy.