‘Walkies, legionella’, ‘heel, legionella’, interesting thoughts to have with the title ‘Legionella Training’. Sadly, we’re not able to train legionella to behave in a certain way: now that would be amazing if we could ‘Out, damned spot*’ [*legionella] [Macbeth, act 5, scene 1].
Hopefully this article will be able to provide a more practical understanding when it comes to training in legionella. It is perhaps worth starting with the notion that ‘legionella courses’ have been around for decades, the requirement for suitable and sufficient training is a must in order to comply with regulations [Management of Health and Safety at Work Regulations; COSHH Regulations] and guidance documents [HSE ACOP L8; HSG274 Parts 1, 2, 3; HTM04-01, SHTM04-01 and WHTM04-01]. Over time, all documentation has been updated and knowledge of legionella [including other waterborne pathogens, i.e. Pseudomonas aeruginosa] has increased. Needless to say, ‘legionella awareness’ needs to have evolved so that it
“provides employees with suitable and sufficient information, instruction….” [HSE ACOP L8, 4th edition (2014)].
This article will look at why training is needed, the importance of identifying who needs to be trained, what type of training based on their role and responsibilities and when training is to be completed.
The importance of training is a good question to ask! The reality being, how often do you hear about cases or outbreaks of ‘legionellosis’ [the term used to describe any illness caused by exposure to legionella] being reported in the news, either on the TV, radio or printed media? The fact is you hear about cases or outbreaks very rarely, they are deemed not interesting enough compared to a global pandemic, Brexit or the ‘goings on’ of a President!
That’s not to say cases or outbreaks are not occurring! Public Health England monitor and report on cases of legionnaires’ disease on a monthly basis [that said, throughout 2020 only two reports were produced due to the pandemic, whereas previous years there have been regular monthly reports]. These reports identify the sources of cases as:
The latest data PHE published in October 2020 details the number and proportion (%) of confirmed cases of Legionellosis by category of exposure for cases with symptom onset from 1 January to 31 October 2020:
(Source: PHE, October 2020.)
"The HSE have detailed in the ACoP L8:
“Inadequate management, lack of training and poor communication are all contributory factors in outbreaks of legionnaires’ disease.”
Although we don’t get to hear about all these cases and outbreaks of Legionnaires’ disease, they are occurring and occasionally do make the headlines. The largest outbreak of Legionnaires’ disease in the UK occurred in Barrow-in-Furness, August 2002 with 180 cases and seven deaths. The HSE investigation into the outbreak identified six failings, one of which related to training standards, more so the lack of training for key staff at the Council.
More recent outbreaks reported include, Bournemouth, June 2019, at a spa where 39 patrons reported symptoms and nine patrons were admitted to hospital for treatment. In October 2013 a confirmed case of Legionnaires’ disease was reported to Harlow Council, whereby the Environmental Health Officers were unable to confirm the effected employee had contracted this from the site at which he worked. Although, they did find a “serious lack of compliance” including staff receiving inadequate training in legionella. The employer was fined £1.8m.
Read more in the blog - " Legionella - The Need for Sufficient Water Hygiene Training"
Further legionella training [and water safety] is more than likely going to be needed. The risk of legionella [and other waterborne pathogens] is one that needs continual management within an organisation.
SHTM04-01 Part B para 5.2 provides an overview for the need for ongoing training:
“The rate of change in building service technology is not great, but knowledge of harmful bacteria continues to grow and management should review the competence of staff on a regular basis, and refresher training should be given; records of training attendance would need to be maintained.”
With time, change happens… employees are promoted, some leave, new join and processes may change for documenting tasks completed. Examples of such change require a review of whether more training is needed, it might be that a new building manager has been recruited, who has had legionella awareness training with their previous employer, and this would be helpful! But training that is applicable to the new employer covering roles, governance policy arrangements, processes and documentation will be needed, for example Legionella Responsible Person training online. A newly recruited Competent Person to assist with temperature monitoring, flushing of outlets will also require this organisational specific training, with additional elements relating to the technical aspect of their role, for example Legionella Competent Person training.
This is not the end of training. We’ve established that initial training is a necessity and this training must be suitable and sufficient to a level that ensures they can deliver their roles and responsibilities safely and competently. The HSE have further detailed in ACoP L8 paragraph 51:
“… and receive regular refresher training. Keep records of all initial and refresher training.”
And in HSG274 Part 2 paragraph 18:
“Regular refresher training should be given and the responsible person(s) should have a clear understanding of their role and the overall health and safety management structure and policy in the organisation.”
Although, there is no indication of a frequency for ‘refresher training’ detailed in the above referenced documents. Reaching for further guidance on a frequency of training, the HSE HSG65 ‘Managing for Health and Safety’ details: “competence levels will drop if skills are not used on a regular basis – schedule refresher training at regular intervals.” Yet again, no frequency is detailed.
Read more in the blog - Responsible person - are you competent enough?
Identification of those involved in the management of legionella and water safety risk needs to be determined by the Water Safety Group [WSG], who have a responsibility to review training needs and ensure applicable training is then provided. Traditionally, those persons who have received training would have included:
Although other persons are invariably involved with legionella / water safety precautions including [but not limited to and dependent on the size and type of the organisation]:
A few more people than you may have initially thought!
With the WSG having established their ‘training needs analysis matrix’, the process has not ended, HTM04-01 Part B paragraph 6.28 states:
“The WSG should review the competence of staff on a regular basis, and refresher training should be given; records of training attendance need to be maintained.”
One of the responsibilities of the WSG is to review training needs analysis routinely [i.e. possibly each WSG meeting], confirming those involved and whether they’ve completed the applicable training for their role; the date when the training was completed to determine when refresher training is needed; possibly including an anniversary date for training to be refreshed / updated regardless. Industry / best practice tends to have a two to three year frequency for refresher training.
Read more -“Legionella awareness training - who should attend?”
The objective of the Training Needs Review Tool is to provide your Water Safety Management Group within an informed status of water safety training.
This training review tool simply allows you to keep track of your team’s training records and easily helps you to identify when training has expired and requires refreshing.
Take to Water Safety Management Group meetings for regular review.
This Free Tool includes:
Fill out the form on the right to receive your free tool.
Earlier in this article I detailed a possible list of people who need training, included in that list were Infection Prevention and Control Managers / Nurses. Taking these as our first example of a cohort who needs to receive training in legionella and more explicitly water safety training. Thinking of the environment where they work, healthcare and hospitals, the nature of these locations being treatment of those patients who are not well and most likely very susceptible to infection from legionella [including other waterborne pathogens, i.e. Pseudomonas aeruginosa]. The need to provide adequate training on the risk associated with water and transmission is paramount to ensure risk control measures remain in place.
HTM04-01 Part B para 5.14 details:
“The WSG should also ensure that infection prevention and control (IPC) teams have received adequate training and that there is compliance with national evidence-based guidelines for preventing healthcare-associated infections.”
A generic awareness course may prove useful but may not include the most appropriate information for Infection Prevention and Control Managers / Nurses! Remember training needs to be appropriate and sufficient for their role.
Conversely in legionella training, for a completely different cohort, are Hotel Workers. The clue here being ‘hotel’ and the fact that water safety training is applicable; although training on ‘other waterborne pathogens including Pseudomonas aeruginosa is not so'. The spectrum of ‘hotel workers’ will need to be detailed in a training needs analysis identifying those ‘workers’ who are involved in water management within the hotel, examples could include:
With any organisation, individual’s roles and responsibilities need to have been defined, as such a Hotel Manager will require different training compared to a Head of Maintenance or the Cleaners / Domestics.
The risks within hotels are certainly interesting as hotels do not operate at 100% occupancy, as such, many rooms can be empty for periods of time. Daily cleaning of occupied rooms and use by hotel guests help with the turnover (flushing through) of water. Cleaning of unoccupied rooms and flushing of outlets is a consideration, more so during the pandemic with the leisure industry having been closed, and hotels have not been in use. This is highlighting the issue of stagnant water in hotels and the need to manage and reduce the risk of legionella proliferation, the action of routine flushing and / or dosing systems with biocides during lockdown will help reduce the risk further. But where is the training to reflect such drastic change in the use of the hotel and water systems? Thinking about reoccupation, the last thing to do is open to guests and allow them into rooms where the water systems have not been adequately managed during lockdown and potentially exposing them to legionella.
Read more - “The importance of Legionella training for hotel workers”
This issue of the right training was touched on in the previous section: ‘the Hotel Manager will require different training compared to a Head of Maintenance or the Cleaners / Domestics’. With this in mind the training needs to be applicable to an individual’s job role, a responsible person needs to look at appropriate management training, maintenance staff need to look at appropriate operational training. It would not be appropriate for plumbers to attend a management course aimed at the responsible person, for sure the plumber will learn a lot, but the training would not have been ‘suitable and sufficient’ for their role and responsibilities.
The established WSG reviewing a training needs analysis will need to have clearly understood each person’s role and thereby select an appropriate training course for their role and have this documented.
Here at the Water Hygiene Centre we have developed a host of training courses to cover various roles and responsibilities. To aid the WSG with the selection of what maybe the most appropriate course, we have prepared a ‘which course is right for me’ matrix. The next step being documenting training, we’ve created a template ‘training needs analysis’ which may help start the WSG with defining their own.
Traditionally our training courses have been completed face to face in a classroom environment. However, with the pandemic we have evolved and our training courses are now available for delivery through Microsoft Teams, as well as our face to face sessions. These are small classes of eight to ten delegates, and all training material is sent to candidates ahead of scheduled course dates.
To further compliment our training offering, e-learning is available! At present we have the following training courses available online:The Water Hygiene Centre also has its own YouTube channel where you will find a selection of helpful, instruction videos on various practical tasks such as taking a temperature or flushing a little used outlet.
As an employer reading this you would be required to provide adequate information, instruction, and training to your employees. Identification of those involved with legionella awareness / water safety precautions throughout the organisation needs to be documented, with identification of any previous training completed and outlining new / refresher training required. The HSE have documented that outbreaks of Legionnaires’ disease have been attributed to poor staff training. Take this opportunity to review where you and your organisation are with legionella training.
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