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1.1. This is a new joint SOP for Essex Police and Kent Police.
2.1 The policy of Essex Police and Kent Police is to follow the guidelines given in L8 by the Health and Safety Commission (HSC), to manage the water systems such that conditions under which legionella can proliferate are designed out of systems. The policy of Essex Police and Kent Police is to use the control of water temperatures as the main control measure for the prevention of Legionellosis together with good system design; maintenance and proactive management of water temperatures to prevent the proliferation of legionella within systems. Regular weekly/monthly checks of water temperatures and systems to comply with L8 must be made by the facilities assistant of each site. Quarterly/annual inspections and two-yearly updates to the site risk assessment, to comply with L8 are carried out by the Essex Police and Kent Police, Estate Services department or by a specialist (legionella) contractor employed by Essex Police and Kent Police. Where it is considered that there are vulnerable persons e.g. custody suites etc. monitoring by a specialist contractor is performed on a quarterly basis in addition to the regular monitoring performed by the site.
2.2 This procedure/SOP will apply, without exception, to all buildings and individuals employed and/or engaged by Essex Police and Kent Police.
2.3 Ultimately, the responsibility for the implementation of the policy and procedures, along with the compliance with the requirements of L8, will rest with the force chief constable. The implementation of the policy however will be delegated to the responsible person (legionella). Individual site managers will be responsible for maintaining site log books. In line with the force health and safety policy, this will be the area commander or head of department but normally delegated to the admin/facilities/property supervisors. Where more than one establishment is located on the same site, it is preferable that a single duty holder serves all establishments.
Compliance with this procedure/SOP and any governing policy is mandatory.
3.1.1 Essex Police and Kent Police are committed to managing water systems to prevent the proliferation and spread of legionella to comply with the terms of L8.
3.1.2 For those Essex Police and Kent Police buildings where the Estate Services department has the responsibility and funding for repairs and maintenance, the Estate Services department will ensure that:
3.1.3 To comply with legal duties, the forces shall:
3.2. Works where the Estate Services department are not involved
3.2.1 This procedure will also apply where establishments order work, directly from contractors without reference to the Estate Services department. Examples of this are work that is an alteration or addition to water systems, including any new provision. The establishment must inform the Estate Services department of their intention to carry out any such work.
3.2.2 The Estate Services department acts as the landlord for premises owned by Essex Police and Kent Police. Certain establishments do not use the services of the Estate Services department as an agent for new construction, extensions modifications, repairs and maintenance, being autonomous in this respect. Under the terms of L8 these establishments are responsible for the compliance with L8 in these properties. These establishments must follow the policy of Essex Police and Kent Police as above. The Estate Services department is available to give advice as required and those responsible for premises are strongly advised to contact the estate services department as soon as any concerns arise.
3.3 Roles and responsibilities
The chief constable – duty holder
3.3.1 Will take overall responsibility and ensure that the procedure for the control of legionella is implemented and that appropriate funding is made available. In practice the duty holder will delegate the day-to-day implementation of the procedure to the nominated responsible person.
The Joint Head of Essex and Kent Estate Services – (responsible person)
3.3.2 This person is specifically charged with:
The Estate Services department building services engineer (deputy responsible person)
3.3.3 This person is specifically charged with:
The admin/facilities manager and admin/facilities/property supervisor on site
3.3.4 They are specifically charged with:
The premises managers, staff, officers etc. at sites
3.3.5 They are specifically charged with:
General contractors and sub-contractors
3.3.6. They are specifically charged with:
Legionella survey contractors
3.3.7 They are specifically charged with:
3.4 Risks
3.4.1 The approved code of practice and guidance (L8) require that all systems susceptible to colonization by legionella and which may create water droplets must be identified and risk assessed.
3.4.2 Police buildings and plant are considered to fall into three categories for the purposes of precautions against legionella infection, these are:
3.4.3 The Estate Services Department will conduct risk assessments in respect of legionella bacteria and have them updated every two years, or when any refurbishment takes place, or when a new building is commissioned, or indeed whenever there is reason to believe that the risk assessment is no longer valid.
3.4.4 The Estate Services Department will employ professionally qualified and competent companies to carry out the risk assessment on its behalf, and ensure they are competent under the duty of care.
3.4.5 The risk assessments are to be held at each premises with a copy kept centrally by the Estate Services department.
3.5 High-risk conditions
3.5.1 Water temperatures between 20º and 45ºC promote growth of legionella. The optimum temperature for growth is 37ºC. Therefore these water temperatures must be avoided wherever practicable. Organisms may be present at temperatures below 20ºC but remain dormant until suitable temperatures are achieved.
3.5.2 Sediment, sludge, rust, scale and organic material will provide nutrients for legionella proliferation. Should such deposits become evident in storage cisterns then cleaning may be required.
3.5.3 The use of some rubbers, jointing compounds, mastics, wood and certain plastics must be avoided as these too will provide a nutrient source for legionella proliferation.
3.5.4 Other organisms in water such as bacteria, amoeba etc. may also indicate the presence of legionella. Cleaning may be required when sampling indicates this necessity.
3.5.5 Biofilms will also provide nutrients and safe “harborage” for legionella. A biofilm is a layer of microorganisms which forms a surface slime.
3.5.6 Stagnant water will also encourage microbiological proliferation.
3.6 Preparation of a written scheme
3.6.1 On completion of the risk assessments, the responsible person will ensure the following are carried out:
3.7 General methods of prevention
3.8 Monitoring - cooling towers associated with air conditioning equipment
3.8.1 There are currently none of these units within the force. N.B. unless exceptional circumstances exist which prevent the use of alternative plant; cooling towers of this type are not permitted to be used in conjunction with any new build or refurbishment project.
3.8.2 All wet cooling towers and evaporative condensers must be notified to the local authority on an approved form under the Cooling Towers and Evaporative Condensers Regulations 1992.
3.9 Domestic hot and cold water
Sentinel outlets
3.9.1 The facilities assistant will be instructed to take temperature readings of the sentinel taps monthly in each building.
3.9.2 All results are to be recorded on the issued water distribution temperature log sheet and returned to the local admin/facilities/property supervisor for filing in the building logbook.
3.9.3 Cold water shall be below 20°C after running for two minutes, hot water above 50°C after running for one minute, with a maximum temperature of 62°C.
3.9.4 Anomalies are to be reported immediately to the Estate Services department.
Annual temperature profile
3.9.5 Annually representative tap temperatures are to be taken by a specialist contractor. The outlets should include all areas of the building and a full range of the facilities.
3.9.6 All results are to be recorded on issued record log sheet and returned to the local admin/facilities/property supervisor for filing in the building logbook.
3.9.7 Cold water below 20°C after running for two minutes, hot water above 50°C after running for one minute, with a maximum temperature of 62°C.
3.9.8 It is the Estate Services departments policy to actively remove any existing spray emission type taps and prohibit the installation of any new. Taps that produce a spray emission as a result of lime scale should be identified to the Estate Services department for repair/replacement.
3.9.9 Anomalies are to be reported immediately to the Estate Services department.
Scale removal
3.9.10 Scale will provide nutrients for microbiological growth. It is also an excellent insulator and as such can shield legionella from pasteurization temperatures. All outlets should be cleaned and descaled annually as part of a planned preventative maintenance routine.
Showers
3.9.11 Each shower-head and associated hose should be cleaned and de-scaled on a quarterly basis.
3.9.12 Records are to be returned to the local admin/facilities/property supervisor on the issued record sheet for filing in the building logbook. A method statement for all such work by contractors should be issued and filed in the logbook.
3.9.13 Emergency/drench showers will be included in the maintenance regime.
Cold water storage cisterns
3.9.14 Wherever possible, new tanks are to be partitioned or a bypass installed to allow for the chlorination and cleaning of the tanks without interrupting the cold water/hot water service to the building.
3.9.15 Tanks are to be fitted with delayed action float valves or in the case of pumped services conductivity rod operated switches to allow for positive water displacement in the tank.
3.9.16 The incoming feed to the tank shall be at the opposite end to the outgoing connections.
3.9.17 Where new tanks are to be installed, GRP sectional tanks externally flanged with integral insulation and a dished bottom drain for ease of cleaning are to be fitted.
3.9.18 All new tanks shall be fitted with 54mm drains to waste to ease the process of tank cleaning and draining.
3.9.19 Where partitioned tanks are installed the policy is to operate both tanks together except for chlorination and maintenance.
3.9.20 Each cistern is to be inspected annually by a specialist contractor and details of the following inspections recorded:
3.9.21 Report to be issued to the local admin/facilities/property supervisor for filing in the building logbook.
Calorifiers
3.9.22 The Estate Services department adopts a temperature regime as primary method of risk control; domestic hot water is stored at 60ºC and is distributed with a minimum return temperature of 50ºC. Anomalies are to be reported immediately to the Estate Services department.
3.9.23 The storage calorifiers may be fitted with a shunt pump set to operate via time switch to pasteurize the internal surfaces for one hour per day. The necessity of a shunt pump will depend on the units design and should be noted in the risk assessment.
3.9.24 Each system should be fitted with the circulation pump on the return leg where required.
3.9.25 Each system should have sensors fitted to the flow and return legs attached to the BMS system, from which a daily log can be taken to confirm the correct operation.
3.9.26 Water temperatures entering and leaving calorifiers are to be checked weekly via the building management system by the building services engineer where these are fitted.
3.9.27 Monthly temperatures are to be taken and recorded on the water storage temperature log sheet and returned to the local admin/facilities/property supervisor for filing in the building logbook.
3.9.28 An annual internal maintenance inspection of each domestic calorifier is carried out, during which microbiological sampling of the drain water for legionella should take place. The calorifier is isolated from the building circuit, the shell is drained down and the internal surface is inspected and cleaned.
3.9.29 Immediately prior to the calorifier being returned to service a full pasteurization process is carried out and the operative records the process on the issued maintenance sheet which is then returned to the local admin/facilities/property supervisor for recording in the building logbook.
Water heaters
3.9.30 The term water heaters is applied to hot water generators with a storage capacity of less than 15 litres.
3.9.31 Temperatures are to be taken monthly and recorded on the water storage temperature log sheet which is then returned to the local admin/facilities/property supervisor for recording in the building logbook.
Infrequently used outlets
3.9.32 Water outlets that are unused for a week or more should be flushed through on a weekly basis and this should be recorded.
3.9.33 Water outlets that are unused for a week or more, that are difficult to flush should only be returned to use after purging and this should be recorded.
3.9.34 Special consideration should be given to disabled toilets as these are used less frequently.
3.9.35 A shower, including emergency/drench showers, which may be unused for a week or more, must be flushed through on a weekly basis and this should be recorded.
Pressure vessels
3.9.36 Pressure vessels connected to the domestic systems should have a drain valve installed to allow for regular monthly flushing. Pressure vessels will otherwise act as a blind end, creating a stagnant area ideal for microbiological proliferation.
3.9.37 Thermostatic mixer valves
3.10 Drinking water distribution
General
3.10.1 As a policy all drinking water outlets should be serviced from a separate supply pipe direct from the mains service.
3.10.2 Drinking water and drink dispensers should only be attached to the rising main.
3.10.3 Drinking water outlets to be located in designated areas only.
3.10.4 All taps which are supplied and positioned for potable water use are labelled “drinking water”.
3.10.5 No alterations or additions to the drinking water supply are to be made without written authorisation from the Estate Services department.
3.10.6 All plumbers working on the Forces sites will be required to be a member of the Water Industry Approved Plumber Scheme.
3.10.7 Any department buying in equipment, required to be connected to the existing service, must inform the Estate Services department.
Water analysis
3.10.8 Routine sampling of the domestic water systems is not required by ACoP L8. Sampling is only recommended in the following instances:
3.10.9 All samples must be analysed by a UKAS accredited laboratory.
3.10.10 All sampling certificates must be returned to the local admin/facilities/property supervisor for filing in the building logbook. Copies must also be provided to the responsible person (legionella).
3.10.11 The water treatment/environmental service contractor shall provide a standard of service described in the code of conduct for service providers produced by the British Association for Chemical Specialities and the Water Management Society and hold a current registration certificate issued by the same organisation.
Tests control limits
3.10.12 Bacteria (total viable colony count):
3.10.13 All results should be interpreted by an experienced consultant/microbiologist, but elevated results may indicate the need for cleaning, disinfection and a review of the system and control methods.
3.10.14 Legionella:
3.10.15 Any detection at the first action level shall cause a retest and a review of the system and control methods. If there are detections at the second action level the building services engineer must be informed and remedial action implemented. The system shall also be reviewed and control methods checked.
3.11 Air washers
3.11.1 There are currently none of these units within the force. N.B. Unless exceptional circumstances exist which prevent the use of alternative plant; air washers are not permitted to be used in conjunction with any new build or refurbishment project.
Humidifiers (ultrasonic humidifiers, fogging systems and water misting systems)
3.11.2 No new spray humidifiers may be installed.
3.11.3 Departments must notify the estate services department of the locations of all existing spray humidifiers.
3.11.4 Existing spray humidifiers must be regularly inspected, maintained, cleaned and disinfected.
3.11.5 Departments must notify the estate services department of the locations of all ultrasonic humidifiers, fogging systems and water misting systems.
3.11.6 It is the responsibility of the individual departments to arrange for the inspection, cleaning, disinfecting and maintenance of all Ultrasonic humidifiers, fogging systems and water misting systems to the standard necessary for the control of legionella.
3.12 Ornamental water fountains (internal or external)
3.12.1 In view of publicised cases of Legionnaires disease attributable to self-circulating water features/ornamental fountains. It is the forces’ policy to actively remove any existing and prohibit the installation of any new.
3.13 Fire hose reels
3.13.1 It is the forces ‘policy to actively remove any existing fire hose reels and prohibit the installation of any new. Replacement fire extinguishers should be installed.
3.14 New equipment and alterations
3.14.1 System design: all new systems or alterations should be designed and installed to minimize the risk of legionella bacteria and facilitate compliance with the ACOP L8 document:
3.14.2 Modifications to existing pipework, including removal of branches must include cutting back to the main, as it is totally unacceptable to leave pipework capped at the end and unused.
3.15 Only Water Research Centre approved water fittings and materials are to be used
3.15.1 Jointing materials such as natural rubber, hemp and linseed oil-based jointing compounds and fibre washers are excluded from use.
3.15.2 Control regime: all departments shall have all proposed alterations to water systems approved by the building services engineer prior to works commencing.
3.15.3 All projects to include costs for updating schematic drawings and issuing them to the Estate Services department for inclusion in the logbook.
3.15.4 If a system is taken out of use for alterations or an area is unused for over seven days the project manager must ensure that one of the following options are taken:
3.16 Residences
3.16.1 The logbook for the systems will be held within the Estate Services department and will contain the following:
3.16.2 A suitably trained specialist contractor will undertake the maintenance/monitoring tasks.
3.16.3 A planned maintenance docket is issued identifying the areas where the maintenance activities are to be undertaken and the appropriate log sheet/report sheet is then completed, dated and signed. The docket will be directed to the local admin/facilities/property supervisor to expedite.
3.16.4 The local admin/facilities/property supervisor must ensure that the completed log sheets/report sheets are returned to the Estate Services department.
3.17 Sports facilities
3.17.1 The logbook for the systems will be held within the Estate Services department and contain the following:
3.18 Emergency action to be taken in the event of legionella contamination
3.18.1 The maintenance contractor or water treatment specialist must inform the responsible person of the serotype and number of bacteria by phone and confirm by facsimile or email.
3.18.2 In the event the responsible person cannot be contacted the deputy should be contacted: refer to responsibility structure for full details of contact names, telephone and facsimile numbers that should be used on an escalating emergency basis.
3.18.3 The responsible person will then instruct a qualified contractor to shut down the specific systems if appropriate, and/or to take further samples followed immediately by a clean and disinfection (or pasteurisation) of the affected systems.
3.18.4 The site specific shutdown procedure must be provided by the maintenance contractor and must be included in this section giving method statements and location descriptions of all relevant fan, pumps, shut-off valves and drain points and other plant and equipment associated with the affected.
3.18.5 The maintenance contractor must ensure that an emergency shut-down procedure is drawn up as soon as reasonably practicable i.e. within three weeks of commencing the maintenance works.
3.18.6 The affected systems shall be retested for legionella contamination seven days following the clean and disinfection.
3.18.7 The routine maintenance regime, system design and risk assessment should be reassessed by a competent and independent person. A full report to be inserted into the water hygiene log book and policy document.
3.19 Outbreak of legionnaires disease
3.19.1 In the event of an outbreak of legionnaires disease in the vicinity of the property the maintenance contractor or water treatment specialist must inform, and confirm in writing, to the force’s responsible person and the local admin/facilities/property supervisor of the possibility that the property’s water system might be implicated. Should the responsible person be un-contactable the maintenance contractor or water treatment specialist must refer to the responsibility structure and inform the next available manager.
3.19.2 The force building services engineer must liaise with the environmental health officer/Health and Safety Executive and ask for their advice and assistance.
3.19.3 It is normal for them to send in a team to investigate. It is important for them to be able to trace where the infection came from. Therefore, do not drain down any systems until told to do so, but do isolate them from service. They may request water samples are taken prior to any emergency disinfection being instructed.
3.19.4 The force building services engineer subject to 2 above will then instruct the maintenance contractor or water treatment specialist to carry out appropriate analytical action and disinfect the systems in accordance with the emergency procedures in this document.
3.19.5 Do not speak to anyone about the problem other than the force’s responsible person or building services engineer. Do not make any comments to the media.
3.19.6 Note: - An ‘outbreak of legionnaires disease’ is defined by the Health Protection Agency as two or more confirmed cases of legionellosis occurring in the same locality within a six-month period.
3.20 Training
3.20.1 Appropriate training will be provided for all Estate Services department staff that may require information about legionella and changes to relevant legislation in the course of their duties.
3.20.2 Training for facilities assistants etc. in the taking of water temperatures, the use of log books will be given at the time that the log books are delivered, either by contractor's staff or by the estate services department building services engineer. More general information on the requirements of legislation will be provided through seminars organised by the Estate Services department.
3.20.3 Refresher training will be provided by the Estate Services department and records of all initial and refresher training will be documented. Refresher training should be undertaken on at least a two-yearly basis.
4.1. This SOP has been assessed with regard to its impact on equality. As a result of this assessment it has been graded as having a low potential impact.
5.1 ACoP L8 requires employers and others to undertake assessments to establish the risk of legionella. The responsibility to ensure that these are carried out rests with the responsible person (legionella), supported by the nominated person (legionella).
5.2 The assessment must take into account a number of parameters that will directly affect the proliferation and dissemination of the bacteria.
These parameters are:
5.3 The assessment must be completed for routine system operation and also for circumstances such as breakdown, abnormal operation, commissioning or other unusual circumstances.
5.4 Once the assessment has been completed, a strategy can be prepared for preventing or controlling the risk. The strategy will be based on a sound knowledge of the varying levels of attention required by the differing risk sources within the building.
5.5 As part of the risk assessment process, schematic diagrams of the water systems must also be provided. The schematic must detail all items of plant, main pipework runs, pumps, valves and all terminal equipment and facilities.
5.6 Persons at risk
5.6.1 Risk assessments have identified that forces staff; visitors and the general public using adjacent buildings and thoroughfares may be at risk. Persons at higher risk include those with the following risk factors:
5.6.2 Areas of risk where control is necessary are:
Policy reference: Estates: Legionella policy (U01d)
Contact point: Head of Estates
Date last reviewed: July 2015
If you require any further information or to request any documentation referenced within the policy please email [email protected]. For general enquiries, contact us.