October 2023
New Requirements for 2023/24
The revised LCA Service Delivery Standard for Legionella Risk Assessment launched on the 1st of July 2023 with no new requirements for Members.
There are some minor changes to the detail in section D that brings the different service standards more in line with each other. Members will need to make sure quotation and other communication templates used to deal with this part of the standard are updated.
In auditing going forward we are moving away from non-legionella specific items and trying to focus attention on core issues. If Members have any feedback on what is most important in the real world and where we should focus audit, please let us know. The 2023 auditing document including checklists is available now with a highlighted changes version.
Common Failings and Areas of Focus
One common failing we see in Legionella risk assessment is lack of evidence to demonstrate the competence of the risk assessor and use of a risk assessment template that does not cover all the elements of the LCA Service Delivery Standard.
Competence
Demonstrating and evidencing competence for your employees to third parties is often cited as one of the most difficult things an employer can do. In court being able to evidence why you think your employees are competent is a critical factor in a successful prosecution or defence.
The LCA gives Members a framework and guidance for assessing and recording competence. Within the Legionella risk assessment report there should be evidence that the assessor was competent to do the work. That report may end up in an evidence bundle for a prosecution and needs to be robust enough to defend the decisions made by your employee.
The LCA Assessor will expect to see a process and procedure that includes the following components:
- What knowledge and training is needed for risk assessment
- A check on your risk assessor’s knowledge and training vs what’s required
- A way to fill any gaps with training
- How you assess their competence in the field.
- How you record this
In addition to the process and procedure the LCA Assessor will check the output from it. From risk assessment XXX the assessor was XXX, show me their training record and record of competence assessment. Is it up to date, does it cover what your procedure says they should know? Is there evidence of the risk assessor’s competence in the risk assessment report? Does it match the central record?
Templates
Templates can be useful and are commonly used. Some software systems will hold your template questions and checks for the risk assessor to fill out. Like any template, these software systems are only as good as the questions and prompts that they contain. Templates must be useful and should not be limiting for the risk assessor. Templates can be a good way to demonstrate how your assessor is guided by the document to cover all areas of the Service Delivery Standard for legionella risk assessment. If you have a template, make sure there is a question, check or prompt for every requirement within the Service Delivery Standard.
Your LCA Assessor will expect to see your process and procedure for legionella risk assessment and real examples of your risk assessment reports, chosen at random by the LCA Assessor. We expect the upstream process to prompt the consideration by the risk assessor during the risk assessment. If the specific item is not applicable to the site in question, we do not expect to necessarily see it in the report output.
Common failings seen are:
- Not assessing the written scheme of control, is it good enough, does it follow HSG274?
- Not quantifying risk – how bad is it?
- Not using the terms inherent, residual and ALARP
- Generic control measure recommendations – these must relate to the risk you’re reporting not all the risks in the guidance!
- Copy and paste recommendations that end in ‘depending on risk assessment’ – if you’ve not done the risk assessment sufficient to advise on that frequency of control measure your customer is probably owed a refund!
If you recognise some of the above in your work, check your process, procedure, and templates as soon as possible.