November 2023
New Requirements for 2023/24
The revised LCA Service Delivery Standard for Hot and Cold Water Monitoring and Inspection 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.
In response to several complaints and some feedback we have expanded the specific detail asked at audit for clauses 8, 9 and 10 around specific tasks. We previously related this back to HSG274 but now we ask some more detailed, specific questions.
The 2023 auditing document including checklists is available now with a highlighted changes version.
Common Failings and Areas of Focus
Some common failings we see in Hot and Cold Water Monitoring and Inspection are:
- Lack of evidence that operatives involved are competent
- Shortcomings in survey process to allow a suitable design of a monitoring and inspection programme and weaknesses in site specific detail – using a one size fits all when it doesn’t
- Ambiguity in detailing the scope of the service to be delivered
These all lead to weaknesses in the monitoring and inspection programme, a potential loss of legionella control and legal exposure for LCA Members. Our intention at audit is to identify and close weaknesses in our Members’ process.
Competence
Under requirement 2 of the Code of Conduct Members are required to have a process of determining what training is needed, training their staff as necessary and assessing and recording competence. This principle must be applied to all staff involved in legionella control services.
At audit we often find that the staff involved in field delivery are well covered by the process but planning, quoting and management staff can be overlooked. Members must be able to evidence the competence for all relevant staff, not just the ones with thermometers in hand!
Survey Procedures and Weaknesses in Site Specific Detail
The LCA requires a consistent, considered approach in design of monitoring and inspection programmes and key to this is survey information. While much of monitoring and inspection work relates back to HSE guidance, the LCA expect members to gather enough information for a specific service to be designed and implemented. Temperature monitoring to HSG274 part 2 for £XXX is sometimes seen and while in some cases this may be adequate, in others it could have financial implications for members or risk poor monitoring programmes being implemented.
For example, in a building with circulating hot water the programme is expected to include subordinate and tertiary loops. If the location, number and accessibility of these loops has not been determined, it is impossible to design and cost a suitable programme. This leads to vulnerabilities for the contractor financially as they have exposed themselves to a commitment to do work, they have not properly allowed for. More importantly, there is a risk that the necessary monitoring has not been considered, is then not completed and legionella is not controlled.
Scope of Service Ambiguity
The LCA requires members to be exacting in their written agreements with clients over the scope of the work they deliver. We still see some scope of work documents where the detail does not make it clear exactly what is being delivered and who holds the responsibility for task delivery. Being clear in written agreements proactively addresses potential misunderstanding, conflict and risk before they can happen.
If you recognise any of the above in your work, check your process, hot and cold monitoring and inspection design procedure and templates as soon as possible.