6th April 2020
Q&A from LCA Members
Over the last few weeks, we have received many questions from LCA members regarding safe management of water systems during the COVID-19 outbreak. We have put together the following questions and answers that may help others in similar situations.
As with all of the LCA guidance, please share with your clients and anybody else you feel would benefit from it.
Q1 – What guidance has been issued by the HSE?
A1 – The HSE has issued several documents on its website that are pertinent to safe management of water systems and for our industry in general.
https://www.hse.gov.uk/news/hse-regulatory-activity-during-coronavirus.htm outlines the approach HSE will be taking to regulation of occupational health and safety during the COVID-19 outbreak. Other risk, including Legionella risk, must still be managed during the COVID-19 outbreak.
https://www.hse.gov.uk/news/chemical-regulation-during-coronavirus.htm details the regulation of chemicals during the COVID-19 outbreak. The main changes are to methods of contact but in general the regulation of chemicals remains the same including the BPR. One exception is a derogation for manufacture and supply of certain biocidal hand sanitiser formulations - https://www.hse.gov.uk/news/hand-sanitiser-manufacture-supply-coronavirus.htm and information on the arrangements regarding Article 95 supply chains.
HSE has also issued two articles on RPE. One deals with how to approach face fit testing while maintaining social distancing https://www.hse.gov.uk/news/face-mask-ppe-rpe-coronavirus.htm and the other is a research article giving useful information on the RPE/PPE suitable and effective for protection in healthcare settings https://www.hse.gov.uk/news/face-mask-equivalence-aprons-gowns-eye-protection-coronavirus.htm
Q2 - Does the LCA have any specific advice on the maintenance of water features (and any other common other risk systems, perhaps water softener systems) similar to your advice on cooling towers and domestic services?
A2 – The approach to all water systems should be based on risk and the need to run the water system. Water features are normally decorative and the expectation would be for these to be decommissioned during COVID-19 precautions. Each should have start-up and shut-down procedures as part of their written scheme of control and these should be followed. For most water features this would include cleaning, disinfection and draining to decommission followed by filling, clean and disinfection and sampling for recommissioning.
Water softeners, RO and other similar plant are normally incorporated in a wider water system such as the pre-treatment for a cooling tower or steam boiler. If the water system is still in use, the plant should be maintained and operated as normal while maintaining social distancing. If the water system is not in use then the plant should be safely decommissioned with the rest of the system and recommissioned when needed. The exact process of decommissioning and recommissioning will vary from system to system which is why it is important to have robust start-up and shut-down procedures in every written scheme of control. For softeners this may include disinfection of resin beds prior to reuse or other measures specific to the system.
Q3 – Is onsite Legionella risk assessment an essential activity?
A3 – All water systems should already have a risk assessment in place for Legionella. It is likely that this assessment will now need to be reconsidered where buildings have low occupancy or where buildings are empty as this may be a significant change to risk. Dutyholders need to ensure their assessment of risk is current and that includes the changing circumstances due to COVID-19. Risk assessors may be able to assist Dutyholders in reviewing their current risk assessment remotely and helping to develop interim control measures to address the changing risk.
While many buildings are closed there may be an opportunity to survey and inspect some water systems that would not normally be accessible. Provided personal risk is managed and COVID-19 social distancing is observed, the current situation could be used beneficially.
Q4 - Why is it acceptable for water hygiene companies to continue to put their engineers at risk throughout this Coronavirus? I don't think we should be attending non keyworker sites; they should be advised to drain down and have samples taken before building reopens. Putting engineers lives and family at risk for profit is unacceptable. When we ask management, they say they are following your guidelines.
A4 - Our advice states that we are providing an interpretation of the government advice that is broad and based on an evolving policy. All decisions on personal risk are up to the individual involved and not the LCA as every circumstance is different. Our guidance relates to managing water systems safely - not to personal risk for individuals.
Any individual working in the field should be assessing their own personal risk and if their assessment makes the determination that the risk is unacceptable, then they should stop work or put in place control measures to reduce the risk. Your employer should provide information, instruction and training for you, support you in this and provide relevant PPE/RPE.
Should companies put profit ahead of safety? Absolutely not.
Should non-essential work be carried out during this time? No - but there is an interpretation of what is essential and what is not and that needs to be made by the dutyholder and service provider, not the LCA.
Systems should not be drained down - HSG274 does not advocate this. Taking samples before reopening is not going to address any issues in water systems. Cleaning and disinfection or at the very least flushing is essential before sampling but all control measures should be derived from risk assessment.
Q5 – Has there been a supply chain impact for the Legionella control sector?
A5 – There has been significant impact on availability of PPE/RPE but stocks of disinfectant and other consumables have also been affected.
Supplies of sodium hypochlorite for water system disinfection are likely to be in high demand when buildings reopen. While it may be prudent to obtain this in anticipation of demand, it is important to be aware that sodium hypochlorite solutions deteriorate over time. As a result, material that has exceeded its shelf life recommendations needs to be added in greater quantities to achieve the desired concentration of available chlorine. 15% sodium hypochlorite used for the cleaning of equipment and plant should not therefore be older than three months after the date of manufacture.
Q6 – Is there any specialist advice for dental surgeries that are shut down or operating at very low patient levels during the COVID-19 outbreak?
A6 – We are working with several dental specialists to bring out some guidance that will be published very shortly.
Q7 – Are laboratories operating and testing as normal?
A7 – Yes, but some labs may be working with skeleton staff due to the outbreak. Check with your laboratory before submitting large quantities of samples.