As people are becoming far more aware of, legionnaires’ disease is a potentially fatal form of pneumonia. It’s actually far more common than was firstly believed, with more and more cases being diagnosed.
Caravan and holiday parks can present a particularly high level of risk due to the seasonal nature of their business, the wide range of occupants and the requirement to store and aerate large amounts of water, predominantly via showers, taps, spa pools/Jacuzzis and hoses. However, there also risks associated with swimming pools, water features, irrigation systems.
Legionnaires’ disease is contracted by inhaling fine, airborne water droplets and anyone can be susceptible to the disease. However, the risk of infection is greatly increased for the following:
Those aged 45 and over, particularly males
Smokers and heavy drinkers
Those with a compromised immune system
Those with any respiratory, kidney, lung or heart disease
The ideal circumstances for legionella bacteria to multiply are for water to sit still at temperatures between 20-45°C. Even allowing for the varying nature of the british weather, greater monitoring of this is needed during the summer months, where Caravan and Holiday Parks are at their highest occupancy.
As an owner or operator of a caravan and holiday park it is your responsibility to do all you can to keep people safe from legionnaires disease. You are, more often than not, the statutory duty holder and failing to keep people safe from illness or worse can result in, as a minimum, severe financial penalties or, at worst, prosecution under corporate manslaughter. Guidance on this can be found in the HSE’s ACOP L8 document (www.hse.gov.uk/pubns/books/l8.htm). The three part HSG274 document from the same site will also provide guidance for dutyholders and employers in complying with their health and safety responsibilities.
Reading the above can make the dutyholder’s role sound incredibly intimidating. However, as with most compliance matters, there are a number of key, simple tasks, to be performed by a competent person, which can assist in reducing the risks associated with legionella:
1.Have an up to date legionella risk assessment for the site – this assessment will provide an asset register, summarise the overall risk, detail task that can enhance the legionella control and a schematic of the water system on the site.
2.Temperature monitoring– water cyclinders/ calorifiers should have the water stored at 60°C and the hot water should be >50°C at all outlets with cold water <20°C.
3.Monitor, clean and disinfect the cold water storage tanks regularly – these are often large, sometimes positioned outside that need to be inspected regularly, checking the condition of the tank itself (lid, rodent/insect screen, vent pipes & overflows) and the water inside the tank (stagnation, biofilm built up, rust or debris). It is also worth reviewing the size and location of the tank to ensure water is being kept moving as much as possible.
4.Clean and descale all showerheads – this should be done quarterly and should involve the hose, showerhead and any inserts being dismantled, fully clean and descaled.
5.Flushing of little used outlets – any taps or water outlets that are not used on a frequent basis should be flushed through weekly to reduce the stagnation risk. Any new water systems must be flushed and to comply with British Standards and current water regulations. A typical guide is that any little used outlet should be flushed weekly for a minimum of three minutes.
6.Remove any pipework blind ends and dead legs – these are runs of often capped pipework where water is not flowing through and can stagnate. Remove these wherever possible, being particularly aware when refurbishment works are being undertaken.
7.Descale all calorifiers and water cyclinders – this is to ensure the reduction of limescale, debris and biofilm building up within the cylinders.
8.Regular water sampling – this will involve microbiological analysis to ensure that drinking water is safe and that the levels of legionella are within permitted parameters. This will also be particularly applicable to jacuzzies, spa pools, hot tubs and swimming pools on site.
9.Back flow protection – make sure that outlets don’t have the capacity for back flow of water into the system. This is especially associated with long shower hoses (enabling showers to sit in water) and with outside/ bib taps where park visitors can attach their own hoses.
Even if all of the above is being done but you are still experiencing issues with legionella, additional measures such as the installation of water softeners or chemical dosing units can be investigated. If you are not doing (or outsourcing) the above the routine maintenance tasks you simply will not know, until it is too late, whether there is an issue with the site water system.
A competent person can be in-house or an external provider. If you are going to use a service provider, ensure they are accredited by the Legionella Control Association (www.legionellacontrol.org.uk). The LCA will audit their members and accreditation is evidence of competence. Seek references where possible, ideally the provider will have an understanding of the unique needs and demands of caravan and holiday parks.
If you are going to do it yourselves, ensure that those performing the tasks are suitably trained and can prove their competence if needed. There are several City & Guilds accredited training courses and centres that can provide specific legionella training. A word of caution however, if you have a high turnover of staff or the same person is not doing all the routine tasks (for example, cleaning staff my be tasked with the shower cleaning) the constant need for re-training to prove competence can outweigh the costs of using an external provider. It is the dutyholder’s responsibility to ensure staff are suitably trained and are performing the tasks correctly.
hsl compliance are accredited by the legionella control association and currently provide legionella compliance services to over 300 caravan and holiday parks across the length and breadth of the UK. They have over 180 field based engineers and have been assisting clients with their legionella control since 1976. They can also provide city & guilds accredited training to assist park owners in managing their legionella control systems.