In a caravan park, the only thing that you really want to be static is the caravans. You certainly don’t want any areas of your domestic water systems to be static, as Gary Nicholls, MD of legionella risk experts Swiftclean, explains.
Legionella bacteria, a naturally occurring bacteria found in water courses, thrives in static water, especially in warmer weather, and it can multiply in pipework and water tanks, especially those which are not sufficiently shaded from sunlight and protected from solar heat gain. Keeping your water supply clean and free-flowing is essential to prevent the proliferation of Legionella bacteria and colonisation of the water system. Exposure to this contaminated water (through inhalation of contaminated water droplets) could have the potential to cause Legionnaire’s Disease, a potentially fatal form of pneumonia, with initial ‘flu-like’ symptoms occurring which would become progressively worse in individuals that have a higher susceptibility because of age, illness, immunosuppression, smoking etc.
The legal responsibilities of a property manager or owner in respect to legionella risk management and control are spelt out in L8, the Approved Code of Practice and guidance on Legionnaire’s disease (fourth edition), issued by the Health & Safety Executive (HSE).
The main focus of the current version of the L8 code is on; risk assessment requirements; responsibilities of the Responsible Person; the control scheme; the review of control measures; and duties and responsibilities of those involved in the supply of water systems.
Each organisation should appoint a competent person under the law, known as the Responsible Person, who must understand and carry out your legal obligations in preventing legionella. This Responsible Person has a number of specific responsibilities which help to fulfil the obligations to provide a safe environment under general health & safety law. This applies to employers, landlords and certainly to those overseeing a caravan park of any description.
These responsibilities are designed to ensure that suitable precautions are taken to prevent or control the risk of Legionella proliferation and exposure. As part of those responsibilities, you are required to identify and assess any sources of risk; to manage those risks, (which might include cleaning and remedial work); to prevent or control any risks (which might include making sure that tanks are shaded from direct sunlight); and you must keep accurate and detailed records of all the actions that you take to prevent and control the risk of legionella. Accurate record keeping is essential, as it protects the property manager as much as the users of the water system. For this reason, the role of the Responsible Person should also be clearly outlined.
The first step towards compliance is an up to date risk assessment, in which you should identify any areas where water can remain static. Installers can be critical in identifying ‘dead legs’ in water systems, which may occur when pipework has been altered to remove a water outlet such as a shower, a sink or even a stand pipe. Water can ‘sit’ in dead ends of pipework, stagnating and providing the ideal conditions for legionella bacteria proliferation; so these dead ends should be removed to enable water to travel through every part of the water system, with no static areas.
Dead ends typically occur in properties whose pipework has been changed over the years; so if your site has been reconfigured or vans have been moved, it is essential to ensure that the revised pipework has no dead legs and that water can circulate freely through every part. If you make even minor amends to the pipework, you will need a new risk assessment.
Some caravan parks have a built-in legionella risk factor – seasonal occupancy. If you have caravans or park homes which are unoccupied for weeks at a time, the water in their pipework will inevitably be static for long periods, risking the development of legionella bacteria. This will also be the case in year-round occupied homes if a tenant or owner leaves and there is a period of several weeks or more before a new occupant moves in. When letting or selling property to new tenants, it is now vital for the landlord or freeholder to ensure that the water supply is clean and healthy.
If a property or water system has been unused for some weeks, the water should be tested for the presence of legionella bacteria and the system thoroughly and safely flushed before use. This means running taps, showers etc. and flushing toilets to ensure a good turnover of water. If you have a camping section adjacent to a caravan park, with communal toilet and shower facilities, don’t forget that these will also need regular flushing and must be covered by the risk assessment.
Most importantly, this flushing should be conducted without the generation of spray and preferably should be done before any cleaning teams enter the building. Ironically, they are often the most vulnerable to infection after a period in which water has been static for some time.
Legionella control is designed to protect residents, staff and visitors alike. Under the Health and Safety at Work Act and COSHH Regulations there are severe penalties for failing to comply with L8. The Responsible Person can be prosecuted if found to be negligent, and in the case of a death from legionella, this can result in a custodial sentence. The organisation itself can also be prosecuted, and unlimited fines can be imposed, as we have seen in cases of legionella outbreaks in UK hospitals over the years.
If you have cold water tanks, these should also form a key part of your risk assessment. In the design and installation of water systems, consideration should be given to shading water tanks and protecting them from the effects of solar gain, and it should be possible to drain them completely if needed. We recommend checking water tanks periodically, at least annually, to make sure that they are free of insects and vermin such as pigeons, squirrels and rats. The structural condition of the tank should be checked and if its interior surface is degraded it should be refurbished or replaced as necessary. Cold water tank storage temperatures need to be checked during the summer.
Compliance with the law is vital, so it makes sense to enlist expert help in establishing and maintaining robust legionella control policies and processes. You should also review your prevention measures regularly. If you have a change of manager, the new Responsible Person must be satisfied that a current, accurate legionella risk assessment is in place. It is a good idea to schedule a simple annual check to ensure that nothing has changed in the water system, so you can be confident that your risk assessment is still current and appropriate. If you are in any doubt about how to keep legionella under control, it is best to call in a specialist.