While static caravans may be a great idea, static water is definitely not. David Randlesome of Swiftclean, the duct cleaning and legionella risk experts, explains how essential it is to achieve and maintain compliance with the Approved Code of Conduct for legionella control also known as ACoP L8.
Every caravan park, whether aimed at permanent residents or holiday makers, must be aware of the inherent dangers of Legionella bacteria, which initially causes a flu-like illness but can develop into a form of Pneumonia. This illness is known as Legionnaire’s Disease. For the fit, healthy adult, Legionnaire’s Disease is severely debilitating. For the elderly, the very young and anyone with an underlying health condition, it can prove fatal – and sometimes does.
Every site must, of course, have a clean and healthy water supply to every van or central facility, but, while some other water associated problems can be easily seen and identified, Legionella cannot. Each site owner or manager has a legal duty to protect residents, staff and visitors from Legionella. UK legislation concerning Legionella prevention is contained in the Control of Substances Hazardous to Health Regulations 1989; Section 3(2) of the Health and Safety at Work Act 1974; and the Management of Health and Safety at Work Regulations (MHSWR).
As a site owner or manager, you must appoint what is known as a Responsible Person. This named individual is responsible in law for ensuring that your organisation does everything possible to comply with the Approved Code of Practice for Legionnaires' disease: The control of Legionella bacteria in water systems (L8). This is issued by the Health & Safety Executive (HSE) and is legally enforceable.
You are required to have a current Legionella risk assessment document, which must be accurate and up to date. This means that if you have had any alterations to the people involved in the site management or water systems since the last assessment, perhaps with the addition or removal of a van – or even a single tap – you must have a new risk assessment. If you do not know how to conduct a risk assessment, or are not sure if you have one, you should call a specialist to help you.
If you are a newly appointed Responsible Person and your predecessor conducted the last risk assessment, you must carry out a new risk assessment to acknowledge the changes in responsibility and reporting.
If there is a Legionella outbreak on a site for which you are responsible, you can be prosecuted. If convicted, your organisation may face limitless fines imposed by the court. Any individuals held responsible may face a custodial sentence, especially if there has been a fatality. Therefore, it is essential to be proactive with your Legionella prevention.
Caravan sites, by their very nature, present some particular challenges for Legionella prevention. One of the most important things to consider in Legionella prevention is long pipe runs for cold water and, of course, every caravan site will have these in abundance, in order to provide running water to each van.
Localised hot water does not present so much of a problem for caravans, provided it is kept at a minimum temperature of 60°C. Legionella does not favour hot or cold water, it breeds in warm or tepid water. The long runs of cold water pipe which connect each van should be a major concern. There are two main scenarios which increase the risk; firstly, if a van is left unoccupied for any length of time so that water sits in the pipework without moving; and secondly, if cold water pipes absorb heat from the ground due to solar gain – usually in spring and summer.
If water outlets are not in regular use, the water behind them will remain static. The general rule of thumb is that if toilets, taps or showers are not used for a week, they should be flushed through by flushing the toilet or running the tap or shower for long enough to flush the pipework through. This might seem like a waste of water, especially throughout the low season in a holiday caravan park, but it is essential to prevent Legionella outbreaks. In the mid or high season, this is even more important as the static water in an unoccupied van may well become warmer, providing the perfect breeding ground for Legionella.
As well as vans themselves, all water outlets in communal toilet or shower blocks must also be flushed through, so if you have additional features such as camping facilities or a central clubhouse or café, the same principles must be applied to these.
Solar gain is a real hazard as it helps to create the ideal conditions for Legionella to breed. Your water pipes should run deep enough below the ground to be insulated from the effects of solar gain. If you have central facilities which rely on water tanks, these must also be carefully maintained and kept free of dirt, debris or vermin, as well as well shaded to be protected from solar gain. It is a good idea, during the low season, to have water tanks drained and cleaned professionally.
Ironically, your cleaning teams could be most at risk from Legionella, especially if the flushing routines have been neglected. Legionella can be air-borne in minute droplets and breathed in by the unsuspecting cleaner. When you flush your systems, therefore, you should take care, as far as possible, not to create unnecessary water spray. Flush toilets with the lid down, close shower doors and avoid undue splashing from taps.
Once you are ACoP L8 compliant, it is essential to stay that way. Ongoing testing and monitoring for Legionella is relatively simple and your service provider should be able to provide the training that you need.
As with so many aspects of good health, prevention is so much better than cure.