Information is a primary organisational asset that supports a business.
Having an effective monitoring regime and keeping records is vitally important to demonstrate that your water systems are well managed and everything is under control.
Efficient recordkeeping can be proof that you have made considered decisions and taken appropriate actions. Records become your protection if you are questioned or challenged. Without them, you are at risk.
Unfortunately, many organizations fail to establish well-organized systems to manage records. As a result, they run the risk of having a poor water hygiene plan and may encourage the growth and outbreak of legionella bacteria in their water systems.
How Important is Legionella record keeping?
Record keeping is one of the key elements in legionella risk management and often the most overlooked aspect.
Organizations do not have a planned approach on how this should be done, what needs to be recorded, and how long the record should be kept.
A good place to start is by completing a legionella risk assessment which identifies the systems susceptible to colonization by legionella bacteria. Depending on the findings of the risk assessment, there would be some cases with no risks and in others, some degree of risk will be present.
In each case, the organization should keep a copy of the risk assessment and make sure it is dated. The assessments must be reviewed periodically to ensure nothing has changes that may lead to an outbreak.
Keeping records of the assessments, results and actions taken will also prove very handy in an event of a safety audit. The records can provide a comprehensive paper trail, proving to auditors that the right approach has been taken to keep risks under control.
The records could also prove extremely important in the event the appointed responsible person changes. This will allow the future staff to know what needs to be done to ensure continued legionella compliance, save time, and avoid expensive mistakes.
Is it a legal requirement to keep records?
HPSC’s National Guidelines for the Control of Legionellosis in Ireland, 2009 state that all businesses in the Republic of Ireland must ensure that appropriate up-to-date records relating to the control scheme are kept.
UK HSE’s ACOP L8 and states that businesses with five or more employees are legally required to keep a record of any significant findings, including those identified as being particularly at risk and the steps taken to prevent or control risks.
Those with less than five employees are not required to have written records, but it is strongly recommended they do so.
What information needs to be recorded?
As part of the Legionella control programme, businesses are required to document the routine monitoring, inspection, and maintenance tasks implemented to manage their water systems safely.
In addition to that, a business must also keep a record of all the management processes in the place, including copies of risk assessment.
ACOP L8 details the requirement for a site legionella logbook to be established and that the legionella logbook is readily available for review and inspection. This is particularly important if a legionella outbreak was to occur.
Records can be kept as digital or hard copies. The site-specific logbook should be utilized to log all tasks relating to water management and legionella control.
The following items should be included in the Legionella control logbook and legionella record system:
- Names and positions of person(s) responsible for carrying out the various tasks under the written scheme i.e. responsible for risk assessment, managing and implementation of the control scheme
- Plans and schematic drawings of the systems
- Details showing the current state of operation of the system e.g. when the system or plant is in use and if not in use whether it was drained down or not
- The significant findings of the risk assessment
- The written scheme of actions and control measures required and details of their implementation
- The results of any monitoring, inspection, test or check carried out, and the dates
- A log detailing visits by contractors, consultants, and other personnel. The remedial work required and carried out and the date of completion
- The signature of the person carrying out the work or other form of authentication where appropriate i.e. contract specification
- Copies of contractor’s method statements
- Cleaning and disinfection procedures and associated reports and certificates
- Results of the chemical and microbiological analysis of the water
- Information on other hazards e.g. treatment chemicals
- Personnel training records
- Review meeting notes and actions
- Product information and chemical/biocide safety data sheets.
What are the methods of keeping and maintaining records?
Most methods will develop their own methods of keeping records. This may not be the best approach to manage records for something this important.
Potential risks associated with legionella outbreak should be taken very seriously and leaving things to chance could have serious consequences. Hence, maintaining accurate and consistent records is critical.
It is in the best interest of the company to electronically manage records using a software. This standardizes the whole process and ensures that inspection, tests, and other monitoring are carried out the same way every time.
Luckily, this is where remote monitoring can help a business eliminate human errors and stay compliant with legislation and codes of practice.
How long should the records be kept for?
All records need to be easily accessible for auditing purposes.
Records should be retained for the period in which they remain current and for two years following review. All monitoring and maintenance records need to be for a minimum of five years
All records should be signed by those persons performing the various tasks assigned to them.
To summarize, records are fundamental to successful water safety management. Records can provide vital evidence that a business has well-managed processes in place to mitigate legionella risk.
Should you need more information on record keeping for legionella risk management, feel free to speak with one of our consultants.