What is a Legionella Written Scheme of Control?
Managing the risks posed by Legionella bacteria is a legal and safety priority for any premises with a water system, especially those with complex infrastructure or vulnerable occupants. One of the most important tools for ensuring these risks are effectively controlled is the Legionella written scheme of control, a legally required document that outlines how a building’s water systems will be monitored, maintained, and managed to prevent the growth and spread of Legionella bacteria. It forms a key part of a business’s duty of care and demonstrates a proactive approach to water safety and compliance.
This article explains what a written scheme of control is, how it differs from a Legionella risk assessment, and why both are essential. It outlines what should be included in a control scheme, from water system schematics and maintenance programmes to responsible personnel and contingency planning. The article also covers the importance of regular reviews, good record keeping, and staff training to ensure that any changes or potential risks are managed swiftly and effectively.
What is a Legionella written scheme of control?
A Legionella written scheme of control is a documented plan that sets out measures to control the risk of Legionella bacteria in water systems. It ensures compliance with water safety standards and helps mitigate risks associated with exposure to Legionella bacteria and Legionnaires’ disease by maintaining safe water systems.
Is a written scheme the same as a Legionella risk assessment?
A written control scheme is not to be confused with a Legionella risk assessment – they are two distinctly different documents and should be treated as such.
A risk assessment is conducted to identify all possible Legionella risk factors in a building or facility. The written scheme of control covers all the procedures required to control the presence of Legionella bacteria in the premises covered by the risk assessment. The written scheme would normally be created after the risk assessment is completed.
The two documents do work together though. If you review your risk assessment and make any changes to it, you should consider whether any necessary adjustments are required to your written scheme of control also.
For example, risk assessments should be conducted regularly and checked, even if no obvious changes have occurred that would prompt this. If there is a material change to the water system or you have reason to suspect the assessment is no longer valid, this should trigger the need for the risk assessment to be reviewed. A good example would be the removal of a sink or other water outlet, or perhaps a redesign or revamp of part of the building that affects the water supply. You should then re-visit the risk assessment to reflect this.
Having done so, you can then review your written scheme of control to consider whether any changes should be made to that document also.
Is it necessary to have a written scheme of control?
In the UK a written scheme of control for Legionella is required by law, so you must have one in place that is available to review at any time.
What should be in a Legionella written scheme?
The written scheme is intended to help manage the risks associated with Legionella bacteria at a specific site, location, or venue. This could be an office building, hospital, swimming pool, or other facility. It is designed to help control the risks present at an individual location, hence why it is a legal requirement to have one.
It should include a full plan of the hot and cold-water systems present in the building. If anything changes, the scheme should be edited or rewritten to accommodate and accurately record those changes. It should also include detailed instructions on how all aspects of the system work. This may be simple or complex, depending on the size of the building and how complex the water system is.
Detailing Legionella control procedures
The written scheme of control must also cover all procedures required to help control the presence of Legionella bacteria within the water system to keep it at safe and acceptable levels. This should involve a programme of regular maintenance to ensure all system components are clean and operating in the correct manner.
Regular monitoring should also be conducted to make sure nothing is missed. This may include monitoring the hot and cold water temperatures. Water testing may also be included to ensure Legionella bacteria remains within safe levels in the system and does not rise unchecked. There should also be details of what should be done if problems arise, or if testing reveals higher than usual Legionella counts.
It is important to note that sufficient details should be provided to ensure that everyone knows what must be done if a problem does arise. That’s why the control scheme should also list all personnel involved in managing water safety at the building. It should detail who is responsible for what, and who should perform the required actions if a problem arises.
Good record keeping
Remember that the written scheme of control should detail everything required to manage and reduce the risks of exposure to Legionella bacteria in that system. While smaller businesses with fewer than five employees do not legally need to keep records, we can see that the written scheme of control is required. Therefore, it is usually easier to keep records of any testing or control measures that are undertaken and completed, for the sake of accuracy and proper coverage.
Legionella training and competence of key personnel
All those involved in maintaining a safe water system should also be fully aware of the risks and what they must do to complete these tasks. Thus, appropriate Legionella training should be undertaken by all these individuals. A record of this should be kept as part of the written scheme, along with any refresher training and the required dates for this to be completed.
A detailed Legionella written scheme of control can help demonstrate a responsible approach to water safety
All these details come together to show that the business or venue in question has approached its responsibilities in the correct manner. The Health and Safety Executive (HSE) or other safety regulators may require evidence of the business’ approach to managing the risks posed by Legionella. If so, the written scheme of control should cover all that is required under health and safety law. It should also provide evidence of how the Legionella responsible person and other members of staff identify and control all risks associated with Legionella.
Of course, the actions taken by one business in a specific premises will vary from those taken by another. That is the reason why a Legionella risk assessment together with a scheme of control is required by law for each venue. A new building with a modern hot and cold-water system may have very different risk factors compared to a much older building that has undergone several renovations, for example. If in doubt, it is always better to add more information than necessary to demonstrate that the risks of exposure to Legionella bacteria are being controlled effectively.
Improved contingency planning for problems and near misses
One final point is to make sure you add a plan to respond to raised levels of Legionella bacteria, or any incident that could potentially lead to this happening. This shows that you have a plan for any mishaps that could cause bacterial levels to rise. By responding quickly and following a preset plan, it is far more likely that any serious issues that do occur are dealt with quickly and effectively. Targeted and prompt action like this may help prevent an outbreak of Legionnaires’ disease altogether. This shows how important a detailed, well thought-out written scheme of control is to a business and its people.
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