The Importance of legionella record keeping and monitoring on the railway
You have undertaken your Legionella risk assessment and it is has identified all of the foreseeable risks posed by Legionella in your buildings, carriage wash plant and on board your trains. So, what do you need to do next?
The first requirement within the Legionnaires’ Approved Code of Practice (ACOP) L8 is to appoint a responsible person and a deputy, put in place a written scheme of control and ensure that everyone involved in managing the risk from legionella is suitably trained. Alongside this, you need to ensure that you monitor your systems in line with the recommendations within the risk assessment and your written scheme to ensure they remain ‘safe’ and keep records of everything you do as part of your Legionella control process. Having an effective monitoring regime and keeping records is vitally important to demonstrate the system is under control and well managed.
Is it a legal requirement to carry out water hygiene monitoring and keep records?
A common question that is asked during Legionella training is when undertaking monitoring and keeping records is it a legal requirement? The answer to this, quite simply, is yes. It is a requirement of ACOP L8 that you keep records for all aspects of your Legionella management and control processes, and therefore, responsible persons are legally required to ensure compliance with COSHH, Management Regulations and the Health and Safety at Work Act 1974. More importantly, the monitoring you carry out and the records you keep are your evidence to the Office of Rail and Road (ORR) and the HSE that you are effectively managing the risks that are present. Without this evidence, they will not know that you are keeping the systems safe, and should any serious issues arise, this could lead to enforcement action.
What type of water hygiene monitoring is required?
As aforementioned, Legionella will likely be present in your water systems, be that your depot or station buildings, your carriage wash or on board your trains, albeit at low levels. To reduce the level of risk, your task is to manage the system and prevent the growth of the bacteria. This can be implemented via a series of control measures such as water movement, temperature control, chemical dosing or filtration. Based on the control measures already in place or required by your risk assessment, you will need to put a monitoring programme in place to demonstrate that these controls are effective.
How often you will have to carry out water hygiene monitoring will depend of the type of system, the system’s condition, the type of occupant and the history of the plant or system present. The Technical Guidance document HSG274 Part 2 provides guidance on the monitoring tasks and required frequencies, and these should be used as a guide and read in conjunction with the recommendations given in your risk assessment by your risk assessor. All of your water systems will require some form of monitoring, including flushing, temperature monitoring, chemical level checks, condition inspections, cleaning, disinfection and sampling.
In addition to the monitoring of the plant and systems present, the entire Legionella control process should be audited, as required by L8, on a regular basis to ensure compliance with the law.
What information is required when keeping records/monitoring Legionella?
You must keep records of everything you do as part of your Legionella control programme, including monitoring, inspections and maintenance. In addition, you must keep a record of all of the management processes in place, including copies of your risk assessment and when the recommendations have been adhered to. Records can be kept electronically or as hard copies – as long as the information is there and readily available, it does not matter how it is kept.
The below examples are typical of the information required when keeping records for Legionella management and control:
- Names, positions and contact details of the people involved in the control process, including maintenance staff and contractors;
- Training records for staff;
- A copy of the risk assessment, a reference to its location and evidence of any remedial work undertaken following it;
- Schematic diagram;
- Information on the system and how it operates;
- A visit log for contractors, consultants and visitors;
- COSHH data and Material Safety Data Sheet (MSDS) information for chemicals in use as part of the control regime;
- Contractor visit reports;
- Audits of the Legionella control programme;
- A list of control parameters;
- Planned Preventative Maintenance (PPM) programme;
- Method statements;
- Records of all monitoring and inspections undertaken – all records must be signed and dated by the person completing the work;
- Defect and fault management records for results outside of control parameters;
- Chemical and microbiological analysis reports and certificates
How long do I need to keep Legionella records for?
All records need to be easily accessible for auditing purposes. Legionella risk assessments and written schemes need to be kept while they are relevant and for two years following review. All monitoring and maintenance records need to be for a minimum of five years.
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