With the amount of supported housing in private hands increasing, Andrew Scott of Gauntlet Group reiterates the significance of checking and balancing for legionella
According to the HCA Statistical Data Return, between 2015 and 2016 we witnessed the largest increase in the total amount of social housing stock owned by privately registered providers of social housing, with 2,761,690 units per bed spaces owned at March 31, 2016.
The transfer of housing stock from councils to private providers and agents typically leads to property refurbishment and repairs and often involves periods of tenant unoccupancy. At other times, capital works, which may disturb or affect the water supply, may be carried out while residents are still in their homes. The ‘invisible enemy’ of legionella can thrive in both scenarios.
Legionella is a potentially fatal form of pneumonia taking hold when tiny droplets of contaminated water (aerosols) are inhaled. The bad news is that all man-made hot and cold water systems can assist the growth of legionella bacteria. For this reason, a landlord (defined as anyone renting property they own under lease or licence for a period under seven years) has legal responsibilities to control the risk of legionella under the COSHH (Control of Substances Hazardous to Health) Regulations of 2002.
Those taking control of housing stock in which some or all of the apartments or units have been unoccupied, even if just for a short period, should hear legionella alarm bells, particularly if tenants receive their water supply from a central tank within which water could have stagnated.
Stagnant water can be a breeding ground for legionella and systems should be drained and thoroughly flushed out Stagnant water can be a breeding ground for legionella and systems should be drained and thoroughly flushed out. Communal tanks are a common feature in large residential blocks and a thorough risk assessment should surround their maintenance and use.
However, all social housing properties should have a legionella risk assessment in place, as legionella could take hold for a variety of reasons: at times because the water temperature of stored water has been too low (under 60 degrees celsius) to kill the bacteria; at others because pipework has not been lagged, or because the water reaches individual units via circuitous pipework with twists and bends that could be home to stagnating or contaminated water.
A written legionella policy that outlines the controls in place, maintains a programme of regular monitoring of the water supply and appoints a ‘responsible person’, charged with maintaining the regime of control and risk identification, is essential. The responsible person may be the social housing provider, or a letting agent and also, at times, tenants themselves.
Some residents are more at risk than others, particularly older people in sheltered accommodation. However, heavy smokers or drinkers, past or present, and those with existing conditions such as diabetes and heart complaints, are also at higher risk. Risk control measures should reflect this and those responsible may decide to implement a regime of legionella water sampling within such properties, though this is not a legal requirement.
In all environments, education is key, so everyone understands both how legionella develops and the signs of a possible outbreak: flu-like demonstrations, headaches, fever, high temperature and diarrhoea.
While property refurbishment can present a legionella threat, it can also create a real opportunity. While older housing stock may have access issues that present barriers to effective monitoring, cleaning and disinfection, these could potentially be improved during the refurbishment process.
Additionally, there may be an opportunity to make water circuits simpler and shorter and remove dead legs. Better insulation could be installed around pipework and tanks, and better screening with more modern materials could prevent contaminants such as insects, rust and organic matter entering the water supply.
Whatever the scenario, one thing is key within legionella management, and that is education. Ultimately, the message is that of not allowing your legionella risk management to stagnate. Continuously assess whether there have been changes to either water systems or the occupants living within properties and adjust controls accordingly. Ensure tenants cannot tamper with hot and cold water systems and make sure legionella education reaches everyone in the risk management chain, from tenants to workmen and suppliers, and not forgetting visitors to the site. Record procedures and actions taken, make policies living and regularly update documents.
Being diligent about legionella management will keep you on the right side of health and safety law, but the catalyst for that diligence should stem from your duty of care and social responsibility as a housing provider. Embracing this ethos should help protect against the invisible enemy that goes by the name of legionella.
Andrew Scott is the health and safety manager at Gauntlet Group