HSE/LA Legionella Intervention Programme 2012/2014 Duncan Smith FOD SG Occupational Hygiene 1
2 Number of Cases
Wet Evaporative Cooling System Outbreaks Stafford General Hospital - 87 cases (1985) Glasgow Royal Infirmary 15 cases (1985) BBC, London 79 cases (1988) Forum 28, Barrow - 172 cases (2002) Bulmers Cider, Hereford 26 cases (2006) 3
High Risk Systems 197 LD cases directly linked to evaporative cooling systems between 2001-2011 (inc 10 deaths) 7 outbreaks Mean number of cases/outbreak = 28 High proportion of legionella enforcement between 2007-2012 was on evaporative cooling systems 4
HSE/LA Legionella Intervention Programme 2012-14 Targeted action to high risk systems Multi-stranded approach Various intervention techniques appropriate to the industry and level of risk Regulators working together to inspect all high risk systems HSE (including ONR) LAs 5
Intervention Programme Aims Promote sustained compliance with relevant legislation by dutyholders Improve control of legionella in high risk systems 6
Multi-stranded Approach Safety notice Cooling towers and Evaporative Condensers Water Systems Compliance checks of high risk systems Joint HSE/LA Notified wet evaporative cooling systems Key stakeholder work (e.g. LCA, trade bodies) Promoting the intervention Information leaflets Develop tools (e.g. tool box talks) 7
Inspector Briefings & Topic Inspection Pack Compliance check approach Indicators of compliance Risk scoring system Enforcement expectations 8
Indicators of Compliance 4 key topics to be assessed Risk assessment Written scheme of control Implementing the scheme of control Recordkeeping Training, audit & review were also assessed as part of this process 9
Inspection Approach Site and details obtained from all 382 LAs (via NCTEC Regs) ~5000 sites GIS data HSL 2km radius (day/night population) Questionnaire 10
Prioritising Visits All sites with mechanically ventilated cooling towers or evaporative cooling towers to be visited High priority sites visited first Questionnaire response Non response Key question fail Total score Population density 11
Stakeholder Events Legionella Control Association Water Management Society Chartered Institute of Environmental Health British Occupational Hygiene Society Royal Society for Public Health Institute of Healthcare & Estate Management 12
Dutyholder Events Joint HSE/LCA information days in Newcastle, London & Birmingham (Feb-April 2014) targeted specifically at dutyholders Possibly future event in Scotland? 13
Guidance & Information Review of L8 ACoP - complete Nov 13 14
Guidance & Information Review of technical guidance completed Nov 13 for Evaporative Cooling and Other Risk systems (HSG274 Parts 1 & 3) completed for H&CW systems April 14 (HSG274 Part 2) HSE Legionella website update PHE/HSE review of guidance for spa pools underway HPS Outbreak Protocol revision in progress 15
Intervention Visit Progress Intervention Report to be published on HSE website and will detail number of inspections and enforcement action Majority of inspections completed by end of 2013-2104 work year - small number carried over into this work year 16
Intervention Visit Progress HSE served IN/PNs at 10-15% of sites visited 19 PNs already served FFI charging at ~30% of HSE sites 17
Common Failings Risk Assessment Written Scheme Work at Height/Access Cleaning Lack of Routine Inspection 18
Access /Work at Height 19 How are the drift eliminators on top of these systems inspected?
20 Blind Ends
Fill Pack Scale Iron Biofouling 21
Drift Eliminators Misalignment Damage Collapse 22
Sump or Pond Cleanliness Organic matter Film or Scum 23
Biofilm Stalactites! 24
Sampling Where and when? Dipslide training Incubation temperature and time 25
Programme review What Next? Follow up with service providers Inform future guidance Disseminate good practice Adiabatic (dry/wet) systems? Legionella remains a Matter of Potential Major Concern for HSE 26
Questions? duncan.smith@hse.gsi.gov.uk 27