Brief highlights of the HSE Report on Legionella Intervention Programme 2013-2014
Of the 5000 sites in GB notified to LAs under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992, only about half were initially allocated for visits. Before any site visits took place, there was considerable effort to cleanse the data. Sites were removed for several reasons:
sites no longer had cooling towers (or they had been replaced with a dry cooling system);
sites had changed use /companies had gone out of business; or
for operational reasons a visit was inappropriate (eg. a recent inspection, such as in preparation for the 2012 Olympics or an on-going investigation/prosecution).
Note I think this would exclude all cooling towers in Corporation of London & Westminster as well as the more obvious Boroughs local to the Olympics).
HSE, LAs or ONR considered some 2,500 sites where evaporative condensers or cooling towers were known or thought to be present.
HSE identified material breaches at ~ 33% of sites, meaning that at these sites at least written advice was needed to secure adequate levels of compliance.
HSE served 400 Improvement and 11 Prohibition Notices on the control of legionella risk at 229 different sites. A further 100 Improvement Notices and 8 Prohibition Notices were served on ancillary issues with a possible impact on legionella control, including work at height eg. to maintain drift eliminators.
LA inspectors sent a letter or served a notice at 21% of LA sites. LAs issued Improvement Notices at 9 sites and sent letters to a further 112.
There has been one successful proactive prosecution, Pride Cleaners (2000) Limited, of Dudley Road, Stourbridge, which has ceased trading, pleaded guilty to breaching sections 2(1) and 3(1) of the Health and Safety at Work etc Act 1974 and was fined £100 and ordered to pay £50 costs
Notifications of Contraventions were issued against a number of service providers (water treatment companies outside the scope of this programme). It is reasonable to expect this also to have a gearing effect, with the learning being shared across company regions and with other clients.
Water Safety Plans and Water Safety Groups (see paragraph 9) represent a holistic approach to managing the risks from HCWS in health care and social care premises, and we plan to explore the potential for collaborative work in this area especially with the LCA, PHE and others. Later, it might also be appropriate to consider auditing standards of compliance eg. in NHS trusts.