WHY is there a Legionella risk in schools?

 A lot of the news headlines come during and just after school holidays when usage of the water systems has been reduced compared to what they would be during term time, potentially leading to stagnation especially if they are not managed effectively. If infrequently used outlets are not included in your Legionella flushing regime at least weekly, in line with the guidance in HSG274, then there is the potential for water to stagnate and provide ideal conditions for bacterial growth.

 If systems are not regularly flushed, it is not overly surprising that when sampled Legionella bacteria are detected. Thankfully, the risk to our children is actually very low. There are very few cases of school-age children being diagnosed with Legionnaires’ Disease. The figures from the 2021 report from the ECDC show only one child (aged 5-14) diagnosed in the year 2021 (European Centre for Disease Prevention and Control – Legionnaires’ Disease Annual Epidemiological Report for 2021). Generally, children of school age are not considered in a high-risk category for contracting Legionnaires’ Disease. Yet we do have a general duty of care to protect people from harm, and as Legionnaires’ disease is very much considered a preventable illness. So schools do need to have in place reasonable steps to control the risk.

 The threat from Legionnaires’ Disease is considered ‘preventable’ and when contracted from an estate, invariably there will be legal ramifications… Good water safety management within school properties can be distilled into the following areas: 1 – Determining management arrangements and responsibility; 2 – Establishing the level of Legionella risk and devising an action plan proportionate to risk; 3 – Evidencing how Legionella risk has been suitably controlled, managed and reviewed. Legionella Guidance ACoP L8 and HSG 274 Part 2 provide the most current guidance and practical advice on managing the Legionella risk– ultimately to help ensure compliance with various health and safety regulations i.e. COSHH and the Management of Health and Safety at Work Regulations (MHSWR).

It’s important to identify and establish a hierarchy of authority for water safety management ensuring that those responsible are demonstrably competent to undertake their role. Doing so will help the school to suitably delineate between management and operational water safety responsibilities. Once the management structure has been agreed upon and formalised within a policy document, water safety management considerations now become more ‘operational’. For example, a good starting point for a school, as for any organisation, would be to commission a site-specific Legionella risk assessment with accompanying schematics. The risk assessment should include a survey that includes all the systems that may contribute to or cause a risk of waterborne infection The HSE’s HSG274 Technical Guidance, Part 2, Table 2.1 provides practical guidance on the minimum requirements for the management of water risk systems.

 Therefore, whilst it’s not mandatory to follow the guidance, bear in mind that should the guidance not be followed then an organisation will need to demonstrate that they have achieved either an equivalent or better standard. Finally, comprehensive and complete water safety records must be kept and be easily accessible, i.e in a log book system. A failure to provide sufficient evidence to demonstrate that the risk of Legionella is being managed and that systems are in control could be interpreted as a failure to ensure that the water is safe.