Compliance Update Legionella Asbestos Nick Williams MRICS - - PDF document

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Compliance Update Legionella Asbestos Nick Williams MRICS - - PDF document

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DMW Environmental Safety Ltd Compliance Update Legionella Asbestos Nick Williams MRICS Director, DMW Environmental Safety Ltd nickwilliams@dmwsafety.co.uk 07813 109094, 01902 791565 DMW Compliance consultancy UKAS accredited

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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

1 Compliance Update

  • Legionella
  • Asbestos

Nick Williams MRICS

Director, DMW Environmental Safety Ltd nickwilliams@dmwsafety.co.uk 07813 109094, 01902 791565

DMW

  • Compliance consultancy
  • UKAS accredited surveying and

inspection body (asbestos and legionella)

  • Laboratory services
  • Health safety and environmental

consultancy

Legionella – Introduction

  • 41 different species of Legionella
  • Around half of them can cause illness
  • Occurs naturally in fresh-water systems
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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

2

Pathogenesis

  • Legionellosis – The term for ALL diseases (fatal or

non-fatal) in humans caused by L. pneumophilia or

  • ne of the of the many other species of legionella.
  • Legionnaire’s disease – pneumonia caused by L.

Pneumophilia

Legionnaire's Disease – Symptoms

  • Pneumonia
  • Incubation period 2 - 10 days (usually 3-6 days)
  • Virulence rate 1-5%
  • Fatality rate 12 - 30% (excluding vulnerable

persons)

  • No evidence of person-to-person transmission
  • ‘Pontiac fever’ is a more virulent illness with flu-like

symptoms (more likely to catch it) but is not life- threatening

Legionellosis – The Risks

  • 690 cases reported in England and Wales (419

confirmed as being legionella)

  • Around 10,000 cases per year in the EU
  • Global infection rate is ‘unknown’
  • Likely to be massively under-reported
  • 35 fatalities in England & Wales in 2017
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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

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Legionellosis – Susceptibility

  • Increases with age (increased for those over 45)
  • Patients with existing respiratory problems
  • Heavy smokers and alcoholics
  • Those undergoing immuno-suppressant therapy
  • Gender (males more susceptible)

Legionella – Ideal Growth Conditions

  • pH - 6.9
  • Temperature - 25-37C (won’t multiply below 20°C

and killed above 60°C)

  • Required nutrients- ferric iron and L.cystein
  • Slimes, sludges and biofilms
  • Stagnant water

Occurrence of Legionella in Buildings

Artificial water systems that may harbour legionella include:

  • Domestic hot and cold water systems
  • Calorifiers
  • Storage tanks
  • Showers
  • Cooling systems
  • Ornamental fountains
  • Jacuzzis
  • Spas horticultural misting systems
  • Industrial car washes
  • Respiratory therapy equipment
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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

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Legionella Risk Factors

  • Aerosol formation
  • Droplet size
  • Concentration of legionella bacteria
  • Duration of exposure
  • Individual susceptibility
  • Virulence of strain present
  • Distance from source of exposure

Legionellosis – Causal chain

  • System becomes

contaminated

  • Legionella proliferation
  • Legionella disseminated in an

aerosol

  • Aerosol comes into contact

with a susceptible individual

  • Contaminated aerosol present

long enough to cause infection

Relevant UK Law

  • Health and Safety at Work etc Act 1974
  • Control of Substances Hazardous to Health

Regulations 2002

  • Management of Health & Safety at Work

Regulations 1999 (as amended)

  • The Notification of Cooling Towers and

Evaporative Condensers Regulations (1992)

  • RIDDOR 2013
  • Corporate Manslaughter & Homicide Act 2007

Guidance/ACOP

  • L8 (2013)
  • HSG274 Technical guidance Parts 1-3
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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

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ACOP - L8 Basic Principles

General principles and requirements include

  • Assessment, monitoring and control of risk

(maintenance and remedial work)

  • Control of aerosol release
  • Avoid 20 - 45 C
  • Avoid stagnation
  • Maintenance and cleanliness
  • Water treatment (where required)
  • Management and review of risks
  • Responsible persons (competency)
  • Emergency/contingency procedures

ACoP L8 – Legionella Risk Assessment

Required for rented and non-domestic premises posing risks e.g:

  • Cooling towers
  • Evaporative condensers
  • Hot and cold water systems
  • Other risk systems

ACoP L8 – Legionella Risk Assessment (cont)

Review risk assessment:

  • Regularly (accepted frequency is

two-yearly but less or more frequently dependent on risk)

  • Risk assessment must be reviewed if

there are significant changes are made to the water system or use of building

  • Emergency review required where

new information or incidents arise such as a legionella outbreak or water analysis shows proliferation

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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

6

PPM’s and monitoring - Hot and Cold Water Systems

Weekly

  • Flush low-use outlets
  • Monthly Monitoring
  • Hot taps to be >50C after 1 minute of running
  • Cold taps <20C after 2 minutes of running
  • Flow and return temperatures of calorifier (above 60C on flow and 50C in

return) Three Monthly

  • De-scale and disinfect shower heads
  • Six Monthly
  • Check in-coming cold water inlet and record

Annually

  • Calorifier drain water inspection and blow-down
  • Cold water tank inspection
  • TMV servicing and fail-safe checks

Good practice

  • Use low corrosion materials where possible

(WRAS and Water Regulations compliant)

  • Water tanks fitted with close fitting lids,

insect/rodent screens

  • Avoid multiple linked tanks (stagnation risk)
  • Systems to be designed to be accessible for

cleaning and maintenance

  • ‘Point of use’ hot water generators are

recommended for new installations, especially in larger buildings

Written Control Scheme

Can be organizational or individual site-based (dependent on risks and uniformity of premises)

  • Responsibility lines (duty holder, nominated

responsible persons, competent persons)

  • Water treatment programmes (if applicable)
  • Disinfection procedures (if applicable)
  • Maintenance and inspection regime
  • Recording of inspection and maintenance
  • Emergency procedures
  • Training records/contractor certification
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DMW Environmental Safety Ltd

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Log Book

Records

  • Risk assessment
  • Schematic
  • Copy of written control scheme
  • All monitoring and maintenance records

associated with water system

  • Site visit log
  • Record of non-conformance and action-log

Can be held in hard copy form on site or centrally/electronic (as long as it is accessible)

HSE Enforcement Programme Findings

Common failings leading to enforcement and high risks to occupants and public include Inadequate definition of responsibilities

  • Failure to assess risks
  • Failure to understand own systems (schematics etc)
  • Failure to implement water treatment systems where

required

  • Failure to clean and maintain water systems
  • Defective systems – no temperature control, failure

to prevent contamination

Top 5 things to comply

  • 1. Risk assessment – (review to determine suitability)
  • 2. Manage and reduce identified risks AFARP
  • 3. Devise and implement written control scheme
  • 4. Ensure competency of all relevant persons
  • 5. Regularly review risk control systems
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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

8

Case Studies

G4S offices, Harlow (2016) – £1.8 million fine after fatality

  • System dead legs
  • Oversized tanks
  • No schematic
  • Hot water temps too low
  • TMV’s not identified or serviced

BUPA (June 2018) – insufficient assessment and controls of hot and cold water systems after refurb

  • f care homes led to a fatality = £151,000 fine

Key Case Study – Individual responsibilities

HSE Statement following Barrow Court Outbreak Prosecution Case: July 2006. “There is a clear lesson for all those that manage installations carrying a risk of legionella. You should check your management systems and

  • versee the work of contractors that do work on

your behalf. It should not be assumed that systems are working as they should and no room for ignoring responsibilities at any level

  • f

management”

Asbestos Update

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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

9 What is Asbestos?

  • Naturally-occurring fibrous

mineral

  • 3 common types (6 altogether)
  • Mined extensively in many

countries

  • 3000 commercial asbestos

containing materials (ACM’s)

  • Not banned in construction

materials until 1999/2000

  • Single biggest occupational

killer in UK

Risks Associated with Different ACM’s

Spray coatings and thermal insulation

Less fibrous Higher density Less dangerous Highly fibrous Low density Most dangerous

Asbestos insulating board (AIB) Asbestos cement products (sheets, pipes etc.) Composites, floor tiles, cisterns etc.

HSE ‘Hidden Killer’ Campaign

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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

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Current Key Requirements – CAR 2012

  • ‘Duty to manage’ in non-domestic premises

(identification & assessment, communication systems, condition monitoring, management plans etc).

  • Identification and control of asbestos risks prior

to maintenance and refurbishment (aligns with CDM 2015).

  • Training for all persons who could encounter

asbestos

  • Strict regulation of work on materials containing

asbestos

Legal classification of work with asbestos

Classification Criteria Examples Controls Non-licensed • Control limits not exceeded

  • SALI not exceeded
  • Short duration work not exceeded
  • ACM matrix (cement and textured

coatings etc) are not deteriorated or will not deteriorate during work

  • Removal of ACM floor tiles
  • Shadow-vacuum drilling

several holes in textured coating to support an electrical re-wire

  • localised exclusion
  • PPE and RPE
  • Hazardous waste disposal
  • CAR 2012 compliant POW
  • Visual inspection

certification (minimum) NNLW

  • Control limits not exceeded
  • SALI not exceeded
  • Short duration work not exceeded
  • Removal of textured coating

from a concrete ceiling (<1m2)

  • Removal of an asbestos

cement sheet garage as above AND

  • NNLW notification
  • Personal exposure

monitoring

  • Medical surveillance

licensed and ASB5 (14-day) notifiable

  • Control limits exceeded or;
  • SALI exceeded or’
  • Short duration on high-hazard

materials exceeded

  • Removal of AIB (asbestos

insulating board) tiles

  • Most tasks with ACM

insulation as above AND

  • ASB5 14-day notification
  • Enclosures and airlocks
  • Decontamination unit
  • Power-assisted

respirators

  • COR testing
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DMW Environmental Safety Ltd

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Licensed Asbestos Removal – Direct Connection

Enclosure (store room containing AIB) Intervening tunnel (airlock) Decontamination Unit

Licensed Asbestos Removal – Transit System

airlock Decontamination Unit Sampling pump used for air monitoring

HSG 264- Asbestos Survey Guidance

Intended readership is both surveyors and clients commissioning surveys Surveyors

  • Technical guidance on procedures
  • UKAS accreditation for firms (ISO 17020)

Clients

  • Guidance on support required to facilitate

surveys, enabling works etc

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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

12 HSG 264- Management Surveys

  • Should identify ‘visible’ asbestos

materials

  • Is possible to undertake minor intrusive

works such as checking the voids inside suspended ceilings in communal areas, lifting carpets to check under- coverings.

  • Suitable for minor maintenance and

refurbishment work which will not disturb the deeper fabric of the building

HSG 264- Refurbishment OR Demolition Surveys

  • Fully intrusive with “aggressive

techniques” required

  • “…should only be conducted in unoccupied

areas….and furnishings removed” from the areas within the survey scope (limitations)

  • Service isolations may be required
  • Only required in areas where the work is

being carried out – often ‘targeted refurbishment’ surveys are carried out (only intrusive in areas where work is being done)

Asbestos Liabilities – Dilapidations

  • Lease term ending on a retail unit
  • Tenants asbestos survey - asbestos present

but in good condition

  • DMW survey on behalf of landlord –

asbestos was found to be damaged and unfit for occupation

  • Big dilapidations claim against tenant.
  • Tenant surveyor argued they were rented a

building with asbestos problems so it’s the landlords problem

  • Landlords surveyor informed by our survey

that tenants work has damaged the asbestos causing the building to be unfit for

  • ccupation (added to dilaps claim)
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DMW Environmental Safety Ltd

Notes provided for convenience only. DMW do not accept liability for any inaccuracies or omissions. Please check latest law, ACOP and guidance

13 Top 5 priorities – asbestos compliance

1. Reliable asbestos register 2. Asbestos management plan (organisation-specific, up-to-date)

  • 3. The right type of survey information

(upgrade to refurbishment or demolition survey when required)

  • 4. Communicate the information to those

at risk

  • 5. Contractor control (training,

conforming to your management plan)

Thank you for listening

Nick Williams 01902 791565 nickwilliams@dmwsafety.co.uk www.dmwsafety.co.uk