CQC registration: Managing legionella risk
Adam Carter advises on minimising legionella risk and commissioning a good firm to help you.
When the Care Quality Commission (CQC) announced that all surgeries must be registered by April 2013 there was a lot of confusion about what this would entail and the associated costs involved.
The CQC registration involves many different areas but in general each GP must provide evidence that they are complying with the various legislation in the UK. An area that has been neglected in the past is legionella control. CQC guidelines are set to follow the HSE's guidance document known as ACoPL8 available on the HSE website.
Every practice will require a legionella risk assessment, a written control and monitoring schedule, appropriate records to be kept (i.e. a log book) and training for the responsible person and deputy. The risk assessment should include every aspect of the water systems on site from design and operation to usage and turnover. The assessment cost will vary depending on the size of the building and design of the systems. A smaller site will cost around £300-500 + VAT. It's important to look at the complete package not just the risk assessment so try and get training and a log book built into a proposal.
What's the risk?
GP surgeries vary in the type, age and size of the building and how large the practice is. The risk associated with each site will vary depending on system design e.g. whether there is a cold water tank or just mains supply. Is there stored hot water or instantaneous and point of use water heaters? Statistically the risks from legionella overall in Medical Centres are relatively low. However it is important to note that people with existing medical conditions, poor health, smokers and the elderly are in high risk categories for Legionnaires' disease. So the potential consequences of exposure are much higher.
A good risk assessment will be comprehensive, detailed and written for you. It is important to implement recommendations, the control scheme and monitoring programme to minimise the risk on site. Even the best risk assessment is useless if no one reads it or doesn't take action.
A good legionella training course can give you sufficient knowledge to implement and manage the risks from legionella in house once a risk assessment is in place. This saves money as you won't need contractors to do ongoing monthly monitoring visits.
How do you choose a legionella control firm?
A few probing questions will help you get the most from your existing supplier or choose a new firm.
1. How long has the firm and staff been doing legionella control? Are they experienced?
2. What is their reputation? Ask for a reference or get testimonials and make sure they are genuine.
3. How long have they been working in legionella control? Talk to one of the risk assessors as they do the work, how credible and trustworthy are they?
4. Do they provide training? Attend a course as this is a great way to assess them.
5. What else does their firm do? Independent ones will act as consultants for you and not do the remedial works etc, most firms will offer what they recommend (so they are not independent) and others do legionella amongst other services. Again there are pro's and con's so decide which type suits you.
6. Ask for examples of their work such as a legionella risk assessment and log book. Read them and see how well you understand them. If they are hard to follow that probably doesn't bode well. How good is the schematic drawing? You should easily be able to follow the recommendations, their importance and understand why?
Adam Carter works for Archer and Stone Ltd