Legionella in social residential housing – Common questions
We provide legionella services to housing associations, local authorities and landlords who require support in managing the risk of legionella in social residential housing
- Do RSL’s have a responsibility under the HSE’s Approved Code of Practice L8 document to cover the water services for legionella in social residential housing stock? Simple answer “Yes”
- If risk assessments are in place for the control of legionella in social residential housing, how can they be policed?
- How can control measures be implemented to manage legionella in social residential housing?
- How can you gain access and maintain tanks in loft spaces above lease holder flats?
- In mixed use sites, who is responsible for the water supplied from a single source?
Facing up to the reality – legionella in social residential housing stock:
The fact is that all Housing Associations, Local Authorities and Landlords including individuals providing privately rented residential accommodation do have a legal obligation to address the risk of legionella a the HSE’s Approved code of practice applies in any situation where there is a commercial undertaking
Aqua legion provide legionella risk assessment and management services to various housing associations – We support the control of legionella in social residential housing stock.
If you are a provider of such accommodation you may already be aware of your responsibilities to ensure the risk from exposure to legionella in social residential housing is adequately managed. In most cases you will be required to assess the risk from exposure to legionella. If you need help in starting a legionella management programme for your residential portfolio please contact Aqua Legion now.
So what do you need to do to start managing legionella in social residential housing?
- First Landlords should conduct a water risk assessment to cover at least the communal services.
- Where access is readily available, an assessment should be conducted of any water containing assets.
- Communal tanks are common in large residential apartment blocks. Communal tanks will need to be adequately managed including annual inspection and sampling in line with the Drinking Water Inspectorate guidelines if they provide drinking water.
- The legionella risk assessment for large council estates and social housing projects can often be done without gaining access to all of the individual apartments.
- By ensuring the communal services are covered adequately and that reasonable attempts are made to gain access to at least a 10% of the units your organisation should be able demonstrate clear effort towards compliance.
- A pragmatic approach to legionella risk assessment and management of legionella in social residential housing should be adopted at all times.
- Although all high risk categories such as sheltered accommodation and shared service buildings should be fully risk assessed and control measures put in place to cover any communal systems if present. Simplified risk assessment formats should be developed to cover the lower risk properties or categories.
- A simplified risk assessment format should mean lower costs, however, it is important that any such assessment remains valid and resolves to provide the Landlord with adequate cover.
- Where maintenance is considered too expensive then alternative control measures and engineered solutions should be adopted to control any risks identified.
- It is also important to educate tenants on the proper management and maintenance of the water services. This can be achieved via internet platforms, newsletters and information packs.
- The management of legionella in social residential housing can be a challenge, particularly when the portfolio is extensive. However by implementing a pragmatic approach to the legionella risk assessment process and control regime the risk of legionella in social residential housing can be covered.
The common problems with controlling and management of Legionella in social residential housing or council mixed stock include:
- Mixed sites with a single landlord can often pose significant issues when trying to manage the risk of legionella.
- For examples, where a site is fed from a single water meter and piped to several buildings and storage tanks.
- Where individual buildings are let and sublet to a number of tenants who manage their own demised areas.
- Where hot water is provided from a single source with a number of outlets which cannot be tested due to access.
How do we overcome such issues?
- It is important that communal areas are assessed or scheduled for assessment on a running programme. All risks identified in communal areas should be addressed and managed.
- Communicate with your tenants, ask the right questions to determine any water supply issues. Tenants can also help with identifying tank and system locations so use their valid knowledge to gain information on your properties.
- Where intelligence indicates the requirement for a survey or inspection, appoint a competent person to assess the accessible systems and address any issues identified in a timely manner.
- Review previous maintenance history
- It is extremely important that Housing Associations and Landlords retain records specifically relating to legionella management and control. The records are to be used to demonstrate clear efforts towards the management of the risks associated with legionella in social residential housing. Records should include site risk assessments, routine inspections and remedial actions taken to reduce the risk of legionella.
What not to do:
Whilst it is generally accepted that the risk of legionella infection from well maintained and permanently occupied residential accommodation is low. There are a number of situations that can magnify the risks at any particular location and time.
It is extremely important to emphasise that if you do nothing to manage the risk of legionella infection in your portfolio of residential or social housing projects, then you will have an increased exposure to risk of litigation from your employees, visitors and tenants. Further to this you may be putting many of your own staff and susceptible clients at significant risk. Ignoring the issue will only amplify the problems in the long run.
The risk of legionella in social residential housing is real and will need to be addressed. If you require support in managing this risk, please do not hesitate to contact us.
If you need further information or would like to arrange a meeting to discuss how we could support you as a Landlord or Organisation please contact us today!
HSE guide for social and residential landlords: Legionella in social and residential housing HSE information.