The Health and Safety Executive states in its Code of Practice on the section about control of Legionella and water systems that the hotel duty holder or responsible needs to “assign a fully competent person with a sufficient level of knowledge and authority of the water system installation to aid with taking the required measures to comply with the regulations and law.”
What does this actually mean? From my understanding there is confusion among hotel owners and managers, so here are some explanations about your actual options when it comes to hiring and assigning a water competent person or CP water.
First option: an expert Legionella control competent person
The law and regulations do not require duty holders and responsible executives to employ the services of a fully qualified Legionella risk manager, but the approved Code of Practice from the Health and Safety Executive states that “those specifically assigned to carry out the control, monitoring and strategies must be properly informed, instructed as well as trained and their suitability evaluated beforehand. They need to be appropriately trained to a level that guarantees tasks are carried out in a technically competent and safe manner; and receive regular up-to-date training.” By working with a qualified professional (for instance a member of the Legionella Control Association), you will be sure that your risk assessment, as well as Legionella control procedures, are in safe hands at all times.
Second option: a fully qualified plumber
There are certain plumbers that are fully trained and qualified in evaluating and managing the Legionella risks, so in case you know a trustworthy plumbing supplier it might be worth asking if they do have relevant qualifications. But in case they have not taken a specialised Legionella training they won’t be sufficiently qualified. For example, they must be able to produce a full schematic drawing of the plumbing system and also be able to identify potential risk sources. The Health and Safety Executive advises that “before you hire a contractor, you need to be satisfied that they will be able to carry out the work you need to the standard that you require.”
Third option: a hotel management firm or agency
In case you are using the external services of a hotel management provider to manage the daily processes of your hotel, they might offer Legionella control services too. Again, it is solely your responsibility to guarantee that they are suitably competent and have correct, up-to-date training.
Fourth option: you can always do it yourself
The Health and Safety Executive acknowledges that it’s acceptable for the responsible duty holder to manage Legionella risk management themselves, as long as they are truly competent. There is no reason why you cannot take a do-it-yourself approach in case you are fully knowledgeable (and formally trained) in all aspects of Legionella risks and plumbing systems. The Health and Safety Executive provides comprehensive advice on what you need to do to be compliant so in case you have enough time and experience, you can take on the task yourself.
Whichever option you go for, do not forget that the monitoring and control of Legionella is indeed an ongoing process, and not a report to put in a drawer. Review your risk assessment often, particularly review it each time that you make modifications to the water system and ensure your paperwork is always kept up-to-date.
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