Legionella – a special approach for the care sector

At Swiftclean, we’re very aware that, within the care sector, the needs of care home residents must be balanced with the legal obligation to ensure that their water system is free from contamination with Legionella bacteria.

This calls for very clear communication and close co-operation between our own work planning teams, our surveyors, our field technicians, and the care home’s own team. We do our utmost to ensure that our Legionella prevention work, which helps to safeguard care home residents, has as little impact as possible on the practical day-to-day routines and care of each individual resident.

Care home residents, particularly the elderly or physically infirm, are often among those most vulnerable to the effects of Legionella bacteria. The bacterium, Legionella pneumophila, and related bacteria are the cause of the illness known as Legionnaires’ Disease. This is a ‘flu-like ailment and a potentially fatal form of pneumonia which can affect anyone, but which principally affects those who are vulnerable due to age, physical frailty, underlying health conditions, immunosuppression, asthma, and even factors such as smoking.

Your legal responsibilities as care home manager

Under the Legionella prevention Approved Code of Practice (ACoP) L8, which is issued by the HSE, you are required to appoint a Responsible Person to ensure that the ACoP L8 is diligently applied to safeguard your residents, staff and visitors. In many cases the care home manager will also be the Responsible Person. Part of your duties is to have an up-to-date Legionella Risk Assessment, in which the Responsible Person must be named. If the Responsible Person changes, as often occurs with a change of manager, the risk assessment must be updated to reflect this.

You must make sure that the water system is well designed so that water can flow freely through every part. Many care homes are established in properties that originally had a different, often residential use. Plumbing and pipework are often modified, either because the use of part of the property has changed, or because the property itself has been extended to provide additional accommodation or support services. These alterations can occasionally result in ‘dead legs’ especially where a water outlet has been removed and pipework left in place. Dead legs allow water to remain static in parts of the system. Static or slow-moving water is one of the three main conditions which Legionella bacteria need to proliferate, so it is essential to maintain a good flow of water throughout the system. If parts of the system are not used for a period of time, perhaps if a resident has left, or has spent a prolonged period in hospital, it is important to flush it through regularly to avoid water stagnation.

Great care must be taken when flushing water outlets. Legionella bacteria, which causes Legionnaire’s Disease, can be inhaled in tiny droplets of water from mist or spray from a flushing toilet, a running tap or from operating a shower head. We recommend flushing toilets with the lid closed and running taps by draping a plastic bag or rubber glove over the faucet to minimise splashing. Shower heads should be immersed in a jug of water before running to prevent spray. We can train your own competent person to carry out safe flushing.

If the outlet is rarely or never used, it is safer to remove it, together with any associated pipework, so that free circulation is not compromised. We regularly recommend and carry out these kinds of remedial work.

You must also, as part of your legal duties, ensure that cold water is kept below 20°C while hot water is delivered safely above 45°C. Hot water systems rarely present a problem, but cold water systems and any cooling systems often need additional shading to prevent the water in tanks and/or pipework being warmed to Legionella-friendly levels by solar gain, especially in summer months. 

The third element needed for Legionella proliferation is a nutrient source, which may be provided by sediment, sludge, ferrous corrosion particles and biofilms. Flushing routines will help to prevent the accumulation of these potential problems in pipework, but you will also need to have cold water tanks inspected and cleaned to remove these, and any vermin which may have entered them. In the case of corrosion, the water tank may need to be replaced.

Minimising disruption

We understand that the routine of the care home adds to the comfort and safety of its residents, so we endeavour to work with care home managers to ensure that we explain everything that we will do, how the process will work, and how we can minimise the effect of our work on your residents.

As an overview, there are a number of steps which we follow that help us, and you, to plan ahead and ensure that we can work around your routines to minimise any inconvenience or risk to your residents. We operate on a completely transparent basis so that you understand exactly what is involved at each stage.

This is the step-by-step process:

1. The Service Delivery Coordinator books in the work and time, completes a Risk Assessment and Method Statement (RAMS), makes sure our technicians have a current DBS check and explains and checks any pre-visit requirements.
2. A Risk Assessment determines any possible mishaps, their likelihood and consequences, and the tolerances for such hazards. At this stage, a generic risk assessment is carried out – your site-specific risk assessment will be carried out by our surveyor once on-site.
3. A Method Statement is a part of a workplace safety plan. It gives specific instructions on how to safely perform a work-related task or operate a piece of plant or equipment. Our teams follow carefully devised Method Statements for each piece of equipment.
4. The RAMS are sent to the Care Home Manager before our surveyor arrives on site.
5. When the Surveyor arrives, they will show their company identification, sign in and make contact with the Care Home Manager.
6. Our surveyor will fill out their permit to work.
7. The surveyor will complete a thorough site-specific risk assessment using their smart phone.
8. The surveyor will discuss with the Care Home Manager whether there are any issues within the water system that they need to be aware of.
9. Our surveyor should be given access cards/boiler room key or be escorted by a member of your staff.
10. Once in the boiler room, the hot water cylinder will be checked for the correct temperature and that there are no visible non-conformances.
11. Moving around the building, the surveyor will check the water temperature at sentinel points. (These are the nearest and furthest points away from the boiler.)
12. If this involves accessing residents’ rooms, this will only be carried out whilst accompanied by a member of your staff who can reassure your resident.
13. A representative number of temperatures will be taken (depending on the size of the property).
14. Results will be entered into our cloud-based reporting system (using the surveyor’s smart phone).
15. These are immediately sent to head office for Swiftclean quality/audit checks.
16. The surveyor may carry out shower head cleans and check thermostatic mixing valves (TMVs).
17. Once all the tasks are completed, the surveyor will tidy away any mess or equipment, lock any doors and return the keys to the care home manager.
18. At this final stage, the surveyor will discuss any non-conformances and recommendations.
19. The manager will sign these off digitally to show that they understand and accept them.

Team vetting to safeguard your service users

Security vetting is something that we take extremely seriously at Swiftclean. It’s a complex process but we feel it’s worth it to ensure that any vulnerable people with whom we come into contact with are protected and that we operate on site in the best way to safeguard residents.

Our checks are thorough and start even before a new employee has arrived at Swiftclean for their first day. Getting DBS clearance means having 5 years’ of employment history. We proactively check any references that a new starter has given us, whether with HMRC, a job centre or a previous employer.

We prefer to have enhanced DBS checks for all our technicians so our clients can rest assured that our people are reliable, and their residents are safe. As this enhanced check can take up to eight weeks, we start the process as soon as a new staff member is appointed, before they start working with us. 

We constantly review our security checking process to ensure we are as efficient and effective as possible at gaining security clearance. We are authorised signatories at a number of UK Airports so are well versed in passing up our staff to a high level. An important aspect of our security checking process is to make sure that when an engineer leaves our employment, their passes are returned and revoked.

Ongoing monitoring

Monitoring tasks can be carried out daily, weekly, fortnightly, monthly or annually. Sometimes, if there is a competent person on site, our surveyor will demonstrate the simpler monitoring tasks to them. Your competent person may prefer to carry out these tasks themselves, as this is a potential cost saving for the care home owner. More complex tasks can still be carried out by the surveyor. We can offer a flexible service.

Swiftclean also operates a training centre, offering Legionella awareness training courses designed for those who are responsible for the day-to-day management of Legionella control, as well as for maintaining on-site logbooks. This may not be the appointed ‘Responsible Person or Duty Holder’, however, but they may have an involvement in facilitating the control of Legionella bacteria within the premises. We also offer the Highfield level 3 Award in Legionella Control for Responsible Persons course, which is sometimes held online, so you can train without leaving the office, or remotely from home.

In all our Legionella prevention services, our aim is to work with the care home manager to ensure the comfort and safety of the residents as well as the safety and compliance of the care home.

You will find more information about Legionella control in our dedicated Legionella website pages.