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Repurposing of buildings during the summer – is your flushing regime good enough?

During the long summer holidays, you may use your building in an alternative way than normal, for example, a university hall of residence might be used to house overseas visitors, or a rugby club or dance school might run kids’ clubs for a couple of weeks in the summer and spend more time empty than at capacity like usual.

But, you do need to be careful. Your water system must, by law, be managed in compliance with the Approved Code of Practice for the control of Legionella (ACOP L8), issued by the UK’s Health & Safety Executive. This also requires the appointment of a Responsible Person, who carries considerable legal responsibility.

Changing the use of your building, even for a few short months, can cause problems when it comes to your water system. Areas of the building may be used less frequently meaning that the water turnover is lower than it would usually be. This could lead to pockets of bacteria which could affect the wider system and potentially lead to an outbreak of the ‘flu-like’ illness caused by Legionella bacteria known as Legionnaires’ Disease.

As part of your water safety plan, you must have a robust flushing regime in place; this is the key to maintaining a safe water system when the system is used differently from the norm.

The flushing regime must be thoroughly detailed in the water safety plan to ensure that all the water in the system is turned over. If the flushing regime isn’t stringent enough, it is safer to clean and disinfect the whole system than risk an outbreak of Legionella.

It’s an easier task for the responsible person if a building is closed completely for the summer. Then your actions are clear – you must clean and disinfect the whole system before regular users return. This is not always realistic or practical though.

An example of what can happen when a building is repurposed can be evidenced by the following scenario:

It’s the summer holidays at a rugby club and their usual training teams have broken up for the summer months. As it’s the school holidays a kids’ club opens for a few days a week; and whereas normally the showers would be used by adults training regularly at the club, because of safeguarding, the kids may not use the showers therefore there is no turnover of water. When the teams return to train in their normal way, there is a far higher likelihood of someone becoming infected with the Legionella bacteria.

Added to this scenario, often the water coming into a building in the summer months has a higher temperature than usual. When this is the case, the only thing that a responsible person can do to control this is to regularly flush the system.

Remember the 4 key points of Legionella control:

  • Keep it hot
  • Keep it cold
  • Keep it moving
  • Avoid stagnation

With these four points in mind, you will go a long way to keeping your water system Legionella compliant.

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