Updates to BS 8580 – Are your Legionella risk assessments and risk assessors up to scratch?
The risks from Legionnaires’ disease are going nowhere. With 532 cases confirmed by the HSE in 2018, the need to manage the risk from your artificial water systems remains as great as ever.
Earlier in 2019, the British Standards Institution (BSI) published a significant revision of their guidance on risk assessments BS 8580-1:2019 Water quality – Risk assessments for Legionella control – Code of practice.
First published in 2010, the document provides guidance to duty holders, responsible persons, competent persons and risk assessors on the assessment of risk from man-made water systems, ensuring a suitable and sufficient risk assessment is undertaken.
Why the new version?
The 2019 version of BS 8580 was long overdue. In 2013/14, the HSE published a revised ACoP L8 and updated Technical Documents, HSG274, with new guidance for Spa Pools HSG282 published in 2017 and an updated HTM04-01 issued in 2016.
The publication of BS 8580:2019 comes shortly after the first million pound fines for deaths from Legionnaires’ disease. With the control of Legionella one of the hottest topics for the HSE, the need for duty holders to receive and be provided with a risk assessment that is suitable and sufficient is still as important now as ever.
What are the key changes?
The document takes on and aligns with the information provided in L8 as part of a general update but there are a number of key changes:
1. Competence of the risk assessor
Section 5.1 stresses that the competence of the risk assessor is of ‘paramount importance and should match the complexity of the systems being assessed’. A risk assessor should be able to demonstrate sufficient experience, specialist knowledge and understanding of risk and control measures to provide a suitable and sufficient risk assessment. Risk assessors are also expected to be independent and have no commercial, financial or other pressures that could compromise their integrity and the risk assessment findings.
Section 7 also states that a risk assessor can decline to undertake or issue a report if insufficient information has been provided to assess risk successfully; reports can be issued in draft if needed. It is the responsibility of the duty holder to check the competence and independence of the risk assessor and ensure that all information available and access is provided to all water systems to allow the risk assessment to be completed.
2. Evaluation of risk
Evaluation of risk and risk scoring is often a point of discussion between risk assessors and clients. In section 8, risk assessors must assess if the residual risk is as low as reasonably practicable (ALARP). Control measures that have been put in place must be regularly reviewed to ensure they are not ‘grossly disproportionate’ and unjustified. BS 8580 now states that risk assessments should, rather than may, contain a risk rating system which needs to be clear and easy for the reader to understand with a clear explanation provided.
3. Risk assessment reporting
Risk assessment reporting (section 9) has been re-written to further emphasise that risk assessments must be clear, easy to read, free from superfluous information and focus on the systems that have been assessed. BS 8580 states that remedial actions should be high priority, where management roles of the systems being assessed are not being fulfilled.
The preparation of a written scheme is not part of the risk assessing process. BS 8580 outlines that a risk assessor must confirm the presence and relevance of the written scheme in place and make recommendations for improvement but the risk assessment should not include a written scheme. If a client requires one, it should be commissioned separately.
4. Risk review and re-assessment
In section 10, risk review and assessment has been made clearer outlining that a policy of planned reassessments must be in place – this is in addition to setting a time when a risk assessment must be formally reassessed. Reassessments must be a new report, and not simply an adaptation of previous reports.
5. Updates to the Annexes (including cooling towers and spa pools)
Finally, the Annexes have been revised and updated to reflect content in HSG274 and HTM04-01. There is more detailed and clearer guidance within Annexe B for Hot & Cold Water Systems, whereas Annexe C for Open Evaporative Cooling Systems and Annex D for Spa Pools have been completely re-written.
In each of these annexes, the competence of the risk assessor is stressed as fundamental to the risk assessing process. Annexe E on Other Systems is more detailed and contains new information on humidifiers and thermal processing in the food industry.
Expected future revisions
BS 8580 has been renamed to BS 8580-1, why is this? There is a plan to provide a British Standard for Pseudomonas aeruginosa risk assessments, undertaken in high risk healthcare environments, and this is expected to be named BS 8580-2.
SOCOTEC has many years’ experience working in Legionella management and control, as well as water hygiene and can offer all the solutions you need. We are a leading provider of Legionella and Water Hygiene consultancy; our Legionella risk assessments are UKAS accredited to ISO 17020 since 2015, providing reassurance that our work is traceable, impartial and independent. Our risk assessors undergo an extensive training and auditing process that includes external independent audits by UKAS and re-inspections.