The need to know about legionella
The approved code of practice relating to Legionnaires’ Disease is quite specific about the need for training. Andrew Steel of Airmec looks at how much and what kind of training is appropriate.
Remember US Defense Secretary Donald Rumsfeld with his 2002 speech about known knowns, known unknowns and unknown unknowns? It’s hard to believe that didn’t start out as a PowerPoint presentation that didn’t translate into the spoken word too well, but we all know the feeling. No matter how high up the chain of command or management you are, you need to know what you are dealing with so that you can manage the risk effectively.
When it comes to the duty to minimise the risks associated with legionella bacteria, there is also a de facto legal requirement to have a training programme that ensures that people in managing and supervising roles really understand those risks and the best way to manage them, not just the operatives undertaking inspection and flushing tasks.
Everyone is likely to have heard of the approved code of practice ‘ACOP L8: Legionnaires' Disease. The control of legionella bacteria in water systems’ — but how many have really read it cover to cover? It is quite specific about the need for training, so the next question is who needs to be trained and how?
The ACOP requires that duty holders must ensure that competent persons and other operatives are knowledgeable and trained. Just to remind you of who these people are, under general health-and safety-law, an employer or person in control of a premises (e.g. a landlord) needs to take suitable precautions to prevent or control the risk of exposure to legionella.
To do that, they typically appoint a competent person, either a member of staff or an external organisation like mine, to undertake as little or as much of the work involved as is appropriate.
Sometimes a turnkey outsourced solution is chosen (but, remember, a duty holder still carries the can — you can never delegate away your ultimate responsibility).
Other firms or establishments contract consultants to update asset registers, undertake risk assessments and scheduled inspections such as tanks and filters, and to set up robust auditing systems. They then deploy their own staff for routine tasks like tap flushing.
Clearly there are different levels of training required, and a decision needs to be made on how much, or how little, to invest in training.
Most training organisations will offer different levels of knowledge aimed at competent persons (including duty holders) and operational staff. Does the duty holder really need to go into such detail? For the sake of a one-day course, I’d say yes, not least because that will help them to find the right plan of action and division of labour. It also enables them to support and judge the recommendations of the competent person, and their budget calls.
How long should training take? A whole day? That could sound like a big ask of your time when you can buy an online course with a few multiple choice questions at the end for £35. But you might end up as confused as the hapless Donald Rumsfeld.
To my mind, there is no substitute for face-to-face interactive training and discussion.
Online courses that I have ‘road tested’ do little more than re-iterate the ACOP and associated guidance, all of which you can download for free and read at your leisure.
Courses delivered on site can be tailored to your premises and the preventative work your team needs to deliver. Rather than ticking multiple choice boxes, there will be an opportunity to talk around the issues and resolve any confusion. It seems to me that anyone will get the right multiple-choice answer sooner or later, but until people really understand why they are being asked to do something, it will be hard to guarantee that they will always get it right.
Yes, it could be five or six times more expensive to have face-to-face training, but a well-trained team will perform well. Training is the best way to protect what might have been a significant investment in updating your asset and register, bringing your risk assessment up to date and works done to resolve existing issues.
One final word of caution: whichever route you choose, online or face to face, choose a provider that is a member of the Legionella Control Association. Look for legionella experts who can train, not trainers who may have jumped onto a lucrative bandwagon.
Andrew Steel is managing director of Airmec Ltd