Water safety plans
A WSP should be a proactive strategic plan that defines and documents the processes required for safe use and management of all water systems (e.g. management of nosocomial infection, management of legionella in water systems, legionella management). It should also be bespoke to any given system in order to accommodate the different types of complexities of water systems (e.g. legionella in domestic water systems, legionnaire's disease in water systems) and related equipment and to take into account the size and type of business or organisation, This is applicable to all organisations, not just to healthcare.
WSPsneed to take account of all potential hazards, including those of a biological(and microbiological), chemical, physical and radiological nature. Riskassessments should be performed to identify physical hazards, such as scaldingand where users may be more susceptible to certain infections. Legionella riskassessments and legionnaires risk assessments should also be performed whennecessary.
It is reallyimportant that the WSP is not a large, unwieldy document, but a high-levelstrategic plan that sets out the way the organisation manages all risks fromwater and meets all applicable legislation, guidance and standards. Thecomplexity of this will vary according to the complexity of the site, butshould, nevertheless, be a ‘living’ document that can be easily managed. Itshould clearly define the legal responsibilities for water safety and theprocesses for ensuring all stakeholders are aware of their individualresponsibilities for controlling any potential risks to health derived fromwater on site.
TheWSP should also include processes for ensuring all those involved havesufficient information, instruction and training to understand the impact ofboth good and poor design, build, commissioning, operation and management onwater system safety, which is specific to the type and range of systems andequipment to be incorporated in the building. The roles, accountabilities andresponsibilities should be clear in cross-functional/departmental projects andprocesses. Further detail should identify processes to ensure safe design,installation, commissioning, operation, management and maintenance. Inaddition, supporting programmes should be in place for staff training andcompetence, surveillance, supervision, audit, records, communication, continualreview etc.
Water safety groups
In order to develop a comprehensive WSP a water safety group (WSG) needs to be created with responsibility for developing and implementing the WSP.
Ideally theWSG should comprise a multidisciplinary group of people with the skills andresponsibility for ensuring that the water is safe at the point of use for alluses and all users of water within the building(s) identified in the WSP. For asmall site, this could comprise the Health and Safety representative, theperson responsible for water maintenance and/or cleaning and a member of staffthat uses water, for example.
For largersites, the lines of accountability and communication up to top level managementby the WSG should be clear and enable regular reporting and review of waterrisk management. The WSG remit, allocation of responsibilities and reportingstructure should be agreed with the duty holder, and the WSG members should:
- be empowered to manage water safety throughout the whole lifecycle
- have the range of skills and competencies needed to manage water safety under a variety of operating conditions; and
- have the resources necessary to carry out their role effectively. Where the necessary skills and competencies are not available in house, external specialist advisers, contractors and service providers should be considered following careful competency review by the WSG
TheWSG should ensure there is an initial high-level assessment of what is alreadyin place to identify any gaps in the existing water safety governance andmanagement measures, and any need for amendment or development i.e. a gapanalysis. For premises that have good management of Legionella risks, accordingto the 'Approved Code of Practice' (ACoP) and associated guidance for'Legionnaires' disease - the control of Legionella bacteria in water systems',3a lot of the microbiological components of the WSP should already be in placeas Legionella control measures include many elements of good water hygienemaintenance. The gap analysis should, however, also identify potential risksfrom scalding, slips/trips, falls, drowning, electrocution, pressurised watersystems etc. and an assessment of the current management of all water includingwells, ponds, engineered water systems and any associated equipment.
BS 8680:2020
BS 8680:2020‘Water quality — Water safety plans — Code of practice’ has a vast amount ofuseful detail about how to set up WSGs and WSPs, with charts and checkliststhat can assist in both setting up a new WSG and WSP, but also to aid existingones (infographic available ). The standard was developed specifically with keydesign considerations and contains a number of useful annexes:
Annex Aprovides an example framework for allocating many of the activities todifferent members of a project or building management team with reference tothe relevant clauses of this standard and is intended to be used as anaide-memoire for activities and development of a WSP.
Annex C (Design, specification andcommissioning) requires that all water systems, attached equipment, fittings,components and equipment should be specified and designed so that they do notintroduce inherent risks, i.e. allow introduction or increase hazards to levelsthat can cause harm to those exposed. They should be as easily accessible aspossible and with sufficient space for cleaning and maintenance. For a newbuilding, upgrade or refurbishment of an existing water system, each step fromthe concept and design stage of the project, through to full occupation andnormal operation of all water systems, should be fully risk assessed to ensureall potential risks of harm arising from all water on site are controlled andminimised at each stage of the project (e.g. avoiding legionella in domesticwater systems, sprinkler systems or pseudomonas in water systems). Therefore,at completion and handover, each system should have been designed, specified,constructed, installed, commissioned and operated to minimise risks from allpotential hazards and hazardous events.
This annex covers specific detail for the following:
- Source water quality
- Responsibilities and training
- Ground contamination
- Design
- Alterations and refurbishments
- Risk factors to be considered at the design stage such as temperature and nutrient ingress
- Materials and fittings
- Healthcare design and specification considerations
- Specification
- Project risk assessments
- Construction and installation
- Commissioning
- Handover
Annex D contains an example of a WSP checklist for new builds.
Some projects may require the appointment of a new multidisciplinary WSG with the skills and competency required to review and approve the design brief.
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