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A water hygiene risk assessment is a structured review of a premises’ water systems, how they are managed and any risks that may need to be controlled. For businesses and other organisations responsible for non-domestic premises, it is an important part of understanding how water systems are being managed and where improvements may be needed.
This guide looks at the responsibilities surrounding water hygiene risk management, when assessments may need to be reviewed and what businesses should do with the findings. To speak directly to an expert or book your water hygiene risk assessment, call us now on 0800 358 1100.
The purpose of a water hygiene risk assessment is to identify risks within a water system and establish whether the controls already in place are suitable.
That involves looking at how the system operates, who could be exposed to risk and whether current management arrangements are working as intended. If there are gaps, the assessment should make clear where further action is needed.
For Legionella, employers and people in control of premises have duties to assess and manage the risk of exposure. The Control of Substances Hazardous to Health Regulations 2002 provide the legal framework for controlling exposure to hazardous substances, including Legionella bacteria. The Approved Code of Practice L8 and Health and Safety Executive guidance HSG274 provide further guidance on how those duties should be managed in practice.
A risk assessment should form part of ongoing water hygiene management. It should not simply be completed, filed away and forgotten.
Responsibility generally sits with the employer or the person who has control of the premises or water system. This person or team is described in legislation and guidance as the ‘dutyholder’. Depending on the building, this could include a business owner, landlord, facilities manager, property manager or estates team.
The same principles can apply across offices, industrial premises, schools, healthcare settings, hotels, leisure facilities, retail sites and managed residential properties.
For Legionella management, the dutyholder may appoint a competent person to oversee the day-to-day controls. An external water hygiene consultant can also carry out or support the assessment where the necessary knowledge or experience is not available in-house.
Using an external consultant does not transfer the organisation’s overall responsibility. The dutyholder still needs to make sure that the risks are properly assessed and managed.
There is no single answer that applies to every building or water system.
Employers and people responsible for non-domestic premises have duties to assess and manage relevant health risks. Where a water system could create a risk of exposure to Legionella, that risk must be assessed and suitable controls put in place.
A new assessment, or a review of an existing one, may be needed when responsibility for a site changes, the water system is altered or extended, or the way the building is used changes significantly.
Alterations in occupancy, management arrangements or the effectiveness of existing controls can also make a review necessary. The assessment needs to reflect the building and water system as they are being used now, rather than how they operated several years ago.
A good assessment should give the dutyholder a clear picture of the water system and the risks that need managing.
It should identify relevant hazards, consider who could be affected and review the controls already in place. Where something is missing or could be improved, the assessment should set out sensible, proportionate actions.
The aim is to provide enough information for those responsible for the premises to make informed decisions about ongoing water hygiene management.
Problems within water systems can develop for many reasons. Some relate to the way the system was designed, while others arise because a building or its use has changed over time.
Typical concerns can include stagnant water, little-used outlets, poor temperature control, badly managed water storage, scale and corrosion. Redundant pipework, design issues and gaps in monitoring or record-keeping can also affect how well risks are being controlled.
Some of these conditions are particularly relevant to Legionella. Stored or recirculated water, suitable temperatures and the presence of scale, sludge, rust or biofilm can all create conditions in which Legionella may grow.
Finding an issue is only part of the process. The next step is understanding how significant it is and what should be done about it.
The terms are closely connected, but they should not automatically be treated as two completely separate types of assessment.
Legionella is one of the main risks associated with the management of water systems in non-domestic premises. A Legionella risk assessment looks specifically at the risk of exposure to Legionella bacteria and the measures needed to control that risk.
Water hygiene is a broader term. It can also cover the general condition, operation and management of water systems, as well as issues that could affect water quality or undermine existing controls.
What needs to be assessed will depend on the premises and the water systems involved. The scope matters more than the label attached to the assessment.
There is no universal review period that applies to every site.
For Legionella risk assessments, Health and Safety Executive guidance states that assessments should be reviewed regularly and when there is reason to believe they are no longer valid. It does not set a single fixed annual or biennial interval for every premises.
A review may be needed after changes to the water system, building use, occupancy or management arrangements. It may also be appropriate if monitoring or inspection results suggest that existing controls are no longer working effectively.
The right review frequency depends on the site, the system and whether anything has changed that could affect the original assessment.
Having the right information available can help a consultant understand the water system and how it is currently managed.
Useful documents may include water system schematics, asset information, previous risk assessments, monitoring records and maintenance information. Details of recent alterations to the system, changes in occupancy or changes in the way the building is used can also be helpful.
Access to relevant plant rooms, storage areas and other parts of the water system should be considered when arranging the assessment.
Incomplete records should not stop a business from seeking competent advice. In some cases, missing information may itself highlight an area where management needs to improve.
Any findings should be reviewed and dealt with according to the level of risk. Some issues may be addressed through changes to monitoring or management arrangements. Others may require further investigation, sampling, cleaning and disinfection or remedial work.
Where Legionella risks are identified and need ongoing control, a written control scheme may be required to set out how those risks will be managed. This is a separate service from the risk assessment itself.
Our wider water hygiene services can support businesses where further monitoring, sampling, clean and disinfection work or other specialist assistance is required.
A common problem is treating the assessment as a one-off exercise rather than part of an ongoing management process.
Responsibilities can also become unclear, particularly where several people or contractors are involved. Records may not be kept up to date, reviews can be missed after changes to a building and recommendations can remain unresolved long after they have been raised.
An assessment is only useful if its findings are understood and acted upon. Responsibilities need to be clear and the controls put in place need to be monitored over time.
Some organisations have the knowledge and experience in-house to manage straightforward water hygiene risks. Others need specialist support.
Professional advice can be particularly useful where water systems are complex, the premises are large or the people using the building may be at greater risk. It can also help where internal teams do not have the experience or resources needed to assess the system confidently. A competent consultant can provide a site-specific view of the risks and help the dutyholder understand which actions should take priority.
At EMS Water, we work with organisations across Great Britain to assess water systems and provide clear, practical recommendations. Our advice is based on the individual site and its water systems rather than an off-the-shelf approach.
If you need professional support assessing the water systems within your premises, our water risk assessment services can help.
Contact our team to discuss your premises and arrange an assessment tailored to your water systems and requirements.
Employers and people in control of premises have legal duties to assess and manage relevant health risks. Where a water system creates a foreseeable risk of exposure to Legionella, this includes assessing that risk and putting suitable controls in place in line with applicable legislation and Health and Safety Executive guidance.
Responsibility usually sits with the employer or person in control of the premises or water system; the dutyholder. A competent employee or external consultant can carry out the assessment, but the dutyholder remains responsible for making sure the risks are properly managed.
There is no fixed review interval that applies to every site. The assessment should be reviewed when there is reason to believe it may no longer be valid, including after significant changes to the water system, building use, occupancy or management arrangements.
A Legionella risk assessment focuses specifically on the risk of exposure to Legionella bacteria. Water hygiene is a broader term that can also cover the condition and management of the water system more generally, although the scope of the two can overlap.
Useful information can include water system schematics, previous assessments, monitoring records, maintenance information and details of any recent changes to the system or premises. If some of this information is unavailable, the assessment can still go ahead.
The findings should be reviewed and any necessary actions prioritised according to risk. This could involve changes to monitoring or management controls, further investigation or sampling, or appropriate cleaning, disinfection or remedial work.
