Alex Sammut - ISAC UK Ltd

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Wednesday 20th May 2015

Latest Comments

Total Number of Property118 Comments: 4

Alex Sammut - ISAC UK Ltd

14:55 PM, 6th July 2015, About 7 years ago

Legionella scaremongering by some letting agents debunked

Reply to the comment left by "Scott 44 " at "01/07/2015 - 18:34":

Hi Scott44, Just to confirm,

"Aqua b are carrying out the risk assessments in line with the legislation to ensure that agents, and landlords, are compliant"

Is that by simply completing a risk assessment for a property or is that by actually offering a set of recommendations for any improvements on the existing system followed up by a written scheme of control?

I wouldn't want you, and others, to think that by simply getting the risk assessment 'done' then that is the job done. Compliance will be a process of maintaining the quality of the water in the system and also the existing control measures throughout time.

I'm sure that this is part of Aqua B's package and/or that you are aware of this already but I thought that I would just mention it just in case. Thanks
Alex... Read More

Alex Sammut - ISAC UK Ltd

13:58 PM, 6th July 2015, About 7 years ago

Legionella scaremongering by some letting agents debunked

Reply to the comment left by "John Walker" at "02/07/2015 - 13:01":

John, Are your saying that your hot water system does not:

Produce water that could sit in the temperature range of 20-45 degrees
Produce any aerosol at all as you have no physical outlets i.e. taps, showers etc
Or potentially have higher risk groups exposed to such aerosols?

If that is the case then you are probably correct. However, the likelihood is your system, regardless of how it heats the water has all three of these elements and thus a risk assessment should be carried out that is suitable and sufficient.

Ultimately the risk may be low (if you have a combi boiler for instance) but there is still a requirement to have suitable controls measures and a written scheme (no matter how basic) for each of your properties.... Read More

Alex Sammut - ISAC UK Ltd

10:17 AM, 21st May 2015, About 7 years ago

Legionella scaremongering by some letting agents debunked

Reply to the comment left by "Badger " at "20/05/2015 - 14:55":

Hi Badger, apologies for the delay in replying to your question.

The biggest case of Legionnaires disease (and deaths) due to an inadequately managed domestic hot and cold water system that I can offer you is that of Basildon Hospital in recent years.

Although set in a hospital environment it was in fact the lack of cleaning and control of their Showerheads and Thermostatic Mixer Valves (TMVs), as well as their stored water in their domestic pipework that ultimately housed the significant amount of Legionella bacteria that the victims inhaled when outlets were used. If you google it the guardian has a reasonable article about all of their failings.

This is not the only big case to make the media. At around the same time Basildon were being fined for this there was an outbreak in a hospital in Brisbane, Australia, due to exactly the same reasons.

Whilst people reading this may highlight the fact that it is in a hospital environment rather than a residential house, with indeed generally higher susceptible groups, the fact remains that all of the key factors could be present within a domestic residential setting too and thus any risk assessment should consider these variables on your properties. Consider this:

1) Is it foreseeable that you have shower heads and TMV's in a house? YES
2) Is it foreseeable that you could present correct temperatures and food supplies in a house as in the hospital cases quoted? YES
4) Is it foreseeable that a rented house will have void periods and/or outlets that don't get used often allowing for stagnation of water? YES
5) Is it foreseeable that you could have vulnerable groups of people renting your properties? YES
6) Is it foreseeable that these vulnerable groups of people will be exposed to an aerosol when using said showerheads and outlets in the property? YES

Whilst residential households typically present very low risks in general, due to the daily use and throughput of water all of the above must be adequately considered and controlled. In a house this will typically not require extensive controls or cost but merely a sensible approach.

In addition, I've heard a lot of people in the letting industry say that there have never been any cases attributed to domestic residential properties. The fact of the matter is that we have never looked for it specifically there and often put it down to another cause, such as travel or community acquired.

The Pubic Health England (PHE) have started quoting an annual figure of between 10-12% of all domestic properties that they test have a positive count for Legionella Bacteria in.
In addition, I recently read a research paper from Ohio, USA, that focused on patients coming into the local hospitals with Legionnaires disease. The research team managed to get a percentage of them to agree that they could test for Legionella bacteria in their domestic properties and figure of around 25% of the properties tested came back with a positive count of Legionella Bacteria.

Hope that this answers your question. Kind Regards Alex... Read More

Alex Sammut - ISAC UK Ltd

11:49 AM, 20th May 2015, About 7 years ago

Legionella scaremongering by some letting agents debunked

Hi, As a Health and Safety Trainer (and director) for a company that have run professional training courses in industry on the subject of Legionella for over 17yrs we have recently designed and run specific one-day courses in Legionella for landlords and letting agents and have done so for the past 13mths. (7mths of which in conjunction with the RLA)

I have read an number of these articles/blogs and whilst I completely concur with the majority of comments that I have read I thought that I would offer my two pennies worth to try and clear up a number of misinterpretations.

1) There appears to be a lot of misuse of the term 'certificate' with regards to this subject in the Letting industry. I can only deduce that this has come people assuming that as the landlord is required to get a 'Gas safety certificate' that the same must be true for Legionella. This is NOT the case.

The term 'certificate' with respect to Legionella Management means something completely different and is actually talking about water analysis and sampling of water from systems. This is something that we explain in detail to landlords and explain why in the majority of cases (99%) is completely irrelevant for residential properties.

Unfortunately, letting agents and indeed now legionella risk assessment companies are scaremongering by suggesting (or misunderstanding?) that this is needed and is often offered initially as a 'free service' included in the price of the risk assessment.

An 'in' if you like for potentially unnecessary repeat, chargeable, business/sampling.

As a landlord, you are required to have a completed Legionella RISK ASSESSMENT for your residential property. This can come in many formats, depending on the person/company that is completing it. There is NO set format or 'certificate' at the end and can take the form of a report.
Following the completion of the risk assessment there should be what is called a 'Written Scheme of Control' produced, which will be a simple management plan for keeping that water system safe and low risk for its users. The scheme should indeed talk about cleaning and flushing of outlets and shower heads and depending on how you set the plan up may or may not involve other people (such as tenants and managing agents) to fulfil some of the roles included. Consideration to the competence and training/advice that may be required should also be thought about. In other words, simple things such as not telling someone to clean a scaled up showerhead with disinfectant before they have actually scrubbed off the scale! (Legionella bacteria can live in the scale and so if the scale is not scrubbed off will be protected from the disinfectant!)

Who can carry out the risk assessment is determinable by the level of competence that person has in the subject, and indeed in the subject of risk assessment itself. They will need to be able to reasonably foresee both normal and abnormal situations with the water system in the property and with the users themselves. In addition, they will need to be able to recommend suitable and sufficient control measures that are reasonably practicable (including in terms of cost).

2) With respect to whether or not it is a legal requirement in the first place, confusion appears to reign again in the residential letting industry. To clear this up, consider it this way -

Landlords are now explicitly included (as of April 2014) in an industrial Technical Guidance Document called HSG 274 Part 2 (freely downloadable on the HSE website). This document alone is NOT law. However, the document is produced to aid people to actually comply with the law, in the form of an Approved Code of Practice called - L8. An Approved Code of Practice has a special legal status as an individual must be able to prove that they have done something 'equal to or better than' what is being asked. For the residential letting Industry, there is currently no document out there that shows how you can be equal to or better than the current code of practice and thus should be taken as LAW.

In addition, the Approved Code of Practice come directly from the CoSHH Regulations that are indeed a legal requirement themselves and and the CoSHH Regulations ultimately fall underneath the Health and Safety at Work Act 1974 which is definitively law.

Simplistically, this has been a legal requirement ever since 1975 when the Health and Safety at Work Act came out, especially under regulations such as No. 4 which focuses on duties to individuals in premises other than employees. In other words, as a landlord is providing a 'service' by offering a property for money the landlord should be meeting the requirements within this section.

In addition, civilly, a claimant can also use ANY statute law in their case to help prove the balance of probability in proving their loss. So even, if after reading this explanation you still believe that this is not a requirement by law please be advised that a tenant that puts in a claim against a case of ill health resulting from the water supply in the rented property can indeed use these regulations that I have stated above as part of their case. Given that there has been a huge amount of past history with cases of Legionnaires disease from hot and cold domestic systems in industry it shouldn't be too hard for a tenant to prove that the cause was the domestic property if they can also back this up with a water sample taken from the system itself and it was found to have the same strain of the Legionella bacteria in....

...and so in a weird way I have managed to come full circle with my response!?

If anyone out there would like further information, or has further questions, please don't hesitate to reply and I will try my best to answer honestly and truthfully, rather than being one of those scaremongers out there!!! Kind regards Alex :)... Read More