From noroviruses to mould, GP practices can be a minefield of contagions and even the most rigorous health and safety arrangements can fall prey to what lurks beneath the surface. Legionella and asbestos can exist in the fabric of your surgery and both can silently attack the lungs and threaten the health of patients and staff if not correctly managed.
How do you ensure they don’t wreak havoc in your practice? “The key is continued risk assessments,” according to Phil Turner, director at 24hr Solutions, and this is also what the Care Quality Commission (CQC) expects – assessments conducted to identify risks and evidence that control measures are in place and regularly reviewed.
Living with legionella?
Understanding what legionella is, and how and where it thrives, is the first step to defeating this microscopic enemy. Present in many water sources in harmless numbers, the legionella bacterium becomes a danger when it multiplies and contaminated water is inhaled. This requires the ‘right’ environment – usually stored or re-circulated water (think tanks or air-conditioning systems) – where the water temperature is between 20 and 45°C and where water contains impurities.
In GP surgeries those most vulnerable to Legionnaires’ disease – patients with poor health, the elderly, smokers – can be exposed so, in the name of health and safety, and in accordance with CQC guidelines, practices are obliged to conduct assessments and manage, monitor and control risks.
Management survey: Locates and evaluates the condition of any ACMs that may be damaged or disturbed through normal occupancy or general maintenance work.
Refurbishment and demolition survey: A more intrusive survey conducted where refurbishment work or demolition will take place to identify if ACMs are a threat.
Annihilating asbestos
Asbestos, at one time heavily used in building materials, has a knack of remaining under the radar.“If in good condition, left undisturbed but regularly monitored, asbestos-containing materials (ACMs) pose little danger,” says David Grocott, managing director at ASI Environment.
By law you are required to manage asbestos and any commercial or public building constructed before 2000 must be surveyed. “Conducting a survey is part of that management, because it will tell you if and where you have asbestos,” David explains, while Phil advises the appointment of a company, or trained in-house health and safety manager, to ensure these risk assessments are completed, reviewed and recorded in up-to-date log books.
Leading with legislation
In a commercial property legislation makes the ‘duty holder’ responsible for risk management; this is usually the lease holder or landlord but may be the practice manager. To ensure you are meeting standards seek the advice of an accredited consultant.
“For asbestos ensure the consultant is UKAS accredited to undertake surveys and, for legionella risk assessments, Legionella Control Association (LCA) accreditation is recommended,” Mark Hildson, director at RSK, explains; he also advises that someone onsite receives appropriate and current training in both asbestos and legionella awareness and legislation.
For guidance, Mark recommends:
The HSE’s Approved Code of Practice (ACOP) which offers notes on asbestos and legionella regulations (free to download);
Information about asbestos can be found in Regulation 4 of guidance document L143, Managing and Working with Asbestos;
For legionella control refer to HSE guidance note L8: Legionnaires’ Disease – The Control of Legionella Bacteria in Water Systems.
CQC compliant
What does it require to be CQC compliant? “When considering legionella the focus will be on the cycle of usage, dead legs and temperatures,” Phil observes, and goes on to recommend, “Regular risk assessment by an accredited provider, monthly water temperature tests, assessment of pipe work against plans/dead legs etc., annual tank cleaning, HWS flushing and cleaning and water sampling.”
Asbestos, too, has a best practice approach and Mark reminds practice managers to be aware of the rules. “For properties built before 2000 an asbestos survey/risk assessment must be undertaken by a UKAS-accredited surveying body. Where ACMs are found to be present a management plan must be drawn up and an asbestos register made available onsite.”
What does it take to meet CQC standards? We asked; they answered
CQC health and safety expectations:
We’d expect to see effective systems in place to monitor health and safety risks for the public and staff. This means risk assessments, the main ones being: fire, legionella, asbestos (in premises built before 2000), the control of substances hazardous to health (COSHH), infection control and the general environment.
Frequency of risk assessment:
The frequency of risk assessment is an area of debate with no clear guidance from the health and safety executive. However, regular review is essential otherwise the provider will not be able to demonstrate effective health and safety monitoring.
Detecting legionella bacteria:
Health and social care providers should carry out a full risk assessment of their hot and cold water systems and ensure adequate measures are in place to control the risks. It is a complex area and should, therefore, be carried out by a competent person.
Asbestos in the practice:
We would suggest that practices seek advice from environmental services as asbestos can only be removed by a company with a Home Office licence. We don’t expect our staff to identify asbestos so, if discovered, we would expect to be informed and details of action taken shared.
Meeting CQC standards:
It starts with good governance. Providers need adequate systems and processes in place and good oversight of these systems to ensure health and safety risks are minimised.
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