LEGIONELLA - World Health Organization
LEGIONELLA - World Health Organization LEGIONELLA - World Health Organization
10.4 Designing regulations Basic principles need to be observed when developing new regulations. There needs to be an overall aim, which in this case is to reduce the risk and incidence of legionellosis. The aim is achieved by applying a set of specific requirements, each of which should have a specific and stated purpose. Compliance with requirements should be measurable and (where appropriate) enforceable. Monitoring regimes should be defined, and corrective action to remediate noncompliance should be described. Specific health-based targets might be established for the incidence of illness or outbreaks. Such targets can be useful in undertaking cost–benefit analyses as part of a regulatory impact assessment. If Legionella testing is included in requirements, target concentrations and responses to detections should be specified. In some cases, there may need to be a balance between different regulatory requirements. For example, in the case of water distribution systems, avoiding temperatures between 25 °C and 50 °C will reduce the risk from Legionella; however, regulations designed to reduce the risk of scalding can require that hot-water temperatures be kept below 50 °C or even below 45 °C. This can be achieved by lowering water temperatures throughout distribution systems or by installing thermostatic mixing valves close to the point of water use. In either case, greater levels of maintenance will be required to compensate for loss of temperature-based control of Legionella. 10.4.1 Managerial responsibilities, registration and notification Regulations should identify managerial responsibilities associated with systems, and should include requirements for the training and competence of operators. Requirements could also be included for registration of devices with regulatory authorities. Consideration should be given to notification requirements in the event of serious non-compliance. 10.4.2 System assessment and design System assessment should include inspections of buildings and surrounding areas to identify potential sources of Legionella and to evaluate the risk associated with devices, taking into account design, location and operating conditions. A risk assessment could include consideration of: • the potential for conditions that could favour the survival or growth of Legionella • the potential for production and dissemination of aerosols • design features, such as deadlegs, the position of air intakes or cooling tower exhausts, and the presence of drift eliminators in cooling towers • control measures to minimize risks (e.g. automated biocide dosing, flushing, cleaning and general maintenance) LEGIONELLA AND THE PREVENTION OF LEGIONELLOSIS
• operating conditions, such as temperature ranges in water distribution systems, and whether devices are operated continuously or intermittently • the location of devices in relation to exposure of vulnerable groups. The risk assessment should determine whether existing control measures are sufficient and operate effectively. If they are not sufficient, additional measures should be identified. Guidance on appropriate control measures can be provided in codes of practice referenced within regulations. In addition, regulations can identify specific control measures to be applied, such as: • application of temperature controls for water distribution systems • use of biocide dosing as part of an ongoing water management programme • regular flushing of water systems • frequencies of cleaning and inspection • use of drift eliminators on cooling towers. A number of design features can influence the growth and dissemination of Legionella; for example, reducing the occurrence of circulating water temperatures between 25 °C and 50 °C, minimizing stagnant water, installing biocide dosing systems and installing drift eliminators on cooling towers. Cooling towers should be located so that outlets are not close to air intakes or windows of adjacent buildings. Consideration of such features is fairly straightforward when designing new systems, but can present difficulties when dealing with existing systems. The inclusion of design requirements within regulations should be considered. Some existing regulations deal with design, and others do not. 10.4.3 Operational monitoring and verification Operational monitoring procedures need to be identified for each control measure. Operational monitoring can take the form of testing for defined parameters and inspection programmes. Regulations should include the requirement to institute operational monitoring systems. Operational monitoring requirements regarded as essential could be defined (e.g. the frequency of testing or inspection of cooling towers or water distribution systems). Further guidance on the design and implementation of operational monitoring could be provided in codes of practice and referenced within regulations. In addition to operational monitoring of individual components and control measures, verification procedures need to be identified. Verification provides reassurance that WSPs as a whole are operating effectively. The process can be undertaken by owner, operators or regulatory authorities, and regulations should specify who is responsible. Verification can include testing for Legionella. LEGIONELLA AND THE PREVENTION OF LEGIONELLOSIS
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• operating conditions, such as temperature ranges in water distribution systems, and whether<br />
devices are operated continuously or intermittently<br />
• the location of devices in relation to exposure of vulnerable groups.<br />
The risk assessment should determine whether existing control measures are sufficient and<br />
operate effectively. If they are not sufficient, additional measures should be identified. Guidance<br />
on appropriate control measures can be provided in codes of practice referenced within<br />
regulations. In addition, regulations can identify specific control measures to be applied, such as:<br />
• application of temperature controls for water distribution systems<br />
• use of biocide dosing as part of an ongoing water management programme<br />
• regular flushing of water systems<br />
• frequencies of cleaning and inspection<br />
• use of drift eliminators on cooling towers.<br />
A number of design features can influence the growth and dissemination of Legionella; for<br />
example, reducing the occurrence of circulating water temperatures between 25 °C and 50 °C,<br />
minimizing stagnant water, installing biocide dosing systems and installing drift eliminators<br />
on cooling towers. Cooling towers should be located so that outlets are not close to air intakes<br />
or windows of adjacent buildings. Consideration of such features is fairly straightforward<br />
when designing new systems, but can present difficulties when dealing with existing systems.<br />
The inclusion of design requirements within regulations should be considered. Some existing<br />
regulations deal with design, and others do not.<br />
10.4.3 Operational monitoring and verification<br />
Operational monitoring procedures need to be identified for each control measure. Operational<br />
monitoring can take the form of testing for defined parameters and inspection programmes.<br />
Regulations should include the requirement to institute operational monitoring systems.<br />
Operational monitoring requirements regarded as essential could be defined (e.g. the frequency<br />
of testing or inspection of cooling towers or water distribution systems). Further guidance on<br />
the design and implementation of operational monitoring could be provided in codes of<br />
practice and referenced within regulations.<br />
In addition to operational monitoring of individual components and control measures, verification<br />
procedures need to be identified. Verification provides reassurance that WSPs as a whole are<br />
operating effectively. The process can be undertaken by owner, operators or regulatory authorities,<br />
and regulations should specify who is responsible. Verification can include testing for Legionella.<br />
<strong>LEGIONELLA</strong> AND THE PREVENTION OF LEGIONELLOSIS