Planning Legionella Risk Management
Yes, I know, there are a multitude of websites and businesses offering 'state of the art risk management plans' for Legionella control. This may be one of them - but on the other hand I can give you some free advice on what a risk management plan should look like.
Every good story has a beginning, a middle, and an end. This is true of movies, books and fairy tales. The idea is we are taken on a journey - and this is the essence of an effective Risk Management Plan - or Water Safety Plan.
So let's use a well known fairy tale to unpack the Risk Management Journey - Red Riding Hood!
The story begins with the characters - Red Riding Hood, Mother, Grandma, the Big Bad Wolf , and the Woodman - and also a forest and a cottage.
Let's re-name them: Mother as the owner/operator (O/A), Red Riding Hood is the Responsible Person (RP), Grandma is the client (C), and the Big Bad Wolf is Legionella (L or other waterborne infections!). The Woodman is the Consultant (SME).
Mother (O/A) tells Red Riding hood (RP) to go look after Grandma (Client C) and watch out for the Big Bad Wolf (L). Of course this now involves a deep dark forest (site plans, and maintenance records) and the cottage (Facility). It is clear that Grandma is under threat. In the end Red Riding Hood (RP) gets some help from the woodman (SME). We know how the story ends - good planning and a clear sense of purpose avoids the disaster.
This is the essence of a well managed and operated risk management plan. Once you know the story you can understand and control the beginning, the middle, and the end. So, using the Red Riding Hood Story we can work through the essential features of an effective Risk Management / Water Safety Plan.
The Beginning - Identify the Characters
Owner / Operator: It is up to you to nominate a responsible person. Within the legislation you can do that - but you retain ultimate accountability.
Responsible Person: You are responsible for delivering and maintaining the risk management plan. Responsibility for system design, operation and maintenance rests with you. You retain ultimate accountability.
Facility: Every facility is unique and requires a unique approach to managing it. It will usually have designated responsible people within it. They are liable to fulfill the requirements of their Facility Manager.
SME: Consultants can be very useful in developing an effective plan. They are liable for their actions within the terms of their contract. They are never the responsible person - rather a resource to implement the plan. They cannot legally accept liability.
Client: The core of your business and the ultimate legal responsibility of all concerned.
The Middle - Build the Story
From top down the Owner/Operator identifies a responsible person and provides resources to develop a plan.
The Responsible Person collects and collates data on the site and may nominate other responsible persons to assist. This may include the SME or others to assist in a full assessment of the facility. It is important to ensure that the assessment is conducted by those who can verify compliance.
Recommendations on compliance and remedial actions should follow on from this. From there an action list can be promulgated that fits into the ongoing organisational budget and controls the risk.
The End
All the data is combined into a relatively simple risk management plan. The plan tells each character what they need to do and how to do it. The plan includes monitoring, review, and sampling to ensure:
1) it is effective
2) it's current
3) it's active!
All the characters sleep peacefully. But the journey continues....
Epilogue
This is a simplified story of what should happen. If it isn't happening, or hasn't happened or doesn't look like happening - then I'm sorry to say - the wolf might eat Grandma!
A Risk Management Plan or Water Safety Plan in a folder on your shelf that you don't use is a waste of money, useless, and a liability.
