What's wrong with Legionella Risk Management Plans?

Legionella risk management plans are a good idea - that is not up for debate. If you don't have a plan, it's time you got one if you're supplying water to vulnerable people (aged care, health care, etc). The plan is supposed to be a workable strategy to meet your compliance requirements and minimise the chance of anyone being exposed to 'nasties' in the water system. Also known as Water Safety Plans, or Water Safety Risk Management Plans they should extend beyond just Legionella to overall compliance and safety of the system.

So what's the problem?

The problem is extracting a workable strategy from the document you've been provided and converting it into the day to day operation. After some soul searching over several evolutions of risk management plans of my own, and reading multiple versions by others I came up with the list below. This list describes the most common Risk Management Plan failures currently in circulation.

Dust collectors - Lofty tomes that sit on shelves, never to be opened.

This is a danger with any manual. If it is not immediately understandable and clearly identifies who it applies to it will get shelved. We're all too busy to read the fine print - most of us will avoid reading manuals at all if we can get away with it! Putting it in a colourful folder with great artwork will not keep it from sitting on the shelf next to the photocopier manual. The document must be pitched to the person(s) who is going to use it.

Encyclopedia Britannica - More like an encyclopedia than a plan of action.

This is also tempting for the avid water safety geek - tell 'em ev'rything you know. A glossary of terms at the front probably means it is already missing the target. Realistically, to implement an effective risk managment plan you don't need to know everything. If the content is irrelevant then the document will soon become the same, and move to the shelf. References and further reading are good to have - but that takes half a page at the end. Too much information dilutes out the important content.

Epic saga - In three chronicles, not for the faint hearted.

If it passes the 'weight test' then it must be a quality product and worth the cash right? Bulking the content out with as much packing as possible (lots of photos, cut and pastes of sections from guidelines, etc) makes it into a substantial document. The average user will be put off just by the mere size; thinking 'do I really have to go through all that?". What's more the real guts of the matter are hidden in all the useless flab packed around it. Sometimes the goal of these types of plans appears to be to persuade you to 'leave it to me' - that is: to forget about your duty of care and trust the provider with your legal obligation, just leave your credit card details!

Tables, tables, and more tables - For fans of the Matrix... this one is full of them.

I think I hate this one most. Don't bother with words or explanations just create dozens of risk matrices. Very easy to mass produce for multiple clients. Leave the user to wonder about whether they are a B2 or a D3 - and what that means? Also, insert plenty of photographs to show you were on site. It can be very hard to implement a matrix. Having created risk matrices myself I know that the end result usually just leaves clients confused and worried.

Was that it? - Your address is the unique identifier in this token gesture.

A bit of duplication between risk management plans is fine. After all a statutory requirement doesn't change between facilities or organisations. That being said; managing risk at any given site is a unique process. A quick search and replace of the site, client and responsible person details and 'we'll throw in a free Risk Management Plan with your Water Treatment Contract' is not an operational risk management strategy. The only reasonable part of that transaction is that it is free, because realistically it is worthless.

So what exactly do I do with it? - An instruction manual that doesn't actually tell you what to do.

This is an easy trap for the provider to fall into. The plan is big on assessment and small on direction. The person creating the plan assumes that the person using it will know what to do once the problem is identified. Assume again! In most instances an FM is managing multiple other disciplines simultaneously. Some dialogue during the plan creation is not a bad idea. A good plan gives clear directions.

So what should the plan look like?

A good plan should be readable for a start and do-able to finish. In my opinion it should be no more than 30 pages beginning to end - let's not get into font size and line spacing here! It's just a guide!

Let's pull the useful common threads out of the descriptions above. The plan should have 6 elements:

WHO - a clear chain of responsibility
WHAT - an accurate system description
WHY - identified compliance targets
WHERE - points in the system where controls can be put in place
HOW - established control measures
WHEN - how often control measures are monitored, reported, and verified.

So in short, a good plan should be something that is, for the most part, easily incorporated into a regular preventative maintenance schedule. Just remember - if it isn't documented it didn't happen - and if you're the responsible person there's non-ones butt to kick but your own.

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