CBRE| GWS| QHSE | UK.

NI COMPLIANCE| BULLETIN
Water Risk Management UK & N Ireland

Duty Holders & Responsible Person

Covid-19 update
All Commercial Buildings
25/03/2020

Despite recent restrictions on social gathering and contact, duties under the Health and Safety at Work Act still
apply within the workplace and as such an employer or those in control of premises must continue to manage
any risk arising from their activity and this includes the control of legionella bacteria within building water
systems.

Refusal of site access could possibly lead to out of control conditions which could lead to future prosecution.

CBRE would like to offer our full support in this difficult and testing time.

We can reassure you that we, as your service provider, have measures in place to minimise the spread of
COVID-19.

While controls in place may need to be adapted to changing circumstances, Duty Holders must still be able to
demonstrate control of risk to a reasonably practicable level. However, they are less likely to have access to
competent help on site while adapting control measures due to social distancing and self-isolation.

Many legionella control activities are monitoring measures rather than interventions and there may be some
flexibility in how these are maintained during the COVID-19 situation. Other systems may require
interventions by service providers to remain safe and these should not be neglected.

Each system should be considered individually by the Duty Holder, if necessary, we can help with this process.

There is a significant level of control that must be maintained on site and is likely to be time critical. In this
respect it is essential that access to the site is possible and travel should continue unless alternative
arrangements have been made. Unless there is reason for individuals to stop working, staff should take the
appropriate hand washing, social distancing and other recommended measures and continue these essential
activities.

CBRE can offer pragmatic solutions if possible, to ensure ongoing control including safe shutdown of water
systems if a building is to be closed - particularly for evaporative cooling systems to ensure ongoing control
including safe shutdown of water systems if a building is to be mothballed and then advise on what is required
to safely recommission water systems when buildings reopen.

Prepared by Sponsor Date

Robert King QHSE 09/09/2016
Issue Number 1 Last Reviewed 09/09/2016 Next Review 31/12/2020
CBRE| GWS| QHSE | UK. NI COMPLIANCE| BULLETIN
Water Risk Management UK & N Ireland

Advice to Give to Service Users for Return to Normal Operation

If buildings or water systems are isolated during the COVID-19 outbreak, the length of time involved may not
have been known at the outset and control measures might not have been considered. Staff may not have
been available to flush outlets to simulate usage.

Assess the risk – it is not advisable to re-open buildings after shutdown with no additional control measures.

Consideration should be given to water system cleaning and disinfection and / or controlled flushing to
mitigate the risk from prolonged stagnation.

Sampling is a very useful indicative tool to demonstrate effectiveness of control measures. Including risk level
mitigation & advice on your water systems and how to manage them safely and economically.

We can get the stored water systems with a safe food grade disinfectant that is fully potable and will allow you
to maintain safe conditions while the system is unused. Also, clean, disinfection and sampling of systems
before re occupation to ensure that water is safe, with total building sanitization together with indoor air
quality testing before reoccupation, clean and disinfection, recommissioning of evaporative cooling systems if
they have been out of commission for some time.

The legal responsibility for legionella control lies with the Duty holder, but CBRE should be providing expert
advice to our customers to assist them in compliance.  Each Duty holder must make their own determination
for each circumstance, but the following principles should be considered when making decisions on what to do
to control legionella during the COVID-19 outbreak:

1) The expectation for evaporative cooling systems is that they will be maintained as usual or switched off
safely – there is no leeway in this

2) The expectation for water systems supplying critical services, for example hospitals, is that they will be
maintained as usual – there is no leeway in this

3) Hot and cold-water systems in buildings that are empty or with under occupancy must address the issue of
stagnation:

a. If the building is still partially in use take additional measures to keep the remaining occupants safe:

i. If possible, drop stored water levels in tanks to maintain <24 hours storage

ii. Flush to simulate use – weekly flushing may not be sufficient

iii. Monitor temperature to ensure thermal gain in cold water is controlled

iv. If fitted, consider temporarily increasing levels of potable water treatment dosing – consider other
consequences of this such as corrosion and make the decision on balance of benefit

v. If controls are lost (temperature, biocide levels, etc.) the guidance in HSG274 is to sample for legionella
weekly

vi. Consider other short-term measures to keep remaining occupants safe such as point of use filters at
designated locations with other areas shut off

b. Buildings that are temporarily shut down (mothballed) should follow the guidance in HSG274 Part 2

Prepared by Sponsor Date

Robert King QHSE 09/09/2016
Issue Number 1 Last Reviewed 09/09/2016 Next Review 31/12/2020
CBRE| GWS| QHSE | UK. NI COMPLIANCE| BULLETIN
Water Risk Management UK & N Ireland

paragraphs 2.50-2.52:

i. Do not drain down pipework 

ii. If possible, remove sources of heat and external thermal gain

iii. Lock off, place signage on doors and otherwise advise potential users that the system has been taken out of
use

iv. Have a plan in place for recommissioning the water system

For all the work above there should be a task risk assessment in place to ensure operatives are working safely.

Where you are faced with clients not allowing you to perform legionella control measures,

1. Make sure clients are aware of their responsibilities under the law and how their actions may be
compromising their control of legionella - do this in writing

2. Offer pragmatic solutions if possible, to ensure ongoing control including safe shutdown of water systems if
a building is to be closed - particularly for evaporative cooling systems

3. Document all the communication around any refusal of site access for any future prosecution

4. Advise on what is needed to safely recommission water systems when buildings reopen

If there is a situation where there is significant risk, contact you’re CBRE Divisional QHSE Director  

Advice to Give to Service Users for Return to Normal Operation

If buildings or water systems are isolated during the COVID-19 outbreak, the length of time involved may not
have been known at the outset and control measures might not have been considered.  Staff may not have
been available to flush to simulate usage.  Assess the risk – it is unlikely that buildings can simply be reopened
with no additional measures. Start-up procedures for systems may need to be reconsidered before buildings
can be reopened. 

Consideration should be given to water system cleaning and disinfection and/or controlled flushing to mitigate
the risk from prolonged stagnation.  Sampling may be useful to demonstrate effectiveness of control
measures.

Recommissioning Water Systems

It is essential that when buildings reopen following the lifting of COVID-19 restrictions, that any water system is
not simply put straight back into use. During the period of shutdown, it would be sensible to formulate a
recommissioning plan for each water system to allow safe start-up and assurance to users that it is safe.

Duty holders are likely to be able to access competent help from service providers remotely during the period
of restricted movement.

Any plan for recommissioning buildings must consider the safety of the operatives carrying out the work. It is
foreseeable that the hazard present within water systems in this situation would be greater than normally
expected.  

Prepared by Sponsor Date

Robert King QHSE 09/09/2016
Issue Number 1 Last Reviewed 09/09/2016 Next Review 31/12/2020
CBRE| GWS| QHSE | UK. NI COMPLIANCE| BULLETIN
Water Risk Management UK & N Ireland

Reasonably practicable measures such as limiting aerosol, minimising exposure and use of RPE should be
considered.

Evaporative cooling systems should already have robust start-up and shut-down procedures in place and the
expectation is that these will be followed.

The minimum expectation for small, simple hot and cold-water systems would be flushing through with fresh
mains water.  Larger buildings, those with tanks, showers, calorifiers and more complex pipework the
expectation is likely to be for more extensive flushing followed by cleaning and disinfection.  

During flushing all valves should be operated in the fully open position so that any particulate matter can be
flushed through. Of importance are float-operated or other restrictive valves which need to be manually
opened to ensure clearing of particulates and prevent fouling of the valves. Where a clearing velocity cannot
be achieved, consideration should be given to removal of valves to enable an effective flush.

Where cleaning and disinfection is carried out, it is very important to monitor the decrease in disinfectant level
over the course of the contact time.

Loss of more than 40% disinfectant concentration could indicate influence of biofilm.  See BSI PD855468 for
more guidance.  

Where buildings have been unoccupied for some time and during warm weather, it is likely that some increase
in bacteria levels and biofilm will occur.  These water systems may require more than a simple disinfection at
50ppm of chlorine for an hour to be successful.

Be prepared for the need to repeat some disinfections to achieve success. Manage customer expectations and
be careful to agree the process rather than guarantee the result.

In all cases where systems are being recommissioned it is sensible to have evidence to prove/reassure that the
recommissioning process has been effective.  

Sampling to BS7592 should be considered for recommissioning plans to validate the effectiveness of the
process.  As per HSG274 part 2, samples should be taken 2-7 days following recommissioning and not on the
day of disinfection.  

Follow up samples may need to be considered as part of the recommissioning plan.

While each individual water system is likely to need individual consideration, it will be helpful to be aware of
the bigger picture regarding demand on services. There will be an increased demand for flushing and
disinfection, sampling and other system recommissioning work. Be aware of this, make the customer likewise
supply chain aware and manage expectations accordingly.

There is potential for multiple outbreaks of Legionnaires’ disease following the COVID-19 outbreak if actions
taken now are not carefully considered. Please make your customers aware of this, and that the
responsibility for legionella control lies with the Duty holder.

Prepared by Sponsor Date

Robert King QHSE 09/09/2016
Issue Number 1 Last Reviewed 09/09/2016 Next Review 31/12/2020