Water Management Policy – Rangefield School

 

Reviewed by:	Suzanne Deadman, 12 05 2025
Ratified by:	Resources Committee, 05 06 2025
Next Review:	Summer Term 2027

Policy Statement

This policy sets out the control of legionella in hot and cold water systems in school, including responsibilities, training testing and records. Rangefield School will undertake to ensure compliance with the relevant legislation with regard to the Control of Legionella in hot and cold water systems for all pupils, employees and visitors and to ensure best practice by extending the arrangements as far as is reasonably practicable to others who may also be affected by our activities.

The Law

As legislation is often amended and Regulations introduced, the references made in this Policy may be to legislation that has been superseded. For an up-to-date list of legislation applying to schools, please refer to the Department for Education website at www.education.gov.uk/schools and the Health and Safety Executive website www.hse.gov.uk.

Some of the key health and safety legislation and Approved Codes of Practice relating to Legionella and Water Management are listed below:

• Health and Safety at Work Act 1974
• Management of Health and Safety at Work Regulations 1999
• The Control of Substances Hazardous to Health Regulations 2002
• The Approved Code of Practice: Legionnaires Disease – The Control of Legionella Bacteria in Water Systems

Definitions

Legionella is a generic term for a type of bacteria which is common in natural and artificial water systems. Legionellosis is the name given to a group of pneumonia-like illnesses caused by Legionella.

Responsibilities

The Headteacher will ensure that:

• A risk assessment is carried out every two years or sooner if there have been significant changes to the water systems and that control measures are implemented.
• Records are kept for water temperatures flushing / testing / chlorination and disinfection procedures.
• Appropriate and sufficient training is provided to relevant staff.
• Ensure that flushing and testing of water outlets is carried out (Appendix 1).
• Any significant issues with the water or the water systems, or legionella outbreaks are reported to Estates Management Team. Lewisham Council.

The Premises Manager will ensure that:

• Regular temperature tests of sentinel taps are undertaken on a monthly basis.
• Temperature tests are undertaken (on an annual rotation) of all other water outlets.
• A competent contractor is employed to undertake a risk assessment every two years and to address any recommendations .
• Regular flushing of the water systems (little used outlets and showers) is undertaken, and the dates recorded.
• Annual water sampling is undertaken by a competent contractor and remedial works planned if required.
• Any changes to the schematic’s drawings are updated when works are undertaken.
• All relevant premises staff attend requisite training.

	NAME	POSTION	TELEPHONE NUMBER
Responsible Person	Chris Ball	Head Teacher	020 8698 3112
Delegated Duty Holder	Denie Deroche	Premises Manager	020 8698 3112
Deputy Delegated Duty Holder	Kenry Deroche	Premises Officer / Assistant	020 8698 3112
Responsible Budgets / Resources	Suzanne Deadman	School Business Manager	020 8698 3112
Contractors Risk Assessment Sampling Chlorination	PRIMEC	Contractor	01787 478 350

General Information

Legionella is a generic term for a type of bacteria (legionellae) which is common in natural and artificial water supplies. The bacteria thrive at temperatures between 20ºc and 45ºc but can be killed by elevated temperatures or chemical treatment.

The school stores and distributes hot water above 50ºc. Users are protected from scalding by controlling the delivery temperature of hot water from a tap to 43ºc by the use of thermostatic mixing values (TMV).

Annual checks are undertaken required to ensure that the valves are working correctly.

Infection is only a risk when there is inhalation of very fine water droplets that are contaminated with high concentrations of legionella bacteria. Healthy people are unlikely to contract an infection and outbreaks are rare though well publicised.

Control is normally achieved by suitable design and maintenance of the water system and its associated plant. Additional control is achieved by appropriate storage of water, the flushing of outlets and showers and delivery of water at temperatures which do not allow the bacteria to proliferate.

Risk Assessment

A risk assessment is undertaken every two years or sooner if there are any significant changes to the water systems.

The assessment of risk is mostly confined to:

• Monitoring whether control measures are being implemented fully.
• Correct water temperatures are being maintained.
• Regular flushing is being undertaken.
• Engineering measures, such as TMV’s are working properly.
• If there is a clear management scheme of delegation in place (with up-to-date information)
• If relevant staff have attended adequate training

Any areas identified as high risk must be reported immediately to the Headteacher.

Control Measures

To achieve ongoing control of legionella, thorough flushing of the water system is required alongside any engineering controls.

Effective control measures will require the school to:

• Monitor any water outlets that are not in regular use.
• Monitor areas where there are dead legs at the end of pipework.
• Record the flushing of all water outlets and showers.
• Record the temperature of hot and cold-water sentinel outlets.
• Regular inspection of water outlets to remove limescale.

Full details of flushing and testing regimes that need to be carried out can be found in Appendix 1

Testing Arrangements

Every year and under certain circumstances, for example when there have been alterations or maintenance work to the water system, testing is to be carried out as described in Appendix 1.

Chlorination and disinfection of the system will be necessary when testing indicates there is a sufficient level of legionella or other bacteria’s present in the water system to require treatment – see Appendix 2.

Drinking Water

Pupils and staff have access to drinking water at all times.

Water fountains are available in the in all Playgrounds. These outlets are inspected monthly for limescale by the Premises staff.

Emergency

In the event of an outbreak of Legionellosis the School will notify the HSE in compliance with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013, should a legionella outbreak be suspected of being caused within the premises. The School will co-operate fully with the HSE in any investigations into outbreaks of legionella thought to have been caused by the school’s water systems. If the schools water system is implicated in an outbreak of Legionnaire’s Disease, emergency treatment of that system will be carried out as soon as possible.

Information / Instruction / Training

The Headteacher will ensure that suitable and sufficient training and information is given to the School Premises Manager, and any other member of staff, who has responsibilities for flushing, record keeping and taking temperature readings as required by the appendices.

• Regular refresher training will be identified and undertaken.
• Any new measures that are introduced to control legionella will need appropriate training provision.
• The School Business Manager will ensure that a record of all instruction and training given to members of staff is recorded.
• Copies of training certificates will be held in the Legionella Log.

Appendix 1 – FLUSHING AND TEMPERATURE TESTING PROCEDURES

FLUSHING

1. All water outlets (hot & cold) will be flushed through monthly or during each half term holiday and a record will be kept in writing on the water outlet flushing checklist by the person carrying out the flushing.
2. Flushing will last for at least two minutes at a reasonable flow rate.
3. Where water outlets are routinely used, then this acts as the flushing routine and additional flushing is not required. However, flushing will always be required for all water outlets during periods of none use which exceed four days.
4. Flushing is also required at the end of the period of non-use

TEMPERATURE TESTING

1. A single cold and hot tap on the main hot and cold water systems, which are not connected via a thermostatic mixing valve, are to be run for one minute (in the case of a hot tap) and two minutes (in the case of a cold tap) every month so that a temperature can be taken using a thermometer and recorded on the Water Temperature Check List.
2. The cold-water outlet temperature should be below 20ºC after two minutes running.
3. Hot water will be stored at 60°C
4. The hot water outlet temperature should be above 50ºC after one-minute running.
5. If these temperatures cannot be achieved, then the Headteacher or School Business Manager is to be informed with a view to taking remedial action or informing Lewisham Council Estates Management Team.
6. Scientific tests may be required when there appears to be a problem with the water supply, e.g. discolouring, temperature problems, etc. These should be reported to the Headteacher.
7. If a positive Legionella test is reported there will be a re-test as recommended by the Competent contractor, dependent upon the test results.

Appendix 2 – PROCEDURE FOR CHLORINATION / DISINFECTION

1. If the school produces a sufficiently high result after testing, and a risk assessment recommends action, it will be chlorinated and disinfected by an approved contractor.
2. The Premises Manager will arrange the time and date of chlorination with the selected contractor.
3. Ideally, the chlorination should be booked during the school holidays or when pupils and staff are not on site.
4. Affected areas will be withdrawn from use until chlorination has been completed. Flushing of outlets in these areas will cease until the chlorination has been completed.
5. A supply of clean water for the kitchen area will be drawn off from an uncontaminated source and stored in containers on the morning of a chlorination visit if required.
6. Once chlorination and disinfection commence, the water system will not be usable (except in WC’s) until the contractors declare it safe. (Note: Drinking water must only be used from the bottled supply).
7. Alternative hand cleaning methods may be instigated to supplement the wearing of protective gloves for personal care. (e.g. Sanitiser & antiseptic wipes).
8. Staff and pupils will be protected from accidental use or drinking of disinfected water by securing the outlets or denying them access.
9. Chlorinated areas will be re-instated immediately after completion of the process and the flushing regime will recommence.

Appendix 3 – PROCEDURE FOR FLUSHING SHOWERHEADS/ KITCHEN POT WASH AND LITTLE USED OUTLETS

1. All should be flushed on a weekly basis and the results recorded in the Legionella Log.
2. Every quarter shower head should be dismantled, de-scaled and disinfected.
3. For showers which are infrequently used we may consider storing the clean shower head in a plastic bag until required and then cleaning and storing again after use.