So, for this month we are asking you to review three areas of your building operations to look at what you currently have in place and any aspects you may want to concentrate on.

Below are three questions for you to consider areas of your management by investing 15 minutes of your time – possibly a little more this time around! - to challenge your processes and procedures. In addition to the questions supporting information is provided for you on each of the subjects.

Our three questions are below, please read on for some points to consider:

  1. What is the guidance and what am I doing around air quality?
  2. Are my water systems and services safe for those returning to work?
  3. What could the expectation of those returning to work be, and how do I support the management of this?

1. What is the guidance and what am I doing around air quality?

Air quality has been a much-discussed aspect of remobilisation with helping reduce the risk of SARS-CoV-2 transmission. For your workplace your strategy will, by nature, depend on the type of ventilation you have.

The main advice is around increasing the levels of fresh air and encouraging air movement, but not recirculated air, around the building.

For naturally ventilated premises the main option is to open windows where you can and where installed, look to turn off any locally recirculating systems.
For mechanically ventilated/air-conditioned properties it is more about increasing run times and fresh air content as well as reducing recirculation. Maintain your routine filter type and change as required – published guidance advises looking to increase the specification of the installed filters for purely COVID-19 related issues only is not necessary and that ductwork cleaning has no practical effect.

Information on air quality from the Health and Safety Executive (HSE) bulletin on the 22nd May 2020 and states:

“The risk of air conditioning spreading coronavirus is extremely low.”

“If you use a centralised ventilation system that removes and circulates air to different rooms, it is recommended that you turn off recirculation and use a fresh air supply. You do not need to adjust other types of air conditioning systems. If you’re unsure, speak to your heating ventilation and air conditioning (HVAC) engineers or advisers. Good ventilation is encouraged to help reduce the risk of spreading coronavirus.”

Where you have installed forced air ventilation/air conditioning further considerations are:

  • Have you inspected ventilation grilles throughout the building to make sure they are clean, working correctly and free from blockages/damage?
  • Have you liaised with the building M&E provider to carry out a survey of any localised recirculating units on your systems (i.e. fan coil units (FCU)) what they supply, and risk assess/evaluate those that can be switched off to reduce recirculation of air? Do these share a plenum chamber in the ceiling void?
  • Do you have any heat recovery systems within your air handling units (AHU)? Can these be switched off to prevent recirculation of air? Have they been cleaned?
  • Have your air handling units (AHU) and any terminal units been inspected and are they appropriately clean and well maintained, where necessary including fresh air intakes, filters, condensate drip trays, drainage, heating and cooling coils?
  • Have you communicated the impact of changing ventilation systems to users?

2. Are my water systems and services safe for those returning to work?

As an owner occupier, landlord, managing agent or tenant, there is no blanket approach that will fit all circumstances or individual buildings for managing water, so your site specific, water management system and risk assessment are the key documents you need to initially review. Knowing your water systems and services remain safe should be central to your re-occupation of your workplace.

The HSE and Chartered Institute of Environmental Health (CIEH) have, amongst others, produced guidance on the subject and both follow a similar approach, which is:

“If your water systems are still used regularly, maintain the appropriate measures to prevent Legionella growth, and if you have already reviewed your risk assessment and implemented additional control measures, then it is unlikely you will need to take any further steps prior to reopening.”

If your building has been closed, had significantly reduced occupancy and/or where no additional action has been taken, or you are concerned about the effectiveness of controls implemented, you need to take reasonable steps to ensure the safety of your water system prior to reopening. So, you need to review your risk assessment and manage the Legionella risks when you:

  • Reinstate a water system or start using it again;
  • Restart some types of air conditioning units.

Here are the links to the guidance,

HSE – “Legionella risks during the coronavirus outbreak”
https://www.hse.gov.uk/news/legionella-risks-during-coronavirus-outbreak.htm#:~:text=If%20your%20building%20was%20closed,the%20risks%20of%20Legionnaires’%20disease

CIEH – “Legionnaires’ disease: lockdown risks and reopening safely”
https://www.cieh.org/media/4208/legionella-guidance-covid-19.pdf

While some premises may have stayed largely operational throughout the ‘lockdown’, others may have had little or no usage. So, in assessing how best you manage your systems, you need to know what has been happening:

  • Look at any high-risk areas or recommendations made in your Legionella risk assessments and water audits, paying particular attention to those that have not been completed and how these may materially affect your management now.
  • Check your recent records (at the very least, the last 6 months), to confirm the systems have been under control or where issues have occurred, what they were, (temperature, flushing cleanliness etc.). These could also manifestly affect how you need to develop your plan for demonstrating ongoing compliance.
  • Assess the likely level of occupancy against the water systems and services installed and you have responsibility for. In tenanted buildings some floors may become completely vacant, where others might have more limited or no reductions in staff. Apply your approach to these areas accordingly and discuss with your landlord or tenants what they have been doing, so you have a complete understanding of the current condition of your water systems.

For buildings that have been fully operational or, for example, with amended schemes to increase flushing due to reduced occupancy and where the records continue to indicate control, it is likely to be business as usual. Those premises that may have been closed and the water systems not used for the last two months or more, are much more likely to need disinfection and a review of their management prior to reintroduction/re-occupancy.

Items you should have or should be considering include:

  • Have you reviewed your Legionella risk assessment? Is it still valid/up to date? Have any remedial actions and changes been documented? This should be reviewed at each stage of re-occupation to capture any additional risks introduced.
  • Have you assessed likely time frames and levels of occupancy against the water systems and services installed (that you have responsibility for) and any necessary works that need to occur prior to re-occupation?
  • Have you reviewed your water management system to reflect changes in activity and clearly documented any additional control measures introduced/removed?
  • Have all planned preventative maintenance tasks been carried out at the correct frequency e.g. flushing, temperature checks, shower de-scaling, tank and plant inspections with remedial actions documented?
  • If any cold-water tanks or water heaters were temporarily by-passed, have these been re-commissioned and re-instated? Do these require a clean and disinfection?
  • Do you need to confirm the availability/projected lead times of your water treatment company to complete any disinfections in line with your timescales for re-commissioning the building i.e. domestic water systems/cooling towers?
  • Are hot water units set correctly to make sure that hot water is supplied within parameter at periods of higher demand (as occupants will be washing their hands more frequently)?
  • Are there any dead legs on the water systems from lack of occupancy/temporary isolations? Have these been flushed, or removed? Coffee machines, water dispensers, dishwashers and ice machines may have been left as dead legs and could need cleaning prior to re-commissioning.

Other considerations:

  • Have vending machines and other drinking water dispensers that may have been out of use over lockdown been appropriately cleaned and re-stocked prior to reintroduction?
  • Have you reviewed and confirmed your cleaning company’s cleaning procedures (where applicable) to make sure that vending machines, water dispensers and kitchen taps are cleaned with cross-contamination minimised?
  • Have drainage and sanitation facilities been checked to make sure they are in good working order i.e. water filled, free of blockages and undamaged for example?

3. What could the expectation of those returning to work be, and how do I support the management of this?

There is, as no doubt you are all aware, a significant volume of information and guidance on what the ‘new normal’ will actually look like. One of the more recently updated documents from the Cabinet Office (at the time of writing the last updated on the 5th June 2020) is “Staying safe outside your home”.

The document provides an overview of what is expected of us all as employers, employees and members of the public and identifies:

“It is your responsibility to adopt these principles wherever possible. The government is also using these principles as the basis of discussions with businesses, unions, local government and many other stakeholders, to agree how the principles should apply in different settings to make them safer.

All of us, as customers, visitors, employees or employers need to make changes to lower the risk of transmission of the virus. The government has consulted with its scientific advisers to establish the principles that will determine these changes.”

As well as general points the content covers several work-related aspects, under the headings of:

  1. Keep your distance from people outside your household;
  2. Keep your hands and face as clean as possible;
  3. Work from home if you can;
  4. Avoid being face-to-face with people if they are outside your household;
  5. Reduce the number of people you spend time within a work setting;
  6. Avoid crowds;
  7. If you have to travel (for example, to work or school), think about how and when you travel;
  8. Wash your clothes regularly;
  9. Keep indoor places well ventilated;
  10. Face coverings;
  11. When at work, follow the advice given to you by your employer.

The link to the advice is:

https://www.gov.uk/government/publications/staying-safe-outside-your-home/staying-safe-outside-your-home

The document could prove useful as reference as to what is expected and also a check against what you currently have in place.

Use your provided information, risk assessments, guidance and advice documents to proactively inform building users of the changes you have made, and encourage them to assist you in keeping your workplace safe.

Assurity Consulting is the leading expert in workplace health, safety and environmental compliance. For more information, please contact us on tel. +44 (0)1403 269375 or email us.

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