The last few weeks have been unprecedented for all of us and I would like to take this opportunity to reassure you that we will continue to provide our critical service to you and your sites. Our approach to service delivery has always been from a partnership perspective and this will continue through this current global crisis.
In this correspondence we will detail the legal position as to the services that we provide, how we will continue to provide services, the extra precautions that we will take to protect our staff and your building users and the challenges that we are facing at site level.
Legal Position of Critical Services
The Health and Safety at Work Act still applies in the current situation and, as such, an employer, or those in control of premises, must continue to manage any risk arising from their activity.
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. In the current situation Duty Holders are less likely to have access to site based competent help and needing to take into account adapting control measures due to social distancing, self-isolation and partial or complete closure of properties.
Attached to this correspondence you will find a set of FAQ’s which, hopefully, will answer many of your queries. These will be updated on a daily basis and can be found on our website. However if you need any individual support or guidance then please contact a member of our management team
Continued provision of service
We have developed a contingency plan for how we will continue to provide service, which we have stress tested under various different conditions, the main points being as follows.
- We have adequate levels of chemical and other products in stocks and have arrangements with suppliers to continue to provide as necessary.
- We have cross trained staff in the business to be able to carry out multiple tasks. If necessary all staff will be diverted to providing services that are classed as critical and are backed by legislation.
- We can defer work that is non-critical until a later date in order to focus on providing critical services.
- We have developed a list of high risk sites that will be maintained at all times regardless of impact of resources.
- We have introduced measures in the business to protect the workforce in line with Government guidance.
Extra Precautions to Protect Staff and Customers
The key fundamentals within the business are to ensure the safety of our staff and to protect the health, welfare and compliance of our customers. In order to achieve both of these core elements at this moment in time we have implemented the following actions.
- Developed a Covid-19 Contingency plan
- Appointed a Covid-19 responsible person in the business.
- Management team meeting twice a day (remotely) to review current guidance and update plans
- Reviewed and updated Risk Assessment and Method Statements
- Imposed greater rigour on site etiquette and prevention of cross contamination between sites.
- Providing our staff with daily updates and reminders about actions to protect themselves and sites
- Introduced a method statement for dealing with customers who are self-isolating
- Conducted individual Risk Assessments on all staff.
- Instructed staff to follow all customer and local operating systems relating to Covid-19
- Managing our supply chain to ensure that they follow our current Risk Assessments and Methods Statements.
- We have implemented a home working policy wherever possible
- We have significantly increased our virtual meeting and conference call licences to enable any meetings to be held remotely.
Our challenges requiring your support
The biggest challenge that we are currently facing is gaining access to sites. We would ask that you reinforce to your sites that our services are critical to the continued safe operation of the site and to provide support when requested to gain access. We would request that you provide us with a signed letter of authority to help us to gain access to sites during this period, an example of the wording provided by another customer is attached in the FAQ’s.
Our Commitment to you
I would like to reassure you of the continued commitment to keeping your sites safe during this very difficult period. If you require additional advice on control measures on your premises due to COVID-19 outbreak please do not hesitate to contact your Account Manager.
Gavin Hartley Managing Director
Should I continue with Legionella Control Services?
Yes, The Health and Safety at work act is still enforceable and, as such, these critical checks to the water systems should still be undertaken. The Government have classified them as critical and they should continue to be undertaken in a timely and safe manner.
What if I have reduced site occupation?
If the site is working at reduced operating capacity due to social distancing and containing the spread of Covid-19 then further control measure to ensure the safety of remaining occupants should be considered.
The measures that could be considered are flushing of parts of the water system that are not being adequately flushed or moth balling of parts of the system not being used. If moth balling is chosen as an option then suitable Return to Normal Operation should be considered
What about when I need to 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 as per HSG 274, paragraph 2.40.
How will we deal with Abortive Visits?
As a result of abortive visits due to clients/sites not allowing us to perform legionella control measures, we will undertake the following actions:
- Make sure that you as our client are aware of your responsibilities under the law and how your actions may be compromising your control of legionella.
- 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
- Document all of the communication around any refusal of site access for any future prosecution or LCA audit to demonstrate that you have done all of the above
- Advise on what is needed to safely recommission water systems when buildings reopen
What if we go into “total Lockdown”?
It will be for Central Government to determine any controls on movement during any future ‘lockdown’ and what will be classed as essential activity.
Can you help with the suggested wording for a Letter of Authority?
We would suggest the following:
“In accordance with Government guidance and under the requirements of the Health and Safety at work act the services provided by hsl Compliance / Alchem Industries in relation to Water Hygiene / Asbestos Control are deemed critical services to the safe operation of your site.
Consequentially, they should be provided access to the site in order to undertake their services. Please ensure that their staff are fully briefed of any local or site based restrictions that may apply due to Covid-19.”
How will you minimise any risk posed by your operatives coming onto site?
We have given full and comprehensive guidance to our staff, anyone with any symptoms or any family member has been instructed to self-isolate. We have over 250 engineers in the field across all disciplines and we have prided ourselves on the vast majority being multi skilled. They will follow our own (currently increased) and your site protocol for hygiene and we would encourage social distancing when they come to site.
We have introduced a dynamic risk assessment they are to complete ahead of entering any site in the current climate.
Are your offices still open?
As far as you, the customer, is concerned, yes, they are. Whilst we have a large number of staff on home working, a small number are in the main offices, observing social distancing and hygiene protocols. Direct lines are diverted to mobiles and staff are accessing their work computers remotely.
Any staff working in a serviced office have been instructed to work from home as of week commencing 24/03/20. Any client meetings (not essential service visits) are being offered as virtual meetings via gotomeeting, skype or conference call.