November 2024
The Aluminium Federation (ALFED) is committed to keeping its members informed about critical health and safety updates affecting the aluminium industry. This article highlights new advice from the Health and Safety Executive (HSE) regarding legionella risks associated with powder coating rinse waters and rinse water tanks. While ALFED aims to provide accurate and timely information, we emphasise that it is the responsibility of businesses to implement and comply with these regulations.
Understanding the Risks
Powder coating rinse waters and rinse water tanks fall under HSG274 Part 3, which covers “Industrial Process Water Systems.” These systems, due to their nature, have the potential to become breeding grounds for Legionella bacteria, particularly when aerosol generation is involved, as in spray rinse systems. The risks arise from:
- Contaminated aerosols: Inhalation of aerosolised water droplets contaminated with Legionella bacteria can lead to Legionnaires’ disease, a serious respiratory condition.
- Favourable conditions for Legionella growth: Factors such as stagnant water, the presence of nutrients, and water temperatures between 20°C and 45°C create an ideal environment for bacterial growth.
Legal Requirements
Under the Approved Code of Practice (ACOP L8), businesses must carry out a suitable and sufficient legionella risk assessment to:
- Identify and assess risks of exposure to Legionella bacteria.
- Implement a written scheme for controlling identified risks.
- Manage and monitor the scheme effectively to prevent exposure.
Key Guidance from HSE
HSE’s advice emphasises the following steps for businesses operating powder coating rinse systems:
- Conducting a Risk Assessment
- The duty holder is responsible for ensuring that a competent legionella risk assessor conducts a site-specific evaluation of the rinse water system.
- The assessment should focus on factors such as water contamination, temperature management, nutrient availability, water stagnation, aerosol generation, and potential human exposure.
- Weekly dip slide results, if available, can provide valuable baseline data for the assessment.
- Implementing Monitoring and Control Schemes
- Based on the findings of the risk assessment, duty holders must establish a monitoring and control schemetailored to their system’s risks.
- Regular testing and system maintenance should be conducted to ensure that Legionella bacteria levels remain controlled.
- Documentation and Compliance
- Maintain detailed records of the risk assessment, monitoring, and control measures.
- Ensure the scheme is implemented and managed according to HSE standards to comply with ACOP L8 and HSG274 Part 3 requirements.
Access to Resources
For detailed guidance, HSE’s HSG274 publication is available for free at:
www.hse.gov.uk/pubns/books/hsg274.htm
The document provides essential advice on managing risks associated with industrial water systems, including powder coating rinse water tanks.
Practical Steps for ALFED Members
- Engage a Competent Risk Assessor
Ensure your business engages a qualified legionella risk assessor to evaluate your rinse water systems. - Review Current Practices
- Check whether your current practices align with the requirements of HSG274 and ACOP L8.
- Review historical records, such as weekly dip slide results, to provide context for the risk assessment.
- Develop a Written Scheme
Based on the risk assessment findings, implement a written scheme for controlling legionella risks, including measures like:- Regular monitoring of water quality and temperature.
- Minimising water stagnation and nutrient build-up.
- Managing and maintaining spray rinse systems to reduce aerosol generation.
- Educate and Train Staff
Provide training for employees involved in maintaining rinse water systems to ensure they understand the risks and control measures.
Significance for ALFED Members
This HSE update underscores the critical importance of managing legionella risks in industrial water systems. Failure to comply with these requirements can lead to serious legal implications, reputational damage, and health risks to employees and visitors. By conducting risk assessments and implementing effective control measures, businesses can safeguard their operations and comply with health and safety regulations.
Conclusion
ALFED encourages members to act promptly to ensure compliance with HSE guidance on legionella risks in powder coating rinse waters. Members should contact a qualified risk assessor, develop a written control scheme, and maintain rigorous monitoring practices.
While ALFED is committed to providing updates and support, businesses are reminded that compliance with regulations remains their responsibility. For more information and detailed guidance, refer to the HSG274 publication or contact the HSE directly.
If you have further questions or require additional resources, please reach out to ALFED. Together, we can work to uphold the highest standards of safety in the aluminium industry.
