Cases of Legionnaires’ disease have risen each year since 2020, according to UK Government data, with 2023 seeing a huge 46% increase on the previous year. Surprisingly, this upward trend coincides with the release of BS 8680: Water Quality and Water Safety Plans, which establishes a framework of better risk management. Despite this guidance, recent enforcement actions have highlighted persistent failings in training, procedures, and record-keeping for the cause of cases, with some organisations facing substantial fines.
Too often, organisations take a reactive stance and engage service providers to prevent bacterial growth, without allocating internal resources or responsibility. This creates dangerous gaps in policy, procedures, and oversight – putting people at risk of infection and increasing the likelihood of enforcement action against them.
It takes a proactive and strategic approach to truly prevent Legionella outbreaks. To meet this need, Churchill Environmental is expanding its services beyond asset management to include risk consulting, audits, and strategic planning for our clients.
Risks leading to bacteria growth
Several key factors add more complexity in water safety management. Hybrid working has created lower occupancy levels, which in turn has disrupted normal water usage patterns and increased the risk of stagnation and bacterial growth. Switching to renewable energy for water pre-heating also has drawbacks, as some systems don’t reach temperatures hot enough to eliminate bacteria. Both factors could lead to a rise in water treatment solutions such as biocide dosing becoming more common in otherwise low-risk environments.
Monthly checks aren’t enough. Water requires much more diligent monitoring compared to gas or electrical systems. Issues with water safety can remain undetected until it’s too late. That’s why we’re focused on getting essential water monitoring right, with 95% of what we do every day relating to hot and cold-water systems.
How water safety groups help prevent Legionella
A water safety group (WSG) is a multi-stakeholder team who ensure that water safety is not just delegated to an external provider. Instead, policies are embedded directly into an organisation’s risk management framework. The WSG oversees the development and implementation of a water safety plan (WSP), making sure that estates, compliance, cleaning teams, and other departments all play their part in mitigating risk.
The Department of Health and the NHS have created a comprehensive water safety plan which emphasises a proactive and organised approach to hygiene and outbreak management. Many organisations outside of healthcare could learn from the NHS’s example.
One national housing provider was recently hit with a £900,000 fine due to relying on a reactive model and a lack of policies or procedures. This meant tenants remained at risk during outbreaks because of poor coordination and oversight. The high cost of this mistake shows that WSPs should be a core part of your risk management, not an outsourced add-on.
Five key areas of a Water Safety Plan
BS 8680 sets out a structured approach to water safety management, which can be broken down into five core areas:
- Governance – Establishing a clear organisational structure to lead and manage water-related risks. This includes defining roles and responsibilities for those involved in water safety management.
- System assessments – Maintaining an accurate register of all water-related assets and conducting regular risk assessments to understand potential vulnerabilities.
- Controlling risks – Implementing control measures, defining limits, and setting up monitoring programmes to identify issues before they escalate.
- Validation and audit – Regularly reviewing the effectiveness of control measures, using audit processes and sampling programmes to ensure compliance.
- Supporting programmes – Developing emergency response plans, record-keeping systems, and training programmes to ensure competence at all levels.
Overcoming common challenges in water safety management
Many organisations struggle with the sheer volume of data that modern electronic logbooks and asset management systems produce. Contract managers and other responsible individuals face the challenge of processing thousands of monitoring results each month, making real-time trend and risk analysis difficult. Critical issues can be missed if the data isn’t managed with a structured WSP.
When so few organisations have truly adopted a WSP approach, this creates further problems down the line. Many mistakenly believe that outsourcing to a service provider guarantees compliance, neglecting to dedicate internal resources. Realistically, consistent training, auditing, and a focus on continual improvement are vital for compliance.
Skills gaps also lead to compliance failures. New colleagues often lack essential training, and competency gaps mean that routine compliance tasks can get overlooked, or carried out incorrectly. With a reduction of skilled workers in FM, especially in building services, companies need to make compliance a priority. For example, we’re audited annually by the Legionella Control Association and competency remains one of their most focused areas of assessment.
WSGs would significantly help organisations plug these gaps, ensuring that knowledge is retained and shared across departments and making compliance with up-to-date laws a possibility.
Water monitoring: more than ticking boxes
Compliance shouldn’t be the only end goal. Organisations doing the bare minimum to meet compliance requirements create increased risk. One HSE report found that 90% of outbreaks had their root causes in failures to identify risk or to put in place effective schemes of control to deal with identified risks. Our own data supports this, with 13% of water samples reporting as positive for legionella, with some bacteria growing to dangerous levels in a matter of weeks.
With hundreds of serious legionella cases occurring in the UK each year (over 600 reported in 2023), compliance cannot be viewed as a one-time achievement. To prevent bacterial growth, FMs must be constantly vigilant. A well-structured WSP, led by a dedicated WSG, ensures that organisations remain proactive rather than reactive. In doing so, they safeguard both compliance and occupants’ health.
Expertise from outside the organisation is needed for four of the five core areas of BS 8680 where only governance is an exception. Embedding a structured WSP helps businesses shift from short-term solutions to a sustainable, future-proof water safety strategy.
To learn more about our approach to water safety and compliance, please get in touch.