Water Risk Management Plans – What You Need To Know

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First posted 26 July, 2018

In February 2017, the Queensland Government amended both the Public Health Act 2005,  to improve water risk management practices in health facilities across the state.

This amendment requires all hospitals with inpatients, residential aged care facilities and any licenced private health facility in QLD to:

  • Develop a Water Risk Management Plan;
  • Complying with Water Risk Management Plans;
  • Notify the Chief Executive of the Department of Health (within 1 business day) upon confirmation that Legionella has been detected in water used by a prescribed facility;
  • Submit periodic reports summarising the results of Legionella tests for a prescribed facility.

On a national scale, this legislation is not mandatory; however, each state recommends implementing a Water Risk Management Plan to manage the risk of Legionella. While most healthy individuals may not develop an illness from Legionella; newborn babies, the elderly and those with compromised immune systems are at risk of Legionnaires Disease. Legionnaires Disease can lead to either serious illness or fatalities.

In health and aged care settings, the mortality rate from Legionnaires’ disease is as high as 40 per cent.

– Queensland Health

Implementing Water Risk Management Plans assist in the management and control of health risks associated with the supply and use of water. Water Risk Management Plans also provide greater public transparency of water testing activities undertaken by your facility.

As outlined by the Queensland Governments Guidelines, here are some key steps to developing a Water Risk Management Plan:

1. Establish a Water Risk Management Team

A Water Risk Management Team is responsible for developing and enforcing written procedures for legionella risk management. The Water Risk Management Team must provide all staff access to the Water Risk Management Plan.

A Water Risk Management Team can contain both internal and external resources.


2. Describe the facility’s water distribution system

When undertaking a proper system analysis, accurate plans of the water distribution system must be held, along with any modifications to the original system.

In older or larger buildings, obtaining an accurate plan may be difficult. To ensure accuracy, conduct physical inspections to identify and highlight where components of the water distribution system may increase the risk of Legionella growth.

3. Identify Hazards

Identifying all potential hazards, hazard sources and hazardous events allows for a better understanding of the risks and how to control them appropriately.


4. Undertake a risk assessment


Undertaking a risk assessment takes into account any the water system risks or health risks.

More specifically, the process will ‘consider the likelihood of Legionella colonisation and infection, and the consequence of the colonisation or infection.’¹

Find out more information on undertaking a risk assessment here.

5. Identify control points

Control points are the ‘locations within a water distribution facility at which a hazard may be reduced or prevented (e.g. point-of-entry into a facility or water leaving a storage tank within the facility).’²

Where possible, proactive control measures should be developed and implemented at these points to reduce the risk of legionella growth within your water distribution system and minimise exposure.

6. Set Critical Limits

Set a maximum or minimum value set (critical limit) for a particular parameter being monitored at each control point. This process indicates whether set controls are effective or not.

7. Develop and implement

A Monitoring Program

Monitoring a facility’s water distribution system provides the ability to assess the effectiveness of maintenance and controls, as well as detecting the presence of Legionella before cases of Legionnaire’s disease occurs.

Sampling and analysing of the water is vital to ‘ensure that the risk control measures instituted are effective’ (operational monitoring) and to ‘determine the presence and extent of Legionella colonisation, both generally and following the implementation of control or remediation measures’ (verification monitoring).¹


Corrective procedure actions for the monitoring program

If Legionella is detected, or a case of Legionnaires’ Disease arrises and is linked to a facilities water distribution system, a number of control measures or an alternative suitable decontamination procedures should be undertaken as a matter of priority, such as:

  • Heat Disinfection
  • Chlorination and hyper chlorination
  • Cleaning of fittings or replacement with new or cleaned fitting
  • Implementation of appropriate exposure controls

For more information on these methods, click here.

Management of incidents and emergency procedures

Sampling, swabbing and testing should be conducted as soon as possible. This will help to determine the extent of potential Legionella colonisation within the water distribution system, before commencing appropriate precautionary control measures as a matter of priority.

Record-keeping procedures

Record-keeping procedures are essential to ensure accurate documentation of all results and actions. The documentation should include:


A schedule for updating and reviewing the Water Risk Management Plan

Your Water Risk Management Plan should be a living document that is reviewed regularly by the Water Risk Management Team. This document must be reviewed following incidents or cases, to assess the effectiveness of the response.

Full reviews should be conducted annually (or more frequently), based on the risk assessment after detection of Legionella in the water distribution system or a case of Legionnaires’ disease, or after significant system modifications or change of use.

Frequency, triggers and plans for review should be outlined in this plan.

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