Paul Nolan Water Hygiene Limited

Water & FM Management Consultant


Consultancy – Compliance – Assurance

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  Water Safety Plans

Creating Water Safety Plans are an additional consideration in preparing your annual budgets for managing water hygiene on your buildings.

Resourcing suitable experienced personnel, in terms of expertise and finances, must not be lightly considered. Including, identifying relevant duty holders.

Assembling the team may not be an easy process, because nominated experienced people may need to consider these new responsibilities.

Before being implemented, they should be assessed by:

Authorising Engineer

DIPC or Infection control team

Responsible Person

Statutory Duty Holder.

Water Safety Plans can address issues for water quality, and must be in addition to your statutory obligations of managing water hygiene regimes, in line with ACOP L8 “The control of legionella bacteria in water systems”  

The risks from legionellosis should form an integral part of any WSP, ensuring that there is adequate documentation and communication with the Water Safety Group (WSG) both for normal operation of the systems and following incidents where there may have been failures with control measures, equipment and cases of illness associated with the system

Importantly, if you decide to implement a WSP, it then becomes an ongoing process, and will need to be reviewed and revised so that it remains up to date, in the same way as your Risk Assessment in line with ACOP L8.

We would recommend that any WSP is based around complimentary and not mandatory implementation.

The WSG (if formed to manage the WSP) should be specific with its aims and purpose.


HSG 274

While not statutory under health and safety legislation, the formation of a WSG and implementation of a WSP complements the requirements in the Approved Code of Practice Legionnaires' disease. The control of legionella bacteria in water systems for an adequate assessment of risk and the formulation and implementation of an effective written control scheme to minimise the risks from exposure to legionellosis. This should be applied proportionately depending on the setting”


“Building WSPs should be complementary to any existing plans developed by operators of community supplies”

HTM 04 01

Development of the WSP will complement the existing operational management requirements of Health Technical Memorandum 04-01 and the work that has to be undertaken to fulfil the statutory requirement for a Legionella risk assessment and written scheme for its control and management