You've just taken over a site. Maybe it's a new facilities management contract, a new lease, or a building your company has bought. There's a lot to get your head around, and somewhere on the roof (or in the plant yard) there are cooling towers. They come with their own set of legal duties, and those duties don't pause while the handover is going on.
Handovers are where things fall through the cracks. The outgoing team knew how it all worked, the paperwork was "somewhere", and the treatment contract ended on Friday. Here's a practical checklist to make sure your towers stay under control from day one.
First, work out who the duty holder is
Under ACOP L8, the duty to manage Legionella risk sits with the employer or the person in control of the premises. On a leased or managed site, that can be split between landlord, tenant and facilities manager, depending on the lease and contracts. Before anything else, get clear on who holds the duty for the cooling towers, and make sure it's written down. Everything else follows from that.
The handover checklist
People and responsibilities
- Has a responsible person been appointed to manage Legionella control, and a deputy? If the previous one has left with the outgoing contract, appoint a new one in writing.
- Do they have the training and authority to do the job?
- Who's the water treatment contractor? Is the contract continuing, ending or being retendered?
The plant
- How many cooling towers and evaporative condensers are there, including standby, seasonal and "disused" units? Are the disused ones actually disconnected?
- Is there a schematic showing towers, pumps, dosing, bleed and sample points?
- What state is it all in? A walk-round with someone who knows towers is worth booking early.
Risk assessment and written scheme
- Is there a current Legionella risk assessment covering the towers?
- Does it reflect the plant as it is now, and the current people and contracts? A change of management is itself a reason to review it.
- Is there a written scheme, and is anyone actually following it?
- Are actions from the last assessment closed out?
Records
- Is there a log book, and is it complete? Look for weekly dip slides, chemistry, dosing checks, Legionella results from a UKAS-accredited lab, and corrective actions.
- When was the last clean and disinfection? Is there a certificate? HSG274 Part 1 expects cooling towers to be done at least twice a year.
- When was the last Legionella sample, and what did it show? Any recent high results, and were they followed up?
Our post on what should be in a cooling tower log book is a useful companion here.
Notification
- Is there a copy of the notification to the local authority under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992?
- Is it in the right name and up to date? If control of the premises has changed, the council's record may need updating. See do you need to notify the council?
Chemicals and safety
- What treatment chemicals are on site, and are there COSHH assessments and safety data sheets for them?
- Is chemical storage safe, bunded where needed and clearly labelled?
- Is there safe access to the towers, with any permits, working at height arrangements and isolations documented?
Avoid the gap
The single biggest risk at handover is a gap in service. The outgoing contractor's last visit is on the 28th, the new contractor's first visit is "sometime next month", and in between nobody is checking the dosing or taking dip slides. Plan it so there's no break: agree the end date of one contract and the start date of the next, make sure chemical stock won't run out in between, and get the records handed over before the outgoing team leaves.
Imagine a new FM provider starting on a multi-building site. The outgoing provider's treatment contract ends on the same day. The log book turns up a fortnight later, with the last month of entries missing and a cleaning certificate that's eight months old. The new team's first jobs are clear: get monitoring going straight away, book a clean, review the risk assessment and update the notification in the new duty holder's name.
Your first 30 days
- Confirm the duty holder and appoint the responsible person in writing.
- Make sure monitoring and dosing carry on without a break.
- Gather every record you can find and identify the gaps.
- Get a competent person to inspect the towers and the treatment kit.
- Book anything that's overdue, such as a clean, a Legionella sample or a risk assessment review.
- Update the local authority notification if needed.
- Brief site staff who'll be doing weekly checks, and give them simple record sheets.
How we can help
Taking on a new site is exactly when a fresh pair of eyes helps. We can audit the records, inspect the plant, review the risk assessment and set up a water treatment and compliance programme that starts on the right day. If you've just inherited some towers and you're not sure where you stand, give us a call.
Just inherited some cooling towers?
We'll audit the records, look at the plant and give you a clear list of what needs doing first, with no gap in treatment.