Consultancy – Compliance – Assurance

Are you confident regarding what is required to become compliant with your legal statutory obligation in regards your water hygiene documentation and compliance?

How we can help you

Our consultancy provides independent and impartial professional advice on water hygiene challenges for controlling Legionella bacteria contamination and Pseudomonas Aeruginosa.

IHEEM Registered Authorising Engineer (water)

Our culture is to work with you.

• Becoming a member of your Water Safety Group

• Writing your water safety plan and written schemes

• Auditing your water management and operational controls

• Assessing the quality and competence of Legionella risk assessments  

Paul Nolan

Managing Director
FIHEEM FSOE FIPlantE  

"We take pride in sharing our experience with valued clients "


Paul is the MD of his bespoke water hygiene consultancy providing independent and impartial advice on water hygiene management advising on the legal drivers for L8 compliance, a qualified BS OSHAS 18001 Lead Auditor and European guest speaker.

He has AE (water) contracts with several large NHS Trusts across the UK and was the water hygiene Authorising Engineer for the Athletes Village, during the London Olympic Games 2012.

Fifty two years working experience in the FM industry, the past twenty years of which he has specialised in water hygiene management, developing a comprehensive understanding of water hygiene guidance including microbiological waterborne contamination in water systems. In 1996 he was the Head of the Estates department, for 5 years at The Royal Liverpool University Hospital followed by a further twelve years PFI experience with the Australian based Lend Lease Ltd on their healthcare and education contracts as their Authorising Engineer.

He currently provides training and AE advice regarding the revised (2016) HTM 04 01 which can create a financial risk for the PFI contractor and Trusts. Recently a BSI British Standards panel member for the revision of BS8558:2011 and co-author of a book, published in Brazil titled: Safety Plans of Water - Vision of Specialists.

He is an experienced European public speaker and recently carried out a water hygiene infection control audit for the Spanish Navarre Government at their world leading Cancer Hospital in Pamplona.

Fifteen years experience working closely in the PFI Healthcare sector.   

Consultancy, Compliance, Assurance 

    Authorising Engineer (water) 

• Independent and Impartial IHEEM REGISTERED Authorising Engineer

• Qualified Occupational Health and Safety Systems Lead Auditor – BS OHSAS 18001:2007 Auditing and reporting regarding compliance with statutory regulations for water hygiene management and operational controls.

• A member of the Trust water safety group (WSG) in compliance with HTM 04 01 (2016)

• Writing and developing Water Safety Plans (WSP) in compliance with HTM 04 01 (2016)

• Writing Written Schemes and Escalation Pathways for the hospital estates department.

• Design reviews for hot and cold water installations – Construction Phase.

• Assessing Legionella and Pseudomonas risk assessments - identified risks can be derogated and costs for remedial works saved.

• Legionella awareness training for staff

• Legal drivers awareness training for water hygiene management

• Assessing, training and informal interview for potential Responsible Persons before being appointed

• Review current water hygiene polices, ensuring they are current with statutory obligations

• Creating Legionella Pseudomonas aeruginosa sampling plans

• Infection control risk assessments for Pseudomonas aeruginosa  

Water Safety Plans

Water Safety Plans are an additional way to manage hot and cold water systems which can align with your statutory obligations:

1. Health and Safety at Work etc Act 1974
2. Control of Substances Hazardous to Health Regulations 2002
3. Management of Health and Safety at Work Regulations 1999

The concept of water safety plans originates from HTM 04 01.

The risks from waterborne pathogens such as Legionella and Pseudomonas bacteria contaminating your hot and cold water systems should never be underestimated in a hospital healthcare environment.

Water Safety Plans are a good approach with Infection control and water hygiene management and is a recognised NHS key document minimising this risk.

Water Safety Plans should not be onerous and voluminous.

Our WSPs are written specifically for your hospital requirements and then they become a “living document” being reviewed regularly to ensure they are current and maximising water hygiene regimes.

We recommend that a Water Safety Plan is based around complimentary and not mandatory implementation which should contain a proportionate and achievable scope aim and purpose.  

Legionnaires' disease

Legionnaires' disease is a potentially fatal form of pneumonia. Legionnaires' disease, also known as legionellosis, is a form of atypical pneumonia caused by any type of Legionella bacteria.

Signs and symptoms include cough, shortness of breath, high fever, muscle pains, and headaches. Nausea, vomiting, and diarrhoea may also occur.

This often begins 2–10 days after exposure.

If you are an employer, or someone in control of premises, including landlords, you must understand the health risks associated with legionella.

Duties under the Health and Safety at Work etc Act 1974 (HSWA) extend to risks from legionella bacteria, which may arise from work activities.

The Management of Health and Safety at Work Regulations (MHSWR) provide a broad framework for controlling health and safety at work. More specifically, the Control of Substances Hazardous to Health Regulations 2002 (COSHH) provide a framework of actions designed to assess, prevent or control the risk from bacteria like Legionella and take suitable precautions.

The Approved Code of Practice known as L8 Legionnaires’ disease: The control of Legionella bacteria in water systems contains practical proportionate and pragmatic guidance on how to manage and control the risks in your system.

As an employer, or a person in control of the premises, you are responsible for health and safety and need to take the right precautions to reduce the risks of exposure to legionella.

Carrying out a risk assessment is your responsibility.

You may not have the skills and experience to carry out the risk assessment yourself.

We can help you carry out this legal obligation by using our expertise to write the risk assessment specification for tendering out in the market place.

Pseudomonas aeruginosa 

Gram-negative rod measuring 0.5 to 0.8 µm by 1.5 to 3.0 µm. Almost all strains are motile by means of a single polar flagellum.

The bacterium is ubiquitous in soil and water, and on surfaces in contact with soil or water.
Its metabolism is respiratory and never fermentative, but it will grow in the absence of O2 if NO3 is available as a respiratory electron acceptor.

The typical Pseudomonas bacterium in nature might be found in a biofilm, attached to some surface or substrate, or in a planktonic form, as a unicellular organism, actively swimming by means of its flagellum.

Pseudomonas is one of the most vigorous, fast-swimming bacteria seen in hay infusions and pond water samples. In its natural habitat Pseudomonas aeruginosa is not particularly distinctive as a pseudomonad, but it does have a combination of physiological traits that are noteworthy and may relate to its pathogenesis.

Its optimum temperature for growth is 37 degrees, and it is able to grow at temperatures as high as 42 degrees. Although there is evidence to suggest it can grow at temperatures from 10 degrees centigrade

Pseudomonas aeruginosa is an opportunistic pathogen, meaning that it exploits some break in the host to initiate an infection.

In fact, Pseudomonas aeruginosa is the epitome of an opportunistic pathogen of humans.
The bacterium almost never infects uncompromised tissues, yet there is hardly any tissue that it cannot infect if the body tissue are compromised in some manner.

It causes urinary tract infections, respiratory system infections, dermatitis, soft tissue infections, bacteremia, bone and joint infections, gastrointestinal infections and a variety of systemic infections, particularly in patients with severe burns and in cancer and AIDS patients who are immunosuppressed.

Pseudomonas aeruginosa infection is a serious problem in patients hospitalised with cancer, cystic fibrosis, and burns. The case fatality rate in these patients is possible.

Like other members of the genus, Pseudomonas aeruginosa is a free-living bacterium, commonly found in soil and water

Viable But Not Culturable (VBNC)

Refers to bacteria that are in a state of very low metabolic activity and do not divide (sleeping), but are alive and have the ability to become culturable once resuscitated.

Bacteria in a VBNC state struggle to grow on standard agar growth plates.

Bacteria can enter the VBNC state as a response to stress i.e. due to
adverse\nutrient\temperature\oxygen and light conditions.

The cells that are in the VBNC state are morphologically smaller and demonstrate reduced nutrient transport and rate of respiration. Sometimes VBNC bacteria can remain in that state for long time periods.

It has been shown that numerous pathogens and non-pathogens can enter the VBNC state, and this potentially has significant implications when attempting to culture bacteria on an agar plate.
Quantitative Polymerase Chain Reaction (qPCR)

An international trial has compared the use of qPCR for Legionella with culture and aimed to establish guidelines for action and alert levels as determined by this technology.

The study confirmed the relatively large discrepancy between the results for Legionella species by qPCR and culture and the better correlation for L. pneumophila.

In hot and cold water below 50 ºC the differences reported by Lee et al. (2011) between qPCR and culture could be explained simply by the culture method only recovering 40–60% of the organisms (i.e. the poor overall recovery by culture alone).

qPCR offers a rapid, reproducible means of monitoring water for the presence of L. pneumophila. It can be used for routine monitoring for L. pneumophila and is particularly useful for investigating outbreaks and failures in control, providing the data are correctly interpreted.

The application of qPCR can prevent unnecessary expenditure and importantly, can quickly rule out negative sites, enabling better focusing of control measures.

Detection of numbers of L. pneumophila dead or alive in a water system indicates that there has been amplification of L. pneumophila within the system.

If these are dead at the point of sampling this indicates that control measures are limiting the release of viable legionellae, but should these be relaxed for any reason the system could immediately present a significant risk to health.

The added benefit of qPCR is that sampling results are known within 24 hours, rather than 10 to 14 days for agar plate sampling.

A selection of clients

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"We take pride in sharing our experience
with valued clients "

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