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Water Safety Policy

Contents

Introduction

At the time of Policy approval Bassetlaw District Council manages in the region of 6,698 tenanted properties. Water systems within blocks and to individual dwellings within the housing stock need to be risk assessed, kept safe for use and, if required, be regularly maintained.

This Policy explains how Bassetlaw District Council’s commitments to water safety – within domestic and non-domestic properties funded via the Housing Revenue Account and as a result directly managed by Housing Services staff – will be met. It will be supported by a Water Safety Management Plan providing more detailed guidance and procedures.

Legionella bacteria can cause a number of diseases including the Legionnaires’ disease. The bacterium is common in natural water sources such as rivers, lakes and reservoirs, but usually in low numbers. They may also be found in purpose-built water systems such as cooling towers, evaporative condensers, hot and cold-water systems and spa pools. Legionnaires’ disease is a potentially fatal form of pneumonia and everyone is susceptible to infection. The risk increases with age but some people are at higher risk as detailed in our Management Plan. If conditions are favourable, the bacteria may grow increasing the risks of Legionnaires’ disease and it is therefore important to control the risks. 

Statement of Intent

Alongside this Policy will sit Bassetlaw District Council's Corporate Water Safety Procedures, which emphasise and illustrate the organisation's commitment and approach to water safety compliance within its non-Housing Revenue Account funded facilities as managed by other staff of the Council outside of Housing Services.

The key objective of this Policy is to describe how Bassetlaw District Council will meet the required statutory, contractual and regulatory requirements in relation to water safety.  It will also cover how Bassetlaw District Council/Cabinet, as Duty Holder, will receive assurance of statutory and regulatory compliance.

The scope of this Policy includes legionella management, scalding prevention, and un-adopted water systems. 

Bassetlaw District Council will comply with all current and relevant legislation and specifically as detailed in the following:

  • Legionella Bacteria in Water Systems Technical Guidance (HSG 274) and Approve Code of Practice L8.
  • Control of Substances Hazardous to Health Regulations 2002 (COSHH).

Bassetlaw District Council takes the view that delivery of the commitments within this Policy will ensure that the requirements of other legislation, such as the Health and Safety at Work Act 1974 and Landlord Tenant Act 1985 will also be met.

In addition, as a Landlord and provider of Social Housing Bassetlaw District Council must meet the requirements of the Regulator for Social Housing’s (RSH) Safety and Quality Standard. 

It is essential to ensure that customers, contractors, staff and visitors remain safe in Bassetlaw District Council’s properties. Failure to properly discharge our legal or regulatory responsibilities may also result in:

  • Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974.
  • Prosecution under Corporate Manslaughter and Corporate Homicide Act 2007.
  • RSH scrutiny.
  • Reputational damage to the Authority and staff.
  • Loss of confidence by stakeholders in the organisation.

Policy

In order to comply with regulatory standards and legal obligations, and to ensure the safety of its customers, staff, contractors and visitors to its properties, Bassetlaw District Council will:

Process

  • Provide clear lines of responsibility for the management of water safety supported by written guidance in the Water Safety Management Plan.
  • Ensure that a clear and consistent process including front-line engagement and enforcement is in place to obtain access to properties to undertake water safety checks, which shall include legal action when required.
  • Proactively assess available data for relevant information about the customer to help gain access (disability, vulnerability, local connections, etc.).

Delivery

  • Regularly review existing properties and assess risk within new stock through a desktop review, which will identify those properties at potential high risk of legionella.
  • All properties with communal stored water systems, and where a potential risk has been identified at desktop review, will have a Legionella Risk Assessment (LRA) undertaken.
  • All other properties identified through the desktop review of potentially high risk will be subject to an LRA to determine if further management is required.
  • The review period for future risk assessments will be established through a risk-based approach within the initial risk assessment carried out by the Competent Person.
  • A water safety management and monitoring programme will be established as required from the LRA findings.
  • A sample of domestic properties without LRAs will be assessed within an ongoing annual programme of LRAs, to determine the level of risk and take action to ensure that staff, customers, contractors and visitors are not exposed to legionella bacteria.
  • Void properties will be flushed and shower heads disinfected or replaced as part of the void management process or before the customer occupies the property if the property has been empty for longer than 7 days. An LRA will be carried out if appropriate.
  • Implement measures to reduce the risk of scalding by installing Thermostatic Mixer Valves (TMVs) to high risk properties, as detailed within the Water Safety Management Plan.
  • Remove lead pipework that may still exist within the housing stock, as Bassetlaw District Council is made aware.
  • Maintain un-adopted water systems to the required standards as defined within the Water Safety Management Plan.

Contractors Competency

  • Bassetlaw District Council has responsibility to ensure that contractors are competent and the following controls will operate to ensure competence can be demonstrated.
  • Only those Legionella/ water treatment contractors registered with and licensed by the HSE, / Legionella Control Association will be permitted to carry out work in our properties.
  • All associated water safety related works will be undertaken by trained and competent contractors who shall be engaged to undertake any water safety related work. This will include a competence assessment against the nature of the work to be completed for any proposed contractor.
  • Carry out an assessment of all contractor competencies annually or at change of contract/contractor, as detailed within the Water Safety Management Plan.

Internal Competency

  • Maintain a skills/training matrix to ensure that all staff undertaking key roles within the scope of this Policy have appropriate training.
  • Operate a detailed competence framework including regular appraisals as part of the Water Safety Management Plan.

Data

  • Maintain an up to date Master Database of all properties where it has a responsibility to provide water safety checks and maintenance.
  • For each relevant property record maintain up to date data confirming which aspects of the water systems and appliances within the scope of this Policy exist and do not exist and the organisation’s associated responsibility.
  • Hold water safety maintenance records electronically in the Master Database by the relevant operational department to be specifically identified in the Management Plan with other Landlord Compliance records.  There may be instances where a hard copy is kept on site and these will be detailed again in the Management Plan.
  • Where a requirement exists hold data and certification relating to the last two safety checks and the next due date.
  • Where a requirement does not exist hold appropriate evidence.

Assurance

  • Ensure that all persons involved with water safety are properly trained and accredited.
  • Carry out works-based assurance activity including checks on certification and post-inspection of onsite works to the level stated within the Management Plan. A proportion of such checks will be carried out by an Independent 3rd Party.
  • Set a timetable for the review of the Water Safety Policy and the associated Management Plan.

Communication

  • Encourage customers, through the provision of publicity information, to allow access to carry water safety checks and inspections and remedial works.

Implementation

This Policy will be effective from 17th March 2020, following Council/Cabinet approval. 

Staff will be made aware of the Policy at priority training and a copy will be available on the intranet. The Policy will be uploaded to the Bassetlaw District Council website. 

This Policy should also be read in conjunction with the Compliance Strategy and Water Safety Management Plan.  

There will be training provided for all those staff involved with the delivery and implementation of the Compliance function both operationally and legislatively.

Consultation

This Policy is based on legislative and regulatory requirements and as     such consultation with customers has not taken place. There has been consultation with internal teams within Bassetlaw District Council.

Equality Analysis (EA)

We believe all people should be treated with dignity and respect regardless of their age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including, nationality, ethnic or national origins), religion, belief or non-belief, sex, or sexuality or by association with someone with any of these characteristics or perception of having any of these characteristics.

The Equality Assessment was undertaken October 2019 and no adverse discrimination was found. (See the full EA document for further     details).

The Council Plan 2019 to 2023 has actions to ‘Improve the quality and performance of Bassetlaw’s housing stock, by regularly inspecting them to ensure that they are maintained to the highest possible standard’ and ‘Ensure that our housing stock is safe and compliant’.

The Council, as a Landlord has statutory, regulatory and legislative requirements it must comply with in respect of areas of compliance.  These include but are not restricted to Health and Safety at Work Act 1974, Regulatory Reform (Fire Safety) Order 2005, Construction (Design Management) Regulations 2015, Control of Asbestos Regulation 2012, Gas Safety (Installation and Use) Regulations 1998, Electricity at Work Regulations 1989, Housing Act 2004.

Failure to comply with these requirements could expose tenants and residents to injury, extreme harm or death and the Council being fined or prosecuted by the Health and Safety Executive.

Monitoring Performance

The following KPIs will be reported:

  • % of Priority Scheme Properties with a valid Legionella Risk Assessment.  Ref: C012.
  • % of General Needs properties within the Legionella maintenance regime where testing has been completed Ref: C013.
    The total number of reportable incidents under RIDDOR for all 6 compliance areas. Ref: C016.

Commentary will be provided for any properties out of date to include the date they became overdue, days overdue, and their position within the access legal process to bring them back into a compliant position. Commentary will also be provided if any properties have outstanding overdue actions. To provide additional context commentary will also include information on the proportion of activities within the reporting period that were undertaken before and after their due date. 

A detailed PI suite will be defined within the Water Safety Management Plan.

The following assurance activity will be undertaken and reported in line with the Water Safety Management Plan:

  • Internal Audit
  • Strategic Review
  • 3rd Party Assurance

Policy Review

This Policy will be reviewed every 12 months or earlier if deemed         necessary though the performance monitoring process. 

Version 6.0

Last Updated on Wednesday, April 22, 2026