Meet the Experts: Paul Robinson


If you’ve been following our ‘Meet the experts: A year in review’ series, you will have seen insights from experts across the Bureau Veritas organisation. Today it’s the turn of Paul Robinson, who manages our Air and Water Quality business unit.

Here he speaks to Vicky Shah, our sector lead for retail, hospitality and leisure, about the challenges of Legionella assessment and control. Including the importance of competence across organisations.

Vicky Shah: Tell us about your own experiences through the years and how they help you in your role at Bureau Veritas.

Paul Robinson: I've been working in the field of air and water quality for nearly 18 years, having started as a legionella risk assessor myself before working through contract management and commercial roles to my current position. My 'hands-on' experience has certainly helped to keep me to grounded with the day-to-day issues faced by our field consultants, although I don' t miss crawling through loft spaces on the occasional warm days we have in England!
Now, as the indoor air and water quality business unit manager for Bureau Veritas UK and Ireland, I’m responsible for the commercial aspects of the business such as ensuring financial delivery targets are met, as well as the overall management of the area manager and field staff ultimately delivering the work to our clients.

VS: What is the most significant legislation that impacts your clients and how can Bureau Veritas support them?

PR: As with all things Legionella-related, the prevailing legislation and guidance is contained with the Approved Code of Practice L8 and the accompanying guidance HSG 274 Parts 1, 2 and 3.

Falling under COSHH Regulations, the management of Legionella follows the process of risk assessment, elimination of risk and the controlling of residual risk. The prescriptive details in the HSG 274 documents go a long way to providing Duty Holders and the Responsible Person with all the information they need to control the risk of Legionellosis.

VS: What are the key areas to be considered?

PR: Competency is key where Legionella is concerned and Legionella control is far more than just ensuring a Legionella risk assessment is undertaken. It's all well and good putting in place a suitable scheme of control in terms of the checks that need to be made on a routine basis, but the worth of competent individuals comes to the fore when ‘out of specification’ results are returned and suitable action is required.

VS: What is required to achieve compliance?

PR: As I mentioned previously, the HSG documents provide a thorough overview of what is required in terms of what checks are required and on what frequencies. An organisation that can demonstrate a suitable and sufficient Legionella risk assessment is in place and that risks are being controlled, with records of such controls being recorded, is well on its way to demonstrating compliance.

VS: In your mind, why does it sometimes go wrong?

PR: Competency is certainly an area where things go wrong on many levels. If Duty Holders and the Responsible Person do not have a sufficient level of understanding, they can leave themselves in the position of procuring services unfit for purpose or with control regimes that are not diligently applied and recorded.

Similarly, being a largely unregulated industry, the competency of Legionella risk assessors varies widely and it’s often the case that you get what you pay for. As a legal document, the findings of a risk assessment report can be reviewed as part of legal process if the worst comes to the worst, so clients need to be comfortable with the competence and level of support their supplier can offer.

One of the biggest challenges we see from the client’s point of view is the sheer volume of sites that often form part of an organisation's portfolio. The management of information on a local level is often very difficult to manage from a central location and reliance on site-based individuals can result in widely varying degrees of competence and emphasis being placed on Legionella control. The adoption of group level policies, procedures and record-keeping documents can go a long way to ensure consistency in approach, whilst also providing an effective benchmark for performance evaluation.

VS: How does your team help?

PR: Being drawn from all levels of the water hygiene industry, my team is well versed in the guidance and its application, whilst our rigorous quality processes and procedures ensure every member of our team is at the top of their game all the time. We can deliver Legionella risk assessments and monitoring programmes along with audits and bespoke consultancy, and we prefer to adopt a stance of independence over the completion of remedial works so that our clients can have faith in the objectivity of our recommendations.

We appreciate that the application of the guidance needs to happen but we also acknowledge that this needs to be done within the confines of the operational requirements of our clients' business. For this reason we are eminently capable of providing bespoke solutions that fit our clients’ requirements in terms of the resources they have available – and that means finances as well as personnel.

VS: What one top tip would you give your clients?

PR: One of the things I always used to come across as an assessor - and still do when discussing contract reviews with clients - is that records are essential to effectively demonstrate control of Legionella.

All too often maintenance teams confirm that they are completing the weekly flushing, monthly temperature checks and plant inspections but do not then follow this through with actually documenting the results of their checks within a site logbook.

In such circumstances, in the eyes of an auditor there is no difference between those that are not carrying out the checks and those that are carrying out the checks but not recording them. The paper trail is everything.

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