Kieran Irving, Legionella and Water Treatment Manager at Lucion Services, explains why recent school closures highlight the need for proactive Legionella management
The temporary closure of Hazeley Academy in Milton Keynes, following the detection of Legionella its water system, has highlighted the compliance challenges faced by Duty Holders and Responsible Persons across the education sector.
For Duty Holders and Responsible Persons, the case underlines a crucial point: water safety compliance cannot be a one-off exercise or box-ticking process. It demands ongoing vigilance, strong procedural oversight, and a clear understanding of how complex water systems should be maintained.
UNDERSTANDING THE RISK
Legionella is a naturally occurring bacteria found in water systems but becomes dangerous when conditions allow the bacteria to multiply. It thrives in stagnant or slow-moving water, particularly at temperatures between 20°C and 45°C. When contaminated water droplets are transmitted into aerosol form and inhaled through showers, taps, or air conditioning systems, there’s a risk of contracting Legionnaires’ disease.
In well-managed buildings, regular water system turnover and temperature control minimise these risks. But even short lapses in maintenance, irregular usage, or system failures can create ideal conditions for growth. For schools and colleges, where facilities often sit dormant during extended holidays or periods of reduced occupancy, the risks are amplified.
EDUCATIONAL ESTABLISHMENTS VULNERABILITY
Schools present a perfect storm of Legionella risk factors. They often operate across multiple buildings of varying ages, each with its own water network and maintenance requirements. Water use fluctuates dramatically throughout the academic year, with classrooms, sports facilities, and science labs going from high usage to near-zero flow during holiday breaks.
When systems sit unused, water stagnation can develop quickly, providing a breeding ground for bacterial growth. Add other contributing factors, such as older pipework, varied water outlets and inconsistent flushing routines, and it becomes clear why schools and universities, specifically on a larger scale, face some of the most complex water safety challenges of any public environment.
COMPLIANCE IS A LEGAL DUTY
Under the Health and Safety at Work Act 1974 and the Control of Substances Hazardous to Health (COSHH) Regulations 2002, Duty Holders are legally required to assess and control the risks posed by Legionella and other waterborne pathogens.
For Duty Holders and Responsible Persons, this means ensuring that:
- Legionella risk assessments are carried out by competent professionals and regularly reviewed.
- Written schemes of control policies are designed and implemented, detailing safe use of water systems, precautions, responsibility and frequency of monitoring tasks.
- Records of inspections, results, and corrective actions are maintained and available for audit.
- Responsible Persons receive appropriate training to understand and manage their systems effectively.
PRACTICAL STEPS TO REDUCE RISK
The best defence against Legionella is prevention. That begins with understanding how water systems behave and implementing measures to keep them moving, clean, and balanced.
1. Legionella risk assessment: Ensure the risk assessment is carried out by a competent individual, and the recommendations within the risk assessment are acted on accordingly by the Duty Holders and Responsible Persons.
2. Temperature management: Ensure hot water is distributed above 60°C from any unit with a capacity greater than 15 litres and ensure this reaches the outlet within one minute above 50°C. Cold water should be stored and distributed below 20°C throughout the system and reach this recommended temperature within two minutes.
3. Flushing routines: Infrequently used outlets, such as those in remote classrooms or sports blocks should be flushed weekly (as a minimum) to prevent stagnation. Flushing of outlets that create significant aerosol release and exposure should be done in a controlled manner.
4. System maintenance: Clean and descale showerheads quarterly (as a minimum), and ensure all outlets are subject to regular inspection. Cold water storage tanks should undergo routine inspections and cleaning and disinfection (when required) to remove any potential nutrients present.
5. Sampling and monitoring: Periodic microbiological sampling verifies that control measures are effective and enables early detection.
6. Holiday management: Extended breaks require scheduled flushing, sampling, and recommissioning before the term begins.
7. Review and update: Risk assessments and control schemes must reflect system changes, refurbishments, or occupancy shifts. All documentation should be subject to review and auditing to ensure compliance.
Embedding these measures into day-to-day operations will reduce the chance of Legionella proliferation, and this becomes a routine part of compliance management rather than a reactive exercise.
WHEN DETECTION OCCURS
The Hazeley Academy case demonstrates that proactive monitoring works. Routine testing identified Legionella before any harm occurred. The school’s swift response, including temporary closure and remedial treatment, prevented potential exposure.
However, the goal should always be prevention, not reaction. Early detection is valuable, but robust monitoring, consistent water movement, and informed oversight remain the most effective tools for maintaining compliance and safeguarding occupants.
BUILDING A CULTURE OF COMPLIANCE
Managing Legionella risk effectively requires more than technical fixes but demands a culture of continuous compliance. Facilities teams should ensure everyone involved in building management understands their role in maintaining safe water systems.
Training, documentation and collaboration between estates, maintenance, and leadership teams are key. When water safety is treated as a shared responsibility rather than a niche compliance issue, schools and public facilities are far better equipped to prevent problems before they occur.
In association with www.luciongroup.com.


