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Phoenix Journal · Ductwork

Legionella Risk in Building Water and Air Systems

Legionnaires' disease is preventable, yet it thrives in the warm, still water and neglected air plant of ordinary commercial buildings. Here is how one site let it happen - and the plain steps that stop it.

LEGIONELLA RISK IN BUILDING WATER AND AI
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Case postmortem

A quiet building over a long summer break looks like a saving. Six weeks later, a cluster of chest infections traces back to a lukewarm storage tank and an air handling unit nobody had opened in two years.

Here is the scenario, drawn from the kind of failure that plays out in commercial buildings every year. A busy site - offices above, a production kitchen and canteen below - winds down for a summer shutdown. Occupancy drops to a skeleton crew. To trim costs, someone turns the heating down and lets the hot water plant idle. The cold water tanks sit still. The rooftop cooling plant keeps ticking over on a timer, and the air handling units that feed the canteen and kitchen extract keep running with nobody watching the drip trays.

Nothing looks wrong. The taps still run, the air still moves, the building is warm. But in the background, water that should be moving has gone still, and water that should be hot has drifted into the danger zone. Legionella bacteria multiply fastest between 20°C and 45°C, and by the time the building fills back up, several systems have been sitting squarely in that range for weeks. When the crews come back, they flush the taps, fire up the showers in the changing rooms and switch the ventilation back to full. Aerosols carry the bacteria into the air people breathe. Within a fortnight, occupational health starts getting calls.

What went wrong

None of this was bad luck. Every failure had a name and, under UK law, an owner. Legionnaires' disease is a preventable pneumonia, and the duty to control it sits with the person in charge of the premises - the dutyholder - under the Health and Safety at Work etc Act 1974 and the Control of Substances Hazardous to Health Regulations 2002. The Health and Safety Executive's Approved Code of Practice, ACOP L8, and its technical guidance HSG274 spell out exactly what that duty looks like in practice. Fall short of an ACOP and a court can treat that as evidence you broke the law unless you can show you did something equally effective instead.

Walk back through the shutdown and the gaps line up:

  • Stagnation. Little-used outlets and full storage tanks that sit still for days are the classic breeding ground. HSG274 expects little-used outlets to be flushed weekly. Nobody did.
  • Temperature drift. Hot water should be stored at 60°C or above and reach the tap at 50°C or above within one minute; cold water should stay below 20°C. With the plant idling, stored hot water cooled and cold water in a warm plant room crept up. Both landed in the growth range.
  • The air side was invisible. Air handling units are not just fans. Their cooling coils shed condensate into drip trays, and a blocked or fouled tray becomes a warm, wet reservoir that the airflow then aerosolises straight into occupied space. HSG274 Part 3 treats these wet systems as a real Legionella risk, yet the trays had not been inspected, cleaned or checked for free drainage.
  • No written scheme, no records. There was no current risk assessment identifying these systems, no written scheme of control naming who does what, and no logbook. ACOP L8 requires records to be kept for at least five years. Without them, there was no trigger to catch any of the above.

The bitter part is scale. This is not a rare event. In 2024 there were more than 460 cases of Legionnaires' disease reported in residents of England and Wales, the great majority caused by Legionella pneumophila. Most cases hit adults over 60, and the illness can be fatal. One idle building can put its own staff and everyone downwind of its cooling plant at risk.

20-45°C
The range where Legionella multiplies fastest in still, warm water
5 years
Minimum period ACOP L8 requires control records to be kept
460+
Legionnaires' cases reported in England & Wales in 2024

The fix

Getting a building back under control is not exotic work. It is a written plan, a competent person and a habit of checking. If you manage a site with hot and cold water services, cooling plant or air handling units, this is the order that closes the gaps:

  1. Commission a proper Legionella risk assessment. A competent assessor maps every water and wet-air system - tanks, calorifiers, dead legs, showers, cooling towers and every air handling unit with a cooling coil and tray - and rates the risk. This is the legal foundation for everything else and it should be reviewed at least every two years, or sooner if the building or its use changes.
  2. Write a scheme of control and name the responsible person. The scheme sets out the control measures, who carries them out and how often. Appoint a named responsible person with the authority and training to make it happen, and make sure they are genuinely competent, not just available.
  3. Hold the temperatures. Store hot water at 60°C or above, deliver it to outlets at 50°C or above within a minute, and keep cold water below 20°C. Check sentinel outlets monthly and a rolling set of others through the year. Never let plant idle into the growth range during a shutdown.
  4. Flush what you do not use. Run little-used outlets weekly, and put a written flushing regime in place before any period of low occupancy - not after. Reinstating a building after a break needs a planned flush and, where risk warrants, disinfection before people return.
  5. Monitor the cooling and air plant. Wet cooling towers and evaporative condensers must be notified to the local authority and dosed, monitored and cleaned to HSG274 Part 1, with dip-slide and Legionella sampling on schedule. Air handling units need their cooling coils, humidifiers and condensate trays inspected, cleaned and confirmed to drain freely - standing water in a tray is a red flag.
  6. Keep the logbook current. Record every temperature check, flush, clean and sample. The paperwork is not bureaucracy; it is how you prove the system is under control and how you spot drift before it becomes an outbreak.
If your building's air-side hygiene has slipped, the same neglect that lets a canteen extract fur up with grease is often what lets a nearby drip tray sit wet and dirty - see why extracted air still feels dusty for how fouled ductwork and units go unnoticed.

Where the water bill gives it away

There is a quiet early warning most managers miss. Systems full of stagnant water, running calorifiers that never cool down and cooling plant left on a timer all show up on the meter as well as in the risk assessment. If your consumption has crept up with no obvious cause, it is worth reading it as a hygiene signal as much as a cost one - the same idle, over-full, poorly controlled water that raises a bill is the water Legionella likes best. If the numbers look off, our note on why a water bill runs higher than it should walks through where hidden usage hides.

The lesson from every postmortem is the same. Legionella does not need a dramatic failure. It needs warmth, stillness and a route into the air - and a building that stopped paying attention. Keep the water moving and correctly hot or cold, keep the wet parts of your air plant clean and draining, keep the records, and the risk stays where it belongs: managed and boring.

Questions

Frequently asked questions

Who is legally responsible for Legionella control in a commercial building?

The dutyholder - usually the employer or the person in control of the premises - carries the legal duty under the Health and Safety at Work etc Act 1974 and the COSHH Regulations 2002. In practice they should appoint a named, competent responsible person to manage day-to-day control. The HSE's ACOP L8 and HSG274 guidance set out what that control must cover, and a court can treat a failure to follow the ACOP as evidence you broke the law.

What water temperatures keep Legionella under control?

Legionella multiplies fastest between 20°C and 45°C, so the aim is to keep water out of that range. Hot water should be stored at 60°C or above and reach the tap at 50°C or above within one minute of running. Cold water should be kept below 20°C. Sentinel outlets should be checked monthly and the readings recorded.

Can air conditioning and ventilation actually spread Legionella?

Yes, where the system holds water. Air handling units with cooling coils produce condensate that collects in drip trays, and humidifiers and evaporative cooling plant hold water too. If those wet parts are dirty or fail to drain, the airflow can aerosolise contaminated moisture into occupied space. HSG274 Part 3 treats these as genuine risk systems, which is why cooling coils, trays and humidifiers need regular inspection, cleaning and confirmed free drainage.

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