HTM 03-01

The Department of Health Technical Memorandum 03-01: Specialised ventilation for healthcare premises Part B : Operational management and performance verification  has introduced new practices for the management of healthcare ventilation systems. Critical care systems are now to be inspected on a quarterly basis and all systems are to be inspected on an annual basis. Findings should be recorded and areas with visible dirt or deposits should be cleaned.

 

Fire hazards from dirty ducts

Grease contaminated kitchen extract ducts represent an increased fire hazard to properties. In recent times, wealth generation has seen a rapid increase in the number of restaurants in the U.K. However, this increase has also brought with it a corresponding increase in serious restaurant fires. This is because of unprecedented grease accumulation in extract ducts. Insurance companies are rapidly getting tired of paying out enormous sums of money due to large scale ductwork fires and are now frequently refusing cover unless clients meet standard ductwork cleaning procedures.

 

Annual insurance losses resulting from fires that are caused by dirty extract ducts have risen in the past two years from £25M to £65M according to statistics provided by the Association of British Insurers. We all have a duty to safeguard life, property and the environment.

 

The current UK market is growing through our membership of the European Parliament and it’s requirements to fulfil an annual inspection/clean of ventilation hygiene systems.

 

Health and Safety Executive

After recent events in the UK i.e. Heathrow Airport and South Mymms Kitchen Extract fires (South Mymms resulted in a £10M claim alone), The Health & Safety Executive and Environmental bodies are becoming more aware and are aiming to place the onus of environmental ventilation hygiene on the Building owner/ Employer to maintain a cleaning regime/register to ensure the employees and general public are provided with clean, uncontaminated air.

 

In this country the rate of small fires, costing less than £100,000 each, which are caused through contaminated kitchen extract systems continues to rise. Smaller insurance companies have now decided to stop providing insurance cover to restaurants and fast food outlets, as the accumulated losses have grown to be unsupportable. The larger insurers have put up their rates significantly whilst also limiting their exposure in this sector, turning away business. The Fire Brigade now includes an inspection of kitchen extract systems when surveying restaurants or fast food outlets for fire integrity. The market for decontaminating kitchen extract systems is set to rise considerably

 

The Regulatory (Fire Safety) Order 2005
From April 06 it will be an offence if systems are not maintained from a fire risk prospective and in the event of personnel injury or death from a fire associated with a poorly maintained system (section 17 of the RRO), charges of corporate liability or manslaughter may be brought against the kitchen operator (responsible person). For compliance with this regulation, Health and Safety Executive, Environmental Health Officers and Fire Inspectors will look for a maintenance routine that includes regular inspection of all ventilation systems to enclosed spaces. They will expect to see logs of the results of these inspections. Inspection frequency will vary accordingly to age and type of system: location and use, the results of the initial survey. Any assumptions and conclusions made should be documented and filed.
The need for cleaning will be determined by the initial inspection, risk
assessments and frequency by the on-going inspections. The definition of ‘Clean’ may be taken as visually clean depending on individual circumstances.

 

Legislation

The Health and Safety at Work etc Act 1974, lays down that: -

 

“Employers and Persons concerned with premises owe the common duty of care both to employees and others who may use or visit the premises”

Section 2 (2) (e)

 

“Requires that you as an employer , provide and maintain a working environment that is , so far as is reasonably practicable, safe and without risk to health.”

Cleaning Intervals – Kitchen Extract Systems

Lead Paint:

The HSE published the Control of Lead at Work Regulations in October 2002 which negates that in any cases where lead is present it must not be disturbed, much like asbestos, lead dust can escape and cause constipation, anaemia, headaches and worst case scenario, toxic encephalopathy.
Control Measures must be utilised to reduce human exposure. Controls include: Medical Surveillance of any persons that come into contact, containing the area to reduce airborne spores & dust, provision of hygiene facilities, etc.

 

Guano:
Although there is no specific  legislation surrounding the removal of Guano and/or vermin carcases, other than the fundamental requirement to provide a safe system of work and safe place of work, (Reference: Health and Safety at Work etc Act 1974) Exposure to airborne droppings particulate can cause severe respiratory disease such as pssittacosis, (commonly known as ‘pigeon fanciers lung).

Disturbance of droppings if not suitably suppressed and give rise to airborne particulate and migration of mites.

Ductclean UK Limited have extensive experience in dealing with such nuisance. In severe cases, or where building users can be affected we can undertake this work under fully controlled conditions.

 

C-Difficile/MRSA:
All NHS Trust foundations must comply with regulations as set out by the Department of Health. Each Trust must invoke their own procedures that address C-Difficile/MRSA and are monitored closely by the CareQuality Commission. It is up to the Trust themselves to deal with the problem at hand but they must show reduction, containment and in some cases eradication of the bacteria.

 

Under the CoSHH Regulations a biological agent is defined as:

 

‘a micro-organism, cell culture, or human endoparasite, whether or not genetically
modified, which may cause infection, allergy, toxicity or otherwise create a hazard
to human health.’

The usual principals of prevention apply, with special emphasis in the cleaning of surfaces to prevent escalation and spread of such agents.

 

Asbestos Regulations:
The Control of Asbestos Regulations 2006 (C.A.R. 2006) clearly states that all asbestos in non-domestic premises must be identified, recorded, managed. When an ACM is either samples or removed it must be undertaken in controlled conditions to reduce any exposure to any persons near the exposed area. Waste produced by asbestos remediation must be disposed off in sealed polythene sacks, (or double wrapped in polythene) and taken to specialist asbestos licensed sites. A record of this must be kept of this. This requirement can be found in the Hazardous Waste Regulations 2005.

 

HVCA TR19:
The new guide is an amalgamation of two publications DWTM2 the guide to internal cleanliness of new ductwork installations and an upgraded version of TR17 the original handbook to good practice for the cleanliness of ventilation systems. It includes further improvements to best practice standards with particular reference to kitchen extract systems. At a time when indoor air quality expectations from building occupiers are more demanding than ever TR19 is a must have reference material.

 

Proposals on revised Control of Asbestos Regulations

The HSE have released a consultation document on proposed changes to the Control of Asbestos Regulations. (Consultation Document CD237).

 

The consultation sets out proposals “…to implement the changes required to comply with the European Commission’s reasoned opinion on the UK Government’s transposition of Directive 83/477/EEC as amended by 2003/18/EC on the protection of workers from the risks of exposure to asbestos at work. The reasoned opinion confirms the European Commission’s view that the UK has not fully implemented Article 3(3) of the Directive which provides for the exemption of some types of lower risk work with asbestos from three requirements of the Directive: notification of work; medical examinations; and record keeping…”

The HSE are seeking views on: the proposals; the guidance to be produced to explain how the changes will work in practice; and the impact on business.

 

http://www.hse.gov.uk/consult/condocs/cd237.htm