ACoP L8 Para 51

An illustration of the levels of service which should be expected from service providers can be found in the Code of Conduct developed jointly by the Water Management Society and the British Association for Chemical Specialities (WMS/BACS). The Code of Conduct does not have any legal status under health and safety law, but should help occupiers choose a suitable service provider to help them control the risks from legionella bacteria.

Buyers (Client) guide to the C.C.A.

Users (Service Providers) guide to the

Preparation of a Statement of Compliance

The statement should be a single concise document.

It should be written for C.C.A. Committee and customers

Be concise - approximately 3 or 4 pages, written in the present tense, in plain English and in an unambiguous manner.

Be auditable - it is a condition of registration that you have in place formalised management systems referring to detailed written procedures ensuring compliance with all elements of the Code. The statement is a single document that ties these separate procedures together. It should be possible to use it to trace the referenced management procedures and establish through documentary evidence that you comply with the Code.

Address all the service provider commitments - there should be a statement of how compliance is achieved for each of the bullet points within the service provider commitments.

Explain how you comply -The statement of compliance should make specific reference to documented procedures. State the title and reference of the documents, their relevance and how they enable you to comply. It is not sufficient simply to restate the service provider commitments as a "wish list". If a commitment is not applicable to your operation then the reason for its exclusion should be clearly stated.

Management system - this describes how you monitor and control your business, it consists of a set of written procedures that contain the instructions to carry out an action

.	Guidance
1. Allocation of responsibilities The service provider will:
explain in detail the client's obligations under the legionellosis legislation	Don’t use wooly statements like “we do or we will” Reference the legislation (L8 at least) and name a procedure that drives the issue of a document (ref.). If you don’t have a procedure write one! The C.C.A. is about documented systems.
identify those services covered by the contract and those which should be provided by the client to meet all current obligations	By all accounts this is some form of list detailing items covered and items not covered by your agreements.
formalise an agreement detailing the respective responsibilities for each requirement	Reference your procedure (WMS/CCA/01c) for issue of agreements and reference your written agreement document (WMS-AG01/06).
2. Training and competence of personnel The service provider will:
supply details of the training that is provided to his personnel associated with the control of legionellosis	Build a training matrix relevant to your activities for each employee and define a procedure name for the monitoring and action required to train staff.
indicate how personnel competence is assessed, training needs are established, and what measures are taken to ensure that personnel are kept up to date with best practice procedures	Competence is not a training certificate! Tell them how you assess if an individual can do their job correctly. Shadowing by senior management using a job instruction and commenting on compliance?
assist the client to assess and meet the training needs of the clients staff	Detail the mechanism you have for ensuring that this is done. Contract review?
3. Control measures The service provider will:
indicate how the design, monitoring and maintenance of an appropriate program of control measures is assessed	If you are supplying a full water treatment service they are going to want to see more than an Lp flowchart! Method statements, product manual, control limits, works planner, assessment of staff returns there is lots to go in the statement here all cross referenced to your documents.
have a system for verifying that corrective and preventive actions are implemented	Stating that your engineer leaves a report does not cut it! Who checks reports client progress, follows up repeated non-conformities?
4. Communication and management The service provider will:
detail the management systems which operate if the control program deviates from specification, e.g. a positive legionella result, and show how these are audited	Here standard escalation procedures are needed from onsite out of spec results through to Legionella positive reaction system.
indicate how his management team would communicate with the client's team in the event of any necessary actions	Contacts data base and onsite logbooks?

We hope this gives you a feel from an assessors view point, if you want help developing your policy or procedures behind it contact us.

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