Legionella at airports: what’s the risk?
Time for another instalment in our ‘What’s the risk?’ blog series! Today, Dynamika director Brett Wallace looks at airport facilities; could a legionella outbreak ruin your holiday before it’s even begun?
With the end of the summer rapidly approaching, many of us are already planning next year’s getaways.
But while some of us might get a bit anxious when it comes to air travel, there’s another risk that you may not have even considered; and that’s a legionella outbreak.
How can legionella spread and grow at airports?
Transport facilities like airports are somewhat unique in combining several potential risk areas for legionella growth together on the same site.
Water systems at airports which can potentially harbour legionella bacteria include:
- Water facilities within the airport building itself (including toilets, showers, vendor kitchens and HVAC cooling towers)
- Water facilities used on the ground (including plane/equipment washing, fire suppression and turf irrigation)
- Potable water stored on board airplanes for in-flight drinking supplies and toilets (which are also filled from airport ground facilities)
In all these cases, poor monitoring and disinfection practices can enable the bacteria to take hold.
Lawn sprinklers and jet-washing equipment both pose a particular level of danger, since they naturally produce aerosolised water droplets. Of course, in these cases, the risk is mostly isolated to aviation industry workers rather than the general public.
But it’s on the planes themselves where passengers and crew alike can be put at risk. Planes present an enclosed space where many individuals are packed closely together; so an outbreak of legionella bacteria while on-board could infect tens or even hundreds of people at once.
Water supplies on planes are required to meet international standards for quality and potability; with procedures for the treatment, regular monitoring and disinfection of aircraft water facilities also enforced by international regulations.
Despite this, an Italian study published in 2022 found that out of 126 commercial aircraft examined between 2007 and 2021, almost half of them were found to contain dangerous numbers of legionella bacteria.
What makes controlling legionella risks difficult at airports?
It’s not just the variety of risk factors which make airport facilities problematic for legionella control; it’s also the variety of dutyholders.
Between airport operations managers, airlines, ground handling agents, maintenance teams, security staff, and retail and catering vendors, many different parties play a role in protecting the health and safety of passengers and airport staff. Carrying out a comprehensive risk assessment can therefore be challenging.
In some situations, there may be confusion over who exactly is responsible for carrying out certain risk mitigation procedures; particularly in smaller airport facilities, and especially if communication between individual companies/departments is lacking.
It’s here that essential legionella control procedures can be missed; and that can put everyone in danger.
Further muddying the waters for airlines is the fact that each destination country will have its own particular laws surrounding public health and legionella control.
What are airport employers’ responsibilities for preventing legionella growth?
We can’t break down every single individual country’s public health laws, but we do know that UK legionella regulations are definitely among the most comprehensive.
Just like any other employer, aviation industry employers have a legal obligation to protect staff and customers from the risks of legionella. The usual ACoP L8 and HSG274 recommendations apply; including:
- Carrying out a full risk assessment
- Creating and implementing a control scheme with specific measures to prevent legionella growth/spread; such as regular maintenance and disinfection
- Appointing one or more responsible person(s) to manage the implementation of the control scheme
- Monitoring water systems to ensure control measures are working, regularly reviewing the risk assessment and control scheme, and keeping appropriate records
The UK’s Civil Aviation Authority (or the CAA; which works alongside the HSE to enforce health and safety at airports) has published guidance on airside safety management. The guidance highlights that in previous court cases, employers retain partly responsibility for maintaining health and safety during the actions of contractors.
In other words, while the duty to perform certain legionella control procedures might fall to a particular airline, ground handling agent, maintenance team or other third party service provider (or several of them), it’s also up to the airport operators to ensure that those parties are performing those procedures.
Operators must be taking reasonable steps to:
Review contractors’ safety provisions – in this case, legionella control procedures – to ensure that they are adequate to maintain safety
Co-ordinate and manage arrangements to carry out work – in this case, carrying out those control procedures
Monitor and review safety performance of contractors
This includes communicating safety policies to relevant parties, and allocating the necessary resources for them to be able to carry out the work.
Clear operating instructions for contractors should be set out in the operator’s Aerodrome Manual. This should be widely available so that everyone is on the same page about legionella control (among other safety practices).
In situations where working procedures might overlap between different parties, joint risk assessments are encouraged. Meetings should be held with the airport operator and the relevant parties to establish who is responsible for which duties; and these responsibilities should be clearly documented to avoid any future confusion.
Of course, we’ve only scraped the surface on the complexities of airport safety. For further reading the International Civil Aviation Organization (or ICAO) goes into much greater detail on setting up an effective safety management system in their Safety Management Manual (Doc 9859).
Looking for help with Legionella risk assessments, testing or disinfection?
Dynamika offers a range of water quality management services for all kinds of aviation industry sites. For more information, or to get a quote for your project, call us on 03333 22 0800 or contact us online today.