Designing a Compliant Legionella Monitoring System

A clear, step-by-step way to understand what Legionella compliance actually requires and whether changing how you monitor is right for your buildings.


If you’re responsible for a building or an estate, you already know that Legionella compliance isn’t about ticking boxes. It’s about being able to stand behind your decisions when systems change, buildings evolve, and questions are asked.


This walkthrough is designed to help you move from habit to intent, starting with your schematic drawing and ending with a clear financial reality check.

Certified member of the Legionella Control Association (LCA) and trusted nationwide by high-stakes sectors like Healthcare and Housing.

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Facilities Management Awards UK 2025 logo with colorful geometric design.

Everything starts with the schematic

Before you think about visits, sensors, data, or cost, there is one non-negotiable requirement:

You need an accurate schematic drawing of your water system.

If your schematic is wrong, everything built on top of it is compromised. Monitoring points are guessed rather than justified. Data; whether manual or automated becomes misleading. And when something goes wrong, explaining why decisions were made becomes extremely difficult.

This is true whether you:

  • continue with traditional manual temperature checks, or
  • move toward automated monitoring


An accurate schematic is what connects the physical system, the risk assessment, and the monitoring regime into something defensible.


If your schematic isn’t right, you can prove activity, but not control.


If you need help correcting or producing a compliant schematic, we provide this as a standalone service.

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Where legislation expects you to demonstrate control

UK guidance (ACoP L8 and HSG 274 Part 2) doesn’t expect you to “check a few outlets and hope for the best”.

It sets clear expectations about where control must be demonstrated.

Using the schematic example in Appendix 4 of HSG 274 Part 2, this walkthrough shows you how to identify monitoring requirements across your system — including:

incoming cold water supplies

calorifiers and hot water generation

hot water

return loops

sentinel

outlets

higher-risk and low-use areas

This stage isn’t about technology.
It’s about understanding how many points of visibility are actually required to demonstrate control of your system.

Once you see this mapped properly, compliance stops feeling vague.

Turning a schematic into a monitoring strategy

When your schematic is accurate and legislative expectations are clear, the next step becomes straightforward.

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Healthcare & NHS
  • Wards closed and services suspended
  • Patients and staff relocated
  • £1m+ impact to mental health services
  • £46m facility opening delayed
A house outline with a heart inside, representing home and love.
Care & Housing
  • Care home evacuations
  • Sheltered housing fines (£900k)
  • Multiple housing schemes affected
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Leisure & Community
  • Repeat closures
  • Permanent closure and £1.5m demolition
  • £3m repair costs
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Education
  • 600 pupils unable to start term
  • Emergency closures and isolated water supplies
  • Special schools shut at short notice
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Justice & Civic Buildings
  • Prisoner death and legal consequences
  • Council HQ closed immediately
  • Legal buildings unable to reopen

How a “manageable issue” becomes a disruptive event

You rarely go straight from “everything is fine” to a full closure.

The pattern is usually a progression and the earlier you can see it, the more options you have.

Diagram showing three stages of business disruption: Early, Operational, and Crisis, with associated factors for each.

What compliance gives you — and what it can’t

If you follow ACoP L8 and HSG 274, you’re doing what the system expects: you’re meeting a defined baseline and documenting evidence. That matters, but it also has limits.

Compliance gives you:

  • Evidence that checks were completed
  • Records for audit and governance
  • Defined responsibilities
  • A defensible baseline position

Compliance can’t give you:

  • Continuous visibility of system behaviour
  • Early warning of deterioration
  • Insight between inspection points

This is not a failure of people or process. It’s a limitation of periodic oversight in systems that change continuously.

Map of England with colored pins marking various locations.
List of locations with counts: Hospital (10), Leisure Centre (4), Care Home (3), Primary School (3), and others (2 each).
Map key showing locations, including university, community, legal, prison, leisure, NHS, and schools.
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The cost of late discovery

If you’re accountable for risk, the question is rarely “can we pass an audit?”
It’s “what happens if we’re forced into disruption?”

Direct costs shown
in the data
Costs you’ll recognise that aren’t included
  • £167k care home fine
  • £600k prison fine
  • £900k sheltered housing fine
  • £1m+ mental health ward impact
  • £1.5m demolition
  • £3m repair costs
  • Legal fees
  • Insurance premium increases
  • Staff disruption and overtime
  • Lost revenue
  • Reputational damage

These examples don’t include the cost of lost trust, scrutiny, or stakeholder confidence.

If you manage multiple sites, you carry a different kind of risk

A person examines a complex plumbing system, writing on a clipboard. The system has red and blue pipes in a utility room.

As the number of sites you oversee grows, so does the likelihood that Legionella will develop somewhere, even if controls are in place.


Not because you’re careless.


Because checks are periodic and systems evolve between them.

At scale, the biggest exposure is often not illness.


It’s the operational and reputational impact when deterioration is discovered late and forces immediate action.

A reality check

As you look through the examples on this page, you’ll already know which sites concern you most.


Not hypothetically but specifically.


The buildings where systems are complex.


The facilities with vulnerable occupants.


The sites where closure would be hardest to explain.


This page isn’t asking you to act immediately.

It’s asking you to pause and consider one question:


If conditions began deteriorating quietly in one of your buildings, how early would you know and how disruptive would discovery be when it finally came to light?

What You Can Expect

Richard Thornett - Lead Engineer - BSW Southampton

“It is like having an engineer 24/7 with their hand on the plant”

James Shaw - Director - Miller Freeman - Nottingham

"The real time data allowed us to make several minor adjustments and changes to achieve satisfactory temperatures throughout the property that would not normally be picked up."

Brendon Moylan - Property Manager - Oakfield Community

“It gives us a good hold on monitoring the whole system”

Andy - Director - Tackle Tidy - Redditch

“I can sleep at night knowing that I'm not putting us in any kind of danger”

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Want to Understand the Bigger Picture?

Need something you can share internally?

Download the one-page, board-ready briefing that summarises the map and the patterns behind it.


Legionella risk management isn’t just about paperwork.


It’s about keeping buildings open, services running, and people safe over time.

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Zero signup required. Get access to the PDF.

Talk it through before disruption forces the conversation

If you want to discuss what earlier visibility could look like across your sites and how it reduces disruption risk we’re happy to help.

Our team is ready to help whether you manage one site or many.

or call 01827 259346 to get started today.