Legionella Risk Assessment: Guide for UK Sports Centres and Recreational Grounds or HSG274 and ACoP L

Legionella Risk Assessment in Sports & Leisure Facilities: A Professional Guide

As water safety specialists working within the sports sector, we understand that these facilities present unique challenges for effective Legionella management. The combination of showering facilities, swimming pools, spa areas, and seasonal usage patterns creates a distinctive risk profile requiring specialised approaches. This guide explores the essential considerations for conducting Legionella risk assessments in sports facilities, focusing on building complexity and key risk factors.

Understanding Your Legal Position

As a facility owner, manager or operations director, you likely serve as either the duty holder or responsible person under the Health and Safety at Work Act 1974 and COSHH Regulations 2002. The HSE's Approved Code of Practice L8 and HSG274 provide the compliance framework, but effective implementation requires understanding your specific operational context.

Your key responsibilities include:

• Ensuring comprehensive risk assessments by competent individuals
• Implementing appropriate control measures
• Maintaining ongoing monitoring processes
• Keeping detailed records
• Providing appropriate staff training across relevant departments

Proactive engagement with these responsibilities creates safer environments while effectively managing compliance obligations.

Building Complexity: A Critical Factor in Risk Assessment

The Challenge of Sports Facility Water Systems

The physical configuration of your facility's water systems shapes your Legionella risk profile and management requirements:

1. Multiple Water System Types

Most sports facilities feature diverse water systems:

• Changing room shower facilities
• Swimming pools and associated plant rooms
• Spa pools, therapy pools and hot tubs
• Drinking water fountains
• Irrigation systems for outdoor playing surfaces
• Decorative water features

This diversity creates a complex network requiring comprehensive mapping. Critical risk areas often emerge where different systems interface, requiring careful management to maintain appropriate control.

2. Mixed Building Stock and Age Profiles

Many sports facilities have evolved over time:

• Original buildings with legacy plumbing systems
• Extensions or additional facilities added during different periods
• Converted spaces repurposed for changing sports requirements
• Outdoor facilities with separate water systems

This development pattern often results in complex interconnections between different sections, creating potential dead legs and redundant pipework. We recently assessed a leisure centre that had expanded from an original swimming pool to include gym, sports hall and spa facilities over 25 years – creating a network of interconnected systems with multiple potential risk points.

3. Specialised Water Features

Sports facilities often incorporate specialised water systems:

• Swimming pools with complex filtration systems
• Spa pools operating at elevated temperatures
• Hydrotherapy facilities for rehabilitation
• Ice baths and contrast therapy systems
• Outdoor irrigation networks

These specialised systems require specific expertise and management approaches that differ significantly from standard domestic water system control measures.

Operational Complexity

1. Dramatic Usage Fluctuations

Sports facilities typically experience significant variations in usage:

• Seasonal sporting activities creating different demand patterns
• Weekend tournament peaks followed by quieter weekdays
• Holiday period fluctuations
• Weather-dependent variations
• Event-based usage creating short-term demand spikes



These fluctuations create challenges for maintaining consistent water movement. During periods of low usage, extensive sections of pipework may experience minimal flow, creating potential stagnation issues.

2. Extended Operational Hours

Many sports facilities operate from early morning to late evening, creating specific challenges:

• Need for constant hot water availability
• Limited access windows for maintenance
• Multiple staff shifts with varying expertise levels
• Complex cleaning and maintenance schedules
• Continuous operation with minimal downtime

These operational requirements necessitate carefully designed control strategies that balance user experience with effective risk management.

Key Risk Factors in Sports Facilities

1. Shower Facilities

Changing room showers represent a primary risk area:

High-Volume, Intermittent Usage

Sports facility showers typically experience distinctive usage patterns:

• Intense periods of use immediately after sporting activities
• Periods of minimal usage between sessions
• Weekend tournament peaks creating extreme demand
• Potential for extended quiet periods during off-season

These patterns create unique challenges for temperature maintenance and stagnation prevention. High-demand periods can stress hot water systems, potentially creating conditions where temperatures fall into the hazardous range (20-45°C), while quiet periods can lead to stagnation.

Temperature Management Challenges

Maintaining appropriate temperatures presents significant challenges:

• Multiple thermostatic mixing valves (TMVs) requiring regular maintenance
• High demand creating potential for cold water temperature increases
• User expectations for immediate hot water availability
• Balance between scalding prevention and Legionella control

For facilities with numerous shower points, we recommend implementing a representative sampling approach for temperature monitoring, with sentinel points in each changing area, supplemented by rotating checks of additional outlets.

2. Swimming Pools and Spa Facilities

Aquatic areas present specific Legionella risks:

Swimming Pool Plant Rooms

Pool plant areas contain complex water treatment systems:

• Filtration equipment requiring regular backwashing
• Chemical dosing systems for disinfection
• Heat exchangers for temperature maintenance
• Backwash water systems and balance tanks

While properly maintained swimming pools present relatively low Legionella risk due to disinfection, associated systems like balance tanks and backwash systems can create risk points requiring careful management.

Spa Pools and Hot Tubs

Spa facilities represent one of the highest risk areas:

• Operating temperatures ideal for Legionella growth
• Significant aerosol generation during normal operation
• Complex filtration and treatment requirements
• High bather loads introducing organic material
• Potential for biofilm development in circulation pipework

These facilities require rigorous management protocols aligned with HSG282, including comprehensive water treatment, regular microbiological testing, and enhanced monitoring.

3. Outdoor and Specialised Water Systems

Many sports facilities incorporate outdoor water systems:

Irrigation Systems

Pitch and grounds irrigation networks present specific considerations:

• Seasonal operation, often unused during winter months
• Operation at ambient temperatures favourable to bacterial growth
• Extended pipework covering large areas
• Multiple outlets with variable usage

These systems require specific seasonal commissioning and decommissioning protocols to manage risks associated with intermittent use.

Specialist Therapy Facilities

Performance sports facilities often feature specialised water-based therapy systems:

• Hydrotherapy pools operating at elevated temperatures
• Cold therapy and ice baths
• Contrast therapy systems with both hot and cold elements
• Rehabilitation pools with specialised equipment

These systems may operate under unique temperature regimes and usage patterns, requiring specific risk assessment and control strategies.

4. System Design Features

Dead Legs and Low-Flow Areas

Sections of pipework where water movement is limited create ideal conditions for Legionella colonisation:

• Building modifications leaving unused pipe sections
• Changing rooms reconfigured without proper system adaptation
• Facilities expanded incrementally without comprehensive redesign
• Original designs including long branches to specific outlets

Detailed system mapping is essential to identify these problem areas.

Temperature Control Challenges

Maintaining appropriate temperatures throughout extensive systems presents significant challenges:

• Heat loss in long pipe runs serving distant changing facilities
• Inadequate insulation causing cold water warming
• Return loop balancing issues affecting circulation
• Intermittent use affecting temperature stability

Comprehensive temperature profiling provides essential data for identifying problem areas.

Conducting Effective Risk Assessments

Pre-Assessment Preparation

Before physical inspection, gather comprehensive information:

• Building schematics and water system diagrams
• Previous assessment reports
• Maintenance records and water quality testing results
• Usage data showing seasonal and weekly patterns

Facilities with incomplete documentation often present higher risks due to knowledge gaps about system configuration.

Physical Inspection Elements

A thorough assessment should include:

Cold Water Systems

• Storage tank condition and configuration
• Temperature measurements at tanks and representative outlets
• Assessment of insulation effectiveness
• Identification of dead legs or poor flow areas

Hot Water Systems

• Calorifier/water heater configuration
• Temperature measurements at storage, distribution points, and outlets
• Evaluation of return loop balancing
• Assessment of TMV function and maintenance

Shower Facilities

• Representative temperature measurements across changing areas
• Physical condition of shower heads and hoses
• TMV performance and maintenance status
• Assessment of usage patterns and potential stagnation risks

Specialised Water Systems

• Pool plant configuration and operation
• Spa pool treatment and monitoring systems
• Specialist therapy equipment management
• Irrigation system design and operation

Operational Assessment

Evaluation of management practices should include:

• Review of the written scheme of control
• Assessment of monitoring record keeping
• Evaluation of flushing regimes for infrequently used outlets
• Review of staff training and awareness levels
• Evaluation of communication between departments

Implementing Effective Management Systems

Written Scheme of Control

Develop facility-specific protocols addressing:

• System description and key control points
• Control measures tailored to operational patterns
• Monitoring procedures reflecting usage variations
• Record-keeping requirements
• Response procedures for adverse results

Usage-Based Management Strategies

High-Usage Periods

During peak seasons or events, focus on:

• Maintaining system balance despite high demand
• Monitoring temperature stability under high-load conditions
• Implementing enhanced cleaning of shower facilities

Low-Usage Periods

During quieter periods, priorities shift to:

• Implementing flushing programmes for unused areas
• Considering isolation of completely unused sections
• Enhancing monitoring to verify control effectiveness

Seasonal Transition Management

The transition between seasons requires:

• Structured recommissioning protocols for seasonal facilities
• Enhanced monitoring during initial reactivation
• System preparation for anticipated demand changes
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Interdepartmental Collaboration

Effective management requires coordination across:

• Cleaning staff implementing shower head maintenance
• Facility booking teams providing usage forecasts
• Maintenance personnel conducting regular monitoring
• Pool operators managing specialist water systems
• Grounds staff overseeing irrigation and outdoor systems

Develop clear responsibility matrices and communication protocols, with particular attention to handover periods between teams.

Staff Training Requirements

Implement tailored training programmes:

• Management teams: understanding of legal responsibilities
• Maintenance staff: technical training on monitoring and control measures
• Cleaning personnel: awareness of shower maintenance
• Pool operators: specialist training in water treatment
• Seasonal staff: effective induction on basic awareness

This ensures all personnel understand their role in maintaining water safety.

Conclusion

Managing Legionella risks in sports facilities requires understanding both technical and operational factors. The complexity of these buildings, combined with their distinctive usage patterns, demands a tailored approach.

By focusing on the key risk factors outlined and implementing robust assessment and management processes, sports facility operators can effectively protect users' health while meeting legal obligations. Remember that Legionella control requires ongoing attention as facilities and their usage evolve.

We encourage you to view Legionella risk assessment not merely as compliance but as an integral component of providing safe facilities for your users, protecting both public health and your organisation's reputation.