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Working both sides of the border: HPSC guidelines vs ACoP L8

Northern Ireland follows the UK framework; the Republic follows the HPSC National Guidelines. For organisations with sites in both, here is how the two line up and where they differ.

HPSC 2009ACoP L8Republic of Ireland

LegioPro works on both sides of the Irish Sea and both sides of the border, so we spend a lot of time explaining how the two regulatory frameworks relate. The short version: the science and the control measures are the same, the documents and the enforcement route are different.

Northern Ireland and Great Britain

Legionella control sits under the Health and Safety at Work legislation and COSHH. ACoP L8 is the Approved Code of Practice; it has a special legal status, in that if you do not follow it you must show you complied with the law in some other way. HSG274 Parts 1 to 3 give the technical guidance for cooling systems, hot and cold water systems and other risk systems. BS 8580-1 sets the standard for the risk assessment itself. The HSE, or the HSENI in Northern Ireland, enforces.

Republic of Ireland

In the Republic, the duty comes from the Safety, Health and Welfare at Work Act 2005 and the Biological Agents Regulations, enforced by the Health and Safety Authority. The reference guidance is the HPSC's National Guidelines for the Control of Legionellosis in Ireland, published in 2009. There is no Irish equivalent of an Approved Code of Practice, so the guidelines carry weight as recognised good practice rather than quasi-legal status.

Where they line up

The HPSC guidelines were written with the UK documents in view, and the control measures are essentially the same:

  • A risk assessment by a competent person, reviewed regularly.
  • A written scheme naming responsibilities and control measures.
  • Temperature control, flushing of little-used outlets, cleaning of tanks, showers and cooling towers.
  • Monitoring, sampling where indicated, and records.

Where they differ

  • The risk assessment standard. BS 8580-1 is a British Standard. It is widely used as the method in Ireland but is not referenced by the HPSC guidelines, which predate it.
  • Cooling tower notification. The UK's 1992 notification regulations have no Irish equivalent.
  • Healthcare. The UK has HTM 04-01 for healthcare premises; Ireland relies on the HPSC guidelines plus HSE (Health Service Executive) policy.
  • Currency. HSG274 has been revised several times; the HPSC guidelines date from 2009, so on some technical points UK guidance is more current.

What we recommend for cross-border operators

Adopt one written scheme template that meets both frameworks, state in each site's scheme which guidance applies, and use the more demanding requirement where the two differ. That way an auditor, inspector or public health team on either side of the border sees a scheme that was written for their jurisdiction, not a UK document with the logo changed.