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Water Risk Management in Healthcare Facilities

13 Dec 2018

Queensland Health has advised of its intention to engage with approved residential aged care providers regarding implementation and application of Chapter 2A Water Risk Management Plan of the Public Health Act 2005 (Cth) (the Act).

Recap of legislation

In 2013, Queensland public health experienced an outbreak of Legionella pneumophila infection (Legionella), which led to a report by the Chief Health Officer in September 2013. Accordingly, in February 2017, the Act and Public Health Regulations 2005 were amended to include provisions requiring healthcare facilities to improve their water risk management practices. The purpose of the legislation is to improve the management and control of health risks associated with water, in particular, the Legionella bacteria, and to provide public transparency of water testing in all healthcare facilities.

The legislation required immediate implementation for all Queensland Health hospitals and facilities, however, the implementation for residential aged care facilities other than State facilities was postponed.

Legislative requirements

Under section 61C of the Act, every Queensland Health hospital and all Queensland public and private residential aged care facilities must manage water-related hazards by developing a water risk management plan (WRMP).

The legislation also requires that health care facilities notify the chief executive of the Department of Health, within one business day, when Legionella has been identified in the facilities water and that the healthcare provider submits periodic reports to the Department of Health summarising results of Legionella testing.

The Department of Health is preparing to engage with healthcare providers to establish an approach to implement these legislative requirements. The Department has advised a survey will be sent to all healthcare providers to commence this process in early 2019. The survey will ask questions for healthcare providers to answer to provide information to the Department to establish a process of implementing these requirements.

Why is this relevant?

If you operate a residential aged care facility, you should ensure you are aware of the legislation and commence developing a WRMP.

In accordance with the Act, when implementing a WRMP you should consider the following key steps:

  • establish a water risk management team;
  • describe your facility’s water distribution system
  • identify any potential hazards;
  • conduct a risk assessment regarding these hazards;
  • identify any locations, process and activities to manage these hazards; and
  • implement the following:
    • a monitoring program;
    • procedures for corrective actions;
    • procedures for management of incidents and emergencies; and
    • record keeping and a schedule for updating your WRMP.

Further information regarding implementing a WRMP, can be obtained from the Department of Health Guidelines for Legionella Control at this link.

In order to enable the Department of Health to develop an effective implementation strategy, it is important, once the survey is received, to ensure that your organisation completes and returns appropriately.

The content of this report is not intended to be a substitute for legal advice. If you are interested in obtaining further advice in relation to the implementing a water risk management plan or require further information about the Water Risk Management legislation, please contact Julie McStay, Director – Aged Care and Retirement Living, Hynes Legal.


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