Managing agents often sit at the centre of a complicated chain of responsibility: freeholders, residents’ management companies, landlords, tenants, maintenance contractors and specialist water-hygiene providers may all be involved in the same building. For Legionella control, the important point is to establish who controls the relevant premises and water system, who is responsible for day-to-day management, and how the control measures are actually implemented.
Which parts of a residential block may need attention?
The answer depends on the design of the building. Some blocks have simple mains-fed domestic systems inside each flat; others include communal cold-water storage tanks, booster sets, central hot-water generation, recirculating systems, landlord-area showers or other shared plant.
A risk assessment should distinguish between the areas and systems under communal control and those that are genuinely part of individual dwellings. Contract wording alone does not replace an understanding of who has practical control over the plant and maintenance arrangements.
A managing agent’s practical checklist
- Identify the dutyholder arrangements. Make sure the parties responsible for the water system and the appointed competent person are clearly understood.
- Keep the risk assessment current. Review it when the system, occupancy or building use changes, or when there is reason to believe the assessment is no longer valid.
- Maintain an asset picture. Know where tanks, calorifiers, booster sets, communal showers, sentinel outlets and other relevant components are located.
- Manage contractors. Define what monitoring and maintenance work is required, how exceptions are reported and who follows up failed results.
- Keep meaningful records. Temperature logs are useful only if out-of-range readings lead to investigation and corrective action.
- Manage vacant or low-use areas. Empty flats, concierge facilities, gyms and guest suites can create changing water-use patterns.
- Plan for major works. Tank replacement, bathroom refurbishment, riser replacement or conversion works should trigger a review of the water-safety arrangements.
Do all residential blocks require an elaborate Legionella programme?
No. HSE guidance recognises that some systems are low risk and can be managed with simple, proportionate controls. The purpose of the assessment is to determine what is actually needed. A small mains-fed block with frequent water use may require a different level of control from a large development with communal stored water and complex distribution.
Cold-water storage needs particular attention
Where communal tanks are present, their condition, temperature, turnover, lids, screens, insulation and cleanliness may be relevant to the risk assessment. For more detail, read our guide to cold-water storage tanks and Legionella risk in London properties.
What about individual landlords?
Landlords also have responsibilities to assess and control Legionella risk in rented accommodation. The precise division between a block manager and an individual landlord depends on the system and who controls each part of it. See our separate guide: Do London Landlords Need a Legionella Risk Assessment?
Official guidance: Health and Safety Executive (HSE) L8 Approved Code of Practice and HSG274 Part 2.
Support for London managing agents: London Legionella Water Survey can assess communal water systems, help clarify practical control points and provide a site-specific report for residential and mixed-use buildings.