School Legionella Management Plan: What to Include in England
A school Legionella management plan is the written record of how your school finds, controls and monitors the risk from Legionella bacteria in its water systems. It names who is responsible, sets out the control measures and checks, and says what happens when something goes wrong. In England the employer or person in control of the premises (the duty holder) must make sure it exists and is followed. This guide shows what goes in it, who owns each part, how to handle holidays, and when to review it.
TL;DR
The duty holder (the employer, governing body or trust) carries the legal duty. It stays with them even when a contractor does the assessment.
A written plan builds on a Legionella risk assessment. It sets out the water system, the controls, the checks and how often, the records and the remedial actions.
Appoint a competent responsible person with real authority and knowledge of your water systems, and train them.
Holidays are the pinch point. Little-used outlets need flushing or isolating, with a record each time.
Review the assessment and plan on a set cycle and whenever buildings, use, staff or test results change.
Table of Contents
What a school Legionella management plan is
The plan is the working document that sits on top of your risk assessment. The assessment tells you where the risks are. The plan tells people what to do about them, week in and week out.
HSE’s Approved Code of Practice, L8, says that where a reasonably foreseeable risk cannot be avoided, the duty holder should prepare a written scheme to control it. Its primary aim is to avoid conditions that let Legionella multiply and to avoid creating spray or aerosol that people can breathe in.
You will see different names for the same thing: management plan, written scheme of control, water safety plan, Legionella policy. Schools often have a short policy (who is responsible and why) plus a plan or scheme for each building, plus a logbook for the day-to-day records. What matters is that all three exist, match the buildings you actually have and are used.
Who is responsible in a school
Three roles come up in every well-run school plan.
The duty holder. This is the employer or person in control of the premises. Depending on your setup that means the local authority, the academy trust or the governing body. GOV.UK estate guidance for schools lists the duty holder’s steps: appoint a competent person, assess the risk under L8, prepare a written scheme, implement and monitor it, and keep records.
The responsible person. HSE says you must appoint someone competent to take day-to-day responsibility for controlling the risk. Competence means sufficient authority, skills, knowledge of the system and experience. In a school this is often the site manager or estates lead. They can be a member of staff, but they must understand the water system and have the authority to get issues fixed. Our guide to the responsible person for Legionella covers the role in more depth.
The people who do the tasks. Caretakers flushing outlets, staff taking temperatures and contractors servicing valves all need to know what they are doing and why. Staff training is one of the cheapest ways to keep a plan alive.
Local authority guidance reflects the same split. Coventry City Council’s school standards say head teachers and governing bodies must make sure effective measures are in place for the buildings under their control. That covers roles and training, risk assessment, maintenance and monitoring, record keeping, water sampling and actions if Legionella is found.
A common weakness is a plan that names a person who has left. Put the role, not just the name, in the document, and check the appointment each September.
Start with the risk assessment
You cannot write a sound plan without a current risk assessment. HSE’s HSG274 Part 3 explains that the assessment decides whether further action is needed. If it finds the risks insignificant and properly managed, no further action may be required, but you still review it in case anything changes. If it shows a risk, you put a written scheme in place, monitor it, keep records and review both as circumstances change.
In practice almost every school has hot and cold water systems, showers in PE changing rooms, and outlets that go unused for long stretches, so a written scheme is the norm. GOV.UK says the assessment and the course of action should be prepared by a company offering these specialist services.
A school assessment should look at:
cold water storage tanks, hot water cylinders and calorifiers
showers, including those in sports blocks and changing rooms
taps and outlets in classrooms, science labs, art rooms and toilets
kitchens, caretakers’ houses and any boarding accommodation
swimming and hydrotherapy pools, which GOV.UK says should be included
thermostatic mixing valves (TMVs), dead legs and redundant pipework
areas that are used only part of the year, such as sports halls let out in the evenings or old science blocks
We carry out Legionella risk assessments for schools, colleges and universities across the UK, from £185. The price depends on the site, so a quote for a multi-building school will be based on its size and systems.
What to put in the written scheme
L8 sets out what a written scheme should include where appropriate. Turned into a school’s plan, that gives you these sections.
Section | What it should say |
Scope and responsibilities | Duty holder, responsible person, deputies, contractors and who covers absence |
System description | An up-to-date schematic of the water systems for each building, with tanks, cylinders, outlets and dead legs |
Safe operation | How the system should run normally, including temperature settings and any water treatment |
Control measures | Temperature control, flushing, cleaning, descaling, disinfection and any chemical programme |
Monitoring | What is checked, where (sampling points and sentinel outlets), by whom and how often |
Sampling | Locations and test frequencies for water samples |
Remedial action | What to do if a check fails, who decides, and who is told |
Emergency procedures | Actions for a positive result or a suspected case |
Records | Where the logbook is kept, what goes in it and how long it is retained |
Review | Review interval and the triggers that bring a review forward |
This follows what L8 lists for a written scheme: the layout plan, correct and safe operation, precautions, checks and their frequency, and remedial action, with detail on control measures, sampling, cleaning, disinfection and emergency procedures.
Temperatures and routine checks
Temperature control is the main method. HSE guidance says hot water should be stored at 60°C or above and distributed at 50°C or above, and cold water should be stored and distributed below 20°C. It also asks you to identify sentinel outlets (the nearest and furthest from each tank or cylinder) for monthly distribution temperature checks, check hot water cylinder temperatures monthly and check cold water tanks at least every six months.
Where a scald risk exists, which in schools means any outlet pupils can reach, TMVs are fitted close to the outlet. HSE’s page notes that TMVs should be as close to outlets as possible, so they need a place in the plan and in the service schedule.
Our guide on how to complete temperature monitoring checks walks through the practical side. Some schools prefer automated water temperature monitoring, which logs readings continuously and takes the weekly or monthly round off a busy caretaker.
Flushing and cleaning
Stagnant water is where trouble starts. HSE advises removing dead legs, flushing infrequently used outlets (taps and showerheads) at least weekly, and cleaning and descaling shower heads and hoses at least quarterly. Cold water tanks should be cleaned periodically.
Published school schemes show how this becomes a schedule. One trust’s written scheme of control lists weekly flushing of infrequently used outlets by site staff, monthly sentinel temperature readings and quarterly showerhead cleaning. A school’s Legionella procedure asks for outlets to be used or flushed at least weekly, short pipe runs, redundant pipework removed and every system flushed during school shutdowns.
Use these as models for the shape of a schedule, not as your frequencies. Your own risk assessment sets the frequencies for your buildings.
Water sampling
HSE says water samples should be analysed for Legionella periodically to show bacteria counts are acceptable, with the frequency set by risk. Your plan should say which outlets or tanks are sampled, how often, which laboratory results come back to whom, and what a result triggers. Our Legionella water testing and analysis starts from £55 per sample.
Holidays, shutdowns and when controls fail
Schools are quiet for around 13 weeks of the year, and much of the estate may not be used during that time. That is why holiday arrangements deserve their own section in the plan.
Guidance from Southampton City Council puts it plainly. Many areas of a school go unused over holidays, so staff must be tasked with managing water through a suitable flushing regime. It describes the approach for short gaps: identify areas used less than once a week and flush them at least weekly, more often in higher-risk premises. Each outlet should run long enough to replace the contents of the outlet and its supply pipework with fresh water.
For longer closures, the same guidance says it can be acceptable to leave a system filled without weekly flushing, as long as unauthorised use is prevented. Draining down is another option, though it brings its own recommissioning needs. The right choice depends on your system, which is why the plan should set it out in advance rather than leaving it to whoever is on site on the last day of term.
A workable holiday section covers:
Before closure: list the outlets, showers and tanks affected and agree who flushes what, and when.
During closure: a named person or contractor, a flushing log signed each visit, and a plan for cover if that person is unavailable.
Before reopening: a full flush of all outlets, a check of hot and cold temperatures at sentinel points, and showerheads cleaned where the plan requires it.
Records: every flush and temperature reading entered in the logbook, with the date and initials.
Our education estate guide goes further into holiday flushing and the records that go with it.
When a control measure fails
The plan should say, before it happens, what a failure looks like and who acts. Typical triggers are a hot water temperature below target, cold water above 20°C, a missed flush, a positive sample or a boiler or tank fault. For each one, name the person who decides, the immediate action (for example isolating a shower), who is told, what repeat checks follow and where it is recorded. Coventry’s school guidance expects the plan to cover actions to take if Legionella is detected and what to do in an outbreak. Remedial work, from system disinfection and tank cleaning to TMV servicing and general remedial works, is best lined up with a contractor ahead of time.
If anyone at the school becomes ill with symptoms that could be Legionnaires’ disease, the school’s health protection contacts and the local authority need to be involved straight away. Put those contact details in the emergency section.
Records and the logbook
If a check was done but not written down, it is hard to prove it happened. The plan should name the logbook, its location and who keeps it up to date. One trust’s scheme says the logbook holds procedures, schedules, temperature checks, flushing records, inspection forms and remedial actions, and that accurate records are essential to show legal compliance.
On retention, one university’s guidance suggests keeping control-scheme records for at least two years and monitoring, inspection, test and check records for at least five years. Check what your local authority or trust requires, and apply the longer period if in doubt.
Keep in the file:
the current risk assessment and its significant findings
the written scheme and schematics
names of the responsible person and deputies, plus training records
flushing, temperature and cleaning logs
sample results and the actions taken
remedial work records, disinfection certificates and TMV service records
Our Legionella logbook is set up for this, and can be tailored to each school site.
When to review the plan
HSE says to review the assessment regularly and whenever circumstances change. There is no single fixed interval in law, so schools set their own. A local authority school procedure states a maximum of two years between risk assessment reviews, plus earlier review when triggers occur. A university’s guidance has the competent person review water systems at least every 12 months, with significant changes prompting a fresh look at the assessment.
Triggers to write into your plan:
building work, new wings, changed pipework or removed outlets
a change in how a building is used or how many people use it, for example a new sports centre let out to the public
sampling results showing controls are not working
a change of responsible person
advice from your Legionella consultant
Other organisations treat this the same way: many publish their own health and safety arrangements and revisit them as circumstances change. For a school, a simple habit works: put the review date in the estates calendar, and tie a mini-review to each summer break. Our article on reviewing a Legionella risk assessment explains what a review should look at.
Our perspective
In our experience, the plans that work in schools are the short ones that people actually follow. A 60-page policy that nobody has opened since it was signed gives less protection than a clear scheme for each building, a logbook on the caretaker’s desk and a holiday flushing rota with names on it. We build plans around the site rather than a template. Every school has a different mix of old and new buildings, shared sports facilities, showers and quiet corners of the estate, and the plan should reflect that. We aim to make compliance simple: a risk assessment, a clear control programme, a logbook your team can keep up and training so that the people doing the checks understand why they matter. We also think the plan should grow with your team’s knowledge. That is why we pair assessments with awareness training, on site or online, and ongoing consultancy, so your responsible person has someone to call when a result comes back unexpected or a building project changes the pipework. Sammi
How we can help your school
We provide Legionella risk assessments, water sampling, awareness training, temperature monitoring, tank cleaning and disinfection, TMV servicing and ongoing support to schools, colleges and universities across the UK. Everything is built around your sites, with documentation your governors, trust and inspectors can follow.
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If you need a risk assessment to build your plan on, or want your existing one checked against the buildings you have now, start with our page for schools, colleges and universities or get in touch. For staff who carry out flushing and checks, see our Legionella awareness training.
FAQ
Does every school need a written Legionella management plan?
Where the risk assessment finds a reasonably foreseeable risk that cannot be avoided, HSE’s L8 says the duty holder should prepare a written scheme. Schools nearly always have hot and cold water systems, outlets and often showers, so most need one. Your risk assessment confirms what your site requires.
Who should write a school’s Legionella plan?
GOV.UK says the risk assessment and course of action should be prepared by a company offering specialist services. The responsible person at the school then runs it day to day, using the schedules and logbook. The duty holder remains accountable either way.
How often should a school review its Legionella risk assessment?
There is no single legal interval, so schools set one in the plan. Published school and university guidance uses between 12 months and two years as a maximum, with an earlier review after building changes, changes of use or poor test results. Write both the interval and the triggers into the plan.
What should a school do with Legionella controls over the summer holidays?
Identify outlets that will go unused, flush them at least weekly (or isolate them, if your plan allows) and log each visit. Before pupils return, flush everything and check temperatures at sentinel outlets. Your risk assessment sets the exact regime.
Can a member of school staff be the responsible person?
Yes. GOV.UK says the person may be a member of staff, provided they have sufficient knowledge of the water system and enough authority to deal with problems. Training and a clear written appointment help them do the job well.
Sources
HSE: Legionnaires’ disease, the control of legionella bacteria in water systems (L8)
HSE: Legionnaires’ disease, what you must do: manage the risk
GOV.UK: Good estate management for schools, health and safety
Coventry City Council: Health and safety standards in schools
Southampton City Council: Legionella risk in schools and colleges
Schools Legionella and water system management procedure (April 2025)
University of Manchester: Safety Services guidance on water systems
University of Reading: Control of legionella in departmental water systems
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