L8MS

Preparation of Statements Of Compliance (SOC) and preparation of internal procedures based on models we have developed saves a great deal of time and a day or so spent with us can get you ready for that 1st LCA assessment which comes a few weeks after you submit an acceptable SOC. If you want a manual to put on the shelf, we respectfully suggest you find someone else. Useful manuals need to reflect actual practices. L8MS tailor our templates around your working practices.

We hope these examples of the first two sections get you started, for advice on furthersections please contact us.

When the LCA Say's:
The statement of compliance should make specific reference to documented procedures. State the title and reference of the documents, their relevance and how they enable you to comply. It is not sufficient simply to restate the service provider commitments as a "wish list". If a commitment is not applicable to your operation then the reason for its exclusion should be clearly stated.

L8MS Guidance:
Don’t use vague statements like “Our quality procedures manual”. Reference the specific procedure reference and name (OCL-LCA-P1.1 Allocation of responsibilities) that drives the use of a form (OCL-LCA-F1.2). If you don’t have a procedure then you will need to write one. The LCA. is about written documented systems. Avoid future tense (we will) as the assessors interpret this as something that you are not necessarily doing at present.

Example:
Section 1 In accordance with LCA Service Provider Commitment 1, we explain in detail the client’s obligations under the relevant legionellosis legislation

Health and Safety at Work etc Act 1974
Control of Substances Hazardous to Health Regulations (as amended)
HSE ACoP L8 - Legionnaires’ disease - The control of legionella bacteria in water systems).

1.1. The procedure for quoting a potential client (OCLL-LCA-1.1 Allocation of responsibilities) drives the issue of an advice note HSE Leaflet IACL27 to inform the client of their obligations. This advice note details among other items the requirement to: -

Identify and assess the sources of risk
Prepare a written scheme of control
Appoint a responsible person
Implement, manage and maintain records of monitoring and inspection.

When the LCA Say's:
Scope does this agree with the tick sheet?

L8MS Guidance:
Don’t include reference to services in your SOC that are not on the tick sheet of services.

Example:
Reference to water treatment product selection when you are not applying for water treatment. By the way the LCA basically mean the on-going use of chemicals to control bacteria when they refer to water treatment. (So not closed system corrosion inhibitors for example that would be outside of the scope of LCA).

When the LCA Say's:
Does it reference relevant legislation and guidance?

L8MS Guidance:
Use the proper names not “the acop” or “l8”

Example:
HSE ACoP L8 - Legionnaires disease - The control of legionella bacteria in water systems

When the LCA Say's:
Is there confirmation of service providers and clients responsibilities

L8MS Guidance:
Your agreement (probably the quote with an order number) must detail what you are and are not supplying. Job quotes can include a general exclusions paragraph in the terms and conditions.

Example:
Tasks to be supplied by OCL: -
Tasks that remain with the client / others: -

When the LCA Say's:
Confirmation of training programme relevant to control of LD – e.g. using LCA matrix as guidance

L8MS Guidance:
Submission of a list of certificates does not work here.

1st Define the staff members roll.
2nd Define what they should have skills in (using the LCA guide if you want to keep it easy
3rd Record the training received and that required

Example:
In accordance with LCA Service Provider Commitment 2, all Oculus Consulting Ltd personnel receive or have received formal training associated with the control of legionella bacteria. 2.1. Our training procedure, OCL-LCA-P2.1 Training & Competence, details the company requirements for producing a training program and recording each employee’s current status on a knowledge matrix. The matrix is based on the LCA knowledge matrix and details the skills relevant to the above services required by each employee. (OCL-LCA-F2.2). Training certificates are held according to OCL-LCA-P5.1 Record Keeping.

When the LCA Say's:
have a system for assessing the competence…….

L8MS Guidance:
Competence assessment is not a training certificate, or even an exam, the LCA requires it assessed by a manager on-site, recorded and a conclusion achieved.

Example:
2.2. OCL operates a formal ‘shadowing’ system for assessing employee competence. Procedure OCL-LCA-2.1 Training & Competence details the requirement for a manager to assess each employee’s ability to follow service method statements (including pre & post service works incorporating site safety assessments). Assessment forms OCL-LCA-F2.3 are based on each of the method statements. An assessment is conducted at least annually on each member of staff.

When the LCA Say's:
Provide examples….

L8MS Guidance:
Don’t send the LCA blank tables send them completed forms for a member of staff. The LCA often request: -

A training record
A competency assessment
An Internal Audit

Example:
We base our assessments on the task to be conducted, this should have a method statement and this can be adapted to record the successful completion of each stage of the process. Legionella risk assessment requires a bit more thinking about! If you want any help we can offer on-site competency assessments for most services.