Legionella risk assessment for Breweries and beverage plants
Updated 7 September 2026
Key points
- A legionella risk assessment is required for breweries and beverage plants premises under the Health and Safety at Work Act 1974 and the Approved Code of Practice L8
- Typical cost: £300 to £1200
- Review every 12 months, or sooner if the water system, its use, or the people using it change
- A named duty holder (usually the employer, landlord, or building operator) must arrange it and act on its findings
The single most common legionella mistake in a brewery is assuming that clean-in-place takes care of it. CIP sanitises product-contact surfaces to protect the beer; it does nothing for the building's hot and cold water distribution, the welfare showers, or the canteen. A brewery can hold impeccable CIP records and still have a completely unmanaged domestic water system. The risk assessment should draw that line explicitly, naming which systems are process and which are domestic, because the controls and the competent people are different.
The process environment itself works in legionella's favour. Brewhouses and cellars are warm, wet, and humid, with condensate on cold pipework and protein and sugar residues that feed biofilm wherever water is allowed to stand. Bottle, can, and cask washers recirculate warm water and generate aerosol across the packaging hall. Pasteurisers and tunnel warmers hold large volumes at lukewarm temperatures. Where refrigeration uses evaporative condensers rather than air-cooled plant, those condensers are notifiable cooling towers with the full control regime that status brings.
The manageable part is the ordinary building system: staff showers after shifts, handwash basins, the taproom if there is one, and any visitor facilities. These carry the same duties as any commercial premises and are usually simple to control once someone has been made responsible for them.
Is it legally required?
Breweries and beverage plants are industrial premises under the Health and Safety at Work Act 1974 and ACOP L8. Evaporative condensers used for refrigeration fall under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992, with HSG274 Part 1 as the technical reference. Product water quality is governed separately by food law; CIP and process hygiene records do not discharge the legionella duty for the building water system.
Who is the duty holder?
The duty holder is whoever has control of the premises or the water system. For breweries and beverage plants premises, this is usually the employer, owner, landlord, or managing agent. The duty cannot be contracted out: you can hire a water hygiene consultant, but the legal responsibility still sits with you.
If you are unsure who holds the duty for your premises, see: Who is responsible for a legionella risk assessment?
What the assessment should cover
ACOP L8 sets out five things a suitable and sufficient assessment must do:
- Identify and assess sources of risk across the whole water system, including stored hot and cold water, dead legs, rarely used outlets, and any equipment that generates aerosols
- Produce a written scheme for preventing or controlling the risk, with specific tasks, temperatures, and frequencies
- Implement, manage, and monitor the scheme in practice, not just on paper
- Keep records of the assessment, the scheme, monitoring results, and any remedial action taken
- Appoint a competent person (often called the "responsible person") to be accountable for the scheme
Free legionella risk assessment template
A structured Word document following the five-step approach in ACOP L8. Covers risk identification, written scheme, monitoring, and records. If it isn't written down, you can't evidence it.
Follows ACoP L8 and HSG274 Part 2. Free. No spam.
Specific water system risks to check
For breweries and beverage plants premises, assessors typically pay close attention to:
- Hot water storage temperatures (calorifiers must reach 60°C throughout)
- Hot water distribution temperatures (50°C within one minute at outlets)
- Cold water storage tank condition, lid seal, and temperature (below 20°C)
- Dead legs, redundant pipework, and little-used outlets
- Shower heads, flexible hoses, and thermostatic mixing valves
- Any cooling tower, evaporative condenser, or spa pool (these are notifiable to the local authority under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992)
How often to review
There is no fixed legal interval, but ACOP L8 requires that the assessment is reviewed regularly and whenever there is reason to believe it may no longer be valid. For most breweries and beverage plants premises, that means at least every 12 months and sooner after any of the following:
- Changes to the water system (new pipework, fittings, equipment)
- Changes to the use of the building or the number of occupants
- A positive legionella test result or a case of Legionnaires' disease linked to the premises
- Prolonged periods of low occupancy or system shutdown (a risk during holidays, term breaks, or refurbishment)
- New guidance from HSE
Typical cost
A professional legionella risk assessment for breweries and beverage plants premises typically costs between £300 and £1200, depending on the size of the building, the number of water outlets, and whether there are any cooling towers or evaporative condensers (these add significantly to the cost because of the statutory inspection regime).
Use our cost calculator for an estimate based on your specific water system.
Need a legionella risk assessment for your premises? We will be partnering with Legionella Control Association registered providers shortly.
Free legionella risk assessment template
A structured Word document following the five-step approach in ACOP L8. Covers risk identification, written scheme, monitoring, and records. If it isn't written down, you can't evidence it.
Follows ACoP L8 and HSG274 Part 2. Free. No spam.