Legionella risk assessment for Churches and places of worship

Updated 12 September 2026

A typical church building is used for a few hours a week, which in water terms makes it a building full of little-used outlets. Between services the water in every branch stands still, the heating is off, and the system drifts to whatever temperature the building reaches. Congregations also tend to be older than the general population, and age is one of the factors that raises the consequences of Legionnaires' disease, so the risk deserves to be taken seriously even where the system is small and simple.

The fabric of older church buildings adds its own problems. Cold water storage tanks are frequently found in towers, belfries and high roof voids — often decades old, sometimes unlidded or uninsulated, and inspected rarely if ever. Piecemeal alterations over a century leave capped-off pipework and dead legs that nobody can now trace, and listed-building constraints mean redundant pipework is often cut off rather than removed. The font, the small kitchen in the vestry or church hall, and the occasional cleaner's tap all go on the flushing list. In some denominations, immersion baptism pools are fill-and-drain vessels that need their own filling, use and draining procedure.

The duty usually sits with the parochial church council or the building's trustees as the persons in control of the premises, and there is often no professional facilities manager — a churchwarden or volunteer ends up as the responsible person. That is acceptable under ACOP L8 provided they are competent for the task, which in practice means a simple written assessment, a weekly flushing rota for the kitchen and toilets, and an annual look inside the tank. Where the church hall is let separately to playgroups and classes, the hirers' use pattern should be reflected in the flushing schedule.

Is it legally required?

Where a church or place of worship has employees — a verger, administrator or cleaner — it is an employer under the Health and Safety at Work Act 1974. Even where it does not, section 4 of the Act places a duty on whoever has control of premises made available as a place of work or where people use plant or substances, which covers halls let to hirers and premises open to the public. ACOP L8 and HSG274 apply in the normal way, and diocesan and denominational property offices commonly require evidence of a risk assessment as a condition of insurance or faculty approval.

Who is the duty holder?

The duty holder is whoever has control of the premises or the water system. For churches and places of worship 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:

1. 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
2. Produce a written scheme for preventing or controlling the risk, with specific tasks, temperatures, and frequencies
3. Implement, manage, and monitor the scheme in practice, not just on paper
4. Keep records of the assessment, the scheme, monitoring results, and any remedial action taken
5. Appoint a competent person (often called the "responsible person") to be accountable for the scheme

Specific water system risks to check

For churches and places of worship 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 churches and places of worship premises, that means at least every 24 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 churches and places of worship premises typically costs between £150 and £400, 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.