Legionella risk assessment for GP surgeries

Updated 12 September 2026

A GP surgery is a clinical setting bolted onto what is usually a small commercial water system: a mains cold feed, a cylinder or unvented heater, and a handful of consulting-room basins, treatment-room sinks and staff facilities. The everyday risk from the domestic-type system is modest, but the people exposed to it are not the average population. Patients attending a surgery skew elderly and chronically unwell, and anyone immunocompromised by treatment is a higher-consequence exposure if the system is poorly managed. That is the argument for managing a surgery to a healthcare-informed standard rather than an office standard.

The features that deserve attention in the assessment are the clinical ones: treatment-room and minor-operations sinks used for hand hygiene and equipment rinsing, any couch-side basin in a phlebotomy room, TMVs fitted to protect vulnerable patients, and little-used outlets in rooms that only see use on certain clinic days. Practices running specialist services, such as minor surgery suites or community dental sessions, raise the bar further, and anything resembling a dental unit waterline brings its own regime. Practices should be aware of HTM 04-01, the healthcare water-safety guidance, as the reference point for good practice in clinical premises, even where its full machinery of water safety groups is disproportionate for a two-partner surgery.

The duty normally sits with the practice partners or the practice manager acting for them, with a named person carrying out the routine checks. A simple written scheme covering monthly sentinel temperature checks, weekly flushing of little-used rooms, TMV servicing, and an annual review is proportionate for most surgeries. The log book matters doubly here because the CQC inspects premises safety and infection prevention, and the water hygiene records are part of the evidence inspectors can ask to see.

Is it legally required?

GP practices are employers and occupiers of non-domestic premises under the Health and Safety at Work Act 1974, with ACOP L8 and HSG274 as the operating framework. CQC registration in England (and the equivalent regulators elsewhere in the UK) brings an expectation that infection prevention and premises safety are managed, and HTM 04-01 is the healthcare technical guidance practices commonly look to for good practice on safe water, even though it is written principally for NHS premises. HSG274 Part 2 covers the hot and cold water systems found in most surgeries.

Who is the duty holder?

The duty holder is whoever has control of the premises or the water system. For gp surgeries 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 gp surgeries 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 gp surgeries 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 gp surgeries premises typically costs between £300 and £700, 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.