Where does legionella come from?
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Key points
- Legionella is everywhere in the natural environment: rivers, lakes, groundwater, at low numbers that cause no harm.
- It enters buildings in trace amounts through the mains; the delivered water is safe, but the chlorine residual decays once water sits in your tanks and pipes.
- The risk is created inside the building, where warmth, stagnation, scale and biofilm let trace numbers multiply.
- The duty sits on your side of the stop tap: the water company is responsible to the boundary; you are responsible beyond it.
- New buildings are not exempt: construction and commissioning can colonise a system before anyone moves in.
Legionella comes from the natural environment. It is a normal inhabitant of fresh water, present at low levels in rivers, lakes and groundwater, and it reaches buildings in trace numbers through the incoming mains supply. The water arriving at your boundary is not the hazard; the hazard develops inside the building, where conditions let those trace numbers multiply.
This origin story matters for one practical reason: it tells you where the responsibility lies. Because legionella is ubiquitous, no water supplier can deliver water guaranteed free of it, and no duty holder can keep it out of a building. What can be controlled is whether the building gives it somewhere to grow. Legionella control is therefore not about keeping the organism out; it is about keeping the conditions wrong for it.
Why the mains is safe and the building is not
Water company treatment and the chlorine residual maintained through the distribution network keep environmental legionella at very low numbers, so mains water arrives safe. But chlorine decays. As water sits in a cold water storage tank, creeps down long pipe runs, or warms up in a loft or a service void, the residual that protected it in the main fades away. What is left is water with little or no disinfectant, sitting at whatever temperature your building gives it. If that temperature is between 20°C and 45°C, and the water is still, and there is scale, sediment or biofilm to feed and shelter growth, the trace numbers that arrived harmlessly become a colony.
Every element of that sentence is a control point. Temperature control keeps water out of the growth range. Flushing removes stagnation. Cleaning and descaling remove the nutrients and the habitat. The whole framework in HSG274 follows directly from understanding where the organism comes from and what it needs once it arrives.
The boundary of responsibility
The water company's duty ends at the boundary of your property. Everything beyond it, the storage tanks, the calorifier, the distribution pipework, the outlets, is the responsibility of whoever controls the premises. Under the Health and Safety at Work etc. Act 1974 and ACOP L8, that duty holder must assess the risk from their water system and control it. It is no answer to an inspector that the bacteria came in with the supply: they come in with everyone's supply. The question is always what your system did with them.
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.
Routes in besides the mains
The mains is the usual route, but not the only one. Tanks that are not properly lidded and sealed can admit contaminated material directly. Construction and alteration work can introduce the organism or, just as effectively, create the stagnation that lets it establish: pipework filled for pressure testing and left for weeks, sections commissioned before the heating is balanced, dead legs left behind when fixtures are removed. A brand-new building can be colonised before occupation, which is why new and refurbished systems are flushed and disinfected before handover rather than assumed clean.
You cannot keep legionella out of a building; it arrives with the water. What you control is whether your tanks, pipes and temperatures let it stay and multiply. The risk is made on your side of the stop tap.
The practical response follows the origin. Assess the system you actually have, its tanks, its temperatures, its stagnant branches, using the legionella risk assessment tool or our guide to legionella in water, then run the controls the assessment identifies and record each one in a log book. The organism's origin is natural and unavoidable; the colony is a building management outcome, and that is what the records need to show you managed.
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.
Frequently asked questions
Where does legionella come from?
Legionella is a natural organism of fresh water. It lives at low levels in rivers, lakes and groundwater, and it enters buildings in trace numbers through the incoming mains supply. The water arriving at your boundary is not the problem; the problem begins when conditions inside the building, warmth between 20°C and 45°C, stagnation, scale and biofilm, let those trace numbers multiply into a risk.
Is legionella in the mains water supply?
Trace numbers can be, because the organism is ubiquitous in the environment and no supply can be guaranteed free of it. Water company treatment and the chlorine residual in the distribution network keep those numbers very low, which is why mains water is safe when it arrives. What matters is that the chlorine residual decays as water sits in a building's tanks and pipework, so the protection fades on your side of the stop tap, exactly where the warm, still conditions are.
Can a brand-new building have legionella?
Yes. New systems can be colonised during construction and commissioning: pipework stands full of water for weeks between first fill and occupation, pressure testing leaves water sitting in branches, and commissioning may happen before the heating and temperature controls are balanced. A new building should have its water system flushed, disinfected where specified, and brought under temperature control before occupation, not assumed safe because it is new.
Does legionella come from the water company?
The organism may arrive via the mains, but the risk is not the water company's to manage. Their duty covers the quality of water delivered to the boundary of the property. Everything beyond that point, the tanks, the pipework, the temperatures, the outlets, belongs to whoever controls the premises, and it is conditions inside the building that turn trace, harmless numbers into a colony. That is why the legal duty under the Health and Safety at Work Act and ACOP L8 sits with the duty holder, not the supplier.
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