For those responsible for the maintenance and management of HVAC water systems, industry guidance documents from organisations such as HSE and BSRIA provide an essential reference.
Based on the latest British and European standards, these documents give best practice guidance and the latest thinking on the various stages of water treatment; from design and pre-commissioning cleaning through to handover and ongoing maintenance.
However, these guidelines are not ‘the law’ and following them to the letter does not always produce the best results.
What is the difference between legislation, codes of practice and guidance?
Legislation contains statutory conditions that must be met in order to comply with the law. Non-compliance can leave organisations and individuals open to prosecution, fines and punishment.
Industry guidelines and codes of practice are not legal documents, however, they can be used as evidence for the prosecution in legal cases.
Following the best practice advice in these documents will, in most cases, ensure compliance with any relevant legal requirements.
What is the problem with industry guidance?
While there is little doubt about the crucial role BSRIA guidance plays in informing water treatment policy, the problem lies with how the guidelines are interpreted and applied.
For example, BSRIA BG29 (Pre-commission cleaning of closed systems) and BS 8552:2020 (Sampling and Monitoring of Water from Building Services Closed Systems – Code of Practice) give guidance about pre-commissioning cleaning, yet despite this, there is still a major problem with corrosion in closed-circuit systems.
One of the reasons for this – and a common issue we see again and again – is that BG29 has been taken as the law, with little thought given to the individual system.
How should industry guidance be used?
BG29 contains the latest thinking surrounding pre-commissioning cleaning and is therefore a vital resource for design engineers, installation contractors, facilities managers and anyone involved in the pre-commissioning cleaning process.
It should be used to inform the method statement, rather than blindly followed without taking into account the specifics of that particular system.
The key point here is that BSRIA guidelines are not legislation and they should not be treated as such. While they can be used as evidence in legal cases, simply stating that BSRIA guidelines have been followed will, in many cases, not meet the mark.
Bespoke is best!
There is no silver-bullet approach to pre-commissioning cleaning or water treatment in general and taking this approach could lead to all sorts of problems further down the line, with corrosion, pipe degradation and over flushing, which wastes huge amounts of water and chemicals.
While water systems that are cleaned and maintained in accordance with BSRIA guidance are less likely to experience operational issues, every water system is unique in its operational environment, application and usage.
To get the best results, water treatment policy needs to go beyond the guidelines, using BG29 as a starting point together with monitoring and trend analysis to allow FMs and building managers to manage their HVAC systems in a bespoke and efficient way.
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