Legionella risk assessment records: a letting agency workflow

A letting agency needs a live Legionella record for each managed property: who assessed the water system, what they found, which controls are required, who owns each action and what should trigger a review. The landlord's duty is to assess and control the risk. An agency should confirm in writing which parts it has been instructed to arrange rather than assuming that a management agreement silently transfers every responsibility.

For most domestic hot and cold water systems, the assessment can be straightforward and the risk may be low. That does not create a universal annual certificate. The Health and Safety Executive's landlord guidance says testing is not usually required for domestic systems, health and safety law does not require a “Legionella test certificate”, and the law sets no annual or biennial review interval. Review is driven by the system and by change.

Start with responsibility, not a certificate order

HSE says landlords have duties to protect tenants from risks arising from their rental undertaking. Its guidance links those duties to the Health and Safety at Work etc. Act 1974 and the Control of Substances Hazardous to Health Regulations 2002. The practical task is to assess exposure risk and put proportionate controls in place.

On a managed property, record the landlord, the agency contact and the person who will make the assessment. Add the scope of the agency's instruction: arranging an assessment, completing routine controls, instructing a contractor, passing information to the tenant, or some combination. If the landlord retains a task, record when evidence is due and what happens if it does not arrive.

The assessor must be competent for the system being considered. HSE says most landlords can assess simple domestic systems themselves, but someone who does not feel competent can appoint another person. A small combi-boiler flat and a large building with storage tanks, multiple circulation loops or little-used outlets call for different judgements. Use competent help where the system or findings exceed the team's knowledge; HSE publishes more detailed technical guidance for dutyholders.

Capture the water system and the conditions that change risk

Give the assessor a property-specific starting record. Note how cold water enters the property, whether it is stored, how hot water is produced, and whether there are tanks, cylinders, showers, long pipe runs or outlets that are rarely used. Record recent plumbing changes and how long the property has been empty.

HSE describes a typical low-risk domestic example as a small building with regular water use, mains-fed cold water, no storage tank and an instantaneous or low-volume hot-water system. Its water-system guidance also notes that all systems need an assessment, although not all need elaborate controls. Use those factors to support a conclusion; do not turn “domestic” into an automatic low-risk label.

For a portfolio, ask the same factual questions in the same order. Consistency makes missing information visible without forcing every property into an identical outcome. Store photos, diagrams or contractor notes where they help another person understand the system later.

Turn the assessment into owned controls

HSE's domestic guidance centres on keeping hot water hot, cold water cold and water moving. Examples include flushing the system before letting, keeping debris out of cold-water tanks, setting a hot-water cylinder so water is stored at 60°C and removing redundant pipework. The appropriate measures depend on the actual installation, and temperature controls must also account for scalding risk.

Convert every recommended measure into a task with an owner and deadline. “Flush before occupation” should identify who will attend, which outlets are covered and where completion is recorded. “Inspect tank lid” should say whether the agency, contractor or landlord will do it. If the assessor recommends specialist work, retain the instruction and completion evidence with the assessment.

HSE's broader dutyholder guidance separates identifying the risk from managing and controlling it. An assessment filed with unfinished actions is not a closed compliance task. Use a status that distinguishes assessment complete, action open, evidence received and review required.

Build vacancy controls into the tenancy workflow

Empty properties deserve their own trigger because water can stagnate. HSE says outlets on hot and cold systems should, as a general principle, be used at least weekly to maintain flow. For an extended vacancy, it advises considering a suitable flushing regime or draining the system. The right instruction depends on the property and the assessment.

Link the control to events the agency already knows: check-out, works completion, a delayed move-in or a student property's summer closure. The case should state when the property became vacant, which regime applies, who can access it and what must happen before occupation. Do not rely on a note in a contractor's diary that the property team cannot see.

Give the tenant clear, limited instructions

HSE advises telling tenants about controls they should maintain. Its examples include not changing the calorifier temperature, regularly cleaning showerheads and reporting hot-water faults or other system problems. Put the relevant instructions in the move-in information and keep a record of when they were provided.

Explain how to report a fault and what makes it urgent. A maintenance message about water not heating, an unused outlet or planned plumbing work can affect the existing assessment. Route it to the person responsible for water safety rather than closing it as an ordinary repair. Our controlled maintenance workflow shows how to retain approval and completion evidence around repair work.

Keep a record that another person can use

HSE says a landlord is not always under a statutory duty to record the findings; its guidance identifies the statutory recording duty for employers with five or more employees. It still describes keeping a record as wise. For an agency, a usable record supports handovers, open actions and evidence of what was arranged. Do not label the file as a statutory certificate.

Keep the assessor's conclusion, action evidence and tenant information together. A purchase receipt without the underlying assessment does not explain why work was needed. Equally, an assessment without evidence of completed controls leaves the operational question unresolved.

Review when the facts change

HSE says assessments should be reviewed periodically, but its landlord guidance does not prescribe an annual or two-year cycle for domestic rental assessments. Useful review triggers include changes to the water system, a long void, a new pattern of use, a control failure or information suggesting the existing assessment is no longer valid. A planned diary check can stop a record being forgotten, but present it as an agency control rather than a legal renewal date.

At review, compare the current system and use with the recorded facts. Close completed actions, carry forward continuing controls and explain any new conclusion. If access is difficult, HSE notes that suitable checks can sometimes be coordinated with visits such as gas safety or routine maintenance inspections.

Use one portfolio view, with the property evidence underneath

A branch-level view should show which properties have no assessment, open controls, a vacancy regime or a review trigger. It should link back to the property record rather than replacing it. This keeps the manager's queue simple while preserving the system details and evidence a contractor, landlord or reviewer may need.

Start with the wider landlord compliance checklist when you need to map other duties around a tenancy. For annual gas work, use the separate gas safety certificate guide; its fixed certificate cycle should not be copied onto Legionella records.

This article follows HSE guidance for Great Britain. Northern Ireland has separate health and safety legislation and guidance from the Health and Safety Executive for Northern Ireland. Check the applicable authority and the property's actual system before setting the workflow.

For a multi-property process, see Tekniti's letting agency offering. Keep the operational standard clear: a usable queue, the underlying evidence and a person responsible for review. Software should not invent a certificate or make the legal judgement automatically.