Non-Compliance Kills. Non-compliance isn’t just paperwork—it’s a death sentence.

Reval Continuing Care Managing Director talks about compliance and puts the record straight for healthcare providers looking to be fully compliant.

Water compliance is especially important in a care home, healthcare, or hospital setting, however, through our discussions with the sector, it’s become clear not many understand what is required. Bring clarity and understanding to the requirements that must be upheld can be described in a nutshell:
‘Any water fitting, which when installed, will carry or receive water from the public mains water supply in the UK, must comply with the Water Supply (Water Fittings) Regulations. These require that a water fitting should not cause waste, misuse, undue consumption, or contamination of the water supply and must be ‘of an appropriate quality and standard’.

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So how do care providers ensure they are meeting these requirements when specifying bathing apparatus and equipment?

The only way is to request compliance certificates from potential suppliers when purchasing bathroom appliances. While all water fittings and associated materials must by law conform with the Water Supply Regulations 1999,_¹ there is no legal requirement to obtain WRAS Approval; it is simply the easiest and most reliable way of demonstrating compliance. According to the Water Supply Regulations, it is down to the installer to ensure that water fittings meet the criteria. WRAS Approval provides valuable peace of mind both for you and your customers.

Care providers need to be confident that the equipment they purchase is of the highest quality to ensure reliability and service continuity whilst meeting stringent quality standards and legal requirements.

The materials and components of construction used in assisted bathing systems must be tested and subjected to the water industries WRAS Category 5 standard. This is to demonstrate the compliance with WRAS category 5 and BS6920. Marketing a product and stating it has WRAS-approved components incorporated, does not guarantee compliance!  Moreover, such language should serve as a warning, and companies using such language should be carefully scrutinised prior to purchasing from them. 

The only way to be sure of equipment compliance would be for your prospective supplier to provide you with a Water Regulatory Advisory Scheme (WRAS) category 5 certificate of approval. That approval must have a live listing on the online WRAS Aapprovalss directory.

Here at Reval, we provide our category 5 certificate complete with the approval number with the appliance. If a product is not listed, then you should question the approval with WRAS for verification.

In the absence of an authentic certificate and directory listing of approval, the appliance cannot be legally installed to UK mains water. The only way would be via a special dispensation from your Local Water Authority, which is highly unlikely as BS6920 is a British Standard.   

It is responsibility of the care operator or healthcare provider to contact the local water authority and provide product details to secure the necessary approval for appliance installation. No one tells you to insure your car, but you know you have to do it, this is exactly the same.

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Here the Water Regs UK outlines how to comply:
1. Ensure the equipment is of an appropriate quality and standard.^₂
2. Ensure the installation is safe by notifying the local water undertaker at least 10 working days before the equipment is installed.^₂
3. To prevent bathing and wastewater contaminating drinking water supplies install the correct level of backflow protection.^₂

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Dangers and Health Risks

‘Bathing equipment in hospitals, nursing, and care homes is categorised as a fluid category 5 risk, a serious health hazard. To protect patients, residents, and staff, as well as the wider community, the supplies to all tap and shower outlets must be protected by a backflow arrangement rated as providing fluid category 5 protection.’_²

An example of where back-flow can occur is when taps and shower handsets are dipped or left submerged in bathwater and the water supply pressure drops.  This action causes a vacuum in the appliance’s pipework. The vacuum action will then back-syphon the bathwater along with any of the bathers’ pathogens, bacteria, soaps, and emollients transferred during bathing, into the building’s freshwater ring main. These pathogens can potentially find their way through an entire building plumbing system if safety devices are not installed and can potentially be discharged anywhere in your building, such as a wash basin or a kitchen sink where food and drink are being prepared.

This level of contamination risk also threatens and potentially extends to adjacent buildings connected to the same main water supply, potentially causing downstream contamination and health and safety hazards to others.  

In the event an operator is found to be the source of the contamination, cost, and fines can be imposed based on the level of contamination clean-up and impact on health and safety caused, etc. The typical cost of a contaminated zone clean-up is likely to be considerable, not including the reputational damage. Non-compliance might also have potential insurance implications in respect to owners and operators found to be responsible for contamination caused by a non-compliant appliance.

To ensure peace of mind and compliance, care providers should request evidence that bathing appliances are compliant, and tested against all appropriate standards as previously highlighted. A possible and effective solution could be for the CQC to incorporate compliance via category 5/BS6920 certification into its inspection process.

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There are three specific things you should bear in mind:

• Understand the regulations and guidance.
• Comply with the regulations.
• Uphold your duty of care to staff, patients/residents by being aware of the compliance. 

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Due to the inherent vulnerabilities in care home and hospital settings, the likelihood of contamination and infection outbreaks is increased. Those who are cared for should expect to be safe from exposure to infections. So how can that be achieved in an environment where multiple individuals may use the same bathing facilities?

Those operating in healthcare premises have a duty to comply with Water Regulations and ensure medical appliances are procured to assure a higher level of Fluid Category 5 backflow protection. Fluid Category 5 represents a serious health hazard because of the concentration of pathogenic organisms, or very toxic substances, including any fluid, which contains faecal material or other human waste, etc.

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As such, Category 5 defines a serious health risk, and appliances must be:

• Designed and manufactured to be of an appropriate quality and standard.
• Suitable for the circumstances where they are used.
• Installed so they comply with the regulations.

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Non-Approved or Compliant Appliances

Amazingly there are numerous non-approved or compliant appliances marketed, sold, and installed in the UK healthcare sector. The very fact this is happening raises a lot of interesting questions, especially for those responsible for policing the standard.

Such technical compliance at this level is a “Dark-Art”, but free and impartial help and advice are on hand simply by going to the Water Regs UK www.waterregusuk.co.uk and WRAS Approvals www.wrasapprovals.co.uk websites where you can read and learn more about the materials, standards and certification process and requirements. 

It is time to be better educated on this standard because it will help everyone keep patients and residents safe and companies compliant. Understanding the regulations is a starting point, but it’s the follow-through with tangible actions that truly make the difference.

Consider the ramifications of using non-compliant appliances in a care home or healthcare setting bathroom; not only does it pose a safety risk, but it could also lead to an offense or a cost consequence when instructed to remove the appliance.

Given all that, it might be worth checking your appliances, just to be on the safe side.

If you have any concerns and would like to discuss them with the author, please don’t hesitate to contact Jason Ashman at: j.ashman@revalcc.com

1. https://www.legislation.gov.uk
2. https://www.waterregsuk.co.uk