The following steps can be taken by the WMP team as an internal self-audit, performed by a second or third party as an independent external audit, or both (e.g., the former to prepare for the latter). To get a price on an external audit, click here to contact RiskNomics.
Going through the steps does not ensure the team has included all control measures in the WMP that are appropriate or required, or that it has even properly implemented the default LAMPS control measures, but provides a pretty good quick check on the set-up and implementation of the WMP.
1. Check the set-up in Configuration Steps 1 and 2
- Step 1-2: Is the correct building type selected?
- Step 1-6: Are the water system selections accurate and complete?
- Step 1-4: Do the flow diagrams include all the “Yes” water systems in Step 1-6? Do the diagrams make sense?
- Step 2-7: Is the water system data complete? For each water system, are all the fields filled in: Does the comments box include all the information required to comply with regulations (see the instructions in that section)?
- Step 2 - 8, 9, and 11: Complete? Check the default text against what is in the WMP. Are any variations from the default text acceptable? Be sure to check both sections of Step 2-8.
- Step 2-10: Do the validation methods match the default? If not, are any deviations acceptable? Is Legionella testing adequate with respect to frequency of sampling and samples per round?
- Step 2-13: Are all Step 1-6 “Yes” water systems included (i.e., not hidden) in the hazard analysis? Is the reasoning for any No’s valid?
2. Check control measures in Configuration Step 3
- Go to reports > status report for control measure verification and click the “Not Entered” radio button: Are there any control measures for which an initial verification date has not been entered? If so, then complete the set-up of those control measures before resuming.
In each control measure category:
- Click the “Hidden” radio button. Expand each hidden control measure and review the comments box. Does the comments box have an acceptable reason for hiding the control measure? Any control measures that should be implemented should be un-hid and set up.
- Click the “Control Measures Added Since You Set-up Your Plan” radio button to see what has been added to LAMPS since the WMP was set up. Any new control measures applicable to the facility should be activated.
For each active control measure:
- Click on “+” to expand the control measure and then click “Default” to review the default text for the control measure, monitoring, control measure frequency, verification frequency, limits, and corrective action fields. In brackets is the date of the last LAMPS update. If the bracketed date in the default is later than the date in your WMP, then the control measure field should be updated with the default text as applicable.
- Review the documentation box. Make sure documentation is entered. The box serves as the hub for documentation of the control measure. Entered in this box should be the documentation or a note about where to find it. If a log or other file is referred to in the documentation box, the file name should be listed. For example, if a cooling tower control measure is documented with a Cooling Tower Log, then the file name or title of the log with the date should be entered (e.g., "See CoolingTowerLog-2017-08").
- Review the verification status. Any that are “Overdue” or “Due Soon” should be updated.
3. Check the documentation section
The following are not mandatory but can indicate the extent to which the team is engaged in the program:
- Chlorine readings entered in database?
- Temperature readings entered in database?
- Legionella test results entered in database?
- Legionella lab reports uploaded?
- How many training courses have the team members completed?
- Check the Team Meeting Notes. How often is the team meeting? What is the level of communication? Are all applicable team members or departments included in team meetings? Has action been taken on noted deficiencies?