Solar hot water heating systems and Legionella (Legionnaire’s disease / Legionellosis)

A new technical report on solar thermal heating systems using solar panels from Legionella Control InternationaI answers independently the twin questions of whether UK’s conventional approach to solar water heating installation complies with L8 (which is the UK Government code of practice and guidance on Legionnella) and whether or not Solartwin’s solar heating technology approach complies.

The complete Legionella and Solar Thermal report is here. For ease of reading Solar Twin Ltd have encircled in gold some of the key areas of interest on the pdf.

The Legionella Control International report on Legionella in solar thermal and Solartwin says

That Solartwin’s solar water heating system takes full account of L8. It says that Solartwin offers significant safety improvements over typical conventional solar installations – which themselves contain a serious flaw in design which make them fall significantly outside L8. (These apparently noncompliant installations probably number some 100,000 homes in UK.)

This report validates Solar Twin Ltd’s safer approach

This is typically to use hot water cylinders with base-of-cylinder backup heaters (or thermal stores) instead. It also justifies Solar Twin Ltd’s long-standing reluctance to install solar thermal according the current UK Government grant specification, MIS 3001. This, and other state documents, are in need of prompt revision or, at least, reinterpretation. At present MIS 3001 is anticompetitive in that customers of Solartwin are denied grants precisely because Solartwin is safer.

Why did Solar Twin Ltd go public on this matter?

We had been warned several times not to raise the Legionella issue. That to do so would be a nuclear tactic which could eventually result in a “shoot the messenger” response, even a catastrophic revenge to the extent of the closure of this business and the removal frm the market of our innovative technology via concerted abuse of regulation and industry power. We are aware of this risk, we view it as real but only significant of the wider public wer not also made aware of the matter. So we dedided that we had to seek a third pary review

We went public with reluctance. Our commissioning of this report was not intended as to undermine the existing solar heating industry. We had not wanted to spend borrowed money on commissioning it! But it was essential to independently examine our approach in context of obstruction which our innovative solar panel technology has faced in terms of withheld accreditation for state subsidy in UK.

What triggered the decision to seek an independent report on solar and Legionella?

One reason was the inexplicable refusal of what was at the time, UK’s only accreditation agency for solar installers at the time, the Building Research Establishment (BRE), to consider the performance of our technology in the context of Legionella, even though we had specifically raised the issue of Legionella safety as a prerequisite to system design with them on more than one occasion.

Another reason was delay. Tthe fact that we had recieved had no subsantive answer from questions which we had posed to the Health and Safety Executive (HSE) about Legionella, even though we asked some as long ago as 11 months. We posed some of them following what appeared to us to be a ham fisted consultation on solar best practice which was headed by the Energy Saving Trust, the documents for which were apparently drafted by the Building Research Establishment (BRE). Not only was this consultation interestingly timed (to span Christmas) it had also proposed to treat only the most Legionella NON-compliant solar installations as best practice, and to marginalise safe designs (including Solartwin’s) into the worst category of installation! We are not sure what is the current status of this consultation but we think that it has may have been indefinitely stalled.

A third was the development of an unfounded whisper campaing against our technology, apparently from established industry players towards potential new clients, a campaign which we knew to be unfounded but which we needed an independent third party player to participate in.

The solar and Legionella report necessarily leaves a some follow-up questions unanswered, such as:

1. Landlords have a duty to ensure compliance with L8, so what is the position in UK’s rented sector? Should private homes comply too, given that over decades homes may move into and out of the rented sector?
2. Why refuse grants to safer solar thermal systems? Why are UK’s solar installers are being being incentivised fit L8 non-compliant systems by UK’s current grant regulations, when these regulations themselves were supposedly established to raise regulatory standards?
3. Proper use of public funds. Have state grant funds such as Clear SKies and the Low Carbon Building Programme phases 1 and 2 been spent appropriately?
4. Fixing solar heating installations on site. If there the Legionella risk from conventional solar is assessed to be significant enough to merit alteration of existing conventional solar heating installations, whether grant aided or not, who would pick up the bill for rectification?
5. Which solar water heating documents need fixing? Will a full list of potentially noncompliant documents be made? We are concerned that the following may need examination: The UK grants specification called MIS 3001 which was produced for the government departments of DTI / BERR / DECC, the domestic heating compliance guide which was produced for DCLG, SAP 2005 which is the building energy calculation methodology from DEFRA, The Chartered Institute of Building Services Engineers (CIBSE) document on solar called CE 131 Solar water heating systems – guidance for professionals, and the British Plumbing Education Council (BPEC) training manual for solar installers on which £86k of state funds were spent, which was authored by the Solar Trade Association (STA) and from which Solartwin has been inappropriately marginalised including that of Legionella.
6. And who will fix the solar Legionella problem? Who will be given the task of amending the duff regulations and documents? Will the players who wrote them in the first place be given the opportunity to cover their backs? Or will new and genuniely independent people come in to sort out the mess? Perhaps the shutters will come down and the bulk of the industry will simply remain in denial.

We hope that this document will encourage a re-evaluation of standards in UK regarding Legionella, not just a rewriting of them to suit the status quo.

I trust that this robust and independent validation of the Solartwin approach is of interest to you, whether you are a medical profesional, customer, regulator, trade body, construction engineer, competitor or have some other interest. Thank you for reading this article.

Regards,

Barry Jonston, Managing Director, Solar Twin Ltd.