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Preparation of a Statement of Compliance

The fundamental requirement of your Statement of Compliance is that the detail provided confirms to the Management Committee that your operation fulfils the Service Provider Commitments of the Code that are applicable to your business. The statement shall comprise a single concise document that demonstrates to the satisfaction of the Committee and customers, that you comply and that there is substance to your claims of compliance. The tick-sheet indicating the services you offer forms part of the statement of compliance and must be signed, dated and attached to the Statement of Compliance.

The Statement of Compliance should:

be concise – approximately 3 or 4 pages, written in the present tense, in plain English and in an unambiguous manner.
show a management system – this describes how you conduct, monitor and control your business. It consists of a set of written procedures that contain the instructions to carry out an action. NB Where you are a sole trader or employ only a very small number of people then it may not be necessary to have separate written procedures provided a) that your statement contains enough detail to represent your operating procedure b) you clearly indicate in your scope section the size of your company and that your statement represents your operating procedure for compliance.
be auditable – it is a condition of registration that you have in place a management system referring to detailed written procedures ensuring compliance with all elements of the Code. The statement is a single document that ties these separate procedures together. It should be possible to use it to trace the procedures referenced and establish through documentary evidence that you comply with the Code.
address all the service provider commitments – there should be a short description of how compliance is achieved for each of the bullet points within the service provider commitments.
explain how you comply –the statement of compliance should make specific reference to documented procedures. State the title and reference of the documents, their relevance and describe how they enable you to comply. It is not sufficient simply to restate the service provider commitments as a “wish list”. If a commitment is not applicable to your operation then the reason for its exclusion should be clearly stated.
be relevant to the scope of your services – the statement should indicate how compliance is achieved for all of the legionella control services which you declare on your tick-sheet (and which will thus appear on your certificate and on the website). You can download a Registration form and an electronic version of a Tick-Sheet by clicking here

Subsequent amendments to the statement should be incorporated into the text, NOT presented as an appendix.

The following paragraphs contain advice on the composition of a Statement of Compliance; they have been put together to assist companies to produce a Statement that will be close to the requirements for registration; you are advised to read these pages before starting your Statement of Compliance.

Your first paragraph must describe the scope of the business acivities of your company. You will use this description to decide how many additional categories you require on your certificate. Assessors will refer to this information when processing paperwork and carrying out site visits.

The left-hand column repeats the text in the Code of Conduct; the right-hand column explains what is required in each instance.

.	Guidance
1. Allocation of responsibilities The service provider will:
explain in detail the client's obligations under the legionellosis legislation	Reference the legislation and your formalised procedure for explaining this to the client. It is not sufficient to simply to say that you advise customers to adhere to relevant legislation. Write a short description of the procedure
identify those services covered by the contract and those which should be provided by the client to meet all current obligations	Reference to a written management procedure or formal contract is required. Explain how you identify the services.
formalise an agreement detailing the respective responsibilities for each requirement	Reference your written agreement which details respective responsibilities

2. Training and competence of personnel The service provider will:
supply details of the training that is provided to his personnel associated with the control of legionellosis	A description of and reference to a written management procedure is required with details of the training given in relation to the control of legionella. It should cover the topics detailed on the training matrix relevant to your activities.
indicate how personnel competence is assessed, training needs are established, and what measures are taken to ensure that personnel are kept up to date with best practice procedures	Describe and give the reference to a written management procedure which ensures that competence of all personnel is regularly assessed and appraised.
assist the client to assess and meet the training needs of the clients staff	Detail the mechanism you have for ensuring that this is done.

3. Control measures The service provider will:
indicate how the design, monitoring and maintenance of an appropriate programme of control measures is assessed	Summarise and give the reference to a written management procedure: your procedure should indicate how control measures such as product selection, chemicals used,risk assessment, service delivery amd sub-contractors are set and managed..
have a system for verifying that coerrective and preventive actions are implemented	Reference needs to be made to the procedures that you use to ensure that the required actions to maintain control are implemented and remain effective.

4. Communication and management The service provider will:
detail the management systems which operate if the control programme deviates from specification, e.g. a positive legionella result, and show how these are audited	Explain and give the reference your management procedure and the mechanism which details how you respond to system deviations, especially positive legionella results.
indicate how his management team would communicate with the client's team in the event of any necessary actions	Summarise the procedure and reference the chain of responsibility, e.g., a list of telephone numbers of contacts and their appointed deputies.
also bring to the client` s attention any significant matters affecting the control of legionellosis of which he has become aware, beyond the responsibilities of his contract	You need to indicate how you formally bring "matters of evident concern" to the clients attention - this includes matters of which you become aware that fall outside your contractual responsibility

5. Record keeping The service provider will:
indicate which records should be kept by both parties and where they will be kept	Describe and give the reference to your procedure and documentation used.
establish with the client who will be responsible for the maintenance of these records	Reference your procedure and documentation used.

6. Reviews The service provider will:
recommend a programme that will allow both parties to review formally all aspects of the agreement covering system management and the control of legionellosis	Describe the contract review programme and reference the procedures for arranging and conducting this with the client.
7. Internal auditing The service provider will:
have a management system to ensure that Service Provider compliance with each of these Commitments is self-audited at least once a year and that a formal record is kept	Reference the management procedure and documentation used. A short description is required. The self-audit needs to confirm that you have systems in place to comply with all the relevant LCA commitments. Your records should give evidence that the systems are being followed. You will also need to audit any sub-contractors who are not members of the LCA.
establish a corrective action programme so that any non-compliance identified is corrected in a timely manner	Describe and reference a procedure that details what you will do to correct the non-conformance and prevent its recurrence.
8. Sub-contractors The service provider will:
have a management system to ensure that any sub-contractor holds an independent registration under the Code of Conduct	Describe and reference a procedure that details all controls relating to your relationship with any sub-contractor, how this is recorded and the actions taken to correct any non-compliance.
and/or maintain additional controls and audits to ensure that all activities carried out by this third party are compliant with the Code of Conduct and any relevant legislation
9. Distribution of the Code The service provider will:
have a management system to ensure all clients to whom services are provided, associated with the control of legionella bacteria, are supplied with a copy of the Code of Conduct and certificate of Registration	Detail what mechanism you have for ensuring that all your clients are issued with a copy of the Code.

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