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Legionella · Hotels, lodges and guesthouses · Checklist
Key facts
- The law OHS Act s9 covers guests, the HBA Regulations 2022 cover staff
- US outbreaks 2000 to 2014 hotels and resorts were the setting in 12 of 27
- Stored hot water 60 °C or above
- Showers at least 50 °C within one minute
- Empty rooms flush outlets weekly
- Showerheads clean, descale, disinfect quarterly
- Hot tubs pH and disinfectant at opening and every 2 hours, Legionella monthly (GN 7779), drained and cleaned at least weekly
- Training before staff are exposed, refresher every year or as the health and safety committee or representative recommends
Train your housekeeping, maintenance and spa team
Legionella Awareness Training is four hours on a phone: the temperature numbers, flushing, showerhead cleaning, what to report and to whom, and a walk through a full hotel case. R799 a person.
Why are hotels a Legionella risk?
The disease got its name in a hotel. In July 1976, 182 people who attended an American Legion convention in Philadelphia fell ill with a pneumonia nobody could explain, and 29 died. The spread was airborne around the headquarters hotel, and Legionnaires’ disease takes its name from that convention.
Fifty years on, hotels are still the most common setting. Of the 27 outbreaks the CDC investigated in the USA from 2000 to 2014, 12 were in hotels and resorts. The reasons are the same everywhere:
- Showers make exactly the fine spray that carries Legionella into the lungs.
- Empty rooms in low season, during renovations or on a closed floor leave water standing in the pipes.
- Hot water set low to save electricity, on heat pumps, solar preheat or geysers on timers.
- Spa pools and hot tubs run warm and put aerosol right in the breathing zone.
- Guests include retirees, coach tours and people with chronic illness, who are most likely to become seriously ill.
What does South African law expect of a hotel or guesthouse?
Section 9 of the OHS Act requires you to run your business so that people who are not your employees, your guests, are not exposed to hazards to their health. The Regulations for Hazardous Biological Agents, 2022 list Legionella spp. as a Risk Group 2 agent and require a documented risk assessment by a competent person, controls, monitoring, records, and training for staff before they are exposed, with a refresher every year or at intervals the health and safety committee or representative recommends. The National Environmental Health Norms and Standards for Premises and Acceptable Monitoring Standards for Environmental Health Practitioners (GN 7779, 7 August 2026) list Legionella spp. in pool and hot bath monitoring at accommodation establishments. They set Legionella monitoring monthly for hot tubs and three-monthly for public pools, a limit below 1 per 100 mL where Legionella is tested, and weekly draining and cleaning of hot tubs. That is what the environmental health practitioner who inspects you will be working from. The full legal picture is in Legionella regulations in South Africa.
What should a hotel Legionella checklist include?
| When | Check | The standard | Who |
|---|---|---|---|
| Daily | Hot tub pH and disinfectant at opening and every two hours, filters backwashed, surfaces cleaned, recorded | Within the supplier’s limits, or out of use | Spa staff |
| Daily | Cooling tower running normally (if you have one, see Legionella in cooling towers) | Water clear, no slime, contractor’s scheme followed | Maintenance |
| Weekly | Flush every outlet in rooms not used that week | Several minutes, hot and cold, spray kept low, recorded | Housekeeping |
| Weekly | Hot tub drained, cleaned and refilled. E. coli and Pseudomonas aeruginosa sample | At least weekly (GN 7779), daily where the risk assessment says | Spa staff, responsible person |
| Monthly | Calorifier or geyser flow and return | Flow 60 °C or above, return at least 50 °C | Maintenance |
| Monthly | Hot and cold at the nearest and furthest rooms | Hot at least 50 °C within one minute, cold below 20 °C within two minutes | Maintenance |
| Quarterly | Showerheads and hoses | Cleaned, descaled and disinfected | Housekeeping |
| Monthly | Hot tub Legionella sample (GN 7779), aerobic count and coliforms (HSG282) | Accredited laboratory. Legionella below 10 cfu/L (GN 7779) | Responsible person |
| Quarterly | Cooling tower Legionella sample | Accredited laboratory, read against action bands | Responsible person |
| Six-monthly | Eyewash stations in pool and chemical stores | Flushed to drain, three to five times the stagnant volume | Maintenance |
| Annually | Roof tanks, calorifiers, TMVs | Inspected and cleaned, TMVs tested for fail safe | Maintenance or contractor |
| At least every 24 months | Legionella risk assessment review | Sooner after any change, incident or bad result | Competent person |
Free tool: walk your hotel in 20 minutes
The free Legionella Water Walk loads a 140-room hotel case so you can see what a walk finds, then lets you do your own. 24 points, findings ranked High, Medium and Low, exported as a spreadsheet.
Try the free Water Walk, then learn to act on what it finds in Legionella Awareness Training (R799).
How do you manage empty rooms and closed floors in low season?
This is the single most common gap I find in accommodation. A floor closed for renovation, a wing shut for winter, rooms nobody books mid-week. Water sits in the pipes at room temperature and biofilm builds. Then the floor reopens for a coach tour of older guests and the first person into each shower breathes whatever has grown.
- Put every unused room and outlet on a weekly flushing list, hot and cold, run for several minutes with the showerhead pointed into the drain and the curtain closed.
- Record each flush: date, room, outlet, time run, your name. A step-by-step routine and a log to copy are in our Legionella flushing procedure.
- Before a closed floor or wing reopens, flush every outlet, and where it has stood for a long time or results require it, sample and disinfect before guests return.
- Shower rooms that are hardly ever used, such as conference centre or pool change rooms, either go on the weekly list or have the outlets removed.
Your housekeepers flush the closed floor. Do they know why?
Legionella Awareness Training gives housekeeping, maintenance and spa staff the numbers, the flushing routine, the hot tub checks and what to report, using a 140-room hotel as the case. Four hours on a phone, R799 a person.
How should a hotel hot tub be checked for Legionella?
In 1999 a whirlpool spa on display at a flower show in the Netherlands, kept at 37 °C without proper disinfection, caused 188 cases of Legionnaires’ disease and 21 deaths. A hot tub is warm water and aerosol in the breathing zone by design. Two documents set the routine. A hotel hot tub that guests share counts as a commercial spa pool under the UK’s spa pool guidance (HSE HSG282), and GN 7779 sets hot tub monitoring in South Africa. ASC’s position: run a hotel hot tub to the stricter of GN 7779 section 7 and HSG282. Section 7 of GN 7779 (public swimming pools and spa baths) is the part that applies, and its 7.3 schedule sets monthly sampling for hot tubs. That gives this routine:
- At opening and every two hours while open: test the pH and the residual disinfectant, and record every reading (HSG282).
- Daily: backwash the filters at the end of the day (HSG282) and physically clean the surfaces (GN 7779).
- Weekly: drain, clean and refill at least weekly (GN 7779), or daily where the risk assessment says so (HSG282). Send water for E. coli and Pseudomonas aeruginosa weekly (GN 7779).
- Monthly: aerobic colony count and coliforms (HSG282), and Legionella monthly (GN 7779, hot tubs). HSG282 alone asks for Legionella at least quarterly.
- Reading the results: GN 7779 sets the limit below 1 per 100 mL, which is below 10 cfu/L, so ask the laboratory for a detection limit of 10 cfu/L or lower. Any count of 10 cfu/L or more: review the controls and resample, whatever the HSG282 band. Above 1 000 cfu/L: close the tub at once and keep people out of the pool area, shut it down, shock dose, drain, clean and disinfect, review the risk assessment, refill, and retest the next day and again 2 to 4 weeks later (HSG282).
Take the tub out of use whenever a check fails or cannot be done.
What hot water settings suit guesthouses with geysers, heat pumps or solar?
Guesthouses and lodges usually run on individual geysers, heat pumps or solar. The rule is the same as a big hotel’s plant room: store at 60 °C or above. A geyser switched off overnight can cool into the growth range as hot water is drawn and cold water refills it, and a heat pump set to 50 °C to save electricity keeps the water in the range where Legionella grows. If scalding is a worry, especially for older guests and children, fit thermostatic mixing valves at the basins and showers instead of turning the water down, and fit and test them before you raise the storage temperature. The numbers are explained in Legionella and hot water temperature.
Roof and JoJo-type storage tanks added after water outages are the other common weak point. Keep the lid tight and the overflow screened, keep stored volume to no more than a day’s use by lowering the float valve so water still flows through every tank, and inspect inside at least once a year. See Legionella in water storage tanks.
What should a hotel do if a guest falls ill with Legionnaires’ disease?
Legionnaires’ disease takes 2 to 10 days to show, so the guest has usually gone home. The diagnosing doctor or laboratory notifies the Department of Health within 7 days, not the hotel. If two or more cases are linked to your property within 12 months, it is a cluster and municipal environmental health practitioners will investigate, ideally starting within 24 hours.
What you do: restrict use of the suspected outlets and the hot tub straight away, do not drain or disinfect until you have agreed it with the investigating EHP so the evidence is not destroyed, have your risk assessment, temperature logs, flushing records and contractor reports ready, and name one person to speak for the property. Who carries which duty is set out in who is responsible for Legionella.
Enrol your team in Awareness Training (R799) →Start the Responsible Person course (R2 950) →
Frequently asked questions
Does a guesthouse need a Legionella risk assessment?
Where guests or staff may be exposed to aerosol from showers, taps, a hot tub or a cooling tower, yes. The OHS Act covers guests under section 9 and the HBA Regulations, 2022 require a documented risk assessment by a competent person, reviewed at least every 24 months.
How often should hotel rooms that are not used be flushed?
Weekly, hot and cold, for several minutes, with the spray kept low and every flush recorded. Before a closed floor reopens, flush every outlet, and sample and disinfect where it has stood for long or results require it.
How often should hotel showerheads be cleaned?
Every quarter: cleaned, descaled and disinfected, or more often if they foul quickly.
What temperature should hotel hot water be?
Stored at 60 °C or above, reaching 50 °C or more at the shower within one minute, with circulation returns at least 50 °C. Cold water should stay below 20 °C.
Are hot tubs a Legionella risk?
Yes. They run warm and put aerosol in the breathing zone. Check pH and disinfectant at opening and every two hours, test E. coli and Pseudomonas aeruginosa weekly and Legionella monthly (GN 7779), aerobic count and coliforms monthly (HSG282), and drain and clean the tub at least weekly. Close it at once if Legionella is above 1 000 cfu/L (HSE HSG282).
Which hotel staff need Legionella training?
Anyone who may be exposed or whose work controls the risk: maintenance, housekeeping, spa and kitchen staff. The HBA Regulations require training before possible exposure, with a refresher every year or at intervals the health and safety committee or representative recommends.
Who reports a guest with Legionnaires’ disease?
The doctor or laboratory that diagnoses it notifies the Department of Health within 7 days. The hotel co-operates with the environmental health investigation and keeps its records ready.
Train the hotel team who run the showers
Four hours for the team who flush, clean and check. Ten hours for the person who carries the duty, with a complete hotel risk assessment and water management plan built in the course.
Enrol in Awareness Training (R799) →Responsible Person course (R2 950)Self-paced, works on a phone. HPCSA CPD accredited. Certificate on passing.
Sources and further reading
- CDC Vital Signs: Legionnaires’ disease outbreaks, 2000 to 2014
- Fraser et al. (1977), the Philadelphia outbreak
- Den Boer et al. (2002), the Bovenkarspel flower show outbreak
- HSE HSG274 Part 2: hot and cold water systems
- HSE HSG282: spa pool systems
- National Environmental Health Norms and Standards for Premises and Acceptable Monitoring Standards for EHPs (GN 7779, 2026)