Cases4107571/2024

Claimant v East Ayrshire Council

8 July 2025Before Employment Judge Mrs M KearnsScotlandin person

Outcome

Claimant fails

Individual claims

Otherfailed

The tribunal affirmed Prohibition Notices issued under the Health and Safety at Work Act 1974 against the appellants. The appellants operated a hot tub/spa pool without adequate control measures to prevent risk of serious personal injury from legionella and other infectious agents. The tribunal found the appellants lacked understanding of the risks, failed to maintain proper bromine disinfectant levels (4-6 mg/l), had no effective scheme of control, did not conduct required microbial testing, and used inadequate testing methods. The system was deemed unsafe and out of control at the time the notices were served.

Facts

The appellants operated a four-person hot tub/spa pool at their day spa in New Cumnock. Following a health and safety inspection on 14 November 2024, East Ayrshire Council environmental health officers found serious deficiencies in the operation of the spa pool, including inadequate chemical disinfection (bromine levels below required 4-6 mg/l), no risk assessment or scheme of control, no microbial testing, inadequate cleaning procedures, and lack of knowledge by the operator about safe operation. Prohibition Notices were issued on 15 November 2024 requiring immediate cessation of spa pool operations until safety measures were implemented.

Decision

The tribunal unanimously affirmed the Prohibition Notices. The tribunal found that at the time the notices were served, the appellants' hot tub activities involved a risk of serious personal injury from exposure to legionella and other dangerous bacteria. The appellants failed to demonstrate understanding of the risks, maintain proper chemical levels, conduct required testing, or implement an effective control system. The evidence showed bromine levels had been recorded as low as 2.5 mg/l when 4-6 mg/l was required, and no microbial sampling had been done in 18 months of operation.

Practical note

Operators of commercial spa pools and hot tubs must demonstrate comprehensive understanding of legionella risks and maintain rigorous control systems including proper chemical dosing (4-6 mg/l bromine), twice-daily testing, regular shock dosing, and monthly microbial sampling to avoid prohibition notices for serious health and safety risks.

Legal authorities cited

HM Inspector of Health and Safety v Chevron North Sea Ltd [2018] SC (UKSC) 132

Statutes

Health and Safety at Work Act 1974 s.3Control of Substances Hazardous to Health Regulations 2002 regs 6, 7, 8, 9Health and Safety at Work Act 1974 s.4Health and Safety at Work Act 1974 s.22Health and Safety at Work Act 1974 s.24

Case details

Case number
4107571/2024
Decision date
8 July 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Name
East Ayrshire Council
Sector
local government
Represented
Yes
Rep type
solicitor

Employment details

Role
Operator of day spa

Claimant representation

Represented
No