SECTION 1 -

Defining the activity subject to Section 1(1) of the Rural Needs Act (NI) 2016

1A. Name of Public Authority.

Causeway Coast and Glens Borough Council.

1B. Please provide a short title which describes the activity being undertaken by the Public Authority that is subject to Section 1(1) of the Rural Needs Act (NI) 2016.

Legionella Management Policy.

1C. Please indicate which category the activity specified in Section 1B above relates to.

Developing and implementing a Policy.

1D. Please provide the official title (if any) of the Policy, Strategy, Plan or Public Service document or initiative relating to the category indicated in Section 1C above.

Legionella Management Policy.

1E. Please provide details of the aims and/or objectives of the Policy, Strategy, Plan or Public Service.

The policy aims to prevent and control the risks associated with legionella bacteria in Council facilities. To safeguard the health of staff, service users, and the public; ensure compliance with health and safety legislation; provide clear lines of responsibility and accountability; equip staff with appropriate training; and maintain safe, well-managed water systems through effective monitoring and communication.

1F. What definition of ‘rural’ is the Public Authority using in respect of the Policy, Strategy, Plan or Public Service?

Population Settlements of less than 5,000 (Default definition).and other definition

Details of alternative definition of ‘rural’ used: N/A

Rationale for using alternative definition of ‘rural’: N/A.

Reasons why a definition of ‘rural’ is not applicable. N/A


SECTION 2 -

Understanding the impact of the Policy, Strategy, Plan or Public Service

2A. Is the Policy, Strategy, Plan or Public Service likely to impact on people in rural areas?

Yes.

2B. Please explain how the Policy, Strategy, Plan or Public Service is likely to impact on people in rural areas.

The Legionella Policy is designed to protect the health and safety of all staff, service users, and the wider public, including those in rural areas. In rural communities it will ensure that water systems in buildings and facilities are regularly maintained, monitored, and tested, reducing the risk of Legionnaires’ disease.

Specific impacts for rural areas include:

  • Improved safety in rural Council buildings such as community halls, leisure and tourist facilities, and offices.
  • Guidance and training for staff and contractors, ensuring rural teams (including facilities that are Council owned and Community run) can implement Planned Preventative Maintenance (PPM) effectively.
  • Inclusive communication, with accessible materials (Easy Read, pictograms, large print, captioned videos, or BSL) ensuring that all staff and users can understand and follow safety procedures.
  • Targeted support and technical advice provision on water systems of various ages through the policy.

Overall, the policy promotes equitable protection, safe practices, and compliance in rural as well as urban areas, helping to reduce health risks and maintain high standards of public safety across the Council’s geographic area.


2C. If the Policy, Strategy, Plan or Public Service is likely to impact on people in rural areas differently from people in urban areas, please explain how it is likely to impact on people in rural areas differently.

The policy is likely to impact people in rural areas differently from those in urban areas due to geographic, infrastructure, and resource factors. Rural sites may face:

  • Reduced usage frequencies when compared to urban facilities, increasing the potential risk of Legionella growth if not properly managed.
  • Increased usage by younger and older groups or people with disabilities.
  • Smaller teams or reliance on community members, meaning fewer trained staff are available to implement Planned Preventative Maintenance (PPM).
  • Limited access to technical guidance due to later opening hours and more flexible service delivery methods.

To address these differences, the policy includes accessible guidance, flexible training, targeted support, and proactive monitoring to ensure that rural staff and service users have equitable protection and safety, despite these logistical challenges.


2D. Please indicate which of the following rural policy areas the Policy, Strategy, Plan or Public Service is likely to primarily impact on.

Rural Tourism.
Other (Please state): Leisure provision.

    2E. Please explain why the Policy, Strategy, Plan or Public Service is NOT likely to impact on people in rural areas.

    N/A.


    SECTION 3 -

    Identifying the Social and Economic Needs of Persons in Rural Areas

    3A. Has the Public Authority taken steps to identify the social and economic needs of people in rural areas that are relevant to the Policy, Strategy, Plan or Public Service?

    Yes.

    3B. Please indicate which of the following methods or information sources were used by the Public Authority to identify the social and economic needs of people in rural areas.

    Published Statistics and other methods or information sources.

    3C. Please provide details of the methods and information sources used to identify the social and economic needs of people in rural areas including relevant dates, names of organisations, titles of publications, website references, details of surveys or consultations undertaken etc.

    The Council has taken steps to identify the social and economic needs of people in rural areas that are relevant to the Legionella Policy. These include:

    • Assessing the distribution of rural facilities, including usage patterns and occupancy levels.
    • Reviewing Rural Census statistics of the population including age, health status, and vulnerability to Legionnaires’ disease.
    • Considering staffing and resource availability in rural locations.
    • Identifying barriers to training, guidance, and communication, and providing inclusive materials (Easy Read, pictorial guides, large print, captioned videos, or BSL) to ensure all staff and service users can engage fully.
    • Monitoring and reviewing risk assessments to prioritise rural sites with higher potential exposure.

    These steps ensure the policy is responsive to rural-specific needs and supports equitable protection, access, and safety across all Council areas.


      3D. Please provide details of the social and economic needs of people in rural areas which have been identified by the Public Authority?

      Social and economic factors relevant to implementing the Legionella Policy in rural areas have been determined as:

      • Population Vulnerability: Our borough has a high proportion of older residents, who are more susceptible to Legionnaires’ disease.
      • Residents with long-term health conditions or disabilities may require additional support to access information or services safely.
      • Access to Facilities and Services: Rural communities may have reduced local access to healthcare and further to travel to hospitals.
      • Some facilities are seasonally used or intermittently occupied (e.g., community halls, holiday accommodation sites), increasing risks of stagnant water.
      • Infrastructure: Council facilities in both rural and urban areas have older water systems.
      • Limited staffing or turnover of volunteers impacts capacity to carry out regular inspections, monitoring, and training.
      • Digital limitations may create barriers to accessing guidance or requesting maintenance.
      • Inclusive and accessible communication (Easy Read, pictograms, large print, captioned videos, BSL) is needed to ensure all staff and service users understand safety procedures.
      • Rural sites may require additional resources to maintain water hygiene and implement preventative measures.


        3E. Please explain why no steps were taken by the Public Authority to identify the social and economic needs of people in rural areas?

        N/A.



        SECTION 4 -

        Considering the Social and Economic Needs of Persons in Rural Areas

        4A. Please provide details of the issues considered in relation to the social and economic needs of people in rural areas.

        Issues Considered for Rural Areas:

        Population vulnerability: Older residents and those with long-term health conditions or disabilities may be more at risk.

        Access to facilities and services: Seasonal/intermittent building use increases stagnant water risk.

        Infrastructure and resources: Older water systems and small or volunteer teams may limit those willing to train and act as the responsible person.

        Communication and inclusion: Need for accessible materials (Easy Read, large print, pictograms, captioned videos, BSL) to overcome geographic or literacy barriers.

        Economic considerations: Maintenance budget considerations across all sites both rural and urban is one pot. Costs of training additional responsible persons to support the potential of volunteers moving on or having restricted volunteer time.

        SECTION 5 -

        Influencing the Policy, Strategy, Plan or Public Service

        5A. Has the development, adoption, implementation or revising of the Policy, Strategy or Plan, or the design or delivery of the Public Service, been influenced by the rural needs identified?

        Yes.

        5B. Please explain how the development, adoption, implementation or revising of the Policy, Strategy or Plan, or the design or delivery of the Public Service, has been influenced by the rural needs identified.

        The development and implementation of the Legionella Policy now incorporates:

        Accessibility and Communication: Guidance, training materials, and water safety information can be provided in accessible formats (Easy Read, large print, pictograms, captioned videos, and BSL) to ensure understanding among all staff, including those in remote or rural locations.

        Monitoring and Maintenance: The policy ensures that rural buildings with intermittently used water systems have clear scheduled for risk assessment, flushing, and maintenance to prevent stagnation and bacterial growth.

        Support and Training: Additional support and flexible training delivery (e.g., remote sessions, on-site briefings) are made available for rural staff or small teams who may have limited access to centralised training.

        Resourcing: The Council recognises potential cost and logistical challenges in rural areas and allocates resources accordingly to maintain compliance with health and safety standards.

        Collaboration and Review: Regular reviews and collaboration with Environmental Health, Estates, and local rural facility managers ensure that rural risks and feedback are incorporated into ongoing implementation.

        These adjustments ensure the policy is inclusive, proportionate, and effective in addressing both urban and rural circumstances, providing equal protection and compliance across the entire Council area.


          5C. Please explain why the development, adoption, implementation or revising of the Policy, Strategy or Plan, or the design or the delivery of the Public Service, has NOT been influenced by the rural needs identified.

          N/A.


          SECTION 6 -

          Documenting and Recording

          6A. Please tick below to confirm that the RNIA Template will be retained by the Public Authority and relevant information on the Section 1 activity compiled in accordance with paragraph 6.7 of the guidance.

          I confirm that the RNIA Template will be retained and relevant information compiled.

          Rural Needs Impact Assessment undertaken by: Assets Officer.

          Division/Branch: Estates.

          Date: 10.11.2025.

          Rural Needs Impact Assessment approved by: Director of Environmental Services.

          Division/Branch: Environmental Services.

          Date: 12/11/25.