Covid-19 Empty or Reduced Occupancy User Guide


Bromwich Hardy have produced this user guide for all Landlords and Tenants who face disruption during the pandemic and having to leave their units empty as directed by the Government. We felt it necessary to produce the attached to help our clients to look after their buildings and by putting this out we also hope it aids others during this crisis.




With the rapidly developing Covid-19 situation bringing about a lock-down status across the UK, we are obviously experiencing a significantly reduced level of occupancy across much of our managed portfolio.

Initially implemented for three weeks from Monday 23 March, the Government announcement on 29 March. They suggested we may in fact see a more prolonged lock down period, and we are planning for the potential extension of the current measures and/or further restrictions in the future. We are working closely with our clients, occupiers and service providers to ensure that service charge levels are appropriate to the unique circumstances for each asset.

There is clearly a desire from clients and occupiers to reduce service charges where occupancy levels are reduced, but as responsible managing agents our priority is to ensure the right level of health, safety and security. Our aim is to strike a balance between reducing services such as reception staff and adjusting the running times for plant and equipment, whilst ensuring statutory compliance, health and safety and security of the properties, occupiers, public and staff is not compromised.


We are reviewing the properties to deliver the right service level provision and ensure management reflects the ongoing priorities and requirements of both occupiers and landlords.

Costs will reflect the specific property’s unique service level provision and while this will lead to reduced cost in a number of areas through reduced provision, it is imperative we continue to meet all contractual and lease obligations and in some instances, increase costs, for example, if security needs to be enhanced over the lock down period.

Whilst we are looking at reducing costs as much as possible to ensure each Property is managed appropriately, it is important that service charges continue to be paid.

We are following government advice and working closely with our supply chain to ensure we are providing our clients and occupiers with clear and appropriate advice.


On Friday 20 March 2020, The Chancellor announced a historic package aimed at further helping employers in times of unparalleled economic uncertainty. The Coronavirus Job retention scheme which has been set up to allow “all UK employers to access  support to continue paying part of their employees’ salary for those employees that would otherwise have been laid off during this crisis.

Although the announcement was made on 20 March, the online service to make claims is not available yet, and is not expected to be made available until the end of April 2020.The Coronavirus Job Retention Scheme is a temporary scheme open to all UK employers for at least three months starting from 1 March 2020. It is designed to support employers whose operations have been severely affected by coronavirus (COVID-19).

Employers can use a portal to claim for 80% of furloughed employees’ (employees on a leave of absence) usual monthly wage costs, up to £2,500 a month, plus the associated Employer National Insurance contributions and minimum automatic enrolment employer pension contributions on that wage. Employers can use this scheme anytime during this period.

The scheme is open to all UK employers that had created and started a PAYE payroll scheme on 28 February 2020.


Currently, our engineering supply chain continue to maintain the buildings under our management. The engineers are focusing on conformance, compliance, life safety and water hygiene tasks over other tasks, and as time progresses and there is an increase in staff sickness or a more stringent ‘lockdown’ activity will move more towards just the delivery of statutory maintenance.  A full lock down will present real problems in terms of complying with even this. Missed planned preventative maintenance tasks will be highlighted through audits and at that time, we will be in a position to verify if the tasks can be still carried out and brought back into line or whether there should be a reimbursement of costs.

Mothballing of sites is not a practice recommended unless it is for a significant length of time and then only after very careful consideration. In our view, it is far better to keep the plant operational and wet systems filled.


We will look to reduce front of house services, cleaning services and waste management services as far as is practicable. In many of the buildings, some cleaning staff will be required to undertake flushing of water outlets. Security staff, as required to maintain the security of the building will still be in place.


As the managing agents for your building, we take our responsibilities for water and in particular legionella management extremely seriously. As a result, we have in place robust policies and systems to ensure that we meet legislative requirements within the landlord demised areas.

 The events around the management of the COVID-19 outbreak are affecting us all and in particular, in the occupation and usage of our buildings, where we are constantly reviewing and amending our procedures to reflect changing demands as a result. The work includes increased flushing of our water systems as needed, isolating or adjusting the use of our systems as demand dictates and ensuring or contractors and suppliers can accommodate our requirements over this time. As one of our occupiers, we wish to remind you of your own responsibilities for legionella management with the water systems and services in your own demised areas. These as I’m sure you are aware are detailed in Legionnaires disease - The control of legionella bacteria in water system (L8). These will typically include:

  • Showers
  • Hot and cold domestic water services - to include, immersion units, and fixtures and fittings supplied by you within your
  • Washroom facilities
  • Kitchenette fixtures and immersion units
  • Evaporative cooling systems
  • Spa baths
  • Water features

Our activities will maintain water quality in the central common area systems, and you will need to do the same for those water services that fall under your responsibility. This could include the increased flushing of outlets that due to reduced occupancy are being infrequently used and/or temporarily isolating systems you may not be using over a prolonged period. Your legionella risk assessment and water management system should help to identify the regimes you have in place to maintain compliance with L8 and which may now need modifying, albeit temporarily. Legionnaires disease Part 2: The control of legionella bacteria in hot and cold water systems (HSG274 Part 2) states:

"Buildings temporarily taken out of use (mothballing).

2.50 Where a building, part of a building or a water system is taken out of use (sometimes referred to as mothballing), it should be managed so that microbial growth, including legionella in the water, is appropriately controlled.

2.51 All mothballing procedures are a compromise between adequate control of microbial growth, the use of water for flushing (while avoiding waste) and degradation of the system by any disinfectant added. Where disinfectants are used, these should leave the system fit for its intended purpose."

So, for example the advice HSG274 Part 2 provides for infrequently used outlets is: "Infrequently used equipment within a water system (i.e. not used for a period equal to or greater than seven days) should be included on the flushing regime. Flush the outlets until the temperature at the outlet stabilises and is comparable to supply water and purge to drain. Regularly use the outlets to minimise the risk from microbial growth in the peripheral parts of the water system, sustain and log this procedure once started". All other maintenance tasks such as temperature testing, shower de-scaling and should continue as usual unless the systems have been isolated or removed. Please make sure you do not create any dead legs in the system if you remove or isolate any of your water systems. It is important to note that the general maintenance and cleanliness of your systems and outlets can affect the entire building system, so it is extremely important to ensure that appropriate regimes are in place.

Thank you for working with us over this time and please feel free to get in touch with one of our professionals on 02476 308900