The written document for the water management program under ASHRAE's proposed Legionella standard must include the following:
• A list of the water management program team members. For example, in a hospital this would likely include one or more employees from facilities, infection control, safety, and administration, along with the medical director, infectious disease specialist, and risk management director, up to about 10 team members total.
• A brief description of the building water systems, with flow diagrams. The flow diagrams do not have to be detailed or scaled drawings. Simple line drawings showing the points (e.g., point of building entry) and processing steps (e.g., water heating) are sufficient and actually better than detailed drawings in giving the water management program team a clear understanding of the locations where Legionella control measures must be applied.
• Analysis of building water systems. The analysis must determine which water systems present a significant potential for Legionella growth and transmission and the locations where Legionella control measures can be applied.
• Control measures. This is the most important part of any Legionella water management plan because control measures are what actually reduce the risk of Legionnaires' disease. If effective control measures are not selected, the water management program will fail to sufficiently reduce Legionella risk. Each control measure must be monitored to determine whether it is performed to the standard — called a control limit — designated in the water management program. If the control limit is not met, then corrective action must be implemented. In the water management program document, the monitoring procedure and schedule, control limit, and corrective action must be listed for each control measure.
• Verification procedures. These procedures are to ensure that the water management program is being implemented. For example, documentation for each control measure must be reviewed to ensure proper implementation.
• Validation. The effectiveness of the water management program must be validated. Testing water systems for Legionella provides the most direct feedback on Legionella control. Legionella testing is discussed as a validation option in draft number four but is not required.
• Documentation. Draft number four instructs the team to “Establish documentation and communication procedures for all activities of the (water management program).”
Building owners who do not already have an adequate Legionella control program will incur expense in following what is outlined in 188P. But, for a facility that is already well maintained, an effective Legionella water management plan can be developed and implemented at a reasonable cost.
It’s worth it. The risk of Legionella is real. Thousands of people contract the disease in the US each year. Many die from it and others endure horrible suffering and long term disabilities.
Preventing Legionnaires' disease will save money, too. The Center for Disease Control and Prevention (CDC) has reported that Legionella is not only the number one cause of waterborne disease outbreaks in the United States, it is also the most expensive based on the average cost of a hospital stay associated with the disease.
Matt Freije is the founder and president of HC Info, a company that provides training courses, management plans, webinars, and consulting services pertaining to Legionella control. Freije is the editor of Legionella Enews, an international newsletter with more than 4,000 subscribers. His first book, Legionellae Control in Health Care Facilities: A Guide for Minimizing Risk, has been distributed in more than 30 countries. He can be reached at mfreije@hcinfo.com.
A Look At ASHRAE's Pending Legionella Standard, 188P
Water Management Under ASHRAE’s Proposed Legionella Standard
