Are you taking Legionnaires’ disease seriously enough? The summer 2015 outbreak in New York City that killed 12 people and sickened over 100 more underscores the danger to your building occupants (and your reputation) if Legionella risk isn’t managed carefully.
Because Legionella is a building water problem, health officials agree that managing building water systems properly is the key to prevention. Since last summer’s outbreak, laws were established to require building operators in New York State to create water management plans by March 2016 that include cooling towers.
Take this opportunity to reduce your legal risk, protect your brand and show leadership in corporate responsibility by instituting a water management program informed by ANSI/ASHRAE 188-2015. This regulation-ready standard has broad support for its Legionella prevention approach and complies with Veterans Health Administration and World Health Organization guidelines.
However, ASHRAE 188 only provides a framework and basic requirements – the rest is up to you. Your decisions can impact the success and cost of your water management program for years downstream. Lay a solid foundation for success with these nine tips.
1) Understand Your Portfolio
Which properties should have water management plans (WMPs)? For a multi-building campus, should all the buildings be included or just some of them?
A WMP can cover all the buildings on one site, but not multiple sites. For example, only one WMP is needed for a property with multiple buildings managed by the same personnel even if the buildings are for different uses (e.g., healthcare and office). But three buildings in different locations – even if the buildings are similar in size and configuration and located within a few miles of each other – will require three WMPs, one for each site.
What about leased buildings? Deal with landlords and tenants as necessary to ensure control measures are implemented. You may need to ask (or require) tenants to maintain their plumbing fixtures per your WMP. Otherwise, those areas could not only present a risk to people in the tenant space but also affect Legionella growth in other parts of the plumbing system. If the tenant is responsible for maintaining a cooling tower that could affect people in its building as well as other buildings on the campus, ensure the tenant’s cooling tower maintenance complies with your WMP.
2) Include All At-Risk Water Systems
Standard 188 requires WMPs to account for cooling towers, whirlpool spas, ornamental fountains, water features, misters, air washers and humidifiers. For plumbing systems, however, the standard requires a WMP only if the building has any of the following:
■ A centralized hot water system
■ More than 10 stories
■ Housing designated for people over 65
■ Patients staying longer than 24 hours
■ An area housing or treating people who are immunocompromised or otherwise more susceptible than the general population to Legionella infections.
How you apply the first two factors – centralized hot water systems and the number of stories – is crucial to risk management.
All other factors being equal, a centralized domestic hot water system (for example, ground floor water heaters supplying hot water to faucets with recirculation back to the heaters) is typically more prone to Legionella growth than a system that supplies only cold water to faucets with tankless heaters underneath. But other non-centralized domestic hot water configurations – such as small tank-type water heaters for apartment units or sets of common-area restrooms – may actually be more prone to Legionella growth than a centralized system with recirculation.
It’s also not uncommon to find Legionella in samples collected from domestic cold water systems, especially during the summer when the water may not be all that cold.
Think carefully about the number of stories as well. Larger piping networks are generally more prone to Legionella growth than ones found in single-family homes or small office buildings, but Legionella testing data indicates that you’d be foolish to assume a building is free of Legionella because it has 7 stories instead of 11.
Consistency is key to making good decisions. If you have authority over several buildings and only some of them have an ASHRAE 188 risk factor, be consistent with control measures regardless of your decision about establishing a WMP.
Let’s say you have 20 buildings in your portfolio, 15 of which have either 10-plus stories or a centralized domestic hot water system, and 5 that don’t have any risk factors. If you establish a WMP for the 15 but not for the other 5, you should still implement control measures in the 5 that are consistent with the 15 for like-kind equipment. For example, if the WMPs for the 15 buildings outline control measures for cold water storage tanks, implement those same measures for cold water storage tanks in the other 5. If the WMP for the 15 buildings has flushing procedures for infrequently used faucets, make sure the other 5 buildings use the same. Otherwise, if a case of Legionnaires’ disease occurs, how will you explain why you implemented control measures in buildings 1-15 but not for the same equipment in buildings 16-20? Saying ASHRAE 188 did not require a WMP is not a good enough answer – your program must be defensible.
A smart approach might be to establish comprehensive WMPs for buildings with risk factors and then decide how to keep the other buildings consistent with that plan. For some facilities, it may make sense to establish a full WMP even if ASHRAE 188 does not require it. In others, you might create a simple list of maintenance measures without all the elements of a full-blown WMP such as team meetings and validation.
3) Define the Assessment Scope
A WMP should be established based on types of building water systems rather than on Legionella test results or the condition of equipment. This means that the objective of the assessment is not to assess risk to determine whether a WMP is needed; the point is simply to identify the types of water systems on the site, note key system components and construct diagrams showing how the systems flow to one another. Taking pictures can be helpful to the team but is optional. Testing water systems for Legionella can provide valuable information for validating the effectiveness of a WMP, but is not necessary for the assessment.
Your assessment also doesn’t need to report conditions conducive to Legionella growth or transmission. A comprehensive WMP will include control measures to correct any problems a surveyor would find. That is why the water management plan model provides better risk reduction than periodic expert assessments. Instead of getting a risk assessment report card once a year, the WMP leads the facilities personnel down a path of continuously uncovering and correcting potential problems.
Because the primary objective is to identify water systems rather than assess risk, it is actually more accurate to call it a site survey or water systems survey rather than an assessment.