CDC data on Legionnaires’ disease outbreaks from 2015-2019 highlights the crucial differences between a document and an implemented process for ASHRAE 188 water management programs (WMPs). Finding 82% of environmental deficiencies were due to missing or inadequate processes, the CDC concluded that “all of the deficiencies associated with outbreaks could have been prevented by comprehensive, properly implemented WMPs.”

Images courtesy CDC


What Makes WMP Implementation Inadequate?

So what does it mean for a WMP to be improperly implemented, or for processes to be inadequate? Many organizations attempt to address water quality problems by creating policies or “aspirational” documents which, while often well-intentioned, almost always lack specific and repeatable actions that are measurable, verifiable, or effective. Facilities often create these static documents for an audience of auditors, or simply to check a compliance box rather than to improve safety. Steps taken to prepare for auditor reviews could lead to some improvements but do not constitute a water management program. Written statements alone will not mitigate the risk of infection in building water systems.

The water management program outlined in ASHRAE Standard 188 follows a process to address Legionella in building water and reduce the risk of infection to staff, guests, and visitors. Comprehensive and properly implemented water management programs have been shown to effectively minimize and control one of the most avoidable causes of death in commercial buildings: premise plumbing pathogens. A water management plan’s impact in reducing risk comes not from some talisman, binder, or document on a shelf, but rather from facilities and cross-functional teams taking concrete, consistent actions. 


What is a Truly Healthy Building?

Healthy building initiatives often address safety issues such as carbon dioxide, carbon monoxide, and fire protection – as they should – but neglect Legionella and other pathogens which are responsible for a significantly higher number of hospitalizations and deaths. To have a truly healthy building, a comprehensive water management program must be implemented to control Legionella and other pathogens in the building water systems. It can make the difference between life and debilitating illness or death for the building’s tenants, patients, residents, visitors, guests, and staff.


Processes that Provide an Effective Water Management Program

Effective water management programs require a process approach in part because water is by nature a “process fluid” and remains dynamic throughout its journey. From source water to a municipal treatment plant, through networks of city piping, and finally to buildings and their associated miles of pipes, water is constantly changing during each part of this maze. Near undetectable traces of pathogens picked up in a network or grown in the biofilm can dramatically multiply in a building where the water is heated, its disinfectant levels drop, or it becomes stagnant. These changes require a process approach to minimize water quality variations that can be controlled. 

Edwards Deming, the famous Professor, author, and management consultant defined process and quality best: “Quality comes not from inspection but from the improvement of the production process.” Testing and inspection will not improve the safety of building water without corrective actions and control measures that are continuously refined based on data collected in an actual water management program. 

Water management programs require a team, and the program must manage the activities and responsibilities of each team member. Much like a conductor leading musicians in a symphony, coordination among internal departments and external partners is vital in managing building water. Team members must share control measure documentation and test results and work together to determine corrective actions needed. 

With all that is required to successfully execute a water management program, automation will be critical for ensuring proper process flow. Just as businesses and other organizations automate payroll, project management, and most other complex operations, water management programs are best executed with software that automates tasks, analytics, and reports. The water management program software must be dynamic and flexible, providing notifications, reports, and analytics–almost like a virtual project manager. 

Do you have a comprehensive, properly implemented water management program – the kind that the CDC reported could have prevented all the deficiencies associated with outbreaks it investigated from 2015 to 2019? Just as you would not use a static binder or template to manage your organization’s finances, you should not trust the same for managing water quality, which affects health and life.

David Swiderski is the Senior Technical Strategist at

What water management program tools or processes have you found to be especially effective in ensuring the implementation of effective Legionella control measures?

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