ASHRAE 514 Water Management Plans: Keys to Smart Compliance

Building owners and operators are facing an important decision about managing the water systems in their facilities: Should they adopt ASHRAE 514?

ASHRAE 514 became an ANSI standard on July 25. Clarity on the requirements and challenges of ASHRAE 514 will help facility managers decide whether to adapt their ASHRAE 188 water management plan to ASHRAE 514 and, if so, how to do it without excessive liability, burden to personnel, or cost.

Purpose and Essential Elements of ASHRAE 514 and ASHRAE 188

ASHRAE standards 514 and 188 outline requirements for the management of water systems in buildings (other than single-family homes) to reduce hazards to humans. “Management” includes design, construction, commissioning, operation, repair, maintenance, replacement, and expansion of the building water systems.

The framework of the two standards is almost identical, probably in part so ASHRAE can combine them at some point. Both standards require forming a program team to implement a water management program (WMP) that has the following:

1. Description of the building water systems, with flow diagrams
2. Analysis of the building water systems to determine where the hazards present a significant risk and can be controlled (control locations)
3. Control measures, each with a control limit (i.e., performance criterion), a monitoring procedure, and a corrective action to take if the limit is exceeded
4. Verification of program implementation
5. Validation that the program is sufficiently controlling the hazard(s)
6. Documentation
7. Communication procedures

Requirements of ASHRAE Standard 514 versus ASHRAE Standard 188

ASHRAE Standard 514 is an expansion of ASHRAE Standard 188. ASHRAE 514 actually requires compliance with ASHRAE 188.

The main difference between ASHRAE 188 and ASHRAE 514 is in the hazard(s) to be controlled (Table 1). The scope of ASHRAE 188 is specific and limited, to control one hazard: legionellosis (Legionella). ASHRAE 514 is broad, requiring control of all microbial, chemical, and physical hazards associated with building water systems.

Some less important but notable differences between the two standards are outlined in Table 2.

Table 1. High Level Comparison of ASHRAE 188 and ASHRAE 514

Table 2. Other Notable Differences Between ASHRAE 188 and ASHRAE 514

Will ASHRAE Standard 514 be Adopted by Authorities?

Whether and when ASHRAE Standard 514 gets “traction” in the US will affect the number of facilities that adopt it.

Will states that already have regulations or pending regulations based on ASHRAE Standard 188 broaden the requirements per ASHRAE Standard 514?

Will new state regulations be based on ASHRAE 514 rather than ASHRAE 188?

Will the requirements of Joint Commission Standard EC.02.05.02 be expanded to align with ASHRAE 514?

Will ASHRAE 514 be adopted only in healthcare facilities?

Will the Centers for Medicare & Medicaid Services (CMS) broaden CMS QSO-17-30 per ASHRAE 514?

Will liability related to the management of building water systems increase because of the additional hazards outlined in ASHRAE 514?

Will ASHRAE 514 replace ASHRAE 188 as the primary standard on which to evaluate building water system management in the US?

For the above questions to which the answer becomes Yes, how long will it take?

Challenges of Complying with ASHRAE Standard 514

Two particular aspects of ASHRAE Standard 514 make compliance challenging.

The purpose statement of ASHRAE 514 – to “reduce illness and injury from physical, chemical, and microbial hazards” – is broad and essentially unlimited. No one can succeed at a task that is poorly defined and ever expanding. For example, “microbial hazards” could mean the team is responsible for a long and expanding list of microbes that have been found in domestic (potable) water systems and have caused infections. Without clearly defining the physical, chemical, and microbial hazards to be controlled, the WMP team will not be able to show that the water management program is successful. The objective of the water management plan must be achievable. Even better: under-promise and over deliver.

Another challenge is the level of detail required in ASHRAE 514 for describing water systems and for documentation and communication. For example, “identification, location, and description of all POUs” could strain already stretched facilities management teams if it literally means listing and describing every point of use (POU).

7 Keys to Smart Compliance with ASHRAE 514

Letting the above challenges scare you into ignoring ASHRAE 514 would be a mistake.

Consider the following in converting an ASHRAE 188 water management plan to ASHRAE 514:

a. Write an expanded WMP scope (i.e., objectives; purpose) that addresses ASHRAE 514 but is limited, achievable, and crystal clear, particularly regarding the hazards to be controlled.

b. Expand the risk analysis of the water systems (hazard analysis) to include the additional hazards. Be specific in the reasoning for whether a water system presents a significant risk and is or is not a control location.

c. Make sure the WMP has effective, specific control measures for the team-defined hazards.

d. Expand as necessary the validation procedures for determining whether the program is effective in controlling the hazards. The validation procedures must be consistent with the scope, specific, and crystal clear so there is no doubt as to whether the WMP is successful.

If you consider validating your water management plan by testing for disease-causing microbes (pathogens) other than Legionella, outline your plan for responding to the findings based on scientific studies or guidelines pertaining to the interpretation of test results for those pathogens.

e. Prioritize measures that protect health and life.

If you do not have the money or personnel to comply with all aspects of ASHRAE Standard 514, prioritize what will protect health and life. Only effective control measures will reduce risk. The other elements of ASHRAE standards 188 and 514 – water system descriptions, flow diagrams, documentation, etc. – are only to facilitate the successful implementation of the control measures. For example, documentation is important for showing compliance but in itself does not reduce the presence or transmission of waterborne contaminants.

Prioritizing control measures makes a water management program more defensible, too. People can get sick if the water systems are managed poorly, but they won’t get sick because the flow diagrams lack details someone insists are necessary, or because you did not describe each of your 1000-plus faucets.

Here’s some good news: a facility that is already implementing a comprehensive water management plan will need to add few, if any, truly risk reducing procedures to adopt ASHRAE 514. For example, for many years, long before the first draft ASHRAE 514, LAMPS water management plans have had measures specific to pathogens other than Legionella (e.g., Pseudomonas) and measures for reducing risks associated with scalding and certain chemical hazards.

f. Make the water management program as easy, automated, and simple as possible.

This does not mean cutting corners. Do every risk-reducing procedure well, but as easily as possible.

A 2021 study of 908 water management programs indicated that making a water management plan easy and less expensive may be important for significantly reducing Legionnaires’ disease by increasing the number of facilities that are fully implementing effective control measures.

g. Focus first on the 18 pages of the standard rather than the 74 pages of appendices. The appendices have some good information but are not part of the standard.

Will ASHRAE 514 Improve Public Health?

History tells us it depends on the answer to more specific questions:

Will ASHRAE 514 increase the number of facilities that execute effective prevention? The response to ASHRAE 188 tells us that the vast majority will do only what is required. It is unrealistic to anticipate a more favorable voluntary response to ASHRAE 514. So, that raises these additional questions:

Will ASHRAE 514 be required by state or other government regulations, accrediting organizations, or insurance companies (e.g., for liability policies)? If so, will the documentation and reporting requirements be:

• Consistent from one state to another, which is especially important for compliance among owners of properties in multiple states?
• Focused on key preventive measures instead of on time-consuming documentation and reporting that, in itself, does not reduce risk?
• Not too lax and not too detailed, to maximize prevention? Ironically, overly burdensome regulations could actually increase illness if facilities focus their time and creativity on surviving inspections instead of on managing water systems well.

The Bottomline

Don’t ignore ASHRAE 514. It is a good standard, overall.

Adapt your facility’s water management program to ASHRAE 514, but in a way that sets you up for success, is easy enough to be sustainable, and minimizes your legal risk.

If your facility does not yet have a comprehensive water management plan, get started now. Without a well executed water management program, a building cannot be truly smart or healthy.

Matt Freije is a certified ASSE Standard 12080 instructor, the CEO of HC Info, and the content director for LAMPS, a cloud application for water management plans, water quality monitoring and benchmarking, and training.