If local and state authorities in the United States “require water management plans in all public buildings including hotels, businesses, schools, apartments, and government buildings” – as recommended in the 300-page report issued by the National Academies of Sciences, Engineering, and Medicine three weeks ago – they will need a way to audit numerous water management programs (WMPs) affordably, fairly, and effectively.
Federal regulations would be much simpler for owners of properties in multiple cities or states, and thus more preventive because of higher compliance. However, they would be no simpler for the agency having to enforce the rules. Any government entity, as well as insurance companies, will find it challenging to effectively audit large numbers of WMPs for quality, performance, and risk with limited personnel, time, money, and knowledge.
Five Secrets to Auditing Large Numbers of ASHRAE 188 WMPs Successfully
Requiring WMPs without auditing performance will result in low compliance and thus failure to prevent disease. Trying to enforce and audit every detail is overly burdensome to both the regulator and regulated, which is expensive, wasteful, and probably unsustainable. For successful outcomes, consider the following for auditing WMPs:
1. Focus on control measures
Only control measures—procedures to control pathogens in water systems and prevent transmission from the systems to people—will reduce the risk of disease. The job of the other ASHRAE 188-required elements (e.g., list of team members; water system information; flow diagrams) is ultimately to ensure effective control measures are implemented.
A WMP audit should thus focus on control measures, ideally to determine whether they are (a) comprehensive, covering all water systems that can harbor and transmit pathogens, (b) effective in minimizing Legionella and other biofilm-associated pathogens that thrive in building water systems, and (c) implemented. Merely writing control measures does not reduce risk—they must be carried out.
2. Be satisfied with 95% of the story
With the right questions, system, and metrics, an auditor can get approximately 95% of the WMP story with 5% of the budget and time it would take to get all 100%.
Letting go of the time-consuming details (last 5%) will allow resources to go much further, ultimately resulting in more prevention. It also frees time to focus on the more important performance metrics that comprise the 95%.
Letting go of the last 5% is not easy, though. Professionals like to be thorough, and government agencies don’t like non-compliance. But it’s necessary for successful outcomes.
3. Audit most WMPs remotely
With smart reporting requirements, routine audits can be performed remotely, at the auditor’s desk. Site visits will be necessary only when the routine audit flags inadequacies to investigate.
Performing routine audits remotely not only saves time and money but requires less knowledge and training for the auditors (see #4). Onsite inspections, when required, could be handled by the more experienced and trained inspectors.
4. Minimize subjectivity and training
No reasonable amount of training will give inspectors the knowledge required to judge the efficacy of WMP control measures or evaluate Legionella risk factors associated with the design, components, materials, maintenance, condition, and operation of various types and configurations of building water systems. Doing that well takes many years of experience.
Therefore, another secret to auditing success is to minimize judgment calls. Doing so reduces the training required for auditors. Audits based on clear, objective criteria will be fairer, too, and reduce corruption.
5. Go paperless
Hire computer-savvy auditors and don’t require them to find, carry, send, or file a single piece of paper.
Eleven Metrics that Make the Five Secrets Possible
The only way to get 95% of the WMP story with 5% of the effort, audit most WMPs remotely, and minimize subjectivity and training, is to use smart metrics to evaluate a facility’s WMP. Consider these 11:
1. Control measures for all applicable water systems
To be preventive, a WMP must include control measures for all building water systems (e.g., domestic water systems, cooling towers, decorative fountains, whirlpool spas) that are prone to harboring and transmitting Legionella or other pathogens.
Simply require the building operator to check “Yes” or “No” for each water system type—Yes to indicate there is one or more of that system type on the property. The auditor can then see if the WMP has control measures for each “Yes” system.
2. Number of operation and maintenance control measures per system type
Obviously, if the control measures are not effective, it doesn’t matter how many there are, but the number of measures per system at least indicates whether the WMP is comprehensive and specific.
Too few control measures for a given system type means the WMP has vague objectives rather than real control measures. For example, “minimize stagnation” or “keep temperatures outside of the Legionella growth range” are not control measures—they are objectives. A control measure must be specific and measurable.
A good way to determine whether a control measure is clear and specific is to ask a maintenance technician to do it. If he or she cannot determine what to do and where the measure is probably vague.
Most facilities need about 40 control measures for operating and maintaining domestic hot and cold water systems. A small number (e.g., 5) indicates the WMP is vague, inadequate, or both.
3. Number of control measures for design and construction
Most control measures taken in the planning and construction of new buildings add zero cost to the project but can significantly reduce the health risk. Planning well can potentially save the facility hundreds of thousands of dollars in remediation and retrofitting, too.
As with operation and maintenance procedures (metric #2), the number of design and construction control measures can indicate whether the WMP is comprehensive and specific. “Consider Legionella prevention in the design and construction of new or renovated buildings” is an objective, not a control measure. A facility may need 30 to 40 specific procedures to accomplish that objective.
The auditor does not need to be trained in the design and construction of water systems. He or she can just count the number of WMP control measures for it.
The “Control Measures Verification Status Report” in the image below shows enough control measures for system maintenance but only one control measure for Design and Construction, which is inadequate.
4. Monitoring, limits, and corrective action for each control measure
Per ASHRAE Standard 188 and the CDC toolkit, a WMP should list performance criteria (control limits) for each control measure, a monitoring procedure for determining control measure performance, and corrective actions to take if the control measure is not performed within the control limit.
Determining the monitoring procedure, limits, and corrective action for each control measure is hard. It takes expertise, time, thought, and sometimes discussion among WMP team members. The auditor does not need to evaluate the monitoring procedures, limits, and corrective actions. He or she just needs to make sure they are listed for each control measure. A simple “Yes” or “No” will do.
5. Control measure implementation
Per ASHRAE Standard 188, WMPs must have procedures to verify the implementation of control measures.
To audit large numbers of WMPs efficiently, require facilities to document and report verification of control measures in a specified structure, electronically. In just a few seconds, an auditor could then determine the percentage of control measures for which verification is on schedule (“okay”) or overdue (see image below).
Also, the facility should upload its documentation for the performance of each control measure implemented in the past 12 months.
6. Plan for shutdowns and incidents
Detailed plans for system shutdowns and responding to incidents (e.g., water main breaks) are crucial for preventing outbreaks. Readiness to act quickly is important.
The auditor can simply note whether the facility’s plan is clear and specific enough—who, what, and when—to be initiated immediately.
7. Plan for responding to a suspected or confirmed case of disease
The auditor just needs to answer two yes-no questions:
Does the facility have a written plan?
Does the plan include instructions detailed enough that it could be initiated tomorrow?
8. Validation procedures
ASHRAE 188 WMPs must be validated for effectiveness in controlling Legionella.
If regulations require testing water systems for Legionella, as the NAS report recommended for healthcare facilities, have the facility report the following:
- Water systems sampled
- Frequency of sampling
- Number of samples tested per water system per sampling round in the last 12 months
- Criteria for interpreting test results
- Plan for responding to test results
- Laboratory reports of the test results
- Actions are taken in response to test results for each sampling round
If Legionella testing is not required and is not voluntarily conducted by the facility, have the facility report the above for whatever it is sampling or measuring, if anything, to validate the WMP.
9. Plan for communication and notification
Does the WMP include a written plan for communication and notification?
Does it list what should prompt communication, what should be communicated (e.g., test results), by whom, and to whom?
10. Number of disinfectant and temperature measurements
Instead of asking auditors to determine the adequacy of domestic water temperatures or disinfectant levels, the facility can provide the readings taken in the last 12 months.
The number and frequency of disinfectant and temperature readings indicate the facility’s attention to monitoring its domestic water systems.
11. Training of personnel
Expecting busy facility personnel to learn to write a WMP that has comprehensive and effective control measures is unrealistic. It has been attempted, with consistent failure. But providing a facility with a comprehensive WMP and then training personnel on the how and why of each control measure has proven successful. Facilities personnel are much more engaged when they understand why a control measure is important for protecting health, instead of just being told what do to and how to do it.
(If you have access to LAMPS Training content, watch video V28, Lessons to Learn from UCSF Medical Center on Executing a Water Management Program. You’ll be amazed by Bruce Mace’s story about plumbers coming up with a shutdown plan after he explained the importance of reducing health risk.)
Have the facility report water management-related courses completed by employees involved in the WMP, preferably with copies of certificates.
Among lessons learned since the June 2015 release of ASHRAE Standard 188 is that few facilities will implement a WMP unless required. However, to reduce disease associated with building water systems, regulations must be enforced, not just established. A smart approach to auditing WMPs will allow regulations to be enforced affordably and sustainably, bringing real prevention.
What do you think is important for auditing WMPs effectively, fairly, and affordably? Please comment below.
I think you have laid out all good arguments. I like the way you narrowed in and showed how to use the least amount of time and use it effectively. Keeping it online is important and makes it afforable by the one auditing. One other quick way for an auditor to see if they are keeping up is if the WMP has an Analytics component to the plan. If they can be shown the Analytics, then you would know they have the logs to back it.
Yes, if a government entity or insurance company could look at reports of analytics for test results, that would be very helpful. Thanks for commenting, David.
I believe that the “secrets” and metrics are all straightforward. These are very common audit tools for many industries and systems, from ISO 9000 audits in manufacturing to State and Federal environmental audits for pollution control compliance.
The real challenge, I believe is to provide an incentive for facilities that are not currently required to have a WMP. Governments, except in limited circumstances are unlikely to provide that incentive unless there is an outbreak of Legionnaires illness as happened in New York a few years ago. Insurance companies are the most likely choice to provide the incentives in the form of premium reductions and enhanced legal protections for clients that have a working WMP.
So, I believe that this is where organizations like AWT, ASHRAE, NSF & others should focus their energies. Lobbying the insurance industry to sell WMPs to their clients as a protection for the insurance company and for their clients is likely to be more effective and produce more results than lobbying politicians.
I think that makes a lot of sense, Richard. Insurance companies have had to pay Legiinella claims but for the most part have done little to incentivize water management plans among their insureds. I hadn’t thought about awt or ashrae approaching insurance companies but that might make sense too. Thank you for commenting.
Looks like a common sense approach to applying the KISS principle to this complex set of regulations.
Having worked in the healthcare realm (which tends to be heavily regulated), I think that your outline for providing successful oversight to an organization’s WMP is spot on (if you don’t mind, I’ll definitely be sharing the link to this info on my blog – as always, many thanks for being such a wealth of information). Ultimately the goal of oversight is to be as effective as possible without being overly burdensome from a compliance standpoint. The architecture you have laid out does just that – it is concise, easy to follow and clearly works towards reducing the risks throughout our communities. The prior comments regarding incentives for industries not currently required to have WMPs is so genius that the degree to which it has not yet happened is surprising. But I guess incremental improvement is still improvement and this is definitely a step towards safer water systems.
Well put, Steve! Yes, please feel free to share the article link. Thanks for commenting.
Much of WMPs has to do with anxiety management for all stakeholders. It is important to boil it down to the fairly simple and reasonable procedures entailed. This is a very helpful article to that end. In the world of WMP it turns out that fear is what we are truly fighting.
Thanks so much. This helps to allay those fears.
So true! Fear, unfortunately, is what often drives action. Thanks for commenting, Pat
Kudos to you and HC Info for yet another timely & pertinent blog on WMP’s, and more specifically: Auditing WMP’s. You are spot on when you stated: “Requiring WMPs without auditing performance will result in low compliance and thus failure to prevent disease.” Not only does NASEM agree with your keen assessment, so does NSF P453, NYC DOHMH, and NYS DOH; each having their own onsite and remote inspection/auditing/reporting requirements respectively.
To audit an HC Info LAMPS WMP is a relatively straightforward task which can easily be undertaken onsite or remotely. There is even a tutorial entitled: ‘Auditing a LAMPS WMP’ which details the steps which can be taken by/for the following:
– Program Team as an internal self-audit
– A second or third party as an independent external audit
With the QVR (Quick Verification Report) and VSR (Verification Status Report) features in LAMPS, this is an absolute ‘breeze’ to accomplish. However, not all WMP’s we’ve encountered are on LAMPS, and therefore, the 11 metrics you’ve outlined which make the 5 success secrets possible, are an absolute must.
The three primary tools we use to audit non-LAMPS WMP’s are:
– (Again), Your HC Info tutorial entitled: “Auditing a LAMPS WMP”, as it provides a comprehensive listing of what to look for in anybody’s WMP/WSP
– A Checklist from CDC (available from: http://www.cdc.gov/hai/prevent/water-management.html) entitled: “Healthcare Facility Water Management Program Checklist”
– The 7 elements of a water management program illustrated in Figure 1, (page 6) of ANSI/ASHRAE Standard 188-2018
Your #1 recommendation to Focus on Control Measures is truly the key Matt. Most times when auditing a non-LAMPS WMP, not only are the control measures typically lacking in substantive content, when present, they usually are either: a) Too vague, and therefore devoid of being tied to an appropriate onsite Hazard Analysis or Risk Assessment, or b) Lack reference-to, or citation-of, an appropriate evidence-based, scientific, regulatory, or industry accepted best practice.
The importance of auditing WMP’s reminds me of a Commanding Officer once who told me: “You get what you INSPECT, not what you expect”, and I have never forgotten that valuable leadership (auditing) lesson. Well done Matt!
Thanks for commenting so thoroughly. Yes, LAMPS WMPs are easy to audit and we have outlined the specific steps for an auditing procedure. Other WMPs can be audited with the metrics outlined in this article and the resources you shared. Keep up your good work, Dominick! It’s making a difference.
Great program for highly regulated hospitals/medical centers.
They have the incentive [patients & Joint Commission].
BUT – Only 8% of the Legionnaires’ diseases in California were healthcare related.
Most of the legionellosis outbreaks with a known source are caused by cooling tower aerosol containing legionella bacteria.
The NAS Management of Legionella in Water Systems distributed on August 16, 2019 takes the best approach to the issue that I have seen since I began working with legionella in my Philadelphia medical school lab in 1977-78.
Thanks for sharing the statistic and link on healthcare related Legionnaires’ disease cases in California, Richard. In the June 2016 MMWR paper “Vital Signs: Deficiencies in Environmental Control Identified in Outbreaks of Legionnaires’ Disease — North America, 2000–2014,” CDC reported “Potable water was the most frequent source of exposure; however, outbreaks related to cooling tower outbreaks were associated with larger numbers of cases.” The report mentioned whirlpool spas as an important source as well. The takeaway is that it makes sense to take reasonable preventive measures in all building water systems that are prone to harboring and transmitting Legionella. Thanks for commenting.
Agree on addressing the 95% that we can control and leaving the other 5%. If the net result is a significant reduction in illness and disease, then the goal has been met, despite the imperfection.
Transparency. The documentation confirms compliance. Properly documented training, control measures, validation results and corrective actions as part of comprehensive plan make for a successful audit. Very insightful article.
Good point about the importance of documentation, Denise. With your background and expertise in compliance, you would certainly know! Thanks for commenting
Great options for performing an audit! One other thing that could be leveraged by the water management team itself is to perform internal audits. Internal audits can be performed on a rotational basis and, through the year, cover each part of the Plan. Then the output from the internal audit could be included in the external audit documentation, which would provide even more direction to the auditor on problem areas to keep in mind. Internal audits are required for other types of organizations, such as accredited testing laboratories, and could be a practical way to assist both the Plan team in identifying opportunities for improvement and to the external auditor to get a ‘lay of the land’. Thanks for sharing this, it’s good advice!
Yes I agree that internal audits are beneficial. LAMPS outlines a step-by-step list for auditing LAMPS WMPs, which could be performed by a facility or an external auditor it hires. Thanks for commenting, Patsy!
I totally agree with you, Matt. Control measures should always be clear and specific. Thank you for this on point and very insightful article.
Having been a facilities compliance manager for the largest gaming resort corporation in the world, I developed great passion and concern for reducing the risk of Legionnaires’ disease and a great understanding for the value add of ASHRAE 188.
With the release of the Centers for Medicare & Medicaid Services QSO-17-30- Hospitals/CAHs/NH Memorandum still many of those facilities continue to neglect their required responsibilities. I have found that accreditation surveyors and government agencies are not holding facilities accountable for adhering to the standard. Many facilities only claim to be in compliance and still others have plans that sit on a shelf in the facilities office never implemented or exercised. Some claim they have no budget to implement, others claim their state surveyor is not worried about it and still others are of the opinion that what they don’t know can’t hurt them; until they have an outbreak and someone dies.
All parties that have a stake should be involved to educate the public, facilities, personnel, government law makers, government regulators and especially facility operators and corporate owners of the value-add of being out ahead of an outbreak and death form the illness. No one seems to have preventative money in the budget, yet once an outbreak occurs they will need to have remediation, repair, renovation and major lawsuit money made available. Then there is lost revenue, the marketing and brand rebuilding costs to bring back customer trust and the stigma that will remain as to how that facility didn’t care enough to the right thing from the start and let people die!
National laws must be legislated to get all facilities to comply with water management safety. If the required facilities are currently willfully neglecting the standard, how do we get the 92% of facilities that have no legal obligation to comply? There are even still many more facilities that are just not aware of the standard. I have talked to manufacturing plants that use spray baths, hotels with pools, spas, water features and vacant rooms, high-rise buildings with cooling towers, closed loop heating and cooling systems and schools and college dorms many vacant all summer with no plan in place to reopen and restart each fall!
Auditing ASHRAE 188 Water Management Programs (WMPs): 5 Secrets and 11 Metrics for Success is great for facilities already with an active plan in place or a facility that has had to deal with an outbreak and remediation, but we must find a way to reach and get through to those who remain ignorant to the consequences of not being compliant and transparent, documenting their actions in their plans DAILY on paper or electronically! How do we reach them without legislation requirements and fines for noncompliance?
Thanks for taking the time to share so much insight from your facilities management experience, Paul. It’s so true that many WMPs sit on a shelf. I’m thankful that our WMP Partners (companies that provide LAMPS WMP setup services) are helping facilities digest and get started with their WMP control measures instead of just delivering the WMP and walking away. A good WMP is doable with a reasonable amount of time and money.
Great article Matt. Working with insurance carriers on a daily basis, it is vitally important they understand that they can require these programs as foundation for underwriting this risk and then can audit their insureds remotely and inexpensively to ensure they are complying with their programs. All too often insurance carriers will require water management programs at the outset, but forget the critical compliance piece going forward. Hopefully some of the insurance carriers will read this piece so that they understand the importance and simplicity of audits.
In comments received so far on this article, at least one other person has mentioned the role insurance companies could play in incentivizing facilities to implement WMPs. Seems it would make sense in that both the insurance company and the insured would benefit, as well as the people who would avoid disease. As far as I know, no consultant to the insurance industry has more Legionella risk management knowlege than you, Russ, so your influence is really important. Thanks for your input!
Very concise and comprehensive! Regarding documentation as it relates to testing, should include basic sampling methods and procedures. As this field continues to change, auditing may produce a valuable study of results that can help the entire industry. How many times you test water is only as important as where, when and how you take the sample.
On a different note, I do agree that all facilities will struggle to implement an effective ASHRAE 188 WMP without the help of a knowledgeable third party.
A certification of a reputable and respected third party can help control LD.
I agree that proper specification of sample locations, sample types (e.g., pre- versus post-flush samples), and sampling frequency is crucial. Course 402 in our four-course series on sampling (https://hcinfo.com/training/legionella-sampling-courses/) covers those details. Good point, too, about the value of a third party that truly has expertise and provides good service. Thanks for commenting, Manuel.
Matt, as all the comments have been stated it is a great approach.The HCInfo platform is almost self auditing as you create the WMP. I do see some issues in healthcare with being allowed to audit the platform as they are very close to the vest with sharing any information. How would you certify these potential remote auditors? How are you going to keep them independent? How are you going to insure that a audited WMP will be approved by agencies like Joint Commission, DNV or state health departments? That will be the deal breaker if the audited WMP isn’t an approved by the authorities of jurisdiction. Just something to think about
Very good points and questions, Tom. I was picturing the auditor being an employee of the regulating entity, rather than a third party. But if the WMP requirements and auditing process were clear and simple, as emphasized in this article, certification of third party auditors would be pretty easy since the auditing process would allow little or no subjectivity. One well written and executed US federal regulation would make it so much simpler for everyone, and thus more preventive. Thanks for commenting, and for your good work. You are a real pro!
Matt–you have it very well covered in my eyes–I think you “hit the nail on the head”! What I (we) am finding is that very few (if any) of our clients are truly implementing their WMP’s. As soon as they see the labor/time required to implement all control measures properly, they’re backing away. At best, our clients are tackling the control measures a few at a time.
Some of the above/below comments are very accurate as well. Until companies are mandated to have and IMPLEMENT a WMP, very few will do so in my opinion. This is evidenced by NYC–we have a couple clients in NYC and they are implementing their WMP’s appropriately–because they HAVE to (or get fined if they don’t). I like the insurance company idea myself–as far as offering premium reductions if a WMP is in place and being properly implemented (but then again–do we want to give insurance companies more power)? 🙂
Good points, Roger. I know you’re doing your best in helping your clients get started with their WMPs. Little by little is better than not at all. A well written and executed federal regulation would probably provide the best prevention for the cost to both the government and facilities, but since that may not happen anytime soon, state regulations or insurance incentives may be the best option now.
Matt: as always, your blog is extremely insightful and practical. I echo Jim Rauh’s comment that you have documented “a common sense approach to applying the KISS principle to this complex set of regulations.” Matt’s recommended “KISS” approach to reducing Legionella disease risk on the many public buildings WE ALL frequent also makes the task affordable. Facilities should not wait for government enforced compliance or worse yet, a Legionella disease incident (dare fatal) to implement these recommendations that amount to “budget dust” in the grand scheme of Facilities Management (FM) building operational costs.
I am testing for Legionella bacteria once every 3 months for cooling towers and once per year for domestic water systems. Is that adequate? I figured it is the least costly method for the building owner and allows them to start a Legionella monitoring program for their facilities. What are the testing requirements / number of legionella tests required for cooling towers / domestic water systems?
Also, what are the actionable ranges when legionella bacteria appears in cooling tower samples?
Mike, thanks for making the effort to do what you think is best. If you will email me directly, myself or someone on our team can get more information before answering your questions.
Great article Matt, as usual. My health department will certainly be taking account of your tips. One thing not yet mentioned in the posts above is the educational value to the facility management of having the auditor working through their water management program. While all of our regulated entities have a program in place, we are aware of compliance issues that really don’t get identified until either an outbreak or an audit. Compliance is ultimately a process, not an event, and audits have a really important role in bringing everyone up to an acceptable standard of performance.
That is such a good point, Greg. Although part of an auditor’s job may be to issue citations and fines for non-compliance, it should be viewed as a positive, educational event during which the auditor helps the facility get back on track. Thanks for commenting
Matt this is an excellent paper and can serve as a metric for regulators. Enforcement is needed to match expectations of ASHRAE 188. We observe few customers do WMPs without some enforcement incentives . We have seen a huge increase at Hospital WMPs due to enforcement requirements.
You outline how agencies can accomplish this without a comprehensive training and inspection program. The idea of 95% is excellent and one I totally support. Too much is wasted on the final 5%, often without much change in outcomes. In corporate lingo, “Analysis Paralysis” sums it up.
Your eleven metrics law a very clear method for an enforcement agency to prioritize and ask the right questions. Legionella control is a process and in other countries, like Quebec, requires scheduled maintenance and monitoring. A one time pass or fail will never solve the problems associated with Legionella.
Hopefully, enforcement agencies can assume a partnership with most customers to minimize Legionella risk at all facilities. Like an ISO program, once started the results will only improve. Matt you did a great job on this paper!
Good points, Les. I like how you referred to the relationship between regulators and facilities as a partnership. Thanks for commenting.
When the ASHRAE 188 Standard first came to our attention, my supervisor and I were quite taken aback by the unawareness/ignorance and lack of resources to information and implementation of WMPs by public health officials, laboratories, and state and local jurisdictions. The Standard and LAMPS have been a very valuable resource and force in formulating and implementing WMPs.
For some time prior to going onboard with LAMPS,
we became the disseminators of awareness and education for WMPs to many contacts, although on an elementary level.
The more our involvement with WMPs, the more scrutiny laden I find myself when in other places, etc. When travelling and staying in hotels, I mull around the idea of requesting from management their WMP and compliance logs (presuming that they would ask me: “WHAT?”) 🙂 I’m not so sure about the insurance industry’s argument at this point, but it would springboard attention for WMPs for the vast majority.
Thank You, Matt for your expertise and correspondence!!
Sounds like your county is doing a great job keeping up with best practices for Legionella risk management. Thanks for commenting, Joel.
You raised a complex question Matt: How to audit Water Management Programs in compliance with ASHRAE Standard 188 effectively and at low cost? The question can also be asked: How to implement effective programs minimizing the cost engaged by building owners? I don’t pretend having the answer to these questions neither. I am a consultant in Quebec Canada where the government adopted a regulation addressed to all Cooling Tower owners. This regulation orders them to hire a professional to write a maintenance program with procedures like inspecting, cleaning or disinfecting the cooling tower system, addressing issues like system shut-down for a short period of time or the whole winter… It also contains procedure for a monthly Legionella Test. Even, these procedures are much less numerous than for a Risk Management Program, I don’t think that at the beginning owners or operators would have been able to do it by themselves taking into account their own daily agenda.
According to LD Prevention, I emphasized the importance of training the people. To my view, this is the first step or step 0. You write at point 11: “Facilities personel are much more engaged when they understand why a control measure is important for protecting health…” Building Managers and maintenance personal should have attended a seminar. It’s done for Health & Safety Program on construction. This is basic. Only personal with a specialized formation can fully assume their responsabilities.
Lastly I insist in my work on corrective actions such as cooling tower relocation, facilitating the access to the equipment and even modifying the piping system. A Risk Management Program means nothing if it stays on paper. When a Risk factor has been identified, corrective action has to be implemented. Owners must operate safer systems. There cannot be any short cut when Safety is concerned. If design measures are not included in a Risk Management Program, it is like keeping holes in Safety Barriers where Legionella can pass through and infect the people. According to the high level of consequences, such a situation cannot be tolerated consciously.
You’ve made some excellent points, Mario. To reduce risk, a WMP must be fully implemented, including corrective measures. Training is certainly important, but as pointed out in the article, it has been effective for facilities personnel only in implementing WMP control measures, not in writing a WMP. Most facilities, even after being provided with a good WMP, will need the help of a qualified person like you to help them successfully implement it. Thank you for commenting
Matt, Once again you have hit the nail on the head with regards to the important points of auditing. Having been involved now in a few audits, I have found that many plans, although not “unautiable” leave much to be desired with the specificity of the control measures. Unless any plan has a number or identifiable quantitative measurement metric associated with it then it is an idea, not a plan, and if it does not have a named individual responsible for assuring that it gets done (verification) it most likely will not get done.
It all goes back to that S.M.A.R.T. graphic that many of us have seen relating to Goals in that to be effective a Goal must be:
Specific (simple, sensible, significant).
Measurable (meaningful, motivating).
Achievable (agreed, attainable).
Relevant (reasonable, realistic and resourced, results-based).
Time bound (time-based, time limited, time/cost limited, timely, time-sensitive).
If a WMP does not contain these components and the Champions to drive it the Plan will not be successful. To be sure our GOAL is to reduce disease, but the PLAN is how we get there.
Yes that makes sense that the SMART method for goal setting applies to WMPs and control measures. Thanks for commenting, Tom. And thanks for the good work you’re doing in both helping facilities and training service providers (e.g., water treatment companies).
Very good point Matt. Without audit, no quality management system is worth anything. Ashrae 188-2018 is getting closer and closer to IS0 22.000 Hygiene Management System, which is used widely in the food industry. We have been using this certified Hygiene management system since 2001, and it is audited every year by SGS or Bureau Veritas. Ashrae 188 focusses only on Legionella – as this is the main risk, However, you will never find Legionella alone in a water system. The risk for having legionella increases, the more contaminated the system is with other microorganisms. Therefore the control measures should not only reduce the risk for Legionella, but also ensure a general high level of hygiene in the system. Control measures and procedures are needed, but in the end only test results can verify that the WSP is working. In an audit, a test plan with identification on flowdiagram, frequency of test and test results should be asked for. Setting limits for total counts of microorganisms at each testpoint is important and when sufficient test results are available a baseline can be established. When test results deviates from baseline action plan is activated.
If you have the chance to influence the next version of 188, I recommend to shift focus a bit from Legionella alone into general hygiene management.
You have raised some good questions, Leo, ones that will continue to be discussed. The relationship between Legionella, Pseudomonas, Mycobacteria, other pathogens, and total bacteria counts needs further study. Studies to date show interesting findings but little or no evidence of clear correlations, at least not in plumbing systems. Thanks for commenting
Thank you for the wonderful article. As someone who audits Water Management Plans for a living, it can be very tough to keep track of every account and maintain their compliance without proper support. HCinfo simplified that by allowing engineers to be a part of the auditing process. By using the control measures, verification methods, documentation/tabulation, and the cloud service provided by by HCinfo; Legionella management becomes much easier for both the auditor and the engineer. This is especially true for preventing violations when an inspector randomly shows up and throws a set of fines on your desk for documentation that exist but were not filed correctly. By conducting regular audits remotely and getting the engineers involved, an inspector showing up unannounced would be a non-event.
In NYC, engineers and building owners can only do so much when it comes to managing Legionella. Most buildings are only concentrated on cooling towers because that is what is enforced. If New York State or New York City came out with a law tomorrow requiring that all buildings are required to produce a WMP for domestic water as well, we would first see buildings have hoards of violations to resolve and then start taking action by utilizing HCinfo to revise their WMP.
If the Federal government mandated a requirement for all cooling towers across the nation to produce a WMP based off of ASHRAE 188, we would see a lot less outbreaks occur across the nation (look at Chesterfield school district in New Jersey and the Sheraton Hotel in Atlanta for example).
In short, training engineers/building owners to conduct regular audits and verification checks are important for the management of Legionella and aids in remotely providing the consult needed, making this strategy the least costly and most effective method to date.
If a federal agency mandates WMPs, let’s hope it’s a regulation for comprehensive WMPs that cover all water systems rather than just cooling towers, so it can bring real prevention. I appreciate your comments, Matt! Thank you