Matt Freije discusses a water management plan performance study at the 2022 Emerging Water Technologies Symposium.
Data from a 2021 study showed that ASHRAE Standard 188 water management programs (WMPs) can effectively reduce Legionella in domestic (potable) plumbing systems, but a shockingly low percentage of facilities are performing WMPs well.
The study started with the assumption that reducing Legionella and other pathogens in building water systems requires procedures that effectively control growth and transmission factors such as temperature, chemistry, water age, and biofilm (“control measures”). And, for a water management program to be successful, control measures must be comprehensive, covering all appropriate measures for all water system and device types that present a risk, and the control measures must be implemented.
Out of the total number of facilities that should have a Legionella water management program per the risk factors outlined in ASHRAE 188, the percentage that have developed a comprehensive WMP is unknown and is difficult to determine based on a simple survey in part because, if asked, some facilities would report having a comprehensive WMP—probably in good conscience—when in fact they have policies rather than control measures, or control measures that are ineffective, inadequate, or non-specific.
According to research funded by the Water Research Foundation (ASDWA 2021), the percentage of facilities with comprehensive WMPs is likely very low. Only 50% of education and hospitality facility managers surveyed had heard of ASHRAE 188. Awareness was even lower among multi-family facility managers—less than 30% knew that domestic (potable) water systems have conditions favorable to Legionella growth or had even heard of water management plans.
Since the percentage of facilities that have comprehensive Legionella water management plans is unknown, we attempted to answer a different question, one for which we have data to study: Of the facilities that have comprehensive water management plans, what percentage are fully implementing them?
To determine the degree of WMP implementation, we reviewed the following metrics for more than 900 WMPs that had been active in HC Info’s cloud-based water management program software (“LAMPS”) for at least 12 months as of June 16, 2021:
- Control Measure (CM) compliance (i.e., the percentage of CMs with “Okay” verification status)
- Number of Legionella and other microbial tests
- Number of domestic water temperature and disinfectant tests
The above metrics were compared with domestic water Legionella positivity (percentage of samples in which Legionella was found).
A detailed analysis of the findings was published in the Spring 2022 issue of the Analyst.
Of interest was that only 19% of the 908 LAMPS water management plans that qualified for the study had control measure compliance > 80%. Fewer than 10% of the properties collected more than 20 samples for Legionella testing a year from domestic water systems.
Two findings, outlined in the table below, were especially significant:
- Facilities with higher control measure (CM) compliance generally performed more tests for Legionella, other microbes, temperatures, and disinfectants than did facilities with lower CM compliance. In short, facilities that kept up with their control measures also performed more tests.
- Facilities that implemented control measures (CMs) and performed tests were likely to have lower Legionella positivity. Legionella positivity was not considered for the 0% CM compliance group because that group’s number of Legionella tests was too low to make a reliable comparison. For all other groups, the average domestic water Legionella positivity decreased with increasing CM compliance and, generally, with increasing numbers of temperature and disinfectant tests.
Table. Comparison of Control Measure (CM) Compliance with Number of Tests and Domestic Water Legionella Positivity in LAMPS WMPs Active > 12 Months
| Control Measure Compliance % OK* | Legionella Tests** | Other Microbial Tests** | Temperature Tests** | Disinfectant Tests** | Legionella % Positive in DW *** |
| 0 | 0.81 | 0.14 | 1.44 | 2.98 | NA |
| 0.5-49% | 5.62 | 2.21 | 8.18 | 12.05 | 24.03% |
| 50-79% | 7.21 | 1.54 | 33.99 | 7.95 | 21.40% |
| 80-94% | 17.36 | 7.82 | 26.77 | 32.50 | 16.88% |
| 95-100% | 33.16 | 23.67 | 51.53 | 33.84 | 14.98% |
* As of the end of the study period, rather than the average over the life of the WMP
** Average number of tests in recent 12 months
*** For the life of the WMP, excluding sites with fewer than 6 domestic water test results total
Insights for Water Management Programs and Legionella Prevention
The data indicates that the premise of ASHRAE Standard 188 is sound— implementing comprehensive control measures can reduce domestic water Legionella positivity.
The reality, however, is that a very low percentage of facilities are fully implementing comprehensive water management plans, which is likely why reported cases of legionellosis have not decreased since ASHRAE Standard 188 was released.
State regulations and insurance requirements would increase the number of facilities with Legionella water management programs but are not likely a sole solution for reducing cases of building-related waterborne illness because enforcing full implementation of comprehensive control measures is not feasible.
In addition to requiring Legionella water management plans, making them easier could really move the needle in prevention. Busy facilities personnel—like all of us—are more likely to do what does not take much time, effort, money, or expertise.
Automation can make water management plans easier and more effective. Automated monitoring, alerts, reporting, and documentation—and to some extent even remediation—will require less time by facility personnel and less help from outside consultants and contractors. As technologies improve, an increasing number of the key water management program elements—control measures, monitoring, and remediation—will ideally become fully automated and continuous.
Some of what’s needed is already in motion: data analytics and sharing to find relationships between pathogens and water quality parameters, water-related artificial intelligence technologies and improved sensors to automate continuous monitoring of parameters, and implementation of IoT in smart domestic water system equipment to make automatic adjustments based on parameter readings.
Technologies and software analytics are advancing so rapidly that getting to automated water management programs and the prevention of disease from building water systems may not take long. Regulations combined with automation dramatically reduced harm from fire and carbon monoxide in buildings, and it can happen with water, too.
What do you think will make water management plans easier and yet more effective in reducing the risk of Legionella and other pathogens? Please comment below.
I understand that I’m a small part of the general, Legionella discussion, as I’m involved with backflow prevention for potable water systems. However, as part of a WMP, I’m offering to Review an existing backflow-prevention program on a remote basis… with submitted documentation such as test reports for testable backflow prevention assemblies. The ‘remote’ idea saves time/money because documentation can be submitted electronically. Of course the ‘remote review’ is not the same as an on-site assessment, but, I think it would be of value and that I could advise the client in a beneficial manner.
Thanks Mike! Reviewing backflow prevention is certainly an important part of managing domestic water systems, so thank you for your work. I agree about the importance of being able to review remotely. We added an audit feature to LAMPS for that reason, so that water management programs could be auditing remotely, well.
Good analysis of current situation – not enough facility managers even know about the potential for Legionella in building water systems, let alone the required steps for managing the risk of Legionellosis per ASHRAE 188. Until the word is WIDELY spread, and the potential for disease and death AND LIABILITY become common knowledge, facility managers will always do the many other tasks that they need to do to keep their buildings operating. Sorry to say it, but we need to convince the attorneys to sue.
Thank you for your input. If pending state regulations become law, insurance companies require water management plans for liability coverage, and WMPs become easier yet still effective, maybe facilities will implement comprehensive WMPs well, essentially ending the need for lawsuits. If no one gets sick, no one sues (usually).
What is our availability to share this on social media? Do you have a LinkedIn post for this?
Thanks for the reminder, George. I just posted it on my linkedin account. If
https://www.linkedin.com/feed/update/urn:li:activity:6976323561158311936/ doesn’t work, go to https://www.linkedin.com/in/mattfreije/. I think it’s also on our company twitter and facebook pages.
This study does not surprise me at all as it mirrors what we are seeing in the field. In addition to poor WMPs, very few people are actually implementing the programs after the initial start up unless there is an issue. Legally, this puts them in a worse position then had they had no program in place at all as their failure to comply with their own programs is clearly negligence. This is very similar to many other types of environmental risk management programs (i.e. asbestos, lead, mold, etc.) which are developed either in response to an occurrence or an insurance requirement, and then are never looked at again until and unless there is an issue.
Thank you Russ! As usual, your expert input is really valuable.
At the heart of this problem, is a global lack of knowledge and an administrative lack of interest. Awareness and training are key.
Thanks for commenting, Peter. Yes, even after decades of government agency and industry association warnings and guidelines, awareness is surprisingly low.
I believe that any WMP must include environmental sampling as a requirement. Without sampling the plan cannot be validated. One sample per floor at minimum of every 6 months should be a part of ASHRAE 188.
This standard should also include POE filtration for dirt/sediment and microbial filtration to protect the building from upsets in the distribution system. Without POE filtration one is simply putting treating a symptom and not the cause.
Some of the US state pending regulations include validation testing (https://hcinfo.com/blog/state-regulations-reducing-legionella/). Thanks for commenting.
It is surprising to me how many engineers in NYC I come across with WMPs that barely tend to the control measures listed. Only after in-person training, remote/digital logs, and a smart controller is installed more control measures are verified effectively as well as a dramatic reducing in legionella positivity rate. Engineers of large residential/commercial buildings want automation!
Thanks for your input, Matt. Automation is available and a lot more is coming!
Matt,
I’m in NYC where people are just starting to return to offices after a long period of working from home. Many of my customers had to deal with stagnant water conditions in their domestic water systems during this period. Many tenants would test and find legionella present. Seemed like if you keep testing, you’re going to find it.
We would tell them that it was caused by their absence from the building and the best way to eliminate the problem was to return to the office and start using the water. What is your opinion on the return to the workplace?
Reoccupying buildings to nearly full capacity will definitely help in controlling Legionella but it’s crucial to do the proper reopening procedures before the building is occupied. LAMPS has a step by step roadmap for reopening closed buildings, but knowing what to do doesn’t make it easy. Many building operators don’t have enough personnel to do what’s required, and they don’t have control over the pace at which their tenants return to their offices. Thanks for bringing up this important issue, Mitchell.
We use LAMPS program, but it would really help if we had some oversight if we are doing it right or wrong.
Thanks for the feedback, Jimmy. The best way to know how you’re doing with your LAMPS water management plan (WMP) is to perform a self audit (or have a third party perform the audit). In the WMP documentation section, click “Start WMP Audit” under “WMP Auditing and Regulatory Reporting.” Our software engineers are also building two reports that could help you. One will be called the WMP Compliance Report. It is mainly for presenting a compliance report to the Joint Commission or an AHJ. The other is a “score” report. It essentially grades your WMP on 10 to 15 key metrics, and shows you how to improve areas with low scores. The WMP Compliance Report should be ready to use within two weeks, and the Score report within about two months.