Legionella Water Safety and Management Plans

Can you afford not to be LegionellaREADY?

Water Management Plan and Water Safety Plans are the best tool for building owners and operators to use against Legionella bacteria and Legionnaires’ Disease. Infection control personnel and Environmental Health and Safety (EHS) professionals must understand how to incorporate water safety into their facility’s risk management processes.

The American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) developed a standard, 188-2021 – Legionellosis: Risk Management for Building Water Systems. This voluntary standard outlines the requirements for developing WMP’s, how risk assessments are performed, along with healthcare-specific requirements.

Water Management Plans

In layman’s terms, a Water Management Plan is a comprehensive living document describing proactive maintenance activities, the unique risks associated with each building, and the corrective actions required if parameters are found out of specification. This plan can be as comprehensive or as simple as necessary, providing it has all the elements of ASHRAE 188-2021 incorporated into it. This plan also serves as the location to keep all water safety-specific documentation and maintenance activities performed, to serve as a legal document proving compliance. Litigation for Legionnaire’s disease can be a huge risk if the defendant can prove the negligence of the building owner, property manager, or other parties involved in water safety. A valid Water Management Plan could be your best defense.

Water Safety and Management Plans have many elements required by ASHRAE 188-2021. Those elements include:

  • Water Safety and Management Program Team – This is the team responsible for your building’s water safety
  • Water Systems/Flow Diagrams – These are diagrams of potable and non-potable water systems that will be monitored as part of water safety
  • Analysis of Building Water Systems – This constitutes a formal risk assessment for each water system
  • Control Measures – The limits (temperature, pH, etc.) that control must be maintained for each system
  • Monitoring/Corrective Actions – This section outlines all maintenance activities (PM) required to verify control limits are maintained, and the specific corrective actions required by the maintenance team if control limits are not in range
  • Verification – A on-going process through the Program Team that the plan is being executed as designed (documentation audit process)
  • Validation – A process that validates the maintenance activities have been effective. This typically constitutes regular testing for Legionella bacteria or other waterborne pathogens
  • Documentation – The process that establishes how and where the documentation will be available for auditors and how to communicate to the Program Team

Water Safety and Management Program Team

Water Safety and Management Program Team

ASHRAE 188-2021 states,

“The Program Team shall include one or more individuals selected from the following: the building owner or designee, employees, suppliers, consultants, or other individuals that the building owner has delegated to have authority and responsibility for the actions required…”

There are many roles to choose from to have on your Program Team. ChemREADY recommends at a minimum you have the following personnel:

  • Building owner or administrator
  • Infection prevention (healthcare)
  • Facility management or Property Management Company Account Manager
  • Engineering and/or Maintenance Heads
  • Water Treatment Account Manager

Other professionals you could choose to add to your Program Team include:

  • Risk and Quality Management
  • Environmental Health and Safety (EHS)
  • Epidemiologist (Healthcare)
  • Legionella and water management consultant

ASHRAE 188 Building Characteristics

ASHRAE 188-2021 defines the following building characteristics as applicable to needing a Water Management Plan:

  • Building includes multiple housing units with centralized potable water-heater systems 
  • Building is more than 10 stories high 
  • Building is a healthcare facility where the patient stays exceed 24 hours 
  • Building contains areas for housing or treating patients receiving treatment for burns, chemotherapy, or organ transplants 
  • Building contains areas for housing or treating patients that are immunocompromised, at-risk, are taking drugs that weaken their immune system have diabetes or chronic lung disease 
  • Building exists for the purpose of housing occupants over 65 years old 

Systems include: 

  • Potable Water Systems 
  • Cooling Towers and Evaporative Condensers 
  • Whirlpool Spas 
  • Ornamental Fountains 
  • Aerosol Generating Misters, Atomizers, Air Washers, and Humidifiers

If your facility falls under the following, you should look into creating a Water Management Plan, if you don’t already have one: 

  • Nursing Homes, Assisted Living, and Rehabilitation Centers 
  • Small Hospitals 
  • Commercial buildings 
  • Government Facilities (jails, hospitals, public buildings) 
  • Hotels, Casinos, Resorts 

Creation and Execution of Water Safety and Management Plans

Your building’s Water Safety and Management Plan should be defensible, easy, and smart. That’s why ChemREADY partners with HC Info, in providing LAMPS; Legionella Assessment and Management Plan Support. LAMPS has built-in audit functionality, the ability to easily update and modify your existing plan, and a cloud-based solution for all of your documentation.

If your Water Safety and Management Plan isn’t on the LAMPS platform, contact ChemREADY to discuss the benefits it will give your Program Team, today.

Legionella Assessment and Management Plan Support
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