Some of the hardest things to prevent are the ones that we cannot see. The recent COVID-19 pandemic has forced health facilities to fight a virus that is not visible. There is a good chance that Legionella, an invisible bacterium, may exist within facility water systems and, if not monitored and controlled, may be transmitted to susceptible persons within the facility and possibly result in death.

It is important that a facility have an active water management plan (WMP) that provides policies and procedures that inhibit microbial growth in building water systems, and reduces the risk of growth and spread of Legionella referenced in CMS QSO-17-30 “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems.” 

The WMP should include several team members throughout the hospital including, but not limited to, facilities, infection prevention and nursing departments — especially those that may care for patients who are the most susceptible to this disease. The plan should provide standard building water system procedures and be ready to respond to issues.

Legionella is the most prevalent in the temperature range of 77-122 degrees Fahrenheit. The WMP should include a risk assessment of the water system. This can be accomplished by mapping the system from three points: the point of water entrance into the health care facility where the water temperature is normally cooler than the growth range; in heating and storage operations where the water temperature may be within the growth range; and at the point of use where chlorination levels should be at a minimum of 0.5 ppm. 

The control limits established may require mitigation measures if breached. These may include simple disinfection by raising the water temperature above 160 degrees Fahrenheit (with precautions for end-user safety), cooling the water or adding disinfectant such as chlorine to the water distribution system. Higher colony counts and more aggressive stereotypes of Legionella may require the purchase and installation of disinfection equipment.

Need guidance? Follow the link in the box above to access the “Water Management in Health Care Facilities: Complying with ASHRAE Standard 188” monograph by the American Society for Health Care Engineering. 

This monograph will provide WMP assistance in meeting the standards and requirements of organizations such as the Centers for Medicare & Medicaid Services, The Joint Commission, and ASHRAE Standard 188, Legionellosis: Risk Management for Building Water Systems.