Industry Guidance for Building Water Management

1. Guidance documents represent current thinking and best practices on a specific topic, in this instance water management for building water systems. Guidance documents do not create or confer any rights for or on any person and do not operate to bind the public to use them.
2. Guidance documents do not establish enforceable responsibilities. The document itself does not legally bind the building owner or public to its implementation. However, your organization may become obligated when either a financial authority (insurer or risk officer) or a legal authority having jurisdiction (AHJ) adopts an industry guidance document by reference to their requirements or law. This can be done for the whole document or a portion of a document by a third-party, local, state, or federal AHJ.

1. Depending upon your organization’s building type(s), operational requirements, financial/insurance/reimbursement obligations, or building occupancy for performing services that engage the public, WMP industry guidance documents may be a requirement for your organization’s compliance with an AHJ over your facility operations, construction procedures, or commissioning of your building water distribution system.
2. Many organizations voluntarily “opt-in” for using industry guidance documents to achieve best practices to reduce the likelihood of injury, illness, or death from exposure to waterborne pathogens (e.g. Legionella or other opportunistic pathogens) commonly associated with building water systems.
3. Additionally, as with any industry, there are usually a series of documents (not just one) that interrelate to assure alignment with multiple authorities having jurisdiction. Deciphering which document applies to which situation in the building water industry sector can be initially challenging for those new to the water safety sector and building water management industry.

1. These industry guidance documents are intended for use by building owners and those involved in associated industries such as design, construction, installation, commissioning, management, operations and maintenance, and service of building water systems. The building owner may have many different professionals within their organization who need to also be familiar with these industry guidance documents such as facility managers, risk and safety officers/managers, infection prevention and control specialists, facility engineers, administrators, financial/controller officers, human resource managers, and legal counsel.

1. Yes. There are various building occupants and building characteristics that are described in industry guidance documents that suggest alignment would be appropriate for any building type. However, single-family residential building owners are often excluded in these definitions and would be related to municipal or city water authority jurisdictions to provide safe water for residential communities.
2. Typically, healthcare occupancies have the most number of building occupants with a higher risk for exposure to a waterborne pathogen since they are there because of an underlying disease complication. However, any building type (education K-12, higher education/academic campus, hospitality, commercial office, retail, manufacturing, or government) may want to consider and benefit from reducing risk to building occupants and increasing defensibility with the implementation of a WMP

1. Healthcare organizations on-going operations - if your organization receives federal, state, or third-party reimbursement for patient care services in acute care, critical access, or skilled nursing facilities, then your organization is most likely required to implement a water management program to assure the facility is a safe environment for patient care operations. Refer to CMS Memo 17-30.
2. Non-healthcare organizations - if your organization resides or conducts business in a federal, state, or local jurisdiction that has adopted WMP industry guidance documents by reference into law (in whole or in part), then these industry guidance documents would be required. Additionally, some insurance, financial investors, or landlords for tenants within buildings may require one or more of these documents to be implemented in order to operate your facility and engage in offering business services to the public. Alignment with industry guidance documents is believed to increase safety, reduce risk, increase defensibility, and reduce financial liability if a disease case or death was associated with your building’s water distribution systems.

1. Healthcare construction projects - if your organization operates in a federal or state jurisdiction that requires the use of the Facility Guideline Institute (FGI) Guidelines for the Design and Construction of Hospitals, your organization is most likely required to develop an infection control risk assessment (ICRA) to reduce the risk of illness, injury, or death from waterborne pathogens associated with construction activities. This applies to all new or renovated facilities. Many of the industry guidance documents require risk mitigation for construction projects related to maintenance and repair, renovations, additions, or modifications to existing buildings, as well as all new construction. Additionally, CMS and The Joint Commission use the FGI Guidelines for establishing the minimum standards of care for creating environments for patient care operations. Click here for more information on water management for construction.
2. Healthcare medical device reprocessing - if your organization performs medical device reprocessing (ex. sterilization of surgical instrumentation or High-Level Disinfection), it may be necessary to follow guidelines from The Association for the Advancement of Medical Instrumentation (AAMI). AAMI is the primary source of consensus standards, both national and international, for the medical device industry, as well as practical information, support, and guidance for healthcare technology and sterilization professionals. According to an AAMI technical information report, TIR34, Water for the reprocessing of medical devices, “The water used to reprocess a medical device needs to be of sufficient quality to ensure that the device is not damaged and that the patient will not be injured by contact with the device.” TIR34 identifies two categories of water that are important for medical device reprocessing:
   • Utility: Water from the tap that is usually used for flushing, washing, and rinsing.
   • Critical: Water that has been extensively treated so it can be used during the final rinsing stage or steam sterilization.

Note that the current AAMI TIR34 guidance document for water in the sterile processing department will in the near future be replaced with a new standard, AAMI ST108: Water for the Processing of Reusable Medical Devices. AAMI ST108 standard is currently under development and will provide guidance on appropriate water system design, monitoring, testing, and maintenance. Click here for more information on water management for medical device reprocessing.

1. An independent water management expert can assist your organization with effective navigation of the complex and overlapping regulatory process involving building water management. Since building water management has evolved over the past decade away from chemical and commercial conflicted providers, the CDC recommends your organization evaluate 7 key characteristics when choosing a water management expert including the level of experience, laboratory experience, environmental assessment expertise, remediation expertise, water management expertise, knowledge of codes, standards, and regulations, and potential conflicts of interest.

1. Phigenics meets all 7 criteria as set forth by the CDC for building owners to consider when choosing a water management expert.
2. Phigenics has account management, technical support, and subject matter
   experts intimately familiar with these building water industry guidance documents. Our staff routinely:
   1. Participate on committees related to such industry guidance
   2. Conduct research influencing industry guidance documents
   3. Share expertise at public speaking engagements
   4. Work with clients on alignment with industry guidance documents
   5. Communicate with local, state, and federal agencies having jurisdiction 
   6. Perform expert witness testimony related to water management