Phigenics' Legionella consultant and phiSAT account manager, Turner Tomlinson has worked with facility water management teams ranging from healthcare to hospitality to manufacturing. Tomlinson shares the benefits organization's receive as a result developing and operating an ANSI/ASHRAE Standard 188 and CMS 17-30 compliant Water Management Program.
We all know the feeling: you get to work, check a few emails, and it’s starting to look like a pretty calm day. At the exact moment you dare to think this—that’s when the phone rings. A water leak, busted pipe, or the hot water isn’t getting hot, or there is a flow issue. Maybe something worse than mechanical failure, maybe the city just put up a boil water notice or infection control has determined that a patient has acquired legionellosis and they suspect it was from your water system. The boots-on-the-ground work of water management seems to occur in cycles like this. Periods of calm, regular operation punctuated by instances of major activity when there’s an issue. And, of course, it’s usually in the middle of a crisis that someone brings up the regulatory requirements you should be meeting—just when you don’t have time to calmly and thoroughly review them.
The Centers for Medicare and Medicaid Services (CMS) issued such a Requirement related to water safety on June 2, 2017. The CMS now “expects Medicare certified healthcare facilities to have water management policies and procedures to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in building water systems.” To put it very clearly, if you have responsibility for the water systems in your healthcare facility, you must:
- Conduct a facility risk assessment to identify where Legionella and other opportunistic waterborne pathogens (e.g., Pseudomonas, Acinetobacter, Burkholderia, Stenotrophomonas, nontuberculous mycobacteria, and fungi) could grow and spread in the facility water system.
- Implement a water management program that considers the ASHRAE (188) industry standard and the CDC Toolkit, and includes control measures such as physical controls, temperature management, disinfectant level control, visual inspections, and environmental testing for pathogens.
- Specify testing protocols and acceptable ranges for control measures, and document the results of testing and corrective actions taken when control limits are not maintained.