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.
There’s no way to guarantee that you won’t get that call about equipment failure or water quality questions out of the blue, but there is a way to streamline what happens when you put the phone down to address the issue. Having a Water Management Program (WMP) in place is a way to ensure your system is defensible ahead of time.
You’re thinking: Great, another program to manage, that’s just what I need! But, a WMP is different. It’s a solution that, yes, takes some time through monthly meetings and periodic verification and validation audits. However, it also saves you time in the long run, as well as giving you assurance that your facility is optimized in all areas: safety and efficiency, utility and potable.
So, what is it? How does it work? Without going into too much detail, a good WMP takes a few weeks to set up. If my associates or I have talked with you about Phigenics, you know there are people out there who are experts in building a WMP from scratch and can help guide you along the way. After the program is set up, almost everything happens automatically. Don’t get me wrong – everyone still has to do their PMs and other normal work; but, the WMP, by design, is evergreen and self-correcting. It becomes your go-to stop for questions about how you’re managing your water, how you KNOW that your system is optimized, and how you KNOW that you’ve been doing everything you can to keep patients safe. For example, consider a worst-case water management event: A confirmed case of Legionnaires’ Disease is traced back to your facility. What happens with and without a WMP in place?
Everyone calls everyone else. Emails fly. The public relations department receives calls from the news media. There is an illusion of progress being made as everyone involved scrambles to turn up any and all information they can and send it to each other before finally agreeing that they have no way to prove beyond a reasonable doubt that they’ve covered all their water quality bases. There are several different opinions on what the next step should be, and the tendency is to do all of them as quickly as possible (boom-bust cycle in full force).
You’ve done your testing, you’ve implemented best practices, and thanks to the documentation in your WMP, you can be sure you’re meeting all CMS (and other industry standard) requirements before anyone even asks that question. Reference the WMP and it will have the next step waiting for you— likely, a trigger for immediate water testing for Legionella in the suspected area. Furthermore, you will have a public relations plan already developed.
The usefulness of a WMP in this and many other examples is easy to see: Having a WMP gives you somewhere to turn in the case of ANY event, and it gives you the confidence to move forward in a structured, routine way. It can save you time, energy, and in extreme cases, your facility’s reputation. In the end, the program pays for itself through achieving compliance with the CMS Requirement, increasing safety and efficiency, and in the form of something you can’t measure: peace of mind.
This article was published in the Arkansas Association of Healthcare Engineers' Fall 2017 Newsletter.