Molly M. Scanlon, PhD, FAIA, FACHA is an Environmental and Occupational Health Scientist, as well as a licensed and certified Healthcare Architect currently working with Phigenics as the Director of Research and Innovation. She has more than 25 years of planning and design experience for healthcare settings to create environments benefiting the health, safety, and welfare of patients, nurses, physicians, and staff. Dr. Scanlon is serving as: an adjunct faculty member at the University of Arizona – College of Public Health; an appointed member of the American Institute of Architects Design and Health Leadership Group; a Fellow in the American Institute of Architects; and a Fellow in the American College of Healthcare Architects.                                                                             

Healthcare facilities with concerns about immunocompromised patients have been early adopters of water safety standards to maintain a healthy built environment. With the Centers for Medicare and Medicaid (CMS) publication of Memo 17-30, healthcare facilities (acute care, critical access hospitals, and skilled nursing facilities) will need to survey their facilities for water safety not only for existing buildings, but also before construction begins for renovations, additions, or modifications to existing buildings, and prior to occupancy of a new building. 

This is a lofty goal when there has been minimal training of facility management and infection preventionist professionals about the dangers of construction activities impacting waterborne pathogens and ensuing disease in patient care settings. In addition to identifying the hazards, there has been minimal effort and a lack of understanding about establishing hazard controls, locations for controls,monitoring procedures, control limits, and corrective actions, as well as the necessary verification and validation procedures. 

Phigenics was launched because we realized that disease and injury caused by Legionella and other waterborne pathogens was an enormous problem that we could help solve. Tens of thousands of people were being unnecessarily harmed and billions of dollars wasted every year because building water systems were being mismanaged.

Today, the problem persists, but the future is bright because a tremendous amount of positive change has occurred, especially in the last 3 years.

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.