By Matt Freije —
Too many industrial hygienists are either missing or messing up opportunities to set up and validate water management programs for their employer or consulting clients. Most are not offering related services at all. Some are, but poorly.
Facilities desperately need good water management programs. To avoid a citation for non-compliance with the Centers for Medicare & Medicaid Services
(CMS) “requirement to reduce Legionella risk in healthcare facility water systems to prevent cases and outbreaks of Legionnaires’ disease (LD)” issued last June, hospitals and nursing homes must “demonstrate measures to minimize the risk of LD.” Those facilities as well as hotels, schools, and commercial, residential, and industrial buildings need water management programs to reduce Legionella risk and comply with ANSI/ASHRAE Standard 188-2015.
If you are or will be involved in water management programs for your employer or client, you have an important role. Success is more than just checking a box to avoid fines and citations. Real success is doing that and effectively minimizing health risks for the people in the facilities, reducing the organization’s legal risk, and protecting the organization’s brand and revenue–all without using more money, time, personnel, water, or chemicals than necessary.
Real success depends on these seven keys:
1. A Smart Hazard Analysis
Although a good water management plan (WMP) will include control measures to reduce the risk of many pathogens, Legionella is the best pathogen by which to define the scope and objective of a WMP because it is almost entirely waterborne, several commercial laboratories in the United States can test for it in water samples, and numerous scientific studies provide an abundance of data on which to base control measures and remediation methods.
If the stated objective of the WMP is to control Legionella, the hazard analysis amounts to determining which water systems present a significant risk of Legionella growth and transmission and an opportunity to reduce risk through proper management.
The determination is important. If systems that should be included are not, you could miss opportunities to prevent disease and will increase your legal risk. If systems that should not be included are, you will waste money on unnecessary control measures. A common mistake is determining whether to establish
a WMP based on Legionella test results rather than types of water systems. Some water systems are inherently prone to Legionella which is why ASHRAE 188 requires a management program for certain water system types regardless of Legionella results.
The hazard analysis is like a rudder. Getting it right is crucial to the rest of the WMP.
Read the full article in the April 2018 issue of Health Indoors Magazine at: https://hi.healthyindoors.com/i/971754-hi-april-2018/21
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