Maintaining a Legionella free water management system requires that you ensure the program is running as designed and is effective. Your program team should establish procedures to confirm, both initially and on an ongoing basis, that the water management program is being implemented as designed. This step is called “verification.”
Example: If you said you would test the hot tub daily for chlorine and record and communicate those results, have you been doing that?
If you found a problem, did you take the action included in your program? People should not verify the program activity for which they are responsible.
Example: If one person is responsible for maintaining the hot tub and another is responsible for the cooling tower, they could verify each other’s work, not their own.
Once you have a water management program implemented, you need to be sure that it is effective. Your program team should establish procedures to confirm, both initially and on an ongoing basis, that the water management program effectively controls the hazardous conditions throughout the building water systems. This step is called “validation.”
Environmental testing for Legionella is useful to validate the effectiveness of control measures. The program team should determine if environmental testing for Legionella should be performed and, if so, how test results will be used to validate the program.
Factors that might make testing for Legionella more important include:
- Having difficulty maintaining the building water systems within control limits.
- Having a prior history of Legionnaires’ disease associated with the building water systems.
- Being a healthcare facility that provides inpatient services to people who are at increased risk for Legionnaires’ disease.
If the program team decides to test for Legionella, then the testing protocol should be specified and documented in advance. You should also be familiar with and adhere to local and state regulations and accreditation standards for this testing.
Now that you have done all of the work required to create your water management program, document it. Your written program should include at least the following:
- Program team including: names, titles, contact information, and roles on the team.
- Building description including location, age, uses, and occupants and visitors.
- Water system description including: general summary, uses of water, aerosol-generating devices (e.g., hot tubs, decorative fountains, cooling towers), and process flow diagrams.
- Control measures including: points in the system where critical limits can be monitored and where control can be applied.
- Confirmatory procedures, including verification steps to show that the program is being followed as written and validation to show that the program is effective.
- Document collection, transport methods and which lab will perform the testing if environmental testing is conducted.
After you have worked hard to develop your water management program and have carefully documented all its aspects, consider notifying building occupants that you have a plan in place to keep the building water systems safe, just as you would for an elevator inspection. Be sure to communicate with your employees and colleagues about your program on a regular basis and train those responsible for implementing and monitoring the program. Use this communication as an opportunity to identify strategies for improving the management and efficiency of your water systems.
For additional information about the growth and spread of Legionnaires’ disease, visit: www.cdc.gov/legionella.
Alliance Environmental Group, Inc. is a leading environmental contractor in California, with more than 75 years of experience. Alliance Environmental Group and Airtek Indoor Solutions provides innovative resolutions in the areas of: asbestos, lead, and mold abatement; air and HVAC duct cleaning; heat treatment for pest control; structural pasteurization; demolition and emergency response. The company has successfully completed over 120,000 remediation projects in California and surrounding areas.
For additional information about the company and its services, visit: www.alliance-enviro.com.