7) Choose the Right Control Measures
Control measures are the most important part of any
Legionella water management plan. They must be thorough,
specific, effective, evidence-based, defensible and doable without costing more than necessary.
If the WMP excludes important control measures or includes
unnecessary ones, it will be inadequate for reducing risk, too
expensive or both.
8) Validate the Plan
Validating the effectiveness
of the WMP in controlling
the hazard is second only
to control measures in
Legionella testing is
discussed as a validation option in ASHRAE
188 but is not required.
Testing water systems
for Legionella can
provide the most direct
feedback on Legionella
control, especially in
plumbing systems and
cooling towers, but only
if it’s done well. Sampling
specifications must outline
the right locations, devices,
water (hot vs. cold) and collection
methods to produce data for decision making. Samples must be collected and
recorded properly and tested by a competent laboratory. And
the test results must be correctly interpreted and acted upon.
9) Ensure Good Execution
The football team with the best players and playbook won’t
win unless its players can put their plan into action. Likewise,
getting a good WMP is only the beginning. It must be well
executed to be successful.
Implement your control measures. Educate employees.
Verify implementation. Validate well. Respond appropriately
to test results. Document thoroughly and efficiently. Hold
team meetings no less than quarterly. Revise the plan based on
verification and validation results and new scientific findings,
technology, standards and regulations.
Like working out, it will be uncomfortable at first. Maybe
even painful. But after a while you will get in a rhythm and
find it quite manageable.
Your efforts will help you reduce your legal risk, avoid business losses and protect against brand damage. You may even
save lives. B
Matthew R. Freije has specialized in Legionella prevention
since founding HC Info in 1995. He has taught seminars in five
countries, served as an expert in more than 60 lawsuits and
written two books, nine e-learning courses, and a web-based
water management plan development and documentation tool.
Legionella is an ideal target pathogen for building water
management. It’s not the only organism that can cause disease
in a building environment, but it’s the best pathogen on which
to base water management procedures because it is the only
one that has caused numerous cases of severe illness and
death, is entirely environmental (meaning that it can’t be
transmitted from person to person), is controlled primarily
in building water rather than city water supplies, can be
detected in water via reliable methods and has been studied extensively, resulting in an abundance of scientific data
on which to base control measures.
Legionella management will affect a number of other pathogens, particularly ones that multiply in biofilms within a proximal temperature range, such as Mycobacteria avium (which
causes tuberculosis-like symptoms in immunocompromised
people) and Pseudomonas aeruginosa, which can cause several
kinds of bacterial infections and is resistant to many antibiotics.
In a sense, a comprehensive Legionella WMP will under-prom-ise and over-deliver.
5) Develop Deliverable Specifications
To be consistent with ASHRAE 188, water management
plans must include a few vital elements (see “What Belongs in
a Water Management Plan?” on page 22).
Keep the plan focused by simply listing what the facility
will do to meet the requirements. Background and explanatory information belongs in training materials, not in the WMP.
Those who have to implement the WMP will appreciate a format that makes it easy, without extra words to read.
6) Know Your Team
Deciding what your own personnel can take care of and
when to bring in an outside expert is crucial for success.
The site survey does not require Legionella expertise.
Someone at your facility who knows your water systems could
do the survey quite well and probably in roughly the same time
they’d spend accompanying a vendor around the facility.
and experience, especially for the hazard
analysis, control measures and validation
In-house facility personnel, particularly
at larger facilities, can and should handle
the routine maintenance procedures outlined in the WMP, but outside help will
be needed for Legionella testing, which
involves writing specifications, collecting
samples and laboratory testing, as well as
water treatment and remediation.
Facilities that try to handle all aspects of
WMP development themselves end up with
inadequate control measures and spend
more money than they would have hiring
expertise where needed. Facilities that try
to sidestep the development process by hiring it all out will overpay for their WMP
and fall short of optimal risk reduction
by undervaluing the importance of their
involvement and ownership. Strike the
right balance for your organization.
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