ASHRAE 188 is a standard developed by the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) to establish minimum requirements for managing the risk of Legionella bacteria in building water systems. This standard provides a comprehensive framework for identifying, assessing, and controlling conditions that promote the growth and spread of Legionella in water systems such as cooling towers, potable water systems, hot tubs, decorative fountains, and evaporative condensers. It matters because the standard is increasingly being incorporated into local building codes and regulations.

Yes, a Water Management Plan (WMP) is required for compliance with the Centers for Medicare & Medicaid Services (CMS) for certain healthcare facilities. CMS mandates that hospitals, critical access hospitals, and long-term care facilities implement a WMP to reduce the risk of Legionella and other waterborne pathogens in their water systems. This requirement is outlined in the CMS memorandum QSO-17-30 and subsequent updates. Key Requirements for CMS compliance:

• Facility Risk Assessment: Facilities must conduct a risk assessment to identify areas where waterborne pathogens could grow and spread.

• Water Management Program: The WMP must align with ASHRAE Standard 188 and the CDC toolkit. It should include policies and procedures to monitor water systems, manage risks, and take corrective actions when control limits are exceeded.

• Testing Protocols: The plan must specify testing protocols and acceptable ranges for control measures and document actions taken when limits are not maintained.

• Documentation: Facilities must maintain records of their WMP implementation, monitoring results, and corrective actions to demonstrate compliance during inspections.

IWC can help with all of the above compliance aspects. Contact us today

A Water Management Plan (WMP) must cover all building water systems and devices that could potentially foster the growth and spread of Legionella and other waterborne pathogens. According to ASHRAE Standard 188, CMS requirements, and related guidelines, the following systems typically need to be included:

• Potable Water Systems
  • Hot and cold water distribution systems
  • Storage tanks
  • Water heaters

• Cooling Towers
  • Used in HVAC systems
  • Often associated with Legionella outbreaks due to aerosolized water.
• Decorative Water Features
  • Fountains and waterfalls
  • Misters or foggers
  • Whirlpools, Spas, and Hot Tubs: (Such systems can create aerosols that may spread Legionella.)
• Humidifiers and Evaporative Condensers
  • Found in HVAC systems or refrigeration equipment.

• Medical Equipment Using Water
  • Devices such as hydrotherapy equipment or respiratory therapy devices in healthcare facilities.

• Areas of Stagnant Water
  • Dead legs in plumbing systems or infrequently used water outlets.

• High-Risk Areas in Healthcare Facilities
  • Locations with immunocompromised patients, such as intensive care units or transplant wards.

The time it takes for our IWC Innovations Legionella experts to develop a Water Management Plan (WMP) typically depends on the complexity of the building’s water systems, the size of the facility, and the scope of the project. On average, it can range from a few weeks to several months. Here are some factors influencing the development time:

• Complexity of Water Systems. Larger or more intricate systems (e.g., hospitals, high-rise buildings, or facilities with cooling towers and decorative fountains) require more detailed assessments and planning. Facilities with simpler systems, such as small commercial buildings, may require less time.

• Initial Assessment. Our Legionella team must perform a thorough site evaluation, including mapping the water system, identifying potential risks, and determining control points. This initial phase can take several days to weeks, depending on system size and accessibility.

• Regulatory Requirements. Compliance with local, state, or federal regulations (such as CMS requirements or state mandates) may add time due to documentation and approval processes.

• Customization. Each WMP must be tailored to the building’s specific needs, which involves creating flow diagrams, identifying control measures, establishing monitoring protocols, and developing corrective actions.

• Team Coordination. The expert Legionella team will work with your water management team, which may include building managers, engineers, and health officials. Scheduling meetings and obtaining input can extend timelines.

• Small Facilities: 2–4 weeks

• Medium-Sized Buildings: 4–8 weeks

• Large/Complex Facilities (e.g., hospitals): 2–3 months or more

In urgent situations (e.g., after a positive Legionella test), our Legionella team may expedite an acute remedial plan within a few days while working on a longer-term WMP.