Water Management Program Assistance

Information on Water Management Legislation and Startup

During the 2020 General Assembly Session, the legislature passed Senate Bill 410. The legislation, which amends Code of Virginia § 22.1-138, adds subsection C, and requires school boards to maintain a water management program for the prevention of Legionnaires’ disease at each public school building in the local school division.   The effective date of the legislation is July 1, 2021, giving school boards time to develop and implement the required water management programs.

Schools and businesses who closed buildings or significantly reduced activities due to COVID-19 should thoroughly flush their building’s plumbing systems before reopening. 


Information for Schools

Frequently Asked Questions Regarding Water Management Programs

The legislation applies to public schools; private schools are not included.
The Georgia Department of Public Health published a water management template, dated June 2019. Click here to download the water management plan template or visit https://dph.georgia.gov/legionellosis. We suggest reviewing CDC’s online PreventLD training and CDC’s Water Management Program Toolkit before you get started on developing your own water management plan so you have a better idea of how it works.
Public schools will now be required to do three main things:
  1. Develop and maintain a water management program for the prevention of Legionnaires' Disease
  2. Validate the program at least on an annual basis
  3. Maintain files on the program documenting program activities, including validation results and remediation activities, and make them available for review
School boards are also required to develop and implement plans to test for lead in drinking water in each school and mold in each school. Information about requirements for lead can be found here (childhood lead poisoning prevention information) and here (VDH Lead in Schools and Childcare Facilities). Information about requirements for mold can be found here (CDC-mold remediation in schools and commercial buildings), and here (EPA-mold and indoor air quality in schools)
Information and guidance on developing a water management plan can be found on CDC’s web site here.  ANSI/ASHRAE Standard 188-2018, Legionellosis: Risk Management for Building Water Systems establishes minimum Legionellosis risk management requirements for building water systems.  A consultant can be helpful to guide the process of developing and implementing a water management plan.  
The Association of Water Technologies (AWT) have posted a list of Accredited Legionella testing laboratories. https://www.awt.org/pub/AD6D24E6-F693-773F-7049- 62DF1AA75EE6
VDH does not have a specific recommendation at this time.  The team responsible for developing and implementing each public school building's water management program should define appropriate ongoing verification processes and a validation process to ensure the water management program is working as designed.  Each building can have unique characteristics and mitigation strategies so a one size fits all approach is not possible.  ASHRAE 188 recommends that the team responsible for developing and implementing the building's water management plan for Legionella control decide when and where to conduct Legionella sampling. ASHRAE Standard 12-2020, Appendix C states that, “Testing water samples for Legionella may be appropriate as a means to confirm that a water management program, when implemented as designed, effectively controls the hazardous conditions throughout the building water systems… Facilities with higher risk of disease may find information from Legionella testing useful… Examples of such facilities include the following:... Facilities where control measures, such as water temperature and disinfectant residual levels, are not being maintained consistently within target limits throughout the building water system.” If the verification or validation process for the water management program involves sampling of Legionella, then building owners should consider most probable number samples instead of presence/absence samples.  ASHRAE Standard 12-2020, Appendix C sets out guidelines that the building owner may use to evaluate the performance of a water management plan and recommends responses to Legionella test results. For more information about this topic, visit https://www.ashrae.org/technical- resources/standards-and-guidelines and review ASHRAE 188 and ASHRAE 12.

Legionella Bacteria and Legionnaires Disease

Legionella is a type of bacteria that can cause a serious type of pneumonia known as Legionnaires’ disease or in some cases, a less serious illness called Pontiac fever. Legionella is found naturally in most freshwater environments, but can become a health concern when it begins to grow and spread in water systems such as cooling towers, hot tubs, and building plumbing systems. 

Legionella spreads after growing in a building water system and then is transmitted to peopleLegionella Factsheet through water droplets small enough to breathe in.  This can even occur through the drinking of contaminated water, which accidentally ends up in the lungs.  This makes people with swallowing difficulties at an increased risk of contracting legionella.  In general, Legionella does not spread from person to person; however, it has been known to do so under rare circumstances.

If you wish to find out more information on Legionella and Legionairres Disease including symptoms, growth, and prevention, please visit VDH's informational webpage here, the CDC page on Legionella or click the factsheet to the right on Legionairres Disease.

In the video below, the CDC better explain Legionella bacteria and how it cultivates.

 

Importance of Water Management

Child drinks from a fountainBuilding owners and operators are responsible for maintaining drinking water quality throughout their buildings. Building drinking water systems are designed to support the continuous delivery of safe water. When buildings or parts of buildings (such as gym locker rooms) go unused, so too does the water sitting in pipes. To make sure drinking water systems remain at safe levels it is important that all of the water in the building be flushed out and replaced with fresh water from the water utility system.

When water is not used, the disinfectant in the water dissipates over time. Without chlorinated water flowing through the pipes for an extended period, microorganisms can grow in water pipes, fixtures and tanks. Prolonged water stagnation also can diminish the normal, protective scale on interior pipe walls. Without the protective scale, metal from the piping may dissolve into the water.

Water management plans will assist building owners to understand, measure, and manage water quality in building plumbing systems. The practice of flushing to maintain building water quality is one tool employed as part of a water management plan.

What is a Water Management Program?

Water management programs identify hazardous conditions and take steps to minimize the growth and spread of Legionella and other waterborne pathogens in building water systems. Developing and maintaining a water management program is a multi-step process that requires continuous review. Seven key activities are routinely performed in a Legionella water management program:

  1. Establish a water management program team
  2. Describe the building water systems using flow diagrams and a written description
  3. Identify areas where Legionella could grow and spread
  4. Decide where control measures should be applied and how to monitor them
  5. Establish ways to intervene when control limits are not met
  6. Make sure the program is running as designed and is effective
  7. Document and communicate all the activities

In general, the principles of effective water management include

  • Maintaining water temperatures outside the ideal range for Legionella growth
  • Preventing water stagnation
  • Ensuring adequate disinfection
  • Maintaining premise plumbing, equipment, and fixtures to prevent scale, corrosion, and biofilm growth, all of which provide a habitat and nutrients for Legionella

Members of a building water management program team work together to

  • Identify ways to minimize growth and spread of Legionella and other waterborne pathogens
  • Conduct routine checks of control measures to keep an eye on areas at risk
  • Take action if a problem is found

Once established, water management programs require regular monitoring of key areas for potentially hazardous conditions. Programs should include predetermined responses to correct hazardous conditions if the team detects them.

For more information visit the full CDC Guidance on Water Management Programs, visit their page here.

To learn more about developing a water management plan, visit the CDC's in depth toolkit here.

Other Useful Information:

The Georgia Department of Public Health produced an example water management template, dated June 2019.  Click here or visit https://dph.georgia.gov/legionellosis

The World Health Organization provides guidance for water safety including in depth guides to creating a water safety plan.  Their document here, consists of a diverse list of water safety measures.

 

Flushing Water Systems and Why it's Important

When water is not used, the disinfectant in the water dissipates over time. Without chlorinated water flowing through the pipes for an extended period, microorganisms can grow in water pipes, fixtures and tanks. Prolonged water stagnation also can diminish the normal, protective scale on interior pipe walls. Without the protective scale, metal from the piping may dissolve into the water.

During the flushing process, stagnant, existing water is replaced with fresh water, which has been continually treated and monitored by the water utility. By running water through the pipes we can flush out the old stagnant water and bring in fresh water to replace it.  

This is usually accomplished by running water fixtures such as showers, faucets, and flushing toilets in order to clear out the old water in the pipes and allow fresh water to flow through.  The amount of time this is done depends on the size of the building and the configuration of the building plumbing.  

Resources and Guides for Flushing Water Systems:

The Hampton Roads Planning District Commission has published a simple, step by step guide for flushing buildings here on their website

The US EPA recommends that building owners and managers take proactive steps to protect public health by minimizing water stagnation during closures and taking action to address building water quality prior to reopening. More information can be found on EPA’s website.

While flushing it is also important to ensure staff safety as it is possible anyone working with these systems could be exposed to bacteria.  The Environmental Science Policy and Research Institute has developed a guide to help reduce the risk of staff during flushing.

American Water Works Company, Inc. (American Water) provides a useful background on flushing pipes and includes resourceful topics in regards to flushing a water system.  - Has your facility been closed for weeks? Flush the pipes.

The State of Michigan EGLE Division has developed great guidance on Procotol for flushing school facilities.  The document provides parameters for specific water systems and steps to take to perform a proper system flush.

Purdue University's Center of Plumbing Safety has developed and collected useful resources and guidance to help assist in creating flushing plans here on their website.  They also provide examples of flushing plans along with educational videos to help understand flushing as well as why it is necessary.

Pamphlet from DC water explaining flushing and water quality measures

 

 

Building Startup

Water Sampling

Legionella & Legionnaires' Disease

Industry Standards/Guidance

AWT 2019 Position Statement (FREE)- provides current Legionella and related legionellosis information
in a broad and useful format that can be easily utilized as a reference and guidance document to manage
the risk of Legionnaires’ disease from water systems
CTI Guideline 159 (2020): Practices to Reduce the Risk of Legionellosis from Evaporative Heat
Rejection Equipment Systems (Requires Purchase)- covers areas such as basic Legionella microbiology,
risk assessment, general maintenance and inspection, equipment operations, and record keeping for
cooling towers
NASEM (2020): Management of Legionella in Water Systems (FREE)- provides a report on a study that
reviews the state of science on Legionella contamination of water systems, specifically the ecology and
diagnosis and explores the process of transmission via water systems, quantification, prevention and
control, and policy and training issues that affect the incidence of Legionnaires’ disease
NIOSH (2019): Preventing Occupational Exposure to Legionella (FREE)- NIOSH recommendations to
employers to prevent conditions that lead to Legionella growth and spread in workplaces

ASHRAE (American Society of Heating, Refrigeration, and Air Conditioning Engineers) Standard 188-2018: Legionellosis: Risk Management for Building Water Systems

IAPMO (International Association of Plumbing and Mechanical Officials) (June 2020) jointly issued a standard  ASSE/IAPMO/ANSI 12080 for Legionella Water Safety and Management Personnel which outlines the minimum qualifications needed to become a member of a building water safety team.

 

Water Management Service Providers

VDH does not endorse or recommend any particular water management service provider, or contractor. The following list is based only on those service providers who have shared their contact information with the agency. The omission of a service provider from the listing is not a statement of unsuitability. VDH also does not guarantee the work or license status of any listed provider. It is recommended that you view the Department of Professional and Occupations Regulation (DPOR) website, www.dpor.virginia.gov, to verify that a service provider is properly licensed in accordance with state law.

Service Provider List

How do I get added to the lists?

Any contractor that can provide waterworks management assistance and would like to be included in the VDH Service Provider listings can click here and provide their contact information.  Only those contractors that have given VDH permission to publish their contact information through the ODW Service Provider Form are included.

Other Certifications

While there is no State Law or requirement for individual certifications, ASSE has recently released a list of certified professionals who have been certified in Legionella.  To gain access to this list, click the link here to visit their certification page.  Then under "Search by Certification" select "12080- Legionella" from the menu and click search.

 

 

In the video below, the CDC talks about the importance of Water Management in preventing Legionnaires' disease.