In June 2017, the Centers for Medicare and Medicaid Services (CMS) issued a mandate requiring their facilities, as well as Hospitals, Critical Care Access Hospitals, and Long-Term Care Facilities to comply with ASHRAE’s standard 188 to reduce the risk of Legionella. In the coming months guidelines for enforcement and penalties for non-compliance are sure to be announced.

What does this mean for your facility?

Legionella RiskLegionella is an environmental bacterium reported from both natural and artificial water systems (with few exceptions, in which they are reported from terrestrial or ambient air environments). Legionella can cause Legionellosis or Legionnaires’ disease, often a severe and lethal form of infection acquired mostly from contaminated water. Each year, an estimated 10,000 to 18,000 people are infected with the Legionella bacteria in the United States. Legionellosis is deadly for 1 out of 10 people afflicted with the infection. Therefore, an active water management plan (WMP) is being encouraged by ASHRAE and CMS to reduce the Legionella risks.

What are the potential sites for Legionella infection?

While healthcare facilities are the main focus of the CMS mandate, certainly any building or location that has a water system or incorporates water features is susceptible to Legionella. This list includes but is not limited to: Hotels, Spas, Amusement Parks, Sports Complexes, Airports, Cruise Ships, Office Buildings, Schools, and Home Residences.

Proactive Planning

Water ManagementTo minimize and control the spread of Legionella in a building’s water and HVAC systems, a water management plan (WMP) is essential. Basically, The crux of the CMS mandate and ASHRAE 188. This plan should be developed specifically to the functions and utilizations of the building’s water and HVAC systems. Because building water systems vary in their design, complexity and functioning, a one-size-fits-all WMP is not possible. Therefore, a custom WMP is required to reduce the risk of Legionella growth in and around a particular building. Developing and maintaining a water management program is a multi-step process that involves multiple disciplines. The accompanying flow-chart offers a simplified overview of the main steps in a proactive plan.

Testing for Legionella is a key to success

Water samples from potential sites of Legionella contamination can be collected for laboratory testing. Data on water quality and growth promotion for Legionella must be assessed to prevent the bacterial proliferation. In most cases, a water sample (250 – 1000 ml) is collected. However, swab, wipe and bulk procedures may also be used for collecting environmental samples for testing. The outcome of laboratory testing and analysis may reveal the potential of an environmental Legionella cluster or epidemic. The severity of which would then guide actions for remediation of the bacteria in the water system and facility.

Important Resources

ASHRAE Standard 188 provides the guidelines for understanding Legionella and developing a plan for your facility. It should be understood and a proactive approach undertaken to adhere to its recommendations. Environmental Diagnostics Laboratory (EDLab) at Pure Air Control Services offers supplemental resources that can help you navigate the standard though implementation.

Legionella Risks HandbookRecently, EDLab presented a free 4-part webinar series about Legionella. A video replay of this series can be found here.

EDLab has also published a useful reference guide titled “Legionella Handbook: Specifications for the Inspection, Detection, and Identification of Legionella within Water Systems in and around Buildings”. This handbook is provided free of charge from EDLab.

Regardless of the CMS mandate and forthcoming enforcement, it is a Good Maintenance Practice (GMC) to take a proactive approach towards Legionella to ensure the safety of your facility and its occupants.

For more information on Legionella testing or to get your free Legionella Handbook please contact Alan Wozniak, President of Pure Air Control Services, Inc. at 1-800-422-7873, ext. 802,  or Dr. Rajiv Sahay, Director of EDLab at 1-800-422-7873, ext. 304. You also can contact us here.

About Pure Air Control Services
Pure Air Control Services, Inc. was founded in 1984 as a small, mechanical, contracting firm and has since set the industry standard for indoor environmental quality diagnosis, environmental laboratory and remediation. Pure Air Control Services has serviced more than 600 million square feet of indoor environments in over 10,000 facilities.

Contact Dr. Rajiv Sahay, CIAQP, FIAS at (800) 422-7873, Ext. 304 for additional information.

Environmental Diagnostics Laboratory (EDLab)
The Environmental Diagnostics Laboratory (EDLab) (established in 1992) at Pure Air Control Services (PACS) is an environmental lab offering complete and comprehensive indoor environmental microbiology laboratory services. They include: microbiology, aerobiology, chemistry, allergen assays and microscopy designed to meet all your indoor air needs. EDLab supports IAQ investigations by assisting with strategic sampling plan development and supplying media collection equipment while performing a wide range of environmental analyses.
For more information on EDLab at Pure Air Services, Inc. please contact Dr. Rajiv Sahay, CIAQP, FIAS, at (800) 422-7873 x 304, or visit