BUILDINGS WITH COOLING TOWERS are the most susceptible to widespread Legionella
outbreaks. Heat exchange in cooling towers provides bacteria with the perfect conditions
for growth, so water management plans are critical to keeping occupants safe.
5) Can you defend your
policies based on expert
An attorney’s case against your
water management practices is only
as strong as the opinion of a qualified expert. The same goes for your
defense. It’s not enough to have just
any WMP. It must be comprehensive
6) Are you doing what’s in your
A perfect car owner’s manual will do
nothing to ensure your car lasts long
and runs well. You have to implement
the procedures outlined in the manual.
It’s similar with WMPs. Only what
you actually do to your water systems
will minimize the risk of disease. The
words in your WMP, unless acted upon,
will do nothing.
The format, medium and flow of your
WMP is almost as important as the content. It needs to be so easy to follow that
it’s almost fun to implement and document the plan.
Implementing your WMP and documenting the procedures are crucial for
legal risk, too. For standard of care,
the only thing worse than not having
a WMP is having one but failing to
implement it. It makes an easy case for
the plaintiff’s attorney.
How did you score? Since the test
covers only the basics, passing requires
a yes to all six questions. If you failed,
don’t panic; just get started on changing any nos to yeses.
Fortunately, establishing and implementing a top-notch water management
program does not take a burdensome
amount of time and money if done intelligently, and it ultimately pays back. The
benefits of protecting your organization
and the people who spend time in your
buildings are well worth the investment. B
Matt Freije is the
founder and CEO of
HC Info, a provider
plans and train-
ing. He has taught
in five countries, served as an expert in
more than 60 lawsuits related to Legion-
naires’ disease and written two books. His
water management and training materials
are used by hundreds of building opera-
tors, water experts, and health officials
ment those same measures for cold
water storage tanks in the other 5. If the
WMP for the 15 buildings has flushing
procedures for infrequently used faucets,
do the same in the other 5 buildings.
Otherwise, if a case of Legionnaires’
disease occurs, how will you explain
why you implemented control measures
in buildings 1-15 but not for the same
equipment in buildings 16-20? Saying
ASHRAE 188 did not require a WMP is
not a good enough answer.
HOT WATER is a breeding ground for Legionella, so hot tubs in hospitality settings should
receive special attention with a water management plan.