LEGIONELLA MANAGEMENT PROGRAM - COOLING TOWERS
Effective June 2015
RSI is encouraging all facilities to review their Legionella Management Program (LMP). Please note that Legionella is naturally occurring and is found in lakes, ponds and water puddles all around us. Trace amounts of Legionella in a cooling tower are not harmful, but should be addressed. Legionella is harmful when it gets to very high levels and is carried away in cooling tower mist or evaporation and is inhaled by an individual. The elderly, immune suppressed, smokers and those with respiratory issues are the most susceptible. RSI will comply with the LMP as defined by your facility or help support the creation of one with information and consultation.
Good cooling tower maintenance and good housekeeping is crucially important in the control of Legionella. Cooling towers with mud and other debris are more susceptible to Legionella and other bacteria multiplying.
A LMP is a maintenance and control plan designed to reduce the risk of contamination and immediately address any health threat. For cooling towers, proper maintenance should include:
A water treatment program with routine testing to monitor program performance.
Oxidizing biocides have proven to be very effective in the prevention and multiplication of Legionella. Even if discharging chemicals is not allowed by your facility, an oxidizing biocide such as chlorine can still be safely used. Ask your RSI representative for details.
Twice annual system disinfection and physical cleaning of the cooling tower. Any approach to controlling bacteria is dependent on the cleanliness of the cooling tower. When there is mud and other debris in a cooling tower sump, any approach to killing bacteria will be spent before being able to kill the harmful bacteria.
While currently not required by law, RSI recommends periodic Legionella testing; quarterly for year round towers, twice during cooling season for seasonal towers. Your RSI representative can provide protocol and pricing through our accredited laboratory partners.
Remediation for an actionable level of Legionella detected in a system includes a plan for the immediate chemical disinfection of the system followed by a physical cleaning. Adhering to the ANSI/ASHRAE 188-2015 standard (pertinent content at the end of this letter) with the development of a LMP demonstrates due diligence and helps provide a safe harbor from increasing legal claims of negligence and liability surrounding Legionella.
Good documented cooling tower maintenance, good documented housekeeping of cooling towers, and testing for the Legionella bacteria are the most important things we can all do in the prevention of this bacteria.
Notes from Recently Published ANSI/ASHRAE Standard 188
The written document for the water management program under ASHRAE’s Legionella Standard must include the following:
A list of the water management program team members. For example, in a hospital this would most likely include one or more employees from facilities, infection control, safety and administration, along with the Medical Director, infectious disease specialist and risk management director, up to 10 team member’s total.
A brief description of the building water systems, with flow diagrams. The flow diagrams do not have to be detailed or scaled drawings. Simple line drawings showing the points (e.g. Point of building entry) and processing steps (e.g. Water heating) are sufficient and actually better than detailed drawings in giving the water management program team leader a clear understanding of the locations where Legionella control measures must be applied.
Analysis of building water systems. The analysis must determine which systems present a significant potential for Legionella growth and transmission and the locations where Legionella control measures can be applied.
Control Measures. This is the most important part of any Legionella water management plan because control measures are what actually reduce the risk of Legionnaire’s Disease. If effective control measures are not selected, the water management plan will fail to sufficiently reduce Legionella risk. Each control measure must be maintained to determine whether it has performed to the standard – called a control limit – designated in the water management program. If the control limit is not met, then a corrective action must be implemented. In the water management program document, the monitoring procedure and schedule, control limit, and corrective action must be listed for each control measure.
Verification Procedures. The procedures are to ensure that the water management program is being implemented. For example, documentation for each control measure must be reviewed to ensure proper implementation.
Validation. The effectiveness of the water management program must be validated. Testing water systems for Legionella provides the most direct feedback on Legionella control. Legionella testing is discussed as a validation option – but is not required in this standard.
Documentation. This standard instructs the team to “establish documentation and communication procedures for all activities of the water management program.”
Cost and Benefits
Building owners and managers who do not already have an adequate Legionella control program will incur expense in following what is outlined in Standard 188. But, for a facility that is already well maintained, an effective Legionella water management plan can be developed at a reasonable cost. It is worth it. The risk of Legionella is real. Thousands of people contract the disease in the United States each year. Many die from it and others endure horrible suffering and long-term disabilities.
Please contact Brad Ramsey (502) 376-0452 for further action.