According to the American Hospital Association, there are more than 6,000 hospitals in the United States with more than 900,000 staffed beds. Patients in hospitals more susceptible than the general population to Legionella, Pseudomonas and Non-Tuberculous Mycobacteria (NTM)—pathogens that live in water systems and affect significant numbers of persons outside of healthcare environments. But hospitalized patients also are vulnerable to pathogens that rarely affect persons in non-healthcare settings. These include Pseudomonas, Acinetobacter, Burkholderia, Stenotrophomonas, nontuberculous mycobacteria (NTM), and fungi, opportunistic waterborne pathogens specifically mentioned in CMS Memo QSO-17-30 (June 02, 2017; Revised July 06, 2018)

Even within healthcare environments, the susceptibility of different patient populations varies. For example, bone marrow transplants, solid organ transplants and burn patients are more susceptible to infection by Legionella and other waterborne pathogens than are the general patient population. Additionally, there are devices and equipment that use water, such as heater-cooler units, that are found exclusively in healthcare facilities. Other equipment used in both healthcare and non-healthcare facilities, such as ice machines, have healthcare-specific uses.

While there are more complex considerations, challenges and regulatory/accreditation requirements associated with the management of building water systems in hospitals, most hospitals also have unique resources and capabilities that are not generally available in other environments. These include specialized programs, such as infection prevention and control (IP&C) and specialized personnel, such as clinicians, infection preventionists and facility engineers with advanced, healthcare-specific training.

Hospitals typically have extensive potable water systems with a wide range of water use end points. In older hospitals, plumbing systems often have evolved over many years, with periodic expansion and renovation. True “as-built” plumbing systems are rare, and risers are frequently out of balance. Scalding limitations make it difficult to maintain temperatures needed for microbial control at patient-accessible taps. Areas dedicated to care of especially vulnerable patients may require special precautions.

Standard of Care

In 2015, ASHRAE Standard 188 helped establish a new standard of care for managing building water systems. The scope of ASHRAE Standard 188, most recently updated in 2021, specifically covers healthcare facilities, such as hospitals.

Accreditation Requirements

The US Centers for Medicare and Medicaid Services (CMS) issued a directive in 2017, CMS Memo S&C 17-30, Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD). The directive, which covers Medicare-certified healthcare facilities (including hospitals), requires policies and procedures that address Legionella as well as other opportunistic pathogens, — e.g., PseudomonasAcinetobacterBurkholderiaStenotrophomonas, nontuberculous mycobacteria (NTM), and fungi. The CMS Memo references ASHRAE Standard 188.

The Joint Commission (TJC) published new requirements, EC.02.05.02 (effective January 1, 2022) for managing water systems in buildings to prevent disease from multiple pathogens. TJC EC.02.05.02 references ASHRAE Standard 188.

Contact Us To Schedule a Consultation

Micromanagement offers comprehensive turnkey services for the reliable, regulation-compliant treatment of potable water systems in buildings. We help you protect your patients, staff and visitors from Legionnaires’ disease and other plumbing-associated infections. Call or write us today to learn more about our services.