Is a water management program a legal requirement?

For Medicare-certified hospitals, critical access hospitals and long-term care facilities, CMS expects one to be in place. For other buildings, ASHRAE 188 is the recognised industry standard, and some states, provinces and cities add their own requirements. Insurers, accreditation bodies and tenants increasingly ask to see a program too.

What’s the difference between ASHRAE 188 and the CDC toolkit?

ASHRAE 188 is the standard that sets out what a water management program must include. The CDC toolkit is a practical guide, based on that standard, that walks you through building one.

How often should a water management program be reviewed?

The CDC recommends reviewing your program at least once a year. It should also be reviewed whenever something changes: new construction or renovation, equipment changes, a water disruption, or a case of Legionnaires’ disease linked to the building.

Can you review a program our water treatment vendor wrote?

Yes, and it’s one of the most useful things an independent consultant can do. We’ll check it against ASHRAE 188, confirm it reflects how your building actually works, and flag any gaps.

Legionella Water Management Consultants Across North America

ISHEM’s North American team is based in Indianapolis. We help hospitals, long-term care facilities, schools, property owners and manufacturers across the United States and Canada build and maintain water management programs that reduce the risk of Legionnaires’ disease.

We’re independent. We don’t sell water treatment, filtration or remediation, so we can assess your buildings and your current vendors without a conflict of interest.

Our Services Across North America

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Legionella Control Management

Water Management

Asbestos Management

Health & Saftey Management

Compliance Monitoring

Indoor Air Quality

Environmental Management

Other Services

ASHRAE 188 And The CMS Requirement

ANSI/ASHRAE Standard 188 is the recognised US standard for managing Legionella risk in building water systems. The CDC’s toolkit, Developing a Water Management Program to Reduce Legionella Growth and Spread in Buildings, is based on it and gives practical guidance on putting a program in place.

For healthcare, this isn’t optional. The Centers for Medicare & Medicaid Services (CMS) expects Medicare-certified hospitals, critical access hospitals and long-term care facilities to have water management policies and procedures that reduce the risk of Legionella growth and spread. ASHRAE 188 and the CDC toolkit are the reference points, and surveyors will ask to see them.

State, Provincial And City Requirements

Some jurisdictions set their own rules on top of the national standards. New York State and New York City, for example, require cooling towers to be registered, inspected and sampled on a set schedule. In Canada, Québec has mandatory cooling tower maintenance rules, and federal buildings follow Public Services and Procurement Canada’s Legionella control requirements. For multi-site portfolios, we map which requirements apply to each building so nothing is missed.

How We Help Build Your Program

Our Legionella control management service covers every stage of the program:

Facility risk assessment and water system flow diagrams.
Identifying where Legionella could grow and spread, and setting control locations, control limits and corrective actions.
Verification and validation, including sampling plans and water management where appropriate.
Documentation your program team can maintain and a surveyor can follow.
Independent annual review of existing programs and vendor performance.