Six Steps To Develop A Water Safety Plan And Comply With ASHRAE Standard 188-2015 – Legionella – A Canadian Perspective

Patrick Racine, P.Eng.

Author: Patrick Racine - General Manager

Water Safety Plan - ASHRAE Compliance
ASHRAE’s long awaited standard on Legionella risk management was launched earlier this year.   This comprehensive best practice document has also become the legal benchmark.  Canada is not immune to this moral and legal due diligence.  Complying to this standard does not need to be complicated.

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STEP 1: Water Safety Team

To comply with ASHRAE Standard 188, the building owner or designee must first form a Water Safety Team.   This team will be responsible for managing the compliance process now and throughout the building life.

STEP 2: Water System Flow Diagram

The team’s first responsibility is to create a Water System Flow Diagram.  This diagram is intended to highlight all the water processing steps in the building, where water changes physical and or chemical properties.

STEP 3: Risk Management Plan

Next, the team is required to prepare a Risk Management Plan.  The goal of this document is to identify all critical “Control Locations”, the monitoring procedures or “Control Measures” for each of those locations, and the appropriate “Control Limits” – as well as pre-planned corrective actions in the event the system drifts outside the pre-defined “Control Limits”.

STEP 4: Verification

The next steps are to ensure the plan is executed.  The verification and validation steps have been confused in the past.   The verification is the act of confirming the plan is being implemented as designed.  It can simply be a check list confirming the control measures are being monitored as planned.

STEP 5: Validation

The validation is the confirmation that the plan is achieving its intended goal.  Is the site minimizing the health risk?   This can be done by disease surveillance.  It can also be done by periodic Legionella sampling by culture.  It is up to the team to define the appropriate validation method.  The Standard does discuss best practices if sampling by culture is used as a method.

STEP 6: Documentation

Finally, the team is required to maintain documentation to verify that the plan is being properly implemented and to validate that the plan is achieving its disease risk reduction goal.  Part of this documentation management process may be revisions to the flow diagram or plan as changes occur in the facility.
Patrick Racine, P.Eng.
Patrick Racine has a Mechanical Engineering degree from McGill University. As General Manager, Patrick is responsible for overseeing operation of all districts and ensuring overall customer satisfaction. He is a recognized public speaker on topics of controls, pre-treatment solutions and Legionella prevention. Patrick has a passion for open water swimming and has swam Lake Michigan, Lake Ontario and many inland lakes in Michigan, Indiana, Ontario and Quebec. His goal is to swim all 5 Great Lakes and an ocean swim!

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