There are numerous cases of Legionnaire’s disease reported in Missouri each year, and the frequency of those reports is increasing. The Section for Long-Term Care Regulation (SLCR) has had several resident cases of possible and confirmed legionella infections in long-term care facilities over the past couple of months. As a partner in protecting the health of the public, please read the letter from DHSS Director, Dr. Randall Williams.
CMS guidance
On June 02, 2017, CMS issued a memo titled Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease. www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-17-30.pdf
As part of the recertification survey process, SLCR surveyors are required to review and ask homes about their legionella risk assessment, water management programs, and testing. Specifically, surveyors will review policies, procedures, and reports documenting water management implementation results to verify that facilities:
- Conduct a facility risk assessment to identify where Legionella and other opportunistic waterborne pathogens could grow and spread in the facility water system.
- Implement a water management program that considers the ASHRAE industry standard and the CDC toolkit, and includes control measures such as physical controls, temperature management, disinfectant level control, visual inspections, and environmental testing for pathogens.
- Specify testing protocols and acceptable ranges for control measures, and document the results of testing and corrective actions taken when control limits are not maintained.
- Maintain compliance with other applicable Federal, State and local requirements.
Did you know?
- Although most people exposed do not develop illness, approximately 25 percent of Legionnaires’ disease reported healthcare-associate cases are fatal.
- The optimal growth temperature for Legionella bacteria is between 77 degrees and 108 degrees. Facilities should make efforts to keep water storage and delivery vessels temperatures out of the optimal Legionella bacteria growth range.
- Examples of building water systems that might grow and spread Legionella include: hot tubs, hot water tanks and heaters, large plumbing systems, cooling towers, and decorative fountains.
Water Management Programs
Adhering to an appropriate water management plan is critical for the successful control of Legionella bacteria in a health care setting. Developing and maintaining a water management program is a multi-step process that must be tailored specific to the facility and should be reflective of what the facility is actively doing. Below are seven steps to building an effective Legionella water management program.
- Establish a water management program team
- Describe the building water systems using flow diagrams and a written description
- Identify areas where Legionella could grow and spread
- Decide where you need to apply control measures and how to monitor them
- Establish ways to intervene when control limits are not met
- Make sure the program is running as designed and is effective
- Document and communicate all activities
Source: www.cdc.gov/legionella/wmp/overview/wmp-fact-sheet.html.
The CDC’s website also provides a list of factors to consider when looking to hire a Legionella consultant: www.cdc.gov/legionella/wmp/consultant-considerations.html.
FREE Online Training
The Centers for Disease Control and Prevention recently launched a free online training program on Legionella water management programs called PreventLD. This training would be helpful for any staff member at a Long Term Care Facility who would be responsible for implementing a Water Management Plan. Details and the link to register are available here: www.cdc.gov/nceh/ehs/elearn/prevent-LD-training.html.