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The Fountains of Youth and Water Management Programs

As a follow to last week’s item about water management programs, I know a lot of folks are not using their drinking fountains (or as we know them in the Boston areas, bubblers—pronounced “bubblahs”—I was hoping to find an audio link, but if you doubt the veracity of that pronunciation, this sort of backs it up). How are you managing those as a function of your water management program?  I’ve seen a lot of these devices sitting idle (and not just in healthcare) and looks like they may be sitting that way for a while. Are you periodically having someone go around to operate them or have you modified other practices to keep an eye on these? Not quite sure why it took me so long to think about this—perhaps it’s the ever-growing drinking fountains covered in plastic. The other question I had in this regard is whether any of you are using this as an opportunity to remove them completely? Depending on the design of your building, these are sometimes placed in a way that reduces the clear width of an egress pathway or two. This might be the best opportunity evah to get rid of them.

Of course, the other dynamic that comes into play (though perhaps less in healthcare than in other industries) is the whole notion of how to manage facilities that are experiencing reduced utilization. Perhaps you have a business office or the equivalent, and you have folks working remotely or some other variation on the theme of forced vacancy. If that’s the case (or could become the case if COVID persists), then you might find the following information worth checking. Fortunately, resources continue to provide guidance in this regard and I don’t think there’s anyone among us that would wish to endure a breakout of waterborne pathogens in the midst of the current climate.

Check out the following resources:

Hope all is well and you folks are staying safe. See you next time!

Madman Across the Water Management Program

This week brings us something of an unexpected development in the management of the physical environment as our friends in Chicago are seeking comments on a proposed standards revision that more clearly indicates the required elements for water management programs. I don’t know that I was expecting this change, though I suppose it falls under the “one outbreak is one too many” category, nor was I expecting the solicitation of commentary from the field (I look forward to seeing the results of the comment period). It would seem that the proposed performance element is based very closely on the CDC recommendations, which clearly take into consideration the guidance from ASHRAE 188 Legionellosis: Risk Management for Building Water Systems and ASHRAE 12 Managing the Risk of Legionellosis Associated with Building Water Systems, so it doesn’t appear that we’re breaking new ground here.

Additionally, we know from past discussions that CMS has been pretty focused on the risks associated with building water systems (most recently, here, but there are others), so this may be a case of ensuring that everyone is paying attention to the areas of (presumably) greatest risk. And, as near as I can tell, none of the existing COVID-related blanket waivers exempts folks from managing the risks associated with building water systems, so hopefully you’ve been staying with your identified frequencies for testing, etc. And if you haven’t, you probably should be identifying a game plan for ensuring that those risks are being appropriately managed.

Clearly, there’s a little time before these “changes” go into effect (the comment period ends November 16, 2020), but since this is pretty much what CMS has been looking for since 2017 or so, you want to have a solid foundation of compliance moving forward. I recognize with everything else going on at the moment, this might not be a priority, but this is one of those concerns in which proactivity will keep you out of compliance jail.

Until next time, hope you are all well and staying safe!