Complying with the Joint Commission's New Water Management Standards

Healthcare facilities continue to face budget and manpower reductions with increased regulations. Kurita America can help with our harmonized programs designed to reduce the time required to manage water treatment programs while enhancing system efficiency and reliability. This includes Legionella risk management support, advanced filtration equipment programs, secondary disinfection, electronic monitoring and record keeping, and on-staff experts familiar with the developing standards to manage waterborne pathogens and minimize the risk of an incident.

Under close study for years, utility water systems are now required to monitor waterborne pathogen transmissions in healthcare environments, such waterborne pathogens as Legionella (Legionnaires’ disease), Pseudomonas, Non-Tuberculous Mycobacteria, and others. Under the EC.02.05.01 Joint Commission standard of 2001, HVAC systems-- which include open evaporative cooling towers for process cooling, evaporative condensers, closed loop and once-through systems—the EC.02.05.02, (EPs 1-4) standard update includes several new significant risk areas and incorporates new document requirements that will likely require increased facility resources for compliance.

After being approved by the Centers of Medicare and Medicaid Services (CMS) in January 2021, the update beginning in January 2022 will have the Joint Commission require accredited hospitals and long-term healthcare facilities to create and maintain a water management plan to address Legionella and other waterborne pathogens. For Kurita America, helping customers understand the hazards involved is the first step in creating actionable programs that mitigate these risks. A water management program will be supported through our united approach, which can include chemical treatment options, equipment, engineering, and service.

The updated Joint Commission standards can be effectively implemented using a third-party consulting firm or developed in-house by using the ASHRAE 188 standard. The ASHRAE standard is considered the authoritative guide for minimizing the risk of Legionella. With the updated Joint Commission standard, the water management plan is now considered a “living document,” which is to be updated regularly and referenced whenever a nosocomial infection is identified. The new living document should include monitoring protocols and acceptable ranges for control measures, such as water temperatures, pH, disinfection residuals, and a document out of limit conditions and corrective actions. Kurita America provides multiple options for packaged equipment and solutions with an on-line control system for 24-hour remote monitoring and accessibility via cloud-based Industrial Internet of Things (IIoT) capabilities.

Kurita America offers analytical services for water testing and Legionella culturing to name a few. Paired with the Lumyn™ system, users are notified through app or email notification of circumstances requiring attention. Conditions are also automatically reviewed with exception reporting and graphical dashboards within the Lumyn app or website. Features, such as seasonal operation or downtime management, eliminate nuisance notifications and allow you to prioritize your time and effort on the applications that require it.

While the updated EC.02.05.02 does not specifically require Legionella or other waterborne pathogen testing (unless required by a local or state mandate), testing regularly for Legionella can be an integral component in a water management plan; unfortunately, there has been little federal or state regulatory guidance. From a risk management standpoint, Legionella culturing should be considered if the facility has old piping, irregular water temperature distribution, stagnant or low flow water conditions, and low disinfectant residuals. Some facilities may rely solely on the water management platform with control limits to monitor and correct actions. Other facilities may decide to actively culture Legionella and other waterborne pathogens and react to results.  

Water management teams will often have outside contractors and third-party vendors as part of the support group to the water management program. Vendors with detailed knowledge of plumbing design and water treatment disinfection chemistry can be valuable, both in the planning stages and ongoing management support of the program. Kurita America’s engineering services have licensed Professional Engineers (PEs), Certified Water Technologists (CWTs) and experience involving design, implementation, and programming of equipment to deliver optimal results to a facility’s unique needs.

As your water treatment experts, Kurita America can assist in several of new requirements of the EC.02.05.02 update, specifically our integrated approach that incorporates treatment chemistry, disinfection protocols, water treatment equipment and automation, inspection services, remote monitoring, and cooling tower cleaning services.

Whether your facility has a current disinfection strategy or is looking to have an improved Legionella management program, Kurita America has comprehensive treatment packages that will help your facility stay in regulatory compliance, overall lower cost of ownership, and conserve natural resources for a better, more sustainable world.

For more information, visit or call 866-663-7633.

About the Author
Paul Sharpe is an industry consultant at Kurita America, specializing in boiler and cooling water. Paul has over 30 years of water treatment experience, including chemical treatment formulations, sales, marketing, and technical product applications.


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