Greg Swafford, CPD, GPD, is technical, sales manager for GF Piping Systems. Swafford can be reached at [email protected].
The number of Legionnaires’ disease cases reported to the U.S. Centers for Disease and Control Prevention (CDC) has been on the rise for two decades. As the number of cases continue to rise, so does the need to manage the risks associated with premise plumbing systems.
In recent years, there has been an increase in Legionella awareness as multiple stakeholders have entered the conversation — government organizations, water utilities, health professionals, local jurisdictions, model code bodies, industry organizations, manufacturers, engineers, academic scholars, Legionella consultants, water treatment professionals, etc. These stakeholders hold conferences, attend seminars, create standards, develop guidelines, establish best practices, write research papers, manufacture products and introduce model code changes.
Through the individual efforts of stakeholders enough is known about the bacteria and its transmission to successfully control growth in premise plumbing systems; however, with the continued rise in reported cases, it is obvious that a comprehensive implementation of control strategies involving multiple stakeholders is necessary.
Most of the resources and standards available focus solely on water management plans and actions by facility operations staff. While this is certainly a critical component to managing risks, it overlooks the tremendous impact that comprehensive plumbing design can make in supporting key water management principles. Design professionals are essential to managing risks. Before diving into how to manage risks in system design, it is important to understand trends affecting premise plumbing safety.
A Perfect Storm
The U.S. is experiencing a perfect storm scenario. Both internal and external factors are contributing to the increase of Legionnaires’ disease cases.
- Aging water service infrastructure. Each year approximately 240,000 water main breaks occur in the U.S. According to the American Water Works Association (AWWA), repairing and replacing old water pipes could cost more than $1 trillion over the next 20 years. The residual effects of water main breaks include bacterial contamination and bacterial corrosion resulting in a habitat favorable to the proliferation of waterborne pathogens. Until new infrastructure is installed, the U.S. will continue to experience water contamination in municipal water service and premise plumbing systems.
- Wide spread use of low-flow fixtures. Water use has changed drastically since the implementation of the U.S. Energy Policy Act (1992). This policy made the production and sale of low-flow plumbing fixtures necessary to reduce water use. However, industry standard sizing methods for water distribution piping did not change. As a result, potable water service and water distribution systems are grossly oversized, creating an environment conducive for biofilm and bacteria growth.
- Building water systems during COVID-19. Feeding the perfect storm is the extended vacancy and reduced occupancy that buildings are experiencing during the coronavirus pandemic. Re-occupying a building with neglected water systems increases the likelihood of Legionella bacteria transmission.
- Increased lawsuits. With greater understanding of the causes of Legionella, there is an increase in allegations of negligence and liability claims. With a standard of care established in ANSI/ASHRAE Standard 188, just one Legionnaires’ disease claim could cost negligent owners millions of dollars in litigation costs and settlement claims. In the case of the 2015 outbreak at the Quincy, Illinois, Veterans’ Home, families of the victims recently settled with the State of Illinois for nearly $6.4 million.
- Insurance coverage. Insurance companies are fighting their liability for coverage as more lawsuits and claims are brought forward. Some insurers are limiting coverage or imposing higher deductibles if building systems are outdated. Others are asking customers to document how they maintain plumbing and cooling systems. This is leaving building owners exposed to great financial risks. It is important to point out that owners are not the only ones exposed to allegations of negligence or liability claims. Engineers are also exposed to liability given the widespread availability of industry research and recommendations concerning design strategies to control Legionella.
- Many buildings still lack a water management program. According to the CDC, nine out of 10 Legionella outbreaks could be prevented with more effective water management. In June 2017, the Centers for Medicare & Medicaid Services (CMS) released a memo requiring healthcare facilities to develop and adhere to an ANSI/ASHRAE Standard 188 compliant water management program to reduce the risk for Legionella in their water systems. While this requirement was a great first step to improving public health and safety, it should not stop here. Unfortunately, facility types outside of CMS jurisdiction are not required to develop or adhere to a water management program. Without this requirement, it makes implementing proven control strategies into a wide range of building types much more difficult.
- Continuous increases in construction costs. Construction cost have increased more than 5% each year since 2017. Architectural, engineering and construction teams are consistently asked to evaluate options for cost savings. Unfortunately, the unrelenting pressure to cut costs makes effective design concepts and innovative products developed to manage risk constantly vulnerable to elimination from the project design.
Plumbing Design is Essential to Managing Risks
Effectively managing risks associated with building water systems takes a commitment from everyone involved from owners and operators to engineers and contractors. Plumbing engineers play an essential role in creating safe and healthy buildings. In part two of this article, we will review how plumbing engineers can implement fundamental design principles and execute comprehensive strategies to manage risks
- Legionnaires’ Disease is on the Rise in the United States, National Notifiable Diseases Surveillance System
- U.S. insurers eye Legionnaires’ disease safeguards as buildings re-open from pandemic shutdowns, Reuters June 18, 2020.
- Construction Analytics, edzarenski.com
- U.S. EPA
- American Water Works Association (AWWA)
- Centers for Disease and Control Prevention (CDC)