Legionella Control Policy vs Water Management Plans

We are often asked to review, audit, improve upon, or otherwise comment on Water Management Plans (WMP’s) consisting of no more than a few pages of boilerplate text which, in reality, are actually NOT Water Management ‘Plans’ at all.  Rather, they are simply Legionella control policies.

So, what’s the difference between a “Policy” and a “Plan”?

Policy (always a noun):  a course, principles, rules, guidelines, etc., proposed or formulated by an organization, government, business, or individual, typically published or promulgated throughout the organization, in order to direct organizational behavior towards (or away from) a particular goal, objective, or condition. 

Plan (both a noun and a verb):  a detailed written account of intended present and future courses of action aimed at achieving specific goals or objectives, or controlling conditions within predetermined parameters, in order to achieve a desired outcome.  Plans include the processes, procedures, and action-steps (verbs) needed to carry out the plan.  It includes contingency plans for emergency situations (e.g., boil water advisories, brown water complaints, pressure losses, interruptions of service, outbreaks, etc.)  In water safety, we call these action-steps:  Control Measures.

The biggest difference between Legionella policies, versus actual water management plans is:  policies typically lack the site-specific control measures found within genuine plans, which are vitally essential in order to help mitigate any specific building or system risks uncovered during a comprehensive on-site physical survey.

“How do I know if what I have is a comprehensive WMP or simply a policy document?”

Here are a few tell-tale signs indicating a “WMP” may not be a plan at all; it might only be just a policy document:

• The document was created from the top-down instead of the bottom-up.  Nobody came in and physically assessed your onsite risk in person.
• If the WMP was created using a “cookie-cutter” document or system wherein all you were required to do was fill in the blanks.
• The plan fails to specifically identify persons responsible for program development and implementation.
• Lack of flow diagrams and/or explanations of potable and non-potable systems present.
• Lack of Hazard Analysis / Risk Assessment specific to the building/site.
• The plan fails to address the quality and disinfection methodology of the water entering the premises.
• Control measures are deficient for the onsite hazards previously identified.
• Control measures lack citation of scientific, evidence-based, or geographically relevant reference sources.
• Missing corrective actions for when a control limit falls out of predetermined ranges.
• Deficient communication, outbreak, and/or contingency response plans.
• If environmental sampling is being utilized to validated WMP effectiveness, the sampling strategy falls short in providing an adequate number of representative samples, from enough locations/systems, with sufficient frequency & repeatability, in order to be meaningful.
• Response protocol action levels are quantitative and not qualitative.
• WMP lacks methods to document routine performance of items such as quarterly team meetings, WMP training, annual physical resurveys, plan updates, etc.
• The plan lacks the means to confirm or verify that it is being implemented, with performance of sufficient control measure frequency and corrective actions, as designed to mitigate onsite risks.
• The WMP fails to take into account requirements or restrictions of the local AHJ (Authority Having Jurisdiction.

For assistance in controlling your buildings water borne pathogen risks, WMPs, Sampling Plans, Risk Assessments, accredited third-party lab sampling, audits, supplemental and emergency disinfections, consultations, or any questions, contact your Chem-Aqua Water Risk Management Service Group today!

Written by:  Dominick Tuzzo