At the beginning and throughout the COVID-19 pandemic, many buildings remained dormant as we attempted to slow the spread of the virus. At the same time, the water and water-sources feeding those buildings were also unused, resulting in old, stagnant water within those buildings. Sudden closures of occupied facilities as a result of pandemic response efforts meant that building systems that were once constantly occupied were now dormant and unused. The combination of building closure and water stagnation provided the perfect conditions for bacteria to survive and thrive. Allowing these human pathogens to survive and grow within water systems can have negative consequences for facilities and subsequently on the people occupying those buildings.
Because of the delicate balance within building drinking water systems, sudden interruptions of these systems can provide the opportunity for bacteria and other human pathogens to grow. Stagnant water can result in the depletion of disinfectants (e.g., chlorine), and the water sources within a building (e.g., sinks) are transformed into exposure points for waterborne pathogens that impact human health. One such organism that has been identified is Legionella bacteria, and cases of Legionnaires disease have been on the rise - even with disease incidence underreporting - since 2000.
Legionnaires Outbreaks and More Could Come
There have been recent reports of Legionnaires’ disease outbreaks from building impacts as well as the detection of Legionella bacteria in public facilities. A recent nursing home outbreak resulted in a resident death, a common occurrence when a building has legionella growing within facility water (i.e., plumbing) systems. The Legionella bacteria was identified at a New York housing complex. Legionnaires disease outbreaks can be widespread, like the recent one in New Jersey that infected individuals across two counties.
The issues with facility water systems and the attention these systems need are becoming more widely recognized, especially when highlighted by the complexities of closing buildings. This further exemplifies the issue that can present from waterborne pathogens in buildings.
GSA Water Testing In Leased Spaces
To that end, the recent effort by the United States General Services Administration (GSA) aims to address the safety of drinking water within facility water systems. In recent years, GSA has recognized the impacts of building vacancy on water quality. These impacts, coupled with increases in incidence of Legionnaires disease, have led GSA to take a more proactive approach to managing water quality within owned and leased facilities. These proactive approaches have already been successful in identifying one GSA facility that had elevated levels of Legionella bacteria within the plumbing system. Legionella impacts on facility occupants - especially those that are at high risk - could be tragic if not addressed in a timely manner.
As part of their initiative to maintain high quality water within GSA facilities, the agency has issued testing requirements to establish safe water conditions within GSA facilities (both owned and leased). Baseline water testing as required by GSA will have to be completed by the end of fiscal year 2024 and includes testing for Legionella, total coliforms (including e. coli), lead, and copper. A checklist for required testing, along with action limits, is available on the GSA website.
Following baseline assessment, annual compliance for the identified contaminants will be required. The baseline testing requirements are for owned facilities that are greater than 1,000 square feet and most leased facilities; there are a few notable exceptions within the requirements (e.g., child care centers). The agency includes examples of those types of professionals that have specific knowledge and experience in relevant fields for testing water of this type, including industrial hygienists with preference for certified industrial hygienists (CIH).
Noble Water Management Efforts with Room to Grow
While the effort by GSA is noble, there are some interesting quirks required by the agency. For example, testing requirements state that samples are to be collected from fixtures that are "primarily designed for human consumption". While this may be applicable to total coliforms, lead, and copper, applying the standard to Legionella bacteria may lead to a false sense of accomplishment when performing these tests. GSA supplies examples of these types of outlets, such as drinking fountains, bottle fillers, and kitchenettes. They also supply examples of common in tenant showers as potential sampling points. Interestingly, bathroom sinks and water lines to the tenant's own equipment (e.g., refrigerators) do not require testing per the requirement. Based on what is known about where Legionella can grow, these areas are locations that actually should be tested. Excluding some of these areas can bias the testing methodology because the focus is on human consumption rather than inhalation, the primary exposure route for Legionella bacteria. Another interesting aspect is that GSA requires testing of common areas where tenants and visitors would have reasonable access and expectation for use. Additionally, the requirements required only first draw samples, again potentially missing locations within water systems where Legionella can grow.
GSA Taking the Lead in Addressing Water Quality
GSA is taking a big leap forward by requiring the testing of water within their occupied facilities. It is an effort that needs to be taken by facility owners and/or operators because of the issues that were highlighted by the COVID-19 pandemic. Reducing the occupant load on the buildings subsequently resulted in water stagnation within those facilities, ultimately leading to the opportunity for human pathogenic organisms to thrive. This step by GSA is an attempt to understand current water conditions within the facilities and to identify when human health hazardous conditions exist. However, focusing on the human consumption aspect of water testing may overlook potential exposure points for Legionella and subsequent Legionnaires disease cases or outbreaks, based on the fact that we know where these organisms like to grow. Hopefully, after baseline assessments, there will be re-evaluation by GSA to move forward with an understanding that additional exposure source points within facilities exist and should be captured by the testing for a true representation of potential human exposures to legionella bacteria.
Water Testing Expertise
If you are a GSA-owned or leased facility, our experienced certified industrial hygienist and team has the relevant experience necessary to assess facility water quality. Please reach for a free consultation with our team to help satisfy the baseline GSA requirements.