Healthcare Hygiene magazine October 2019 | Page 14
infection prevention
By Sylvia Garcia, MBA, RN, CIC
Legionella: Recognizing the Risk
and the Resources
E
very day, patients are at risk because healthcare facilities
are not aware of hazards related to water systems and
equipment that uses water, or they have not prioritized it as
an important issue. It is estimated by the Centers for Disease
Control and Prevention (CDC) that 9 out of 10 infections
acquired in a healthcare setting could have been prevented if
the facility had initiated a better water management system. 1
Shockingly, 1 in 4 patients who develop healthcare-as-
sociated Legionnaires’ disease will die, compared to 1 in 10
that will die from community-acquired pneumonia. 2 Even
more surprising is the fact that at least 80 percent of the
Legionella cases that occur in healthcare facilities could
have been prevented by implementing an effective water
management program.
The most common sources of Legionella cases are show-
ers, cooling towers, decorative fountains, and hot tubs but
anything that can create droplets or aerosols could become a
source. For example, putting tap water into a room humidifier
could lead to infection. About half of Legionella outbreaks
are linked to incidences associated with human error, such
as a healthcare professional not following instructions for
use of equipment.
Although Legionella is highly publicized, it is not the only
risk related to healthcare water systems. At the Association
for Professionals in Infection Control and Epidemiology (APIC)
2019 Conference, researchers reported that 22 percent of
consultations conducted by the Division of Healthcare Quality
Promotion (DHQP) 3 were water-related.
Causes of patient infections were identified as preventable,
had the healthcare organization properly utilized available
information and followed procedures communicating the
need for the organization to implement an effective water
management plan. For example, use of consumer-grade
humidifiers in an operating room was linked to an outbreak of
nontuberculous mycobacteria. Yet, the 2003 CDC Guidelines
for Environmental Infection Control in Health Care Facilities
clearly state that this this type of humidifier has been linked
to Legionella outbreaks.
As with other infection prevention and control challenges,
organizations need to follow a standardized approach to
reducing risk related to waterborne disease.
➊ Regulatory Requirements. Organizations should know
their state’s regulatory requirements. Sources include health
department and building code requirement documents. New
York has enacted state regulations that require hospitals and
residential healthcare facilities to perform environmental
assessments, implement sampling and management plans
to sample their potable water systems for Legionella and
institute control measures in the event of a Legionella
exceedance. New York also requires cooling towers to be
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registered and monitored for Legionella. All states provide
or employ healthcare-associated infection liaisons to direct
healthcare workers to relevant information.
It is also important to understand state reporting require-
ments for Legionella and to identify known or suspected
outbreaks caused by waterborne pathogens. To meet these
requirements, facilities must implement a system to identify
and evaluate possible cases. A laboratory finding is usually
the first step in identifying a possible case. However, the
infection preventionist or other knowledgeable person is
also needed to apply generally accepted case definitions or
create a case definition in the outbreak setting.
State building codes vary, but many states have adopted
a version of the Facilities Guideline Institute (FGI). Or-
ganizations can gain access to relevant building codes or,
depending on the year, can access the information directly
via FGI’s read-only access. For example, FGI 2014 and
2018 state “provisions based on a risk-assessment plan
shall be included in the heated potable water system to
limit the amount of Legionella bacteria and opportunistic
waterborne pathogens.” For the same reason, unsealed,
indoor decorative fountains are prohibited in these versions.
FGI also provides excellent references — including CDC
Guidelines for Environmental Infection Control in Health Care
Facilities, American National Standards/American Society
of Heating, Refrigerating and Air-Conditioning Engineers
Standard 188: Legionellosis: Risk Management for Building
Water Systems, American Society of Heating, Refrigerating
and Air-Conditioning Engineers Guideline 12: Minimizing
the Risk of Legionellosis Associated with Building Water
Systems and the American Society of Plumbing Engineer’s
Legionella Control in Health Care.
➋ Centers for Medicare and Medicaid Requirements.
In July 2018, CMS updated its requirement to reduce
Legionella risk in healthcare facility water systems to
prevent cases and outbreaks of Legionnaires’ disease. The
updated requirement makes certain that Medicare-certified
hospitals, critical-access hospitals and long-term care facil-
ities develop, implement and monitor the effectiveness of
water-management programs to protect patients, visitors
and staff from exposure to waterborne pathogens, including
Legionella pneumophila.
This article (with references) continues online; visit
https://www.healthcarehygienemagazine.com/infection-
prevention/
Sylvia Garcia, MBA, RN, CIC, is director of infection
prevention and control in the Division of Healthcare Im-
provement at the Joint Commission.
october 2019 • www.healthcarehygienemagazine.com