Title: Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems
The aim of this lecture is to provide attendees information about the existing standards, guidelines and regulations. The presentation will also focus on the efforts being made by the regulating agencies having jurisdiction and industry and professional associations working to develop standards to establish minimum requirements for supplemental disinfectants application.
Alberto Comazzi, PhD
Awareness of Legionella and Legionaries’ disease by the public and the media has increased more in the last two years than in the previous two decades. One of the reasons this is happening is that, as reported by the Center for Diseases Control (CDC), the number of reported Legionaries’ diseases cases have increased by a 4x factor in the last ten years.
Despite the fact Legionellosis is a well know diseases and it’s very clear how the infection can be contracted, there is not a universal technique that ensures a 100% efficacy on the disease prevention.
The first step buildings owners and managers shall take is to establish a water management team and develop a water management plan. Various industry associations and organizations (NSF, ASHRAE, ASDWA, AIHA) are developing standards and guidelines to assist facilities in developing water safety plans and implementing remediation technologies.
There are several technologies that are available, including non-residual techniques (UV and ozone) and methods that are able to establish a chemical residual in the building water system, also know as “supplemental disinfectant” (chlorine, monochloramine, chlorine dioxide, ionization). Among all the methods here reported only chlorine, monochloramine and chlorine dioxide are listed as disinfectants under the EPA-Safe Drinking Water Act.
Despite there are several disinfection options and technologies that a facility owner/manager can implement in the building, there is no uniformity on the requirements that a disinfectant/technology has to fulfill in order to be permitted by the agency that has jurisdiction.
The only federal regulation that applies to the whole country is the National Primary Drinking Water Regulations (40 CFR 141). The regulation applies to community water systems and non-transient non-community systems. The definition of non-transient non-community systems (NTNCWS) is “A public water system that regularly supplies water to at least 25 of the same people at least six months per year”. It is easy to understand that buildings such as hospitals, nursing homes, hotels, condominiums and dormitories all fall under this category.
This definition puts the building owners/managers in a difficult position because the addition of a disinfectant (treatment) to drinking water subjects the facility to the same requirements of a public water supply. The States are responsible for the enforcement of this rule, but the regulating agency having primacy may vary on a State by State basis (DOH, EPA, and DEP). The requirements can vary in each State, for example Florida requires a permit only for cold water applications whereas New Jersey doesn’t require a permit at all. This inconsistency confuses the owners and managers and often makes them feel that they are the only ones that are going to have to deal with this serious public health matter.
The purpose of this presentation is to educate the audience on the state of the art about the existing regulations, standards, guidelines and permitting requirements and the efforts that should be made by the regulatory agencies in order to get a consensus and minimum requirements when a supplemental disinfection system is in installed.
Dr. Alberto Comazzi earned a PhD in Industrial Chemistry from the University of Milan. His research during his academic experience was focused on the study of the stability and the interaction among different chlorine based water disinfectants. Alberto is a member of the ASHRAE SSPC 188 committee.
Dr. Comazzi currently works as Technical Director in Sanipur US, based in Philadelphia PA. Sanipur US distributes and provides technical support for the production and application of supplemental disinfectants for Legionella remediation in building utility water systems.