Proactive Water Quality: GSA's New Directives and Baseline Testing for Federal Facilities

[00:00:00] You might not realize it, but we are exposed to dozens of hazards every day. Can any of these hazards negatively impact your health? Definitely this is the Exposure Scientist podcast.

[00:00:13] My name is Alex LeBeau and here we answer your questions and concerns on what you may be exposed to every day. Welcome to the Exposure Scientist podcast. The views expressed in this podcast may not be those of the host or management,

[00:00:30] this podcast is for informational purposes only and should not be considered health advice. It is recommended that you consult the Exposure Scientist to discuss the particulars of your exposure scenario. Hello everyone and welcome to today's episode of the Exposure Scientist podcast.

[00:00:45] One thing I have often spoken of on the podcast or in presentations that I have given is the the one from the Industrial Hygiene Perspective or the Exposure Scientist perspective to be in a proactive stance.

[00:00:59] Getting ahead of an issue, talking about the return on investment of getting ahead of an issue instead of playing catch up on that issue I think is imperative. Because so much more can be done when you are ready for an event to happen.

[00:01:15] You can analyze, you can do what we do traditional industrial hygiene roles and anticipate recognized, and evaluate and control a potential hazard.

[00:01:25] And there has been a lot of want to do that, but again a lot of my career has been on the reactive side where we are coming in from a reactive stance and saying,

[00:01:35] OK, we already have an issue, what can we do to either correct it as you understand what the impact of that issue currently is on the facility and the occupants or however, and how are we going to fix it going forward?

[00:01:50] And more often times and not it costs a lot more from the reactive standpoint to get ahead of an issue to get an issue under control and figure out how to manage that issue going forward than it would have been.

[00:02:05] I think it's a great thing to take a proactive approach to the issue. And I like to highlight those instances where I see people taking a proactive stance or a proactive approach and recently one organization has been doing that.

[00:02:20] I think it's a great thing that they have been doing that. So the agency or organization I would like to highlight today is the US General Services Administration or GSA. We have heard about some of the water quality regulations or rules coming out from them, or directives.

[00:02:39] And I want to highlight that, but I want to bring them up because they are in period if they are important what they are doing to kind of take control of water quality and building.

[00:02:54] So again, you kind of a general idea of who GSA is just you know, GSA was founded in 1949 if you're a new R or not aware of GSA.

[00:03:06] They are there to help with procurement in the federal government, purchasing and distribution of supplies to government agencies and maintaining supplies for critical materials. Also, discusses construction of government and maintaining government buildings and maintaining communication systems used by the federal government.

[00:03:26] There at an agency that hasn't been established for a long time and recently, I say recently, this directive came out at the end of last year. And more of a push on the early 2024 is the need for GSA to be committed to water quality.

[00:03:46] And there has again, there is a direct issue at the end of last year. There has been a lot of FAQs and presentations, etc. from GSA discussing water quality and getting ahead of water quality.

[00:04:01] And I want to highlight this because I think it's commendable. Many times there has been issues with, I don't want to say convincing organizations at the end of the have facility water management plans are understand their facility water management.

[00:04:18] But they don't see the importance of it in some instances. You know, with the ASHRAE 188 that came out in 2015 recently, ASHRAE 514 came out.

[00:04:31] ASHRAE 188 was for Legionella, Legionella, Santa Fe, 144 expanded into that to other waterborne pathogens chemicals that are used in water, etc. It's more of a comprehensive view of facility water management than has been

[00:04:50] stated previously in a guidance document. And the fact that GSA is recognizing the importance of water management is commendable. The agency is getting ahead of these issues, I think. You know, they are they have lots of presentations that given you can go out and take a look.

[00:05:14] If you talk about it to look on the internet. But you know, so there's statements and said either they're committed to maintaining water quality in their office. It's pivotal for healthy work environment. I think that's great for them to say safety federal employees, the public and contractors is highest priority for them.

[00:05:32] So, you know, one thing that they're doing is they're enacting some baseline water testing in owned and lease facilities. Certainly a certain own facilities, but many of their lease facilities. So much in fact, they are going back and there's near changing some of the leases to say you have to comply with these guidelines or this directive that we have issued to establish baseline water testing.

[00:05:58] And I think that's great. That's the proactive approach that's needed because again, it's all one of the pivotal things about this is baseline testing. What is going to be done to understand where your systems are right now?

[00:06:12] You know, they've state in their their presentations. There are goals to proactively identify issues and they're just water management practice to correct conditions. They want you get ahead of this. They recognize especially during closures from buildings during COVID-19 that there have been.

[00:06:33] Issues caused by water stagnation within those buildings. So what are some of the. What are some of the things that are being looked at for water management within these facilities because I think that's important to understand. They have criteria.

[00:06:50] They have issued criteria. They have a checklist available on their website. You can easily go to that. I'll try to link it to in the show notes. What they're looking for.

[00:06:59] You know, they're they want to understand what the concentration of lead is what the concentration of copper is.

[00:07:07] They are looking at children, call forms and highlighting equal I in the last again the most near and dear. I'll say to what I have been doing and talking on his legionella. They have a criteria for legionella within their presentations.

[00:07:24] They discuss the increases in legionella's as religion theirs disease over the past number of years they cite CDC information. Within these presentations with I think is commendable now.

[00:07:39] If any of you had a participate or attended at AI J connect this year. AH a connect 20 24 during my talk, which from again and I think I brought this up during the talk.

[00:07:51] My talk, if you witnessed search on the app or search there was the only talk on specifically dedicated to lead you know at the conference.

[00:08:00] I think that I'm hoping to use this GSA information to establish there's more of a proactive approach that we need to get ahead of this. We need to have more conversations at the conferences not less because we have had discussions at conferences in the past with the Legionella presentations.

[00:08:20] But they have diminished over the past few years and again my was the only one of this year's conference. That was dedicated to Legionnaires disease or Legionella. So I want to use this opportunity as a growth at the industrial hygiene level conferences to continue this conversation.

[00:08:37] So if you were not there one of the discussions that I had was under reporting from CDC data on Legionnaires disease and within the GSA information they discuss. There's been a ninefold increase from 2018 and has been on the rise and within that presentation, AI J actually.

[00:08:56] Quantified the under reporting that was going on you've received some averages and some information about information to my blog about the presentation.

[00:09:05] And just how much more Legionnaires disease or likely is just based on under reporting looking at weekly versus cumulative totals. So this effort by GSA is a great proactive attempt to get things done.

[00:09:21] They are taking that you're taking charge they realize that some of their facilities have had problems impacted by stagnation issues.

[00:09:34] They have on one of their presentations they have a list of a number of 15 different visually owned facilities and four least and six of them it looks like have.

[00:09:46] Water stagnation issues because of site closures so it's important to maintain that water quality so what they're looking at is for baseline testing the regular choir least facilities to establish.

[00:10:04] And they're looking at federal owned facilities that are over 1000 square feet with drinking water systems and in their direct to we can go find other websites it's very easy.

[00:10:20] They discuss public water utilities or public water systems and the request responsibilities and requirements of those and what goes on in building water and discusses the portable water systems within these facilities and you know it's important to understand that some of these facilities are.

[00:10:36] Child care centers some of them are healthcare centers so there are some that are all saved not that maybe at a higher risk. So if you look at the healthcare center, you can know that.

[00:10:49] Based on the data there's an increased chance of getting an infection of the Legion area, Legionella and a couple of Legioners is if you're already hospitalized so depending on the type of facility it may be even the higher risk.

[00:11:04] As compared to other facilities so it's important to understand that there's there's a lot that is going into this effort by GSA to increase the proactive approach addressing water systems and I think.

[00:11:21] Again, I think it's a great effort from what they're doing you know within some fact sheets and FAQs and everything they're referencing ash ray standards 188.5 14 they're talking about guideline 12 talking about CDC.

[00:11:37] Legionella tool kit. There's a lot of good information here and I think it's information in other facility owners should consider when you're doing this and know them and you're saying well does my facility need.

[00:11:54] Testing this need to have this baseline kind of understanding and the answer is yes all facilities need again as I discussed before your water quality is only as good as to what comes into the meter you know the public water utility will say well we give enough to get you to the meter after that you know we don't have anything to do with a water than the water within your facility.

[00:12:16] Is under your control and safety of it is under your control exposure to individuals within your facilities under your control so this proactive approach by them. Is great even on their FAQs you know there's there's specific ways listen you know if you have a positive.

[00:12:36] There are things that have to be done they have to be if there any else it exceeds is of any of their thresholds and they have thresholds that are established for lead.

[00:12:45] Copper total call forms and Legionella the there have to be timely notifications to those facilities so they can get ahead and address the water quality issues that's all laid out from GSA it's a well I think well thought out document.

[00:13:04] For what has to go on now the important part here I'll say the important part is important for us to recommend or remember is industrial hygienists. We have the expertise here we are the ones who.

[00:13:19] With indoor environmental quality expertise who can understand building water systems are building systems and how they impact those at the occupants of the facility.

[00:13:26] It talks about what are their requirements for people who are doing this testing there are things that you know they mentioned within the document itself industrial hygiene. Reach out to us info at exposureconsulting.com for a free 15 minute consultation to discuss the specifics of your exposure scenario.

[00:14:12] Exposure science covers a broad subject area including tax ecology and industrial hygiene and risk assessment from occupational community or environmental exposure exposure scientists apply scientific methodologies to understand exposure risks in applied controls when necessary. We at exposure assessment consulting have this expertise.

[00:14:33] Please reach out to us info at exposureconsulting.com for a free 15 minute consultation to discuss the specifics of your exposure scenario. An industrial hygienist somebody who has experienced you know certain minimum number of years. Talking about engineering consulting firms one of the things is a preferential certification.

[00:15:03] So it's important to recognize again that we are in this conversation and many people may not remember. I don't think it's included in the version two but the version one.

[00:15:13] Document from CDC the Legion of the toolkit it highlighted and talked about who is part of the water management team. It's certified industrial hygienists. We continue to be part of the conversation for Legionella and water management because we have the knowledge and expertise within that area.

[00:15:31] So it's important to highlight that we see IHS know how to address these issues, know how to sample know how to understand where deficiencies are reporting the results. Understand the importance of reporting results and having a remediation or addressing these problems.

[00:15:49] Again, one thing we've done at AIA is that we have a technical framework for Legionella when you're addressing when you're a technician in the field when you're a responder professional or program professional.

[00:16:04] We know how to address these problems and I think GSA recognizes that we know how to address the problems here and can do so professionally. Again, it's a is a great effort by GSA now I think there are some areas in room for improvement within the GSA guidelines.

[00:16:27] They talked about areas that are going to be sampled and very much focuses on outlets primarily designed for human consumption. I think that may be missing a few things now we're talking if you're talking about to call forms or lead in copper.

[00:16:45] I think that's that's the ingestion route is going to be the primary route that you're going to be concerned with. They mentioned areas where people typically drink water, water filling stations, caching sinks, drinking mountains etc.

[00:17:00] Now it's I think it's another important to recognize that the main ground of exposure to Legionella is through arosalization of water inhalation of that. Arosalized water droplet containing Legionella. So it says areas that are not required for testing.

[00:17:24] It does include bathroom sinks, doesn't include water lines to tenant own equipment and then it gives the example of refrigerator.

[00:17:33] I've seen it detections of Legionella and refrigerator water lines I know we've seen them in bathroom sinks they have air raiders typically on those now there's some discussion of.

[00:17:43] Removal of those air raiders in those types of sinks but there's still exposure points and I think that's important to remember that there is I think room to grow here. On what is necessary for sampling.

[00:18:02] And is it possible that some may be missed it's it is possible that there are some areas that may not get the attention that they deserve I think it's interesting one other area of the direct of its myth.

[00:18:14] I think it's interesting to remember that there are some areas that are common areas to guests who make your customers who may come into the building.

[00:18:32] And how to maybe sample those areas as well you know there are minimal numbers of samples that are to be collected or typical numbers of samples to be collected I think that's important as well is that.

[00:18:55] Remember and with the documents it says there's not a one size fits all.

[00:19:01] Each facility is unique and different and I think that's important to remember because there may be a large number of potential exposure points within a one building versus one another building who may only have one.

[00:19:17] And we can also see that there are a lot of other areas that are very fast and fast. So we can see that there is a lot of data in the background, one kitchen.

[00:19:28] So it may not be possible to get all the samples that they would like to see in there so I think that's important also right now is with anything else there's not a one size fits all model each scenario is different in the unique and you have to look at the unique this in that scenario and how it's within the sampling paradigm.

[00:19:44] And in the early early own facilities and talking about. Other occupancy issues is you know maintaining or or a guideline or how are you going to maintain a restore water quality let's just say something happens.

[00:20:02] Has issues that causes issues with the so the how are you going to do that there's an implementation discussion in buildings over 50,000 square feet with one or more booster pumps.

[00:20:16] And buildings over six stories and heights so there's other nuances to the regulation I highly as I say regulation to the.

[00:20:28] The directive I think it is is useful for you to review that information review the FAQs information is put out for the guideline but it's a it's a great step forward by GSA recognizing this thinking about all these types of facilities it may be even the facilities of their lease facilities.

[00:20:49] It may even be where a lease facility who has never even thought of testing for Legionella gets his notification from GSA says, huh maybe I should do this for my entire facility.

[00:21:03] I may not even heard about the problem. I you know, I don't think that there has been a great effort by organizations focusing on. Facilities and building owners to get the word out about the requirements or get the word out about the hazards that exist from water.

[00:21:24] Born pathogens and exposure to those with the facilities and this may be an initiating event for a number different building owners across the United States and say well if GSA is concerned about it for there.

[00:21:37] Who East office area or their lease space maybe this is something I should do building wide. And if that is the case I think that's great because then those people will be hungry for more information and again is industrial hygienists we can step in.

[00:21:52] And give them the information they need feed their hunger give them the direction and guidance to be proactive instead of react because again the discussion from our presentation a IHA and the discussion for CDC the Legionella numbers are going to go up.

[00:22:07] There's a small dip during COVID there are lots of caveats given by CDC talked about there is under reporting or lack of reporting for certain states and coincided with COVID-19.

[00:22:21] Legionella cases are continuing to rise and are going to do so we see in the data and it's important that we are getting ahead of this this is just GSA effort is just one part in that.

[00:22:32] I think it's good for us as industrial hygienists to use this you know it may be these lease these owners and operators buildings see this requirement from GSA say maybe I need to test my building.

[00:22:45] Maybe this is an approach to go talk to those management companies or owners of operators and say look and listen GSA is doing it this facility they're concerned do you have any concerns I can answer questions and help you out with it help address and help you understand.

[00:22:59] I think we need to take that lead.

[00:23:01] I think this is a great act by GSA I think there is some room for improvement I think that this baseline testing is going to help answer some questions I think it's going to create others and I think was in recent industrial hygienists should be there to help answer those questions to help guide.

[00:23:20] Especially those of us with experience in this area help guide those individuals on where we should go again. It's a great effort by GSA is it's awesome to see I'm a.

[00:23:32] Great seat implemented so many presentations and discussions on that from GSA of why it's necessary and I think this is a big step forward. I'm hoping others are going to take big steps as well.

[00:23:43] I appreciate you joining us on today's episode the exposure scientist podcast hopefully I gave you some information that's going to create some discussions I hope we will have some more information on some additional GSA details and topics but this is this is a great start this is a great place to be as far as expanding.

[00:24:01] Where we are from a management side of water quality with facilities. Thank you so much for joining us today I appreciate it.