California Considering Requiring Water Management Programs for Legionella bacteria control

California Considering Requiring Water Management Programs for Legionella bacteria control

By Hilary Nardone, Environmental Group Training Manager
Certified ASSE 12080 Legionella Water Safety and Management Specialist

In February 2022, California State Senator Scott Wiener introduced SB1144, a bill focusing on both lead pipe identification and remediation in certain buildings, as well as the implementation of a Water Management Program (WMP) for buildings that have cooling towers.  The bill would add Chapter 20 to Division 7 of the California Water Code.  Since February, the bill has made its way through various committees, including the Committee on Rules, Senate Environmental Quality Committee, Committee on Education, Committee on Appropriations, and the Committee on Environmental Safety and Toxic Materials.  Though the bill has not yet been passed, it is important to understand its potential requirements as it is currently written, to be prepared for what may be soon required. 

Be prepared for California SB1144 by knowing 5 key takeaways:

  1. No later than January 1, 2025, covered buildings that meet at least one of the following two criteria: 1) owned and occupied, or leased, or maintained, and occupied, by a state agency; 2) public-school buildings, to complete a Water Efficiency and Quality Assessment Report (WEQAR) for each covered building.
  2. This report shall include, among other requirements pertaining to lead piping and remediation, a determination if a Water Management Program (WMP) consistent with ASHRAE Standard 188 has been implemented for covered buildings that have cooling towers. The WMP must be implemented at covered buildings with cooling towers no later than one year after the completion of the WEQAR.
  3. The WMP must be completed by a WMP Team that shall include appropriately qualified personnel.
  4. The WMP must include the following:
    1. Schedule for routine bacteriological culture sampling and routine Legionella culture sampling.
    2. Identify conditions or events that require immediate Legionella culture sampling and analysis.
    3. Include Legionella remediation and disinfection plans.
    4. Include start-up safety procedures for stagnant cooling towers that have been shut down without treatment and recirculation for more than five consecutive days.
    5. The WMP must be updated annually, retained for at least three years, and made available upon request.
  5. Local health departments must be notified within 24 hours of receipt of a positive Legionella culture sampling analysis that exceeds 1,000 CFU/mL. The results must also be publicly posted outside the lobby window of the building or other conspicuous place near the primary entrance and clearly visible to the public.

It is important to note that SB1144 has not yet been passed.  If passed, the final law could contain different or varying requirements compared to its current draft.  The bill is scheduled for its next hearing in the California Assembly Appropriations Committee on August 11, 2022.

Barclay Water Management, Inc. can assist you in preparing for SB1144.  Barclay has created, implemented, and validated hundreds of WMPs.  In partnership with our Customers, Barclay is dedicated to ensuring its WMPs comply with national and local standards and guidelines including ASHRAE Standard 188, CDC, Department of Veteran Affairs, and state and local Health Departments.

Contact us today to learn how Barclay can help implement a Water Management Program and Legionella bacteria sampling policy at your facility.

Contact Barclay Water Management, Inc.