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

The Department of Veterans Affairs recently updated its VHA Directive 1061: Prevention of Health Care-Associated Legionella Disease and Scald Injury from Water Systems. Originally released in 2014, this document intended to control healthcare-associated Legionnaires’ disease cases and scalding injuries in Veterans Health Administration (VHA)-owned buildings in which patients, residents, or visitors stay overnight. The updated version of VHA Directive 1061 aims to provide a more robust set of requirements for VHA-owned buildings to minimize their risk of health care-acquired Legionnaires’ disease cases and scalding injuries.

Three major updates to VHA Directive 1061:

1. Expanded Scope and Applicability of the Document:

VHA Directive 1061 now applies not just to VHA-owned buildings in which patients, residents or visitors stay overnight (such as, but not limited to: acute care facilities, Community Living Centers, domiciliaries, Fisher Houses and temporary lodging facilities), but now also to Veterans Affairs-owned buildings where staff are required to sleep overnight as part of their job (such as, but not limited to: fire stations), and to outdoor non-potable, aerosol-generating water systems (such as, but not limited to: cooling towers and irrigation systems). [1]

2. Adds Provisions on Non-Potable Water:

• Each Department of Veterans Affairs medical facility that owns and operates one or more cooling tower systems must ensure that a Cooling Tower Management Plan (CTMP) is developed, and is reviewed, certified, and updated at least annually. The Cooling Tower Management Plan must include: a cooling tower inventory; a systems risk analysis that considers the system design and operation, a water flow analysis, a plan to reduce biological/ organic material and poor water quality, and system maintenance requirements. The CTMP must also include water chemistry and biological testing requirements.
• Each cooling tower must be tested for Legionella bacteria via culture methodology within 7 days of startup and every 90 days during periods when the tower is operational or operational-ready (i.e. cleaned, disinfected, full of water and ready for operation). At a minimum, samples must be collected from each basin/sump and the supply to and return from the chiller(s) (unless the chillers are on a common header, in which case only one sample is quired). At the time of sampling, pH, temperature, and biocide level must also be recorded. Remediation begins at 10 CFU/mL of Legionella bacteria.
• Each cooling tower must be sampled for Heterotrophic Plate Count (HPC) at system start-up and monthly while the cooling tower is in use. Remediation begins at 10,000 CFU/mL.
• Other outdoor non-potable, aerosol generating water system (other than cooling towers), such as irrigation systems, should be documented for their potential to harbor Legionella bacteria, and be reviewed and updated annually or after any construction or demolition activities.
• Per the VHA Engineering Standard ES-2019-001, also updated on February 2021, each cooling tower must be cleaned, maintained and inspected to ensure proper operations. All actions must be documented, with records retained for three years. This includes the following:
  • Semiannual preventative maintenance (PM) as part of the startup/shutdown process, including:
  • Cleaning of the sump and fill: the system must be disinfected, cleaned and re-disinfected
  • Immediately prior to initial startup following commissioning or any shutdown period of greater than one month
  • At intervals not exceeding 6 months

3. Updates Provisions on Environmental Legionella Bacteria Testing and Actions for Potable Water Systems:

• Legionella bacteria sampling requirements have changed: at least 20 water samples (first draw) water outlets from each building must be tested for Legionella for each quarterly testing cycle. Temperature, pH and level of biocide must be documented for each cycle. At least two of the 20 samples must be from an ice machine or other pure cold-water source, and at least two of the 20 samples must be from a pure hot water source (i.e., no mixing valve present). The remaining samples will be considered a hot/cold “mixed” sample if there is a mixing valve present. If no mixing valve is in place at the outlet, take the first-draw sample from either the hot or cold side.
• If Legionella bacteria are detected in at least one sample, then there are three different sets of actions that are required: assessment of routine engineering controls, remediation requirements and considerations, and clinical validation. Remediation will be on a “graded response” based on the number of positive Legionella bacteria samples, the concentration of Legionella bacteria when compared to previous routine testing, and if the positive Legionella bacteria samples are in high or low risk patient areas.

Barclay Water Management, Inc. has created, implemented, and validated hundreds of complete Water Management Plans (WMPs) which include the changes recently added in the VHA Directive 1061. In partnership with our Customers, Barclay Water Management is dedicated to ensuring its CTMPs comply with national and local standards and guidelines including ASHRAE Standard 188, Department of Veteran Affairs, and local Health Departments. We would be pleased to assist in creating or modifying existing CTMPs and WMPs for any Federal facility that is now subject to these modifications to assure complete compliance with the updated VHA Directive 1061.

Barclay is also an industry leader in Legionella bacteria risk minimization by offering sampling and testing programs to detect Legionella bacteria in potable and non-potable systems and validate Legionella Bacteria Management Plans. Barclay’s third-party laboratory is accredited by the CDC ELITE Legionella program.

[1] Department of Veterans Affairs.VHA Directive 1061: Prevention of Health Care-Associated Legionella Disease and Scald Injury from Water Systems.VHA Veterans Health Administration.Published February 16, 2021.Retrieved from: https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=9181.