Analyst Spring 2021

the Analyst The Voice of the Water Treatment Industry

Volume 28 Number 2

1300 Piccard Drive, Suite LL 14 • Rockville, MD 20850

Spring 2021

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

Volume 28 Number 2 Spring 2021

Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems What Should Water Treaters Know About Pseudomonas Aeruginosa?

Managing Waterborne Pathogens: There’s a Party in Your Pipes T.U.T.O.R.: Understanding Water Treatment Markets

Published by

Cover A photomicrograph of Pseudomonas, which can be found in building water systems.

Photo by Jennifer Oosthuizen/SCIENCE PHOTO LIBRARY.

Spring 2021

Volume 28

Number 2

8 Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

Shaimaa Ahmed, Ph.D.; Danielle Walker; Alan Mears, Ph.D.; Sergey Golovan, Ph.D.; Paul Lem, M.D.; and Chris Harder, Ph.D., Spartan Bioscience Inc. qPCR (quantitative Polymerase Chain Reaction) is an alternative and highly sensitive methodology that can be utilized for Legionella detection and quantification. In this study, onsite qPCR was used to monitor Legionella levels in two problematic HVAC cooling towers. For these in-field case studies, we demonstrate that this technology outperforms culture, and its rapid sample-to-result reporting is essential for efficient responses to high Legionella levels and monitoring the efficacy of treatment regimens.

20 Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems

Alberto Comazzi, Ph.D., Sanipur US LLC There are several technologies available in the marketplace for Legionella prevention and remediation. The first category is point-of-use filters. These filters are used as a barrier between a virulent strain and building occupants. The second category includes non-residual techniques, such as ultraviolet (UV) and heath/ flush. The third category of technologies are those able to establish a chemical residual in the BWS, also known as “supplemental” disinfectant, such as chlorine, monochloramine, chlorine dioxide, or copper-silver ions. These are listed as disinfectants under the Safe Drinking Water Act, which the EPA enforces. The implementation of this type of technology is not always indicated in the water management plan but is the only category that ensures a long-term protection for the building occupants.

28 What Should Water Treaters Know About Pseudomonas Aeruginosa?

Jeff Bates and Kristin Majeska, IDEXX Laboratories Pseudomonas aeruginosa, a major source of expensive waterborne infections, is one of the top causes of infectious outbreaks from pools and spas and has even been identified as a concern in cooling towers. Water treaters increasingly need to understand where P. aeruginosa is most likely to be found, where it could be of significant concern (and where it is not), and how to help minimize the risk of it causing disease.

4

Calendar of Events

5

President’s Message

6

Message From the President-Elect

48 Membership Benefits 49 Industry Notes 54 CWT Spotlight 55 Making a Splash 56 Capital Eyes 60 Tales From the Waterside 63 Life Beyond Water 68 T.U.T.O.R. 76 Business Notes 78 Advertising Index

36 Managing Waterborne Pathogens: There’s a Party in Your Pipes

Janet E. Stout, Ph.D., and David Pierre, Special Pathogens Laboratory Not that Legionella needed help, but COVID shutdowns and reduced occupancy have created just the right conditions for microbes to have a party in your pipes!

These conditions are not new but have created more opportunity for the growth and spread of Legionella and other waterborne pathogens in building water systems. These types of water systems are commonly found in hospitals, hotels, commercial properties, and schools. Can this confluence of calamities be an opportunity to educate and improve water management and disease prevention?

The answer is “yes,” and we will examine this topic in the article.

3 the ANALYST Volume 28 Number 2

1300 Piccard Drive, Suite LL 14 Rockville, MD 20850 (301) 740-1421 • (301) 990-9771 (fax) www.awt.org

2021 AWT Board of Directors

Calendar of Events

Michael Bourgeois, CWT

Association Events

Matt Jensen, CWT

2021 Business Owners Meeting

President

President-Elect

September 21, 2021 Providence Convention Center and Omni Hotel Providence, Rhode Island

Secretary

Stephen C. Hallier, CWT

Treasurer

Noah Baskin

Immediate Past President

2021 Annual Convention & Exposition

Thomas Brandvold, CWT

September 22–25, 2021 Providence Convention Center and Omni Hotel Providence, Rhode Island

Directors

John D. Caloritis, CWT Mark Coldren, CWT Stephanie Keck, CWT Fred Shurtz

Ex-Officio Supplier Representative

Garrett S. Garcia

Past Presidents

Jack Altschuler John Baum, CWT R. Trace Blackmore, CWT, LEED AP D.C. “Chuck” Brandvold, CWT Thomas Brandvold, CWT Brent W. Chettle, CWT Dennis Clayton Bernadette Combs, CWT, LEED AP Matt Copthorne, CWT James R. Datesh John E. Davies, CWT Jay Farmerie, CWT Gary Glenna Charles D. Hamrick Jr., CWT Joseph M. Hannigan Jr., CWT Mark R. Juhl

Brian Jutzi, CWT Bruce T. Ketrick Jr., CWT Bruce T. Ketrick Sr., CWT Ron Knestaut Robert D. Lee, CWT Mark T. Lewis, CWT Steven MacCarthy, CWT Anthony J. McNamara, CWT James Mulloy Alfred Nickels Scott W. Olson, CWT William E. Pearson II, CWT William C. Smith Marc Vermeulen, CWT David Wagenfuhr Casey Walton, B.Ch.E, CWT Larry A. Webb

Staff

Executive Director Heidi J. Zimmerman, CAE Deputy Executive Director Sara L. Wood, MBA, CAE Senior Member Services Manager Angela Pike Vice President, Meetings Grace L. Jan, CMP, CAE Meetings Planner Marci Hickey, CMP Exhibits and Sponsorship Manager Barbara Bienkowski, CMP Marketing and Meetings Coordinator Kiki DeVane Marketing Director Jennifer Olivares Marketing Coordinator Mary Claire Gordon Managing Editor Lynne Agoston Production Manager Maryia Alenchyk Director of Accounting Services Dawn Rosenfeld

The Analyst Staff

Publisher, Heidi J. Zimmerman, CAE Managing Editor, Lynne Agoston Production Manager, Maryia Alenchyk Technical Editor Michael Henley, mdhenleywater@gmail.com, (303) 324-9507 Advertising Sales Manager Carol Nettles, carol@adboomadvertising.com The Analyst is published quarterly as the official publication of the Association of Water Technologies. Copyright 2021 by the Association of Water Technologies. Materials may not be reproduced without written permission. Contents of the articles are the sole opinions of the author and do not necessarily express the policies and opinions of the publisher, editor or AWT. Authors are responsible for ensuring that the articles are properly released for classification and proprietary information. All advertising will be subject to publisher’s approval, and advertisers will agree to indemnify and relieve publisher of loss or claims resulting from advertising contents. Editorial material in the Analyst may be reproduced in whole or part with prior written permission. Request permission by writing to: Managing Editor, the Analyst, 1300 Piccard Drive, Suite LL 14, Rockville, MD 20850, USA. Annual subscription rate is $100 per year in the U.S. (4 issues).

Please add $25 for Canada and Mexico. International subscriptions are $200 in U.S. funds.

2022 Annual Convention & Exposition September 21–24, 2022 Vancouver Convention Centre Vancouver, Canada

2023 Annual Convention & Exposition

October 4–7, 2023 Amway Grand Hotel and Grand Rapids Convention Center Grand Rapids, Michigan

Also, please note that the following AWT committees meet on a monthly basis. All times shown are Eastern Time. To become active in one of these committees, please contact us at (301) 740-1421.

Second Tuesday of each month, 11:00 am – Legislative/Regulatory Committee Second Tuesday of each month, 2:30 pm – Convention Committee Second Wednesday of each month, 11:00 am – Business Resources Committee Second Friday of each month, 10:00 am – Special Projects Subcommittee Second Friday of each month, 11:00 am – Cooling Subcommittee Second Friday of each month, 2:00 pm – Pretreatment Subcommittee Third Monday of each month, 9:00 am – Certification Committee Third Monday of each month, 3:30 pm – Young Professionals Task Force Third Tuesday of each month, 3:00 pm – Education Committee Third Friday of each month, 9:00 am – Boiler Subcommittee Third Friday of each month, 10:00 am – Technical Committee Quarterly (call for meeting dates), 10:00 am – Wastewater Subcommittee

Other Industry Events

AWWA, Annual Conference & Expo, June 14–17, 2021 (Virtual) ASHRAE, Annual Conference, June 28–30, 2021 (Virtual) BOMA, International Conference and Expo, July 18–21, 2021, Boston, Massachusetts ASHE, Annual Convention & Expo., August 1–4, 2021, Anaheim, California ACS, Fall Meeting & Expo, August 22–26, 2021, Atlanta, Georgia USGBC, GreenBuild, September 21–23, 2021, San Diego, California WEFTEC, Annual Technical Exhibition & Conference, October 16–20, 2021, Chicago, Illinois IWC, Annual Conference, November 7–11, 2021, Scottsdale, Arizona RETA, Annual Convention, November 9–11, 2021, Schaumburg, Illinois

4 the ANALYST Volume 28 Number 2

President’s Message

By Michael Bourgeois, CWT

As I write this, our industry finds itself in the midst of supply challenges caused by raw materials shortages, transportation issues and trade disputes. The combined effects of all of these issues has resulted in the largest number of broken supply lines that I have seen in my career. While this is hopefully a temporary blip, the first source I turn to in times like this is my fellow AWT members. It helps to learn we are not alone in this challenge and to get ideas and suggestions from others.

Shared Responsibility Document An example of a fantastic resource developed by the AWT community is the Shared Responsibility material, which was created by the Cooling Subcommittee.

Over the course of the past 20 years, we have seen facilities eliminate key management and maintenance staff positions responsible for water treatment oversight.

At the same time, water treatment vendors have taken on more day-to-day responsibilities at their accounts.

This means that the close, collaborative relationship between water treaters and facility staff no longer exists and instead, water treaters have taken on a large amount

of risk and responsibility at our accounts. The Cooling Subcommittee wrote a paper on this topic and also developed an accompanying template you can use at your accounts to clarify roles and responsibility. You can find this on the Members Only section of the website.

Volunteering If you aren’t already, I hope you consider getting involved with AWT by volunteering for a project or committee. When I started out in the industry, coming to AWT events and then serving on a committee expanded my network and knowledge. It was a great way to quickly develop a trusted group of peers to exchange ideas with. I’ve been able to bring great resources and material back to my company, making us stronger for it. Volunteering can be as simple as reviewing a paper for the Annual Convention or helping with a long-term project. We have many opportunities to suit your availability. If you're interested, please reach out to AWT staff at (240) 404-6477 and they can set you up on the right path. That’s how I got started—one quick conversation with staff.

Thank you for the opportunity to serve. I can be reached at mbourgeois@chemcoprod.com.

5 the ANALYST Volume 28 Number 2

Message From the President-Elect At this moment, things are looking good for our Annual Convention in Providence, Rhode Island, September 22–25, 2021. As we get closer to the convention, things continue to look better, and states continue to open back up. We are all looking forward to the opportunity to finally see friends and colleagues in our industry after a long time away. This meeting is needed for all of us and will be a great way to re-engage with our community.

By Matt Jensen, CWT

meeting. I would argue that these are dollars well spent and that you receive a significant return on your investment. You’ll learn about new technologies and meet new colleagues. More importantly, you’ll come away refreshed and re-engaged in our industry. And after the past year, there is nothing we need more!

As we continue to plan the 2021 Annual Convention, I welcome your feedback. I can be reached at mjensen@ gwt-inc.com. Thank you for the opportunity to serve.

Educational Program We once again have a very solid educational program this year. There are over 35 sessions on a variety of topics in our industry. There are great sessions on polymers, wastewater, innovative technologies, Legionella, and business issues.

You’ll come away from these sessions with new ideas and insights.

Silent Auction I’m also looking forward to seeing our friends from Pure Water for the World. They are doing incredible work in Haiti and Honduras. And thanks to the generosity of AWT members, we have funded over four communities in Honduras, providing them with safe water and sanitation stations. We will once again have a silent auction during the convention. You’ll be able to bid on items that you use at work every day, plus some fun and unique things, too.

And you’ll do this all while raising money for a great cause.

Convention ROI Going to the Annual Convention and Exposition is an investment—both financially and personally. There is a bottom-line dollar cost to attend the convention. Travel is not cheap, and in difficult financial times, it can seem counterintuitive to spend funds for a 6 the ANALYST Volume 28 Number 2

The Most Competitive Water Treatment Insurance Insurance costs for water treatment and chemical manufacturing operations are increasing. WaterColor has the solutions to deliver to AWT members of all sizes, the lowest cost, most appropriate coverages. WCM has the underwriting authority and the access to multiple strong carriers to provide to you, in 50 states and Canada, the broadest policies at the best prices, for: • Auto:- Commercial and Hired & Non-Owned Liability • Products, Professional, Pollution and General Liabilty • No Contaminants Exclusions such as Bacteria, Mold, Foulants or Corrosives • Pollution Onsite, Offsite and during Transportation incl. HAZMAT up to $25m • Occurrence-based policies:- coverages are valid until the expiry of the statutes of limitations • Products Recall • Property, Inland Marine and Equipment Breakdown • Employee Fidelity, Cyber Extortion and Cyber Theft Water Color’s clients include: • Industrial and Commercial Water Treatment Firms • Servicers of Boilers and Cooling Systems • Sellers and Servicers of Water Treatment Equipment • Manufacturers, Blenders and Distributors of Water • Treatment Chemicals • Manufacturers of Pumps and Water Treatement • Equipment • Water Testing Laboratories • Water Treatment Consultants

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Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

Shaimaa Ahmed, Ph.D.; Danielle Walker; Alan Mears, Ph.D.; Sergey Golovan, Ph.D.; Paul Lem, M.D.; and Chris Harder, Ph.D., Spartan Bioscience Inc.

8 the ANALYST Volume 28 Number 2

Introduction

HVAC (heating, ventilation, and air conditioning) cooling towers are used as a cost-effective means to remove excess heat from large residential, commercial, and industrial buildings. Unfortunately, such systems are prone to microbial contamination. Opportunistic waterborne pathogens such as Legionella can thrive in such environments (1, 2). Generation of contaminated aerosols from HVAC cooling towers represents a public health risk, and in the case of Legionella pneumophila, may lead to outbreaks of Legionnaires’ disease, a potentially fatal form of atypical pneumonia (3, 4).

Under current guidelines, Legionella levels of ≥ 100 colony forming units per milliliter (CFU/mL) in cooling towers represent a potential increased threat to human health (5). Methods to accurately detect and quantify Legionella are essential to react to high levels of contamination that may pose a threat to human health (6). Currently, a culture is considered the standard for testing, but it is reliant on external laboratories and is subject to a 10-to-14-day delay between sample collection and result. In theory, it provides a reliable enumeration of viable and culturable bacteria; however, it is prone to underestimation due to sample preservation issues during shipping as well as processing effects at external laboratories (7–12). These issues may contribute to considerable interlab variability, which was highlighted by the ELITE (Environmental Legionella Isolation Techniques Evaluation) study completed at the CDC (11). A similar observation was made in our previous study on Canadian HVAC cooling towers (13). qPCR (quantitative Polymerase Chain Reaction) is an alternative and highly sensitive methodology that can be utilized for Legionella detection and quantification (12).

However, the primary criticism is that qPCR overestimates the number of Legionella due to the presence of dead cells, free DNA, and viable but non-culturable (VBNC) bacteria in the sample. The issue of the relevance of VBNC Legionella detection in terms of health risk is complicated due to their potential resuscitation into infectious forms via protist hosts (14–17). Until recently, qPCR had to be performed in a centralized laboratory location. The requirement to transport samples to these laboratories results in a significant time delay between sample collection and processing (typically 24–72 hours). In addition to risks associated with

transportation of a human pathogen by mail, the accuracy of testing may be negatively affected by sample loss or mishandling, poor sample preservation, and Legionella growth or degradation during shipping.

Recently, we described an onsite qPCR system that enables simple and robust quantification of Legionella in the field (13) that quantifies comparably with culture and is not impacted by the presence of free DNA. In this study, onsite qPCR was used to monitor Legionella levels in two problematic HVAC cooling towers. For these in-field case studies, we demonstrate that this technology outperforms culture, and its rapid sampleto-result reporting is essential for efficient responses to high Legionella levels and monitoring the efficacy of treatment regimens.

Materials and Methods Water sample collection and preparation HVAC water samples from two Ontario-based cooling towers (designated Tower 1 and Tower 2) were collected by site personnel using each building’s standard collection procedure in accordance with one of the sampling guidelines for ISO/TS 11731-2:2017, ISO/TS 12869:2012, or CDC culture procedure (18–20). A total of 1 to 4 liters (L) of water was collected at each testing time from a sampling port, unless otherwise indicated.

For external laboratory analysis, samples were collected in sterile 500-mL containers with sodium thiosulfate (provided by the laboratories), then mailed in a styrofoam cooler by express post for culture plating in accordance with laboratory recommendations. A chainof-custody form was required by each company, and the sample’s condition was assessed upon arrival for compliance with recommendations. For onsite qPCR, sodium thiosulfate was not added to water samples.

Tower 1 procedures: Samples were collected weekly for 13 weeks. These samples were analyzed by onsite qPCR, direct qPCR, in-house direct culture, and external laboratory culture.

Tower 2 procedures: Samples were collected weekly for 22 weeks. To identify the donor source of Legionella, additional samples were taken from the reservoir, the biofilm of the reservoir, sludge from the reservoir, and the exit pipe (the input source of city-supplied water into

9 the ANALYST Volume 28 Number 2

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

the cooling tower). Biofilm was sampled by physically scraping the walls of the reservoir and collecting the resulting debris. Samples were analyzed by onsite qPCR, external laboratory culture, and in-house direct culture.

In-house direct culture and colony PCR Tower 1 procedures: For direct culture analysis, samples were assumed to contain high amounts of Legionella pneumophila (from qPCR results) and were thus plated directly, as per ISO11731:2017, Section 8.4. These multiple volumes (1,000, 500, 100, and 50 microliters [µL]) of collected water samples were spread onto Buffered Charcoal Yeast Extract (BCYE) agar plates (Bio-Media Unlimited Ltd., Toronto, Ontario) and then incubated at 37 °C for up to 14 days. Representative colonies were selected from the plates and then analyzed by colony PCR using QuantStudio™ qPCR (Applied Biosystems, Foster City, California) using pan-Legionella, Legionella pneumophila, or Legionella pneumophila serogroup 1-specific primers with SYBR® Green detection of amplified products (13, 21). PCR products were resolved on agarose gels to confirm specificity.

Bacterial counts from plates were based on the identified morphology of the Legionella-positive colonies on plates with the least amount of observable competing microflora.

Tower 2 procedures: For direct culture analysis, 200 and 100 µL of collected water samples were spread onto Glycine-Vancomycin-Polymyxin-Cycloheximide (GVPC) agar plates on site (Bio-Media Unlimited Ltd, Toronto, Ontario). Samples were transported (~20 minutes [min]) back to the lab and then incubated at 37 °C for up to 14 days. For the direct culture from biofilm, samples were collected on site and brought back to the lab (~20 min). The sample was then diluted in sterile phosphate-buffered saline (PBS) (2% w/v) prior to plating and colony counts were reported relative to mass of biofilm collected (CFU/g). Bacterial identification and plate counting procedures were performed as described above, except colony PCR was performed with only Legionella pneumophila and Legionella pneumophila serogroup 1-specific primers.

Onsite qPCR using the Spartan Legionella Detection System Onsite qPCR was performed using the Spartan Legionella Detection System (Spartan Bioscience,

continued

Ottawa, Canada). This system, described in Ahmed et al. (13), is used to concentrate the intact L. pneumophila bacteria from an HVAC sample into a single use test cartridge. Each test cartridge includes qPCR primers and probes as described in Ahmed et al.(13). The sample is then analysed using the Spartan Cube, a portable DNA analyser.

For the sludge sample isolated from the reservoir of Tower 2, the silt could settle before removing the liquid from the sample for testing.

Quantification of L. pneumophila in HVAC samples by external laboratory culture Water samples for culture analysis were collected as previously described and sent to the following laboratories: Mold and Bacteria Consulting Laboratories (MBL) (Mississauga, Canada), Pinchin (Mississauga, Canada), and EnvironeX (Quebec, Canada). Individual samples may have been subjected to heat and/or acid pre-treatments to reduce or eliminate competing microflora, as per each laboratory’s standard methodology. These include ISO 11731:2004 (International Organization for Standardization 2017), CDC procedures (18–20), or Standard Methods for the Examination of Water and Wastewater (9260J Detection of Pathogenic Bacteria – Legionella Quantification and Identification). Results were reported as CFU/mL. Statistical analysis Linear correlation between the datasets generated by onsite qPCR and external laboratory culture was performed using the Pearson correlation coefficient. All calculations were performed using Microsoft Excel.

Categorization of test results Test results for qPCR and culture were categorized according to current standards for Legionella monitoring in Canada (22). As per this standard, samples with a concentration of ≥10 genomic units per milliliter (GU/ mL) would require additional monitoring or action (such as potentially shutting down the tower), and concentrations <10 GU/mL were considered to reflect cooling towers under control. Therefore, values <10 GU/mL were negative, whereas values ≥ 10 GU/mL were positive.

10 the ANALYST Volume 28 Number 2

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

Results Tower 1: Onsite qPCR detects high levels of Legionella while external laboratory culture produces variable results Tower 1 was monitored for a 13-week period by onsite qPCR and culture by two external laboratories to compare and evaluate methodologies. In Week 1, onsite qPCR identified very high levels of Legionella (1,300 GU/mL), whereas external culture values were inconsistent and laboratory dependent. Laboratory 1 reported a comparably high Legionella count (960 CFU/mL), whereas Laboratory 2 reported extremely low Legionella levels (5 CFU/mL), which missed the high levels of Legionella present in this tower. The disparity in terms of reported Legionella counts between onsite qPCR and the two different culture-based external laboratories continued for the entire 13 weeks of monitoring (Figure 1). Laboratory 1 showed a strong correlation with onsite qPCR (ρ= 0.88; Pearson correlation), whereas Laboratory 2 reported negative or low Legionella levels for the entire period, with a peak value of only 11 CFU/ mL (ρ= -0.06; Pearson correlation). A comparison of the two culture-based external laboratories reveals an extremely poor correlation (ρ= 0.19; Pearson correlation), which is like previous reports about the inconsistency of culture laboratories for the accurate enumeration of Legionella (11).

continued

Due to the high Legionella levels observed in Week 1, direct qPCR was also performed on the water samples over the first four weeks (Table A). It should be noted that this tower was disinfected in Week 2 in response to the onsite qPCR result for Week 1. This treatment resulted in a significant drop in Legionella levels in Week 3 (23 GU/mL in Week 3 versus 980 GU/mL in Week 2, by onsite qPCR). However, this treatment did not eradicate the bacteria completely and regrowth was evident in Week 4 (280 GU/mL). This clearly indicated that the Legionella contamination was not under control. Although the correlation was strong between the onsite qPCR and direct qPCR methodologies, direct qPCR resulted in higher quantification values for the three samples on which it was performed. This was to be expected because direct qPCR quantifies all Legionella bacteria and free DNA in the water sample, whereas onsite qPCR eliminates free DNA during the filtration step.

Table A: Quantification of Legionella pneumophila by Onsite qPCR, Direct qPCR, In-House Direct Culture, and External Laboratory Culture for Weeks 1–4.

Week

Onsite qPCR (GU/mL)

Direct qPCR (GU/mL)

In-house Direct Culture (CFU/mL)

Lab 1 Culture (CFU/mL)

Lab 2 Culture (CFU/mL)

1

1,300

3,100

11,000

960

5

2

980

1,100

2,000

320

-

3

23

-

<4

<1

<1

4

280

730

-

-

-

Figure 1: Quantification of Legionella pneumophila by onsite qPCR and two external laboratory cultures over 13 weeks demonstrated that correlation with onsite qPCR was laboratory dependent.

11 the ANALYST Volume 28 Number 2

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

In-house direct culture was also performed on samples for the first three weeks to compare with external laboratory culture (Table A). As previously discussed, Laboratory 1 reported much higher quantification results than Laboratory 2. In comparison, in-house direct culture quantified significantly higher than Laboratory 1 (11,000 versus 960 CFU/mL for Week 1 and 2,000 versus 320 CFU/mL for Week 2). In all cases, culture protocols were performed on samples 48 to 72 hours after collection. As previously reported (13), this delay between sample collection and testing by culture can significantly affect the colony counts, potentially resulting in under- or overestimation of Legionella.

For in-house direct culture, identification of Legionella colonies was performed by colony qPCR and verified on agarose gels (Figure 2).

Figure 2: Colony PCR performed on select bacterial colonies observed on in-house direct culture plates identifying the samples as Legionella genus (LEG), Legionella pneumophila species (LPN), and belonging to Legionella pneumophila serogroup 1 (LP1) as displayed on agarose gels.

continued

Overall, monitoring of Tower 1 by onsite qPCR and external culture demonstrated that onsite qPCR quantified similarly to culture (Laboratory 1) and enabled immediate action to be taken in a case of very high Legionella levels of contamination. Furthermore, external laboratory culture was shown to be highly variable, and one laboratory failed to detect the hazardous levels of Legionella.

Tower 2: Onsite qPCR detects persistent contamination with Legionella over a 22-week period that is undetected by external laboratory culture Tower 2 was monitored for a 22-week period by onsite qPCR and culture by an external laboratory to compare the two methodologies. Onsite qPCR identified low, but persistent levels of Legionella (10 to 50 GU/mL) for weeks 1 through 16, culminating in a brief spike (growth event) of 76 GU/mL at Week 17 and then a distinct and significant growth event that resulted in 120 and 250 GU/mL at weeks 20 and 21, respectively, before a sharp decrease at week 22, which was likely due to chemical-based remediation. External laboratory culture reported low levels of Legionella throughout the entire monitoring period and missed the significant growth events at weeks 17 and 21 (Figure 3).

Figure 3: Onsite qPCR detects persistent and moderate levels of Legionella missed by laboratory culture, including significant growth events observed at weeks 14-17 and 19-21.

12 the ANALYST Volume 28 Number 2

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Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

Tower 2: Onsite qPCR and in-house direct culture identifies the donor source of Legionella Due to the persistent levels of Legionella that were detected in Tower 2 during the 22 weeks of monitoring, the HVAC cooling tower was further investigated by testing additional sampling points to identify the source of Legionella. Onsite qPCR and/or in-house direct culture was utilized to determine the likely Legionella source within the HVAC system. The normal sampling point reported 32 GU/mL by onsite qPCR and 15 CFU/mL by in-house direct culture. The reservoir contained similar levels of Legionella as the sampling point. Direct culture of the reservoir biofilm revealed extremely high levels of Legionella (26,000 CFU/g) and high levels were also detected in the sludge collected from the reservoir (3,000 CFU/mL). The supply point from the city water system that enters the HVAC system (exit pipe) showed nondetectable levels of Legionella (<8 GU/mL by qPCR, <5 CFU/mL by direct culture) (Table B). These findings demonstrated that onsite qPCR was detecting viable bacteria that was being missed by external laboratory culture. As previously observed for other HVAC samples (Ahmed et al., 2019) (13), this may be due to the death of bacteria during shipping to the external laboratory. The high levels of Legionella found in the biofilm and sludge of the reservoir indicated the donor source of the bacteria.

Table B. Quantification of Legionella From Different Sources Within the HVAC Cooling Tower by Onsite qPCR and In-House Direct Culture.

Source

Onsite qPCR (GU/mL)

In-House Direct Culture (CFU/mL)

Sample point

32

15

Reservoir

31

10

Biofilm-Reservoir

Not tested

26,000*

Sludge-Reservoir

1,700

3,000

Exit pipe

<8

<5

Note: Significant sources of Legionella were identified in the biofilm and sludge present in the reservoir. *CFU/g of biofilm.

Tower 2: Onsite qPCR successfully monitors the outcome of a treatment regimen Based on the persistent presence of Legionella, likely due to the reservoir-based donor source, the tower was monitored to determine the impact of treatments over a period of 30 days. After the addition of biocide to a

continued

concentration of 5 parts per million (ppm) free chlorine on Day 1, the Legionella levels did not diminish on Day 2 but increased (from 12 GU/mL to 190 GU/ mL). After the reservoir water was disrupted (Day 2) to release scale and biofilm, there was a large spike (>1,000 GU/mL) in Legionella on Day 3, possibly due to release of bacteria from the reservoir biofilm and sludge. The released bacteria, when exposed to biocide, decreased significantly on Days 4 and 5 (110 and 44 GU/mL respectively). Legionella levels were relatively consistent (34 to 59 GU/mL) until Day 24, when they decreased to <10 GU/mL. On Day 25, with Legionella levels at 17 GU/mL, additional biocide was added to a concentration of 15 ppm of free chlorine. This resulted in Legionella levels dropping to below 10 GU/mL (Figure 4). In summary, onsite qPCR was used to dynamically monitor the success of HVAC cooling tower treatment on a day-by-day basis, thereby enabling operators to readily respond to changes in the tower.

Discussion

In-field testing of two HVAC cooling towers by onsite qPCR and external laboratory culture demonstrated the variability in accuracy of culture in the enumeration of Legionella (Figure 5). In the case of Tower 1, which had dangerously high levels of Legionella (1,300 GU/mL) by onsite qPCR, one external laboratory reported similar levels by culture (960 CFU/mL), indicating that the onsite qPCR was identifying live bacteria at high levels.

By contrast, the second external laboratory, which was the normal testing facility for this tower, reported the tower as positive for Legionella but at negligible levels (5 CFU/mL), requiring no further action according to the Public Works Guidelines (22). The basis of this laboratory-to-laboratory discrepancy could be shipping effects, although the time delay for the two laboratories was similar from sampling to culture. From our previous study (13), 262 samples shipped according to the laboratories’ recommendations showed that the time from sending the sample to analysis was highly variable, and as few as 14% of samples were analysed within 24 hours (Table C). These samples were shipped by express post in Styrofoam coolers (including a chain of custody form), and the sample’s condition was assessed upon arrival for compliance with recommendations.

14 the ANALYST Volume 28 Number 2

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

continued

Figure 4: Monitoring of Legionella levels by onsite qPCR in HVAC cooling tower indicated that additional biocide was required to achieve Legionella levels below 10 GU/mL.

Figure 5: The onsite DNA analyzer that quantifies the amount of Legionella in water samples.

Table C: Time Delay Between Sending the Sample and Analysis by Commercial Culture Laboratories.

Time delay (Days)

Count

%

<1

36

14%

1

134

51%

2

78

30%

>2

14

5%

Total

262

100%

Another explanation is that culture laboratories may use different sample processing protocols that could impact the results. For example, heat and acid may be used to aid in the identification of Legionella colonies by removing competing flora, but this is known to result in underestimation of Legionella counts (7–8, 23). For culture, the time from sample processing to result is typically two weeks. Onsite qPCR, which avoids the detrimental effects of shipping and processing, reports the Legionella count in less than an hour. In the case of Tower 1, the speed of results was important because it revealed in real-time that Legionella was present at levels that posed an immediate public health risk. Disinfection was performed and onsite qPCR showed a drop in Legionella levels, which demonstrated that the treatment was initially effective. However, by the fourth week, Legionella levels started to climb again, indicating that live Legionella bacteria had survived the treatment and that further monitoring was required.

One criticism of onsite qPCR may be that it overestimates the amount of Legionella in a sample due to the presence of free genomic DNA, dead bacteria, and VBNC bacteria. However, VBNC bacteria have the potential to be infectious (15, 24–28) and, therefore, reporting their presence may in fact be an advantage of onsite qPCR compared to culture methods. A study 15 the ANALYST Volume 28 Number 2

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

by Kirschner et al. (29) showed that in two hospital cooling towers, most Legionella bacteria detected were in the VBNC state, and thus, culture may severely underestimate the total number of Legionella pneumophila.

This means that qPCR may not be overquantifying the amount of Legionella but simply detecting Legionella in the VBNC state.

In terms of free genomic DNA, >99.9% of extracellular DNA passes through the filter of the onsite qPCR concentration system and hence has a negligible impact on the qPCR results (manuscript in preparation). For Tower 1, due to the high Legionella counts, direct qPCR was also performed to detect all bacteria and free DNA. Comparison of samples analyzed by both onsite and direct qPCR revealed that filtration removed 11 to 62% of the Legionella signal in the three samples tested. In-house direct culture of samples from Tower 1 reported Legionella counts higher than that observed for onsite qPCR. The explanation may be that this culture was performed after a two- to three-day delay, and therefore, the bacterial population may have grown significantly in the sample during this time, which we have reported previously (13).

The external laboratory culture for Tower 2 reported negative or extremely low, nonactionable levels for the entire study period, while onsite qPCR revealed low-to-moderate levels throughout the same period (22).

Onsite qPCR also revealed several growth events, which suggests the presence of viable and replicating Legionella bacteria. During the investigation of the Legionella sources in this tower, onsite direct culture not only revealed a moderate level of Legionella at the sampling source on par with prior observations, but it also identified areas of the reservoir (biofilm and sludge) with very high levels of bacteria (3,000 CFU/mL in sludge and 26,000 CFU/g in biofilm) that were acting as a constant donor source.

These observations strongly suggest that the negative or very low levels of Legionella reported by external laboratory culture were significant underestimates for this tower. The advantages of rapid sample-to-result outcomes provided by onsite qPCR are evident for Tower 2 in the monitoring of treatment efficacy on a day-to-day basis. The immediate response in Legionella levels to changes in biocide levels as well as to tower disruption

continued

was readily monitored. The sudden increase in Legionella counts the day after tower disruption revealed that the donor source was present in a protected refuge. Daily monitoring of Legionella revealed that the bacterial levels were significantly reduced by the treatment regimen but not entirely eradicated. The desired response (reduction of Legionella levels to <10 GU/mL) was finally observed with a higher dose of biocide.

This study highlights issues with current monitoring strategies of Legionella by culture. The onsite qPCR system evaluated in this study detects and quantifies Legionella at a level comparable with culture when culture is performed under ideal circumstances. This suggests that quantification by this onsite qPCR system is not impacted by the presence of extracellular DNA or dead bacteria. As evident from this study, previous observations (13), and reports in the literature, external laboratory culture is highly variable due to shipping effects and different sample processing methodologies, whereas onsite qPCR is not affected by these factors.

Furthermore, onsite qPCR provides immediate and reliable quantification of Legionella and may be used for routine monitoring or specific investigative scenarios where response time is critical as evidenced by the work presented here. As such, onsite qPCR offers significant advantages, and this technology represents a practical alternative approach for environmental testing for Legionella.

Field testing of two problematic HVAC cooling towers demonstrated the advantages of using onsite qPCR to detect and dynamically monitor Legionella levels. In both cases, there were examples of external laboratories failing to detect Legionella contamination by culture. Sample processing differences and shipping effects may account for the issues with culture, whereas onsite qPCR is not subject to these factors. Furthermore, rapid sample-to-result reporting with onsite qPCR enabled remedial actions to be taken within hours. This was relevant for these two HVAC cooling towers as one showed dangerously high levels of Legionella that required immediate treatment and the second tower continued to have moderate but very persistent levels. For this second tower, daily testing, and sampling from different regions of the tower enabled operators to identify the donor sources of Legionella and to monitor the efficacy of their treatment regimen. The observation that qPCR results are comparable to culture

16 the ANALYST Volume 28 Number 2

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

when performed under optimal conditions suggests that the onsite qPCR system does not over-quantify due to free genomic DNA or dead bacteria.

Acknowledgements

At the time of the research, all authors were employed

by Spartan Bioscience. The authors thank Jeff Moffat for support and advice throughout the duration of the project (Public Services and Procurement Canada) and other Spartan employees who helped to complete the research, including Nicole Boyle, Alyson Bush, Mark Coumans, Laura Cramm, Clare Dolan, Roxanne Gauthier-Ferland, Steven Price-Williams, Samantha Robertson, Cassandra Roeske, Gillian Tanabe, Miranda Yu, and Agnes Zoldowski.

References

1. Lucas, C.E.; Fields, B.S. (2016). “Legionellae and Legionnaires’ Disease,” In: Yates, M.V.; Nakatsu, C.H.; Miller, R.V.; Pillai, S.D., eds., Manual of Environmental Microbiology, 4th ed., American Society of Microbiology, pp. 3.2.9-1-3.2.9-13, doi:10.1128/9781555818821.ch3.2.9.

2. Winn, W.C. (2015). “Legionella,” In: Whitman, W.B.; Rainey, F.; Kämpfer, P.; Trujillo, M.; Chun, J.; DeVos, P.; Hedlund, B.; Dedysh, S., eds., Bergey’s Manual of Systematics of Archaea and Bacteria, John Wiley and Sons, Ltd, Chichester, UK, (pp. 1-44), doi:10.1002/9781118960608.gbm01178.

3. Walser, S.M.; Gerstner, D.G.; Brenner, B.; Höller, C.; Liebl, B.; Herr, C.E.W. (2014). “Assessing the Environmental Health Relevance of Cooling Towers— a Systematic Review of Legionellosis Outbreaks,” International Journal of Hygiene and Environmental Health, 217, pp.

145–154. doi:10.1016/j.ijheh.2013.08.002.

continued

12. Whiley, H.; Taylor, M. (2016). “Legionella Detection by Culture and qPCR: Comparing Apples and Oranges,” Critical Reviews in Microbiology, 42, pp. 65-4, doi:10.3109/1040841X.2014.885930.

13. Ahmed, S.; Liwak-Muir, U.; Walker, D.; Zoldowski, A.; Mears, A.; Golocan, S.; Mohr, S.; Lem, P.; Harder, C. (2019). “Validation and In-Field Testing of a New On-Site qPCR System for Quantification of Legionella pneumophila According to ISO/TS 12869:2012 in HVAC Cooling Towers. Journal of Water and Health 17(2), pp. 237-253. doi:10.2166/wh.2019.252.

14. Steinert, M.; Emödy, L.; Amann, R.; Hacker, J. (1997). “Resuscitation of Viable but Nonculturable Legionella pneumophila Philadelphia JR32 by Acanthamoeba castellanii,” Applied and Environmental Microbiology, 63, pp. 2047-2053.

15. Ducret, A.; Chabalier, M.; Dukan, S. ( January 2014). “Characterization and Resuscitation of ‘Non-Culturable’ Cells of Legionella pneumophila,” BMC Microbiology 14, 3, doi: 10.1186/1471-2180-14-3.

16. Garcia, M.T.; Jones, S.; Pelaz, C.; Millar, R.D.; Abu Kwaik, Y. (2007).

“Acanthamoeba polyphaga Resuscitates Viable Non-Culterable Legionella pneumophila after Disinfection,” Environmental Microbiology 9, pp.

1267-1277, doi:10.1111/j.1462-2920.2007.01245.x.

17. Kirschner, A.K.T. (2016). “Determination of Viable Legionellae in Engineered Water Systems: Do We Find What We Are Looking for?”

Water Research, 93, pp. 276-288, doi:10.1016/j.watres.2016.02.016.

18. Centers for Disease Control and Prevention (CDC) (2005). “Procedures for the Recovery of Legionella from the Environment”.

19. International Organization for Standardization (2012). ISO/TS 12869:2012— “Water Quality— Detection and Quantification of Legionella spp. and/or Legionella pneumophila by Concentration and Genic Amplification by Quantitative Polymerase Chain Reaction (qPCR)”.

20. International Organization for Standardization (2017). ISO 11731:2017— “Water Quality— Enumeration of Legionella”.

21. Benitez, A.J.; Winchell, J.M. (2013). “Clinical Application of a Multiplex Real-Time PCR Assay for Simultaneous Detection of Legionella Species, Legionella pneumophila and Legionella pneumophila Serogroup,” 1. Journal of Clinical Microbiology, 51, pp. 348-351. doi: 10.1128/JCM.02510-12.

22. Public Works and Government Services Canada (2016). “Mechanical Design 15161—2013 Control of Legionella in Mechanical Systems - Real Property – PWGSC”.

4. van Heijnsbergen, E.; Schalk, J.A.C.; Euser, S.M.; Brandsema, P.S.; den Boer, J.W.; de Roda Husman, A.M. (2015). “Confirmed and Potential Sources of Legionella Reviewed,” Environmental Science and Technology, 49, pp. 4797-4815, doi:10.1021/acs.est.5b00142.

5. Occupational Safety and Health Administration (OSHA) (1999).

“Legionnaires’ Disease,” In: OSHA Technical Manual [TED 1-0.15A].

Section III: Chapter 7. United States Department of Labor, Washington, D.C., accessible at https://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_7. html#app_iii:7_3.

6. Bartram, J.; Chartier, Y.; Lee, J.V.; Pond, K.; Surman-Lee, S. (2007).

“Legionella and the Prevention of Legionellosis,” World Health Organization, Geneva.

7. Roberts, K.P.; August, C.M.; Nelson, J.D. (1987). “Relative Sensitivities of Environmental Legionellae to Selective Isolation Procedures,” Applied Environmental Microbiology, 53, pp. 2704–2707.

8. Boulanger, C.A.; Edelstein, P.H. (1995). “Precision and Accuracy of Recovery of Legionella pneumophila from Seeded Tap Water by Filtration and Centrifugation,” Applied Environmental Microbiology, 61, pp.

1805–1809.

9. Delgado-Viscogliosi, P.; Solignac, L.; Delattre, J.-M. (2009). “Viability PCR, a Culture-Independent Method for Rapid and Selective Quantification of Viable Legionella pneumophila Cells in Environmental Water Samples,” Applied Environmental Microbiology, 75, pp. 3502-3512, available at https://doi.org/10.1128/AEM.02878-08.

10. McCoy, W.F.; Downes, E.L.; Leonidas, L.F.; Cain, M.F.; Sherman, D.L.; Chen, K.; Devender, S.; Neville, M.J. (April 2012). “Inaccuracy in Legionella Tests of Building Water Systems Due to Sample Holding Time,” Water Research 46(11), pp. 3497–3506, doi:10.1016/j. watres.2012.03.062.

11. Lucas, C.E.; Taylor, T.H.; Fields, B.S. (2011). “Accuracy and Precision of Legionella Isolation by U.S. Laboratories in the ELITE Program Pilot Study,” Water Research 45(15), pp. 4428-4436, doi:10.1016/j. watres.2011.05.030.

23. Leoni, E.; Legnani, P.P. (2001). ”Comparison of Selective Procedures for Isolation and Enumeration of Legionella Species from Hot Water Systems,” Journal of Applied Microbiology, 90, pp. 27-33, doi:10.1046/j.1365-2672.2001.01178.x.

24. Epalle, T.; Girardot, F.; Allegra, S.; Maurice-Blanc, C.; Garraud O.; Riffard, S. (2015). “Viable but Non-Culturable Forms of Legionella pneumophila Generated after Heat Shock Treatment Are Infectious for Macrophage-Like and Alveolar Epithelial Cells after Resuscitation on Acanthamoeba polyphaga,” Microbial Ecology 69, pp. 215-224, doi: 10.1007/ s00248-014-0470-x.

25. Marinelli, L.; Cottarelli, A.; Solimini, A.G; Del Cimmuto, A.; De Guisti, M. (2017). ”Evaluation of Timing of Re-appearance of VBNC Legionella for Risk Assessment in Hospital Water Distribution Systems,” Annali di Igiene (Annals of Hygiene) 29, pp. 431-439, doi:10.7416/ai.2017.2175.

26. Dietersdorfer, E.; Kirschner, A.; Schrammel, B.; Ohradanova-Repic, A.; Stockinger H.; Sommer, R.; Walochnik, J.; Cervero-Aragó, S. (2018).

“Starved Viable but Non-Culturable (VBNC) Legionella Strains Can Infect and Replicate in Amoebae and Human Macrophages,” Water Research, 141, pp. 428-438, doi: 10.1016/jwatres.2018.01.058.

27. Schrammel, B.; Cervero-Aragó, S.; Dietersdorfer, E.; Walochnik, J.; Lück, C.; Sommer, R.; Kirschner, A. (September 2018). “Differential Development of Legionella Sub-Populations During Short- and Long-Term Starvation,” Water Research, 141, pp. 417-427. https://doi.org/10.1016/j. watres.2018.04.027.

28. Cervero-Aragó, S.; Schrammel, B.; Dietersdorfer, E.; Sommer, R.; Lück, C.; Walochnik, J.; Kirschner, A. (2019). “Viability and Infectivity of Viable but Nonculturable Legionella pneumophila Strains Induced at High Temperatures,” Water Research, 158, pp. 268-279. doi: 10.1016/j. watres.2019.04.009.

29. Kirschner, A.K.T.; Rameder, A.; Schrammel, B.; Indra, A.; Farnleitner, A.H.; Sommer, R. (2012). “Development of a New CARD-FISH Protocol for Quantification of Legionella pneumophila and its Application in Two Hospital Cooling Towers,” Journal of Applied Microbiology, 112, pp.

1244-1256, doi:10.1111/j.1365-2672.2012.05289.x.

17 the ANALYST Volume 28 Number 2

Can Onsite qPCR Accurately Detect Legionella Contamination in Cooling Towers?

continued

This article was authored by a team of experienced scientists in the fields of environmental water testing and molecular biology.

Their work focused on creating an onsite qPCR test that can be used to validate and monitor levels of Legionella in water systems. Currently, Legionella detection has been limited to slow and inaccurate testing methods that rely on offsite centralized labs. This research team sought to demonstrate that onsite, rapid molecular tests could help solve this problem and minimize the risk of a Legionnaires’ disease outbreak. The research team included Shaimaa Ahmed, Ph.D. (Research Lead); Danielle Walker (Research Scientist); Alan Mears, Ph.D. (Research Scientist); Sergey Golovan, Ph.D. (Research Scientist); Paul Lem, M.D. (founder of Spartan Bioscience); and Chris Harder, Ph.D. (VP of Diagnostics at Spartan Bioscience). Since writing this article, some of the authors have moved to positions at other companies.

Shaimaa Ahmed, Ph.D.

Danielle Walker

Alan Mears, Ph.D.

Sergey Golovan, Ph.D.

Paul Lem, M.D.

Chris Harder, Ph.D.

This article is based on a presentation given at the 2020 AWT virtual conference, which was conducted September 29–October 2, 2020.

Ask for Legiolert and deliver more accurate Legionella results The Legiolert® Test is a more accurate culture test for Legionella pneumophila Spread plate methods are notoriously inaccurate, with up to tenfold variability in results for the same sample.1 Multiple peer-reviewed studies have confirmed that the Legiolert Test provides more accurate and consistent results.2–5

Request the Legiolert Test from your laboratory today or find a laboratory at idexx.com/LPlabs.

References

1. Lucas CE, Taylor TH Jr, Fields BS. Accuracy and precision of Legionella isolation by US laboratories in the ELITE program pilot study. Water Res. 2011;45(15):4428–4436. doi:10.1016/j.watres.2011.05.030 2. Petrisek R, Hall J. Evaluation of a most probable number method for the enumeration of Legionella pneumophila from North American potable and nonpotable water samples. J Water Health. 2018;16(1):25–33. doi:10.2166/wh.2017.118 3. Spies K, Pleischl S, Lange B, et al. Comparison of the Legiolert/Quanti-Tray MPN test for the enumeration of Legionella pneumophila from potable water samples with the German regulatory requirements methods ISO 11731-2 and ISO 11731. Int J Hyg Environ Health.

2018;221(7):1047–1053.doi:10.1016/j.ijheh.2018.07.006 4. Sartory DP, Spies K, Lange B, Schneider S, Langer B. Evaluation of a most probable number method for the enumeration of Legionella pneumophila from potable and related water samples. Lett Appl Microbiol. 2017;64(4):271–275. doi:10.1111/lam.12719 5. Barrette I. Comparison of Legiolert and a conventional culture method for detection of Legionella pneumophila from cooling towers in Québec. J AOAC Int. 2019;102(4):1235–1240. doi:10.5740/jaoacint.18-0245

© 2020 IDEXX Laboratories, Inc. All rights reserved. • 2485785-00 • All ®/TM marks are owned by IDEXX Laboratories, Inc. or its affiliates in the United States and/or other countries. The IDEXX Privacy Policy is available at idexx.com.

18 the ANALYST Volume 28 Number 2

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Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems Alberto Comazzi, Ph.D., Sanipur US LLC

20 the ANALYST Volume 28 Number 2

Introduction

Legionnaires’ disease is a lung infection caused by a waterborne pathogen called Legionella. The infection is fatal in approximately 28% of the hospital-acquired cases. The Centers for Disease Control (CDC) reported that in the last decade, the number of cases of Legionnaires’ disease in the United States has increased four-fold. For this reason, the interest in Legionella by scientific researchers, the healthcare industry, water treatment professionals, industry associations, and state regulatory agencies has grown proportionally, with the objective being to protect the public health.

Legionella is a relatively prevalent bacteria naturally found in freshwater environments such as lakes, streams, and groundwater sources. Public water utilities usually carry out two disinfection steps in the treatment plants.

The first step is with chlorine or chlorine dioxide, and the second is with either chlorine or monochloramine.

The aim of disinfection is to kill harmful waterborne pathogens but sometimes bacteria such as Legionella can survive the two-step disinfection process and enter the water distribution system.

buildings, such as healthcare facilities, nursing homes, apartment complexes, hotels, and casinos, are at risk.

The U.S. Environmental Protection Agency (EPA) has set a Maximum Contaminant Level Goal (MCLG) of zero for Legionella, but no actual enforceable Maximum Contaminant Level (MCL) for Legionella in drinking water (1). In other words, there is no rule that public water systems (PWS) must follow regarding Legionella levels when they deliver the water to the potable distribution system. Although there are no federal requirements for controlling Legionella, it presents a big threat for building owners and managers if an infection, or even worse, a Legionnaires’ disease outbreak happens in their buildings, since they will be held responsible.

Guidelines and Technologies for Legionella Remediation

Building owners and managers are the people who are responsible for the safety of the occupant, and for this reason, they are responsible for eradicating the Legionella problem from the BWS. Not all buildings have Legionella, so not all of them have to remediate it.

A proactive approach is the best way to prevent the issue before it even happens.

Generally, Legionella is below the detectable level in the source water supply. It does not colonize well in cold water and therefore does not constitute a health threat.

The first step that building owners and managers However, the conditions that favor Legionella growth must take, regardless of whether they are remediating and the way the infection is transmitted dramatically or trying to prevent the issue, is to establish a water increase the risk of acquiring Legionnaires’ disease management team and develop a water management from building water systems (BWS) and cooling towers. plan. The CDC published a toolkit for building owners The perfect environments for the proliferation of this and managers to help them to develop a water manageopportunistic waterborne pathogen are stagnant water ment plan. In June 2017, the Centers for Medicaid and warm temperatures.

Medicare Services This is why Legionella (CMS) published a becomes a health risk memo that requires “Building owners and managers are once the bacteria enter all healthcare facilithe people who are responsible for a building’s complex ties to develop a water plumbing system and management plan. the safety of the occupant, and for start to colonize it. this reason, they are responsible for This is particularly true Various industry eradicating the Legionella problem in domestic hot water associations and systems, where temperaorganizations (i.e., the from the BWS.” tures are ideal for coloniAmerican Society of zation and the formation Heating Refrigeration of complex biofilms. The infection is then transmitted and Air Conditioning Engineers [ASHRAE], NSF when a person breathes water droplets that contain International, the American Society of Sanitary Legionella germs. This is why hundreds of thousands of Engineering [ASSE], and the American International 21 the ANALYST Volume 28 Number 2

Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems

Health Alliance [AIHA]) are also developing standards and guidelines to assist facilities in developing water safety plans and implementing remediation technologies. In June 2020, ASHRAE published the updated Guideline 12-2020, “Managing the Risk of Legionellosis Associated with Building Water Systems,” (2) and is now collaborating with NSF International on the new Standard 514 (3). In the meantime, ASSE just published its professional certification for water management specialists (4).

There are several technologies available in the marketplace for Legionella prevention and remediation. The first category is point-of-use filters. These filters are used as a barrier between a virulent strain and building occupants.

They offer almost complete disease prevention, but they are usually used in buildings where there are immunocompromised people due to the high labor and maintenance cost.

The second category includes non-residual techniques, such as ultraviolet (UV) and heath/flush. The UV emitter is usually installed at the BWS point of entry; therefore, it kills the bacteria entering the building, but it has no effect on the bacteria that are already colonizing the building plumbing system. The heath-and-flush procedure is a remediation technique where the temperature of the water is raised to levels that are above the thermal resistance of Legionella. For a complete disinfection, a temperature higher than 160 °F is required.

This technique may work on the short term, but it is not a long-term solution and presents a risk of scalding building occupants if not properly performed. Also, in most cases the hot water heaters were not designed to achieve these elevated temperatures for sustained periods.

The third category of technologies are those able to establish a chemical residual in the BWS, also known as “supplemental” disinfectant, such as chlorine, monochloramine, chlorine dioxide, or copper-silver ions. Chlorine, monochloramine, and chlorine dioxide are listed as disinfectants under the Safe Drinking Water Act, which the EPA enforces. The implementation of this type of technology is not always indicated in the water management plan but is the only category that ensures a long-term protection for the building occupants. After the CMS memo published in 2017 made the obligation

continued

to implement a water safety plan for healthcare facilities receiving Medicare and Medicaid funding, there was a dramatic increase in the demand for supplemental disinfection systems in buildings. The increase in Legionella testing created by implementing these water safety plans identified the need for remediation.

Regulatory Compliance: The “Permit” Application

Thanks to the long-term protection and prevention that a supplemental disinfection system can offer, building owners and managers often decide to implement this type of Legionella treatment technology on their building plumbing systems. However, there is no uniformity to the requirements that a disinfectant/technology must fulfill in order to be permitted by the agency that has jurisdiction in a certain state. The only federal regulation that applies to the whole country is the National Primary Drinking Water Regulations (40 CFR 141) (5). The regulation applies to all community water systems and all non-transient, non-community systems that treat their water with a chemical disinfectant for either primary or residual treatment.

In the regulation, it notes the following: “The Stage 1 Disinfectant Byproducts Regulation (DBPR) applies to public water systems that are community water systems (CWS) and non-transient, non-community water systems (NTNCWs) that treat their water with a chemical disinfectant for either primary or residual treatment. In addition, certain requirements for chlorine dioxide apply to transient non-community water systems (TNCWS).”

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 supplemental disinfectant to drinking water subjects the facility to the same requirements of a PWS. The states have primacy and are responsible for the enforcement of this rule, but the authority having jurisdiction (AHJ) may vary on a state-by-state basis depending on individual regulatory standards. Based on the requirements of the AHJ in a

22 the ANALYST Volume 28 Number 2

Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems

state, the owners/managers may be required to apply for a PWS “permit” to operate the water disinfection system.

The permit application must be executed by the building owners/managers, as they will be the ones responsible for the supplemental disinfection application. There is no federal regulation about the permit requirements, so this makes it really challenging for building owners and managers who manage buildings in different states or who apply for a permit for the first time, since different states may have different requirements. For the states where a permit is required, the only common requirements are an engineering drawing stamped by a Professional Engineer in that state and a “State PWS Licensed Operator” to oversee the supplemental disinfection operation. Even with these two common requirements, many discrepancies exist. Some AHJs require just a stamped engineering drawing, whereas others may require a full engineering proposal or a demonstration project of the supplemental disinfection system. At the same time, it is unclear how much time the licensed operator has to be on site. It can vary from every day to never, as long as the supplemental disinfection system has remote surveillance capabilities.

The PWS permit application also includes a water sampling plan that, again, differs based on the agency that issued the permit. The testing requirements will vary based on the disinfectants used but generally include coliforms, lead and copper, disinfectant residual, disinfection byproducts, and sometimes even some unregulated contaminants. Often, the water-quality monitoring plan for a BWS includes excessive testing requirements that may unnecessarily increase the operating cost of the water disinfection program. Also, some parameters are not under the control of the building owner/manager and are more appropriately the responsibility of the PWS. Due to all these different and sometimes excessive requirements, the permitting applications may take

“For the states where a permit is required, the only common requirements are an engineering drawing stamped by a Professional Engineer in that state.”

continued

several months or even more than one year before the final permit is issued. This delay puts building occupants at risk if Legionella is already colonizing the BWS. For this reason, some states provide the option of an “emergency permit” that allows the building manager to operate the disinfection system in the interim while waiting for the full permit. After the permit is issued, the facility’s manager/owner starts licensed operation and has to report the data required in the permit to the state’s AHJ.

The ASDWA Survey

In 2019, the Association of State Drinking Water Administrators (ASDWA) published the results of a survey about the different states’ approaches to BWS regulation (6). The purpose of the project was to provide states’ primary agencies with a summary of the current federal guidance for controlling Legionella and to share what some states have been doing with the current regulatory environment.

ASDWA acknowledged that the lack of federal regulations in terms of Legionella leaves the states in an uncertain position of trying to protect the public health, and furthermore, the Safe Drinking Water Act was not expressly intended to apply to BWS. ASDWA started the survey by asking the states whether a BWS is a PWS or simply a connection to the already existing PWS, and of course the answer was “it depends.” Based on the survey results, a BWS is a simple connection to the PWS if it only purchases water from it and does not provide any treatment. However, if the building has a treatment system in place and serves at least 25 people daily for at least 60 days, the PWS requirements are triggered.

The second question on the survey was to determine what constitutes “treatment” in a building. ASDWA suggested that a simple and practical definition of treatment for BWS would be “a technology that results in an adverse change in some regulated water parameter.”

It then developed a table with the minimum regulated water parameters based on the treatment technology (Table A).

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Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems

Table A: Regulated Water Parameters Based on Disinfection Method Building Disinfection Technology

Regulated Parameters

Free Chlorine or Monochloramine

THMs, HAA5, and Disinfectant Residual

Chlorine Dioxide

Chlorite and Disinfectant Residual

Ozone

Bromate

Copper/Silver Ionization

Copper and Silver

The answer to the second question from all the primacy agencies that were surveyed twice (in 2015 and 2018) was that the interpretation of the word treatment varies across the country and there is actually a great diversity of opinion among states on what exactly constitutes “treatment.” This result is just one confirmation of how different the process is based on the various geographical areas in the country alone.

The ASDWA survey results also reported some examples of different states’ approaches for the permit of a BWS. Some states, such as New Jersey, do not regulate BWS because they are waiting for EPA-federal guidance and decisions. In New York (NY), there is no permit requirement for the implementation of a disinfection system; however, NY focused its attention on the healthcare sector. All hospital and residential healthcare facilities are required to perform an environmental assessment and to implement a sampling plan for Legionella. The buildings shall monitor a minimum of 10 samples in the hot water portion of the building’s potable water system and notify the authorities when 30% or more samples contain Legionella.

Florida requires a full permit for supplemental disinfection applications made on cold water but does not require any permit for applications made on hot water only. Florida is also considering amending some of the rules for the full permit and transforming it in a simpler approval. The approval will require only the minimum level of staffing and will limit the PWS annual fee but will still require the same PWS compliance waterquality monitoring. The reason Florida is moving from the full permit requirements to a much simpler approval is to avoid discouraging buildings owners and managers to implement onsite disinfection systems when needed.

States such as Pennsylvania, Ohio, and Nevada instead

continued

currently require a full permit application. This means that the facilities that implement a disinfection treatment on their potable water system (hot, cold, or both portions) will effectively be a PWS and regulated as such. In the case of Pennsylvania, if the disinfection treatment system is installed in response to a Legionella outbreak, the building is required to develop and implement a water safety plan. California does not require a permit in BWS, but any supplemental water treatment device installed in healthcare facilities has to be Office of Statewide Health Planning and Development-approved.

This approval requires the submission of engineering drawings and design data.

PWS Licensing Requirements

In addition to the challenge that building owners and managers already face in order to clearly understand permitting in their area, the second biggest problem is the one related to the PWS licensed operator. First, even in the states where a supplemental water disinfection system requires a full PWS permit, the role of the certified operator varies widely. Some primary agencies may require the operator to be onsite every day, while others allow the operator to “remotely” oversee the disinfection process without actually being on site. The licensed operator requirement presents two major problems: the actual availability of operators and the skills needed for the operator to run a PWS as opposed to the ones that are needed in a BWS. In order to become a PWS licensed operator, an individual must take a test. In some states, there is also pre-test or 120 hours of training with state-certified training agencies. Once a person passes the test, he or she obtains a trainee license that allows work for the minimum of one year under the direct supervision of an already licensed operator. The Association of Board of Certifications (ABC) offers a four-class certification program that requires a minimum of one year experience for Class I operators and goes up to four years, including two years of direct responsible charge for Class IV operators.

Once the final license is issued, the operator has to complete continuing training and education hours in order to maintain the license. The operator’s license is valid in the state where it was issued. However, some state licenses have reciprocity with other states, and the

24 the ANALYST Volume 28 Number 2

Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems

operator simply needs to fill out a form in order to extend the validity of its license in different states. For example, a Maryland licensed operator can apply for reciprocity in Pennsylvania and Delaware.

continued

“Because of this series of requirements, in order to become a licensed operator, it is easy to understand that very rarely, a building engineering team already has a licensed operator on staff.”

The minimum requirement of one year of experience to apply for at least a Class I operator license presents a big issue for individuals who would like to obtain the certification. Because of this series of requirements, in order to become a licensed operator, it is easy to understand that very rarely, a building engineering team already has a licensed operator on staff. Building owners and managers often rely on the water treatment company that does the water treatment in the building if they have a licensed operator on the team, but usually, licensed operators often do not work for water treatment companies. It is unlikely that a water treatment professional leaves his/her job to work in a municipal water plant in order accomplish the minimum requirement of one year of operator-in-training to apply for the operator’s license.

This, therefore, often requires the building owners and managers to hire an outsourced licensed operator just to manage the supplemental water disinfection system. This inevitably increases the operating costs of the disinfection program and can discourage implementing supplemental disinfection when needed.

In May 2019, the Environmental Science Policy & Research Institute (ESPRI) published a paper prepared for ASDWA where it explained the differences in the skills between a PWS licensed operator and a person who should run a disinfection system in a building, referring to this person as “certified building water system (BWS) operator” (7).

The main difference between a BWS and a drinking water distribution system is the ecosystem: it is completely different. Once the water enters a building plumbing system it encounters extremely different conditions from the ones in a water distribution system.

Often, the condition of the water in a building offers a much better environment for the growth of waterborne

pathogens, such as Legionella. The main differences between a water distribution system and a BWS are materials of construction, presence of water processing units (e.g., heat exchangers, softeners, cooling towers) extreme variations in flowrates (from no water flow to hundreds of gallons per minute), variation in temperatures, much higher water age, and an extremely high-surface-area-to-volume ratio of piping. The higher surface to area ratio of a BWS exponentially increases the risk of biofilm formation.

Because of all these differences, a person who is qualified to run a PWS does not necessarily understand how a BWS works and vice versa. Some skills required for a licensed PWS operator may overlap with the ones for a BWS operator, such as the knowledge of the chemistry of disinfectants, water analysis, waterborne pathogens, and chemical feeders. Some other skills apply only to BWS operators, such as the knowledge of hot water systems, cooling towers, ice machines, point-of-use filters, and understating regulations and guidelines for water safety plans.

Closing Thought: What Is the Next Step?

As of June 2020, there is no federal guidance to the states on the permitting of treatment technologies for the prevention of waterborne pathogens in BWS. The only federal rule available (“National Primary Drinking Water Regulations: Disinfectants and Disinfection Byproducts,” 40 CFR 141) puts the buildings in the same position of a full PWS, and the state agencies are responsible for the enforcement of this rule. The enforcement of this rule may result in a permit requirement that differs on a state-by-state basis. The requirements to obtain a permit are written to ensure a successful disinfection application and to avoid any unintended consequences; in other words, to protect the public health.

Because of this lack of federal guidance, the requirements from the states can sometimes be excessive.

The Safe Drinking Water Act was not intended for BWS, and the state enforcement of the rules for a PWS to a building can actually go in the opposite direction:

26 the ANALYST Volume 28 Number 2

Regulatory Compliance Experiences of Supplemental Disinfection in Premise Plumbing Systems

pushing the building’s owners or managers to avoid applying for a permit in order to save oneself from the liability of becoming a full PWS. Often, owners and managers decide to opt for a short course remediation (shock chemical treatment and/or heath and flush) that will not be effective over the long term and may put the buildings’ occupants at risk.

Due to the discordant results obtained in the survey, ASDWA reported that as of right now it is difficult to think about a federal regulation for the permit of supplemental disinfection technologies in BWS that is valid in every state. BWS have similar characteristics across the country, so the difficulty in the development of a federal rule arises only from the different interpretations of the existing regulations that state regulatory agencies have.

It would be difficult, at least in the short term, to find a common point between states that require a full permit and those that do not require one at all. In other words, it is not impossible, but this process could take several years, assuming an agreement can be reached between the various viewpoints.

A first step that can be taken in the meantime to ease the permitting process would be, as suggested by ESPRI, to develop and establish a nationwide training and certification program for BWS operators. The guideline and standards now available in the literature (ASHRAE, NSF International, AIHA, CMS, and ASSE) are specifically developed for buildings. Buildings are, for the most part, the same throughout the United States. A hot water system and a cooling tower work in the same way in California as in New York State.

Water treatment professionals in the United States could benefit greatly from this type of training and certification. Much of the remediation in buildings such as hospitals, nursing homes, and hotels are being implemented by these professionals and their firms. A professionally trained and certified BWS operator would be a key person in the water safety team for the implementation of supplemental disinfection in buildings that will protect the public health.

ESPRI concludes that drinking water professionals of the American Water Works Association (AWWA), rather than other organizations (ASHRAE, NSF International, and ASSE), would best develop a certification program

continued

for BWS operators. When AWWA engages in the development of this new category of BWS operator the Association of Water Technologies (AWT) should participate in the committees and workgroups in a collaboration with AWWA. AWT is a nonprofit international industry association of water treatment firms engaged in all types of BWS treatment. These are the firms that are most often asked by building owners to implement supplemental disinfection. It is important that appropriate stakeholders, regulatory agencies, and healthcare representatives participate in this training and certification development process to ensure a functional program that protects the public health with trained and certified operators having the appropriate skill set for BWS.

References

1. EPA (2000). “Legionella: Drinking Water Fact Sheet,” U.S. Environmental Protection Agency, Office of Water, Washington, D.C. 2. ASHRAE (2020). “Guideline 12-2020: Managing the Risk of Legionellosis Associated with Building Water Systems,” American Society of Heating Refrigeration and Air Conditioning Engineers, Atlanta, Georgia.

3. PHCP PROS (March 4, 2019). “ASHRAE, NSF Develop Water Safety Standard for Building Systems,” https://www.phcppros.com/articles/9107ashrae-nsf-develop-water-safety-standard-for-building-systems.

4. ASSE International (2020). “ASSE/IAPMO/ANSI 12080 for Legionella Water Safety and Management Personnel Now Available,” ASSE International (American Society of Sanitary Engineering), Mokena, Illinois, www.asse-plumbing.org.

5. Federal Register (December 1998). “National Primary Drinking Water Regulations: Disinfectants and Disinfection Byproducts,” (40 CFR 141-143), Federal Register 63(241), pp. 69390-476, https://www.govinfo. gov/content/pkg/FR-1998-12-16/pdf/98-32887.pdf#page=1.

6. ASDWA (2019). “State Approaches to Building Water System Regulation,” Association of State Drinking Water Administrators, Arlington, Virginia.

7. ESPRI (May 2019). “Building Water System Operator Certification,” white paper prepared for the Association of State Drinking Water Administrators, Environmental Science Policy and Research Institute, Arlington, Virginia.

Alberto Comazzi, Ph.D., is the technical director of Sanipur US, based in Philadelphia, Pennsylvania. He holds a doctorate in industrial chemistry from the University of Milan. His research during his academic career focused on the study of the efficacy, stability, and interaction among different chlorine-based water disinfectants. Along with his main research project, Dr. Comazzi collaborated with different industries and universities on several catalysis and oil and gas research projects. He is a member of the ASHRAE SSPC-188 Committee, the AWWA premise plumbing Committee, and the AWT Pre-Treatment Committee.

This article is based on a presentation given at the 2020 AWT Virtual Conference, which was conducted September 29–October 2, 2020.

27 the ANALYST Volume 28 Number 2

What Should Water Treaters Know About Pseudomonas Aeruginosa?

Jeff Bates and Kristin Majeska, IDEXX Laboratories

28 the ANALYST Volume 28 Number 2

Introduction

Legionnaires’ disease continues to make headlines, and most of the warnings around safely reopening buildings are aimed at controlling the growth of Legionella pneumophila. However, the focus on Legionella can often mean that other opportunistic building water pathogens are overlooked.

drains, respiratory equipment, humidifiers, endoscopes, water baths, and hydrotherapy pools, among other places (3). Effective risk control is extremely complicated at both the system and point-of-use level, and water treaters working with clients need to understand best practices for risk assessment and control. These are described in more detail later in the article.

Pseudomonas aeruginosa, a major source of expensive waterborne infections, is one of the top causes of infectious outbreaks from pools and spas and has even been identified as a concern in cooling towers. Water treaters increasingly need to understand where P. aeruginosa is most likely to be found, where it could be of significant concern (and where it is not), and how to help minimize the risk of it causing disease.

While hospitals are the sites of greatest concern, other facilities cannot afford to ignore the pathogen.

Left unchecked in pools and spas, P. aeruginosa can cause “Swimmer’s ear” and “Hot tub rash” and lead to outbreaks, especially in hotels and resorts. These outbreaks can lead to pool and spa closures and a lasting stain on the reputation of these businesses, with significant financial impacts.

Why and Where Exactly Is P. aeruginosa a Concern?

Finally, P. aeruginosa can also cause illness during cooling tower maintenance and cleaning and should be controlled to maintain occupational safety (4).

Furthermore, the bacteria can metabolize nitrogen-based corrosion inhibitors, leading to corrosion issues (5).

The Centers for Disease Control and Prevention (CDC) lists P. aeruginosa as a “serious threat.” According to its 2019 Antibiotic Resistance Threats Report, in 2017, “multidrug-resistant P. aeruginosa caused an estimated 32,600 infections among hospitalized patients and 2,700 estimated deaths,” leading to significant healthcare expense (1). P. aeruginosa is particularly dangerous in neo-natal intensive care units (NICU), and tragic outbreaks with multiple infant deaths have occurred in several countries.

As an example of how difficult P. aeruginosa can be to control, multiple outbreaks at a Maryland NICU ultimately led to public health authorities and the hospital voluntarily closing the unit (2). An initial outbreak occurred in 1999 and was addressed using improved hand hygiene and cleaning practices. However, another outbreak occurred in March 2016, leading to two deaths.

Interventions began in August 2016 and included hyperchlorination and point-of-use filters. These interventions did not eliminate transmission, and the hospital closed the unit in November 2016 to identify additional control measures, including the replacement of proximal plumbing. As seen in this example, traditional measures that may be effective against L. pneumophila may not be effective against P. aeruginosa.

P. aeruginosa can grow in multiple systems within a hospital: potable water, faucets/taps, sink and shower

While L. pneumophila is often the principal target of water management plans and bacterial control measures, P. aeruginosa can also be present in many of the same premise plumbing and cooling tower systems managed or maintained by water treaters. While it shares many of the same habitats and characteristics as L. pneumophila, it is a unique organism, and controlling its growth may require unique, and potentially more intensive, interventions. The remainder of this article details regulations and best practices on the control and measurement of P. aeruginosa.

“Pseudomonas aeruginosa, a major source of expensive waterborne infections, is one of the top causes of infectious outbreaks from pools and spas and has even been identified as a concern in cooling towers.”

29 the ANALYST Volume 28 Number 2

What Should Water Treaters Know About Pseudomonas aeruginosa?

What Do Current Guidance and Standards Documents Say About P. aeruginosa?

Centers for Medicare and Medicaid Services (CMS)covered hospitals and long-term care facilities are required to control P. aeruginosa risk in their facilities (6).

The CMS released a memo in June 2017 outlining hospital and long-term care facility requirements for reducing risk associated with waterborne pathogens.

While the document focuses primarily on Legionella, the requirements for minimizing the risk associated with other opportunistic pathogens, including P. aeruginosa, are clear. The first line of the section titled “Expectations for Healthcare Facilities and Surveyors” reads: “CMS expects Medicare-certified healthcare facilities to have water management policies and procedures to reduce the risk of growth and spread of Legionella and other opportunistic pathogens in building water systems.” (emphasis added) Additionally, all three actions required of healthcare facilities in the 2017 CMS memo include P. aeruginosa as a target pathogen. The first requirement, to conduct a facility risk assessment, explicitly indicates Pseudomonas.

The second requires that hospitals and long-term care facilities create a water management plan that adheres to ASHRAE Standard 188 and includes environmental testing for “pathogens.” While “pathogens” is not defined in more detail in this requirement, it is logical that this refers to the same pathogens listed in the first requirement. The last requirement calls for specific testing protocols and acceptable ranges for control measures for the same pathogens.

CMS-covered facilities, therefore, must take measures to reduce risk associated with P. aeruginosa. The risks and negative consequences detailed in the previous section are well worth avoiding and should motivate any infection-control team to take the bacterium seriously. This includes ensuring that the facility’s water management plan includes actions specifically aimed at controlling P. aeruginosa, which may be different and incremental to the measures required to control L. pneumophila. Water treaters should work closely with infection control to identify the highest risk areas for P. aeruginosa within a facility and to implement these measures where they have the highest potential for risk reduction.

continued

CMS-covered healthcare buildings are not the only facilities that need to control the bacteria. Any building with a spa—defined as a whirlpool spa, hot tub, whirlpool, or whirlpool bath—should also take measures to control P. aeruginosa, and ASHRAE Standard 188 has specific content around control of and testing for P. aeruginosa in these areas (7). Section 7.3 of the standard outlines preventative measures required for public spas, including bather-related requirements (e.g., bather load), filter operation and maintenance, water quality, disinfection, and monitoring. According to ASHRAE Standard 188, facilities with spas must have procedures for a minimum of monthly testing for pathogens. The document references ASHRAE Guideline 12, which lists P. aeruginosa and sets an action limit of < 1 organism per 100 milliliter (mL) (8).

Beyond current requirements, industry associations are also working on developing standards to further address the risk. ASHRAE is currently working to develop ASHRAE Standard 514: Prevention of Injury and Disease Associated with Building Water Systems, which includes mitigating the risk of P. aeruginosa in its scope. The committee developing this standard will work to ensure there is no conflict or duplication between ASHRAE Standards 514 and 188 (9).

While the CMS requirements and forthcoming ASHRAE Standard 514 focus on controlling P. aeruginosa in the US, regulations in the UK, France, and Germany can also provide valuable examples of how the pathogen can be effectively controlled. In the UK, regulation was spurred by two tragic outbreaks in an NICU that led to four deaths. The outbreaks were traced back to the units’ potable water systems.

As a result, all hospitals in the UK must test for P. aeruginosa at least every six months (10). Often the pathogen

“Water treaters should work closely with infection control to identify the highest risk areas for P. aeruginosa within a facility and to implement these measures where they have the highest potential for risk reduction.”

30 the ANALYST Volume 28 Number 2

What Should Water Treaters Know About Pseudomonas aeruginosa?

is found close to the point of use, so regulations require taking a pre-flush sample, ideally during times of low or no use. Hospitals are directed to sample outlets that supply water that is in direct contact with patients, is used to wash hands, or is used to clean or fill equipment that will have contact with patients. Because controlling P. aeruginosa growth can be so difficult, the regulation calls for specific sampling procedures that help determine whether P. aeruginosa is an issue at a specific outlet, or a more systemic issue. These procedures are outlined in greater detail in the next section.

P. aeruginosa is also regulated in France and Germany, in hospital potable water systems, pool water (artificial and natural), and bottled water. Action levels for these regulations range between 0/100 mL and 100/100 mL, depending on the specific water type. The Association of German Engineers’ Technical Guidelines call for operators to monitor cooling towers for P. aeruginosa via the VDI Cooling Tower Code of Practice 2047-2 (11).

The regulation was put in place in 2015 to maintain occupational safety and requires disinfection when levels are above 100/100 mL.

What Are Best Practices for Controlling P. aeruginosa?

There is no single source for best practices for controlling P. aeruginosa. The following practices have been compiled from peer-reviewed literature, guidelines from industry groups, and international regulations. However, more research is required to develop a comprehensive set of measures for controlling the bacteria.

The most adverse P. aeruginosa health outcomes occur in healthcare settings due to proliferation in premise plumbing systems and susceptibility of occupants. While no universal consensus exists on the best practices for controlling the P. aeruginosa in premise plumbing, recommendations based on the most up-to-date science do exist and include the following (3): Using faucets that minimize surface area contact with water or stagnant mixed cold and hot water or plastic/ elastomeric materials.

Carefully considering the use of thermostatic mixing valves, which should only be used if patients that will use the faucet are at risk of scalding.

continued

Avoiding the use of flow straighteners and aerators.

Avoiding flexible hoses, stagnant water, poor temperature control, and dead legs.

Implementing a drain cleaning program.

Using point-of-use filters, as appropriate.

Using shock disinfection as appropriate.

Bédard, Prévost, and Déziel also present a review of the documented impact of the principal disinfectants used in premise plumbing on P. aeruginosa in their 2016 study in MicrobiologyOpen.

Best practice also includes testing for the presence of P. aeruginosa. As illustrated by regulations in the UK, sampling practices can provide information on the location and extent of contamination (10). By taking both pre-flush and post-flush samples, professionals can determine whether any contamination is an issue with a specific outlet, or if the problem is in the system itself (Table A). The number of outlets with positive results for P. aeruginosa can also indicate a broader issue.

Table A: What Positive Test Results for P. aeruginosa May Suggest P. aeruginosa Count

Possible Cause

High P. aeruginosa pre-flush count (>10 CFU/100 mL) and low post-flush count (<10 CFU/100 mL)

Suggestive of a local water outlet problem.

High P. aeruginosa pre-flush count (>10 CFU/100 mL) and high post-flush count (>10 CFU/100 mL)

Suggestive of a problem not related to a local water outlet but to a wider problem within the water supply system.

What Tools Can Be Used to Detect and Measure P. aeruginosa?

The industry standard for detecting P. aeruginosa is by a culture method performed in an accredited laboratory.

Traditionally, culture tests have been performed on hot and cold tap water as well as on treated pools and spa water. Culture testing of biofilm samples collected by swab techniques is also common. Recently, research has found that performing a liquid culture test provides a quicker time-to-result with equivalent or greater accuracy than traditional plate methods. Quicker time-to-result can be critical during a remediation when a hospital

31 the ANALYST Volume 28 Number 2

What Should Water Treaters Know About Pseudomonas aeruginosa?

or spa is shut down due to unsafe conditions and needs to get back into service quickly and greater method precision gives facilities and building owners a more accurate assessment of risk.

In 2015, Sartory et al. evaluated a liquid culture method A against traditional agar plate-based methods for the recovery of P. aeruginosa in hospital potable water samples (12, 13). Because recovery of P. aeruginosa is typically extremely low in hospital samples, the study combined both routine hospital samples as well as artificially contaminated water samples, for a total n of 272. The evaluation of the combined data set showed that liquid culture performed significantly better than traditional methods for the recovery of P. aeruginosa (Figure 1). Additionally, the liquid culture method had an extremely low false positive rate of 0.7%.

Figure 1: Monitoring effectiveness of the liquiding culture method.

Sartory et al. (12, 13) also evaluated the performance of liquid culture in both spa and pool waters, using both routine and artificially contaminated samples. In this case, liquid culture and the traditional agar-based methods were shown to have no significant difference in terms of accuracy or performance. As in all studies, liquid culture results were obtained much more rapidly than traditional methods, in 24 to 28 hours versus 40 to 48 hours.

More recently, Spies et al. (5) tested the different recovery methods’ effectiveness in cooling tower samples and found that the liquid culture method had significantly better performance than traditional plate methods. The researchers concluded that traditional plate

continued

“…in many cases, liquid culture methods produce significantly more accurate results than traditional methods.” methods are not suitable for analyzing cooling tower samples because of the tendency for non-target bacteria to interfere with plate counts. Cooling tower samples are often highly contaminated, and interfering bacteria can make plates difficult to read or actively inhibit growth of P. aeruginosa. A liquid culture does not suffer from these same drawbacks because bacteria are physically separated in wells. With a low false-positive rate (2.4%), liquid culture was shown to manage the effects of interfering bacteria and was determined to be a more appropriate test for cooling tower samples.

Water treaters working to control and limit the growth of P. aeruginosa can benefit by requesting an alternative testing method from their partner laboratories. As already discussed, in many cases, liquid culture methods produce significantly more accurate results than traditional methods. Additionally, water treaters may receive results from newer alternative tests faster than results from a traditional lab test, meaning they can examine the effectiveness of different remediation actions much more quickly, leading to faster decision-making about putting areas back in service and improved health outcomes for their customers and the public.

Closing Thoughts What actions should water treaters take to address P. aeruginosa risks in their customers’ facilities?

Water treaters have the often-difficult responsibility of educating their customers on all water quality risks and helping them understand that an ounce of prevention is worth a pound of cure. Water treaters should consider the following actions to effectively minimize the risk posed to their customers by P. aeruginosa: 1. Work with healthcare and long-term care customers to ensure their Water Management Programs include specific measures to reduce P. aeruginosa risk for their most vulnerable populations. Additionally,

32 the ANALYST Volume 28 Number 2

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What Should Water Treaters Know About Pseudomonas aeruginosa?

Water Management Programs in these facilities should include testing for P. aeruginosa to ensure the risk is sufficiently mitigated. Any other method for validation is only as effective as crossing your fingers.

2. Work with any customers who have spas to develop an effective Water Management Program that includes P. aeruginosa. Water treaters should follow the best practices and action limits outlined in Guideline 12 for controlling P. aeruginosa in these systems.

continued

11. VDI (Verein Deutscher Ingenieure) (2015) R€uckk€uhlwerke - Sicherstellung des hygienegerechten Betriebs von Verdunstungsk€uhlanlagen (VDI-K€uhlturmregeln) (Cooling Towers– Securing Hygienically Sound Operation of Evaporative Cooling Systems [VDI Cooling Tower Code of Practice]), Report VDI 2047 Part 2. D€usseldorf, Germany: Association of German Engineers, available at: https://www.beuth.de/en/technical-rule/vdi-2047-blatt-2/224206933.

12. Sartory, D.P.; Pauly, D.; Garrec, N.; Bonadonna, L.; Semproni, M., et al. ( June 2015). “Evaluation of an MPN test for the Rapid Enumeration of Pseudomonas aeruginosa in Hospital Waters,” Journal of Water Health 13(2), pp. 427–436, available at: https://iwaponline.com/jwh/article/13/2/427/28341/Evaluation-of-an-MPN-test-for-the-rapid.

13. Sartory, D.P.; Brewer, M.; Beswick, A.; Steggles, D. (September 2015).

“Evaluation of the Pseudalert/Quanti-Tray MPN Test for the Rapid Enumeration of Pseudomonas aeruginosa in Swimming Pool and Spa Pool Waters,” Current Microbiology 71, pp. 699-705, available at https:// link.springer.com/article/10.1007/s00284-015-0905-8.

Endnote

The Pseudomonas monitoring test mentioned in the text is Pseudalert™, which is made by IDEXX Laboratories Inc., Westbrook, Maine.

A

3. Educate cooling tower customers on the risks of P. aeruginosa and take measures to ensure staff are protected when servicing units.

As awareness of the risks posed by P. aeruginosa increases, water treaters who understand current science, regulations, and best practices can effectively communicate with their customers and mitigate risk.

References

1. CDC (2019). “Antibiotic Resistance Threats in the United States,” available at https://www.cdc.gov/drugresistance/pdf/threats-report/2019ar-threats-report-508.pdf.

2. Weng, M. K. et al. (September 2019). “Outbreak Investigation of Pseudomonas aeruginosa Infections in a Neonatal Intensive Care Unit,” American Journal of Infection Control 47(9), pp. 1148-1150, doi: 10.1016/j. ajic.2019.03.009.

3. Bédard, E.; Prévost, M.; Déziel, E. ( June 2016). “Pseudomonas aeruginosa in Premise Plumbing of Large Buildings,” MicrobiologyOpen 5(6), pp.

937-956, doi: 10.1002/mbo3.391.

4. Wiatr, C.L. ( January 2002). “Detection and Eradication of a Non-Legionella Pathogen in a Cooling Water System,” The Analyst IX, pp. 38-48.

5. Spies, K.; Pleischl, S.; Sartory, D. ( January 2020). “Comparison of the PseudalertTM/Quanti-Tray MPN Test for the Enumeration of Pseudomonas aeruginosa in Cooling Tower Water with the ISO 16266 Membrane Filtration Culture-Based Method,” Journal of Applied Microbiology 128, pp. 1843-1850, doi: 10.1111/jam.14586.

6. CMS (2017). “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires' Disease,” available at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/ Survey-and-Cert-Letter-17-30.pdf.

7. ASHRAE (2018). “ANSI/ASHRAE Standard 188-2018, Legionellosis: Risk Management for Building Water Systems,” accessible at https:// www.ashrae.org/technical-resources/bookstore/ansi-ashrae-standard-1882018-legionellosis-risk-management-for-building-water-systems.

Jeff Bates is the strategic marketing manager for Premise Water at IDEXX. In his role, he is responsible for promoting testing for waterborne pathogens in premise plumbing systems globally and the IDEXX liquid culture tests Legiolert and Pseudalert. He holds a bachelor’s degree in environmental studies from Middlebury College and received his MBA from the Darden School of Business at the University of Virginia.

Mr. Bates can be contacted at Jeff-Bates@idexx.com.

Kristin Majeska is director of government affairs and market development for the IDEXX water business. She works with researchers and public health stakeholders throughout the world to encourage application of best practices and laboratory methods that help ensure safe water and reduce the risk of waterborne diseases, including Legionnaires’ disease. Ms. Majeska’s background includes both national healthcare policy work and extensive experience helping small and medium-size businesses enjoy profitable growth. She may be contacted at kristin-majeska@idexx.com.

This article is based on a presentation given at the 2020 AWT Virtual Conference, which was conducted September 29–October 2, 2020.

8. ASHRAE (2020). “Guideline 12-2020 - Minimizing the Risk of Legionellosis Associated with Building Water Systems,” available at https://www.techstreet.com/ashrae/standards/guideline-12-2020-managing-the-risk-of-legionellosis-associated-with-building-water-systems?product_id=2111422.

9. ASHRAE (April 2, 2019). “ASHRAE to Continue Development of Building Water Management Standard,” accessible at https://www.ashrae. org/about/news/2019/ashrae-to-continue-development-of-building-water-management-standard.

10. Department of Health (2016). “Health Technical Memorandum 04-01: Safe Water in Healthcare Premises,” retrieved from https://assets. publishing.service.gov.uk/government/uploads/system/uploads/ attachment_data/file/524882/DH_HTM_0401_PART_B_acc.pdf.

34 the ANALYST Volume 28 Number 2

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Managing Waterborne Pathogens: There’s a Party in Your Pipes Janet E. Stout, Ph.D., and David Pierre, Special Pathogens Laboratory

36 the ANALYST Volume 28 Number 2 ©Special Pathogens Laboratory

Not that Legionella needed help, but COVID shutdowns and reduced occupancy have created just the right conditions for microbes to have a party in your pipes! These conditions are not new but have created more opportunity for the growth and spread of Legionella and other waterborne pathogens in building water systems. These types of water systems are commonly found in hospitals, hotels, commercial properties, and schools. Can this confluence of calamities be an opportunity to educate and improve water management and disease prevention? The answer is “yes,” and we will examine this topic in the article.

First, who’s at the party in the pipes? Legionella bacteria like a crowd. They grow well in the company of other microbes. The proximity of some of these other bacteria and their exponential growth can provide Legionella with nutrients it needs to grow.

Who’s in the crowd? Other microbes to be concerned about, particularly in healthcare facilities include Pseudomonas aeruginosa, Acinetobacter, and Burkholderia species, non-tuberculous mycobacteria (NTM), and one of our personal favorites—Stenotrophomonas maltophilia. These are shown in Figure 1. While the results of heterotrophic plate count bacteria (HPC) or ATP testing are not predictive of the presence or absence of Legionella, they might be indicative of conditions that favor the growth of other microbes.

Figure 1: Common pathogens that can attack healthcare facility water systems. Figure images ©Special Pathogens Laboratory.

What are some examples of the party getting out of hand? How about the pediatric dental practice that didn’t realize that NTM were in the dental unit water lines, and nine children contracted serious oral wound infections as a result? (1) Or, how about the previously healthy family of five that contracted NTM lung disease from their hot tub? (2). Stenotrophomonas maltophilia was isolated from sink faucets and aerators and implicated as the source for a cluster of patients in a surgical intensive care unit who were colonized or infected with S. maltophilia (3). Legionella was detected in school hot water distribution systems in Ohio and Pennsylvania after COVID shutdowns (4). A janitor at one Ohio school contracted Legionnaires’ disease (5).

Better Water Management

The purpose of a water safety and management plan is to minimize the risk of Legionella and other waterborne pathogens in building water systems. That said, just having a water safety and management plan does not guarantee control of Legionella or other waterborne pathogens, even if it meets the requirements of ASHRAE Standard 188 and the Centers for Medicare and Medicaid (CMS). Many plans don’t include a section to address unoccupied spaces or low-use/no-use conditions. Additionally, some plans don’t address other waterborne pathogens, the infections they cause, and the different modes of transmission (Table A).

“Many plans don’t include a section to address unoccupied spaces or low-use/no-use conditions.”

37 the ANALYST Volume 28 Number 2

Managing Waterborne Pathogens: There’s a Party in Your Pipes

continued

Table A: Differences Among Legionella and Other Waterborne Pathogens*

Waterborne Pathogens

Environmental Sources

Infection Sites

Modes of Transmission

Legionella species

Hot water systems, cooling towers, water features, spas, ice machines.

Severe pneumonia, rarely extrapulmonary infections.

Inhalation of aerosols, aspiration or direct instillation via equipment rinsed in tap water.

Potable water, ice machines, moist surfaces, medical equipment, cleaning and other solutions, distilled water, dialysis, nebulizers, water baths.

Bloodstream infection, peritonitis; septic arthritis; respiratory infection; urinary tract infection.

Acinetobacter species Burkholderia species

Mycobacterium species Pseudomonas aeruginosa

Stenotrophomonas maltophil

Dry surfaces, hands, medical equipment, humidifiers, ventilators, vaporizers, water baths.

Respiratory and ventilator associated pneumonia; bloodstream, urinary tract, and wound infections.

Direct, indirect, and environmental contact. Hospital-acquired infections from medical instruments and equipment.

Person-to-person contact.

Hospital-acquired infections may be caused by contaminated medical equipment and solutions.

Potable water, ice machines, moist surfaces, medical equipment, dialysis, dental units, hydrotherapy tanks.

Disseminated disease Environmental contact, aspirainvolving bone marrow, lungs, tion, or aerosolization. liver, lymph nodes, skin, and soft tissue.

Potable water, ice machines, moist surfaces, medical equipment, cleaning solutions, distilled water, dialysis, nebulizers.

Bloodstream infection; menin- Direct and environmental contact. gitis; urinary tract infection; pneumonia; peritonitis; soft tissue and eye wounds.

Potable water, ice machines, moist surfaces, medical equipment, dental units, dialysis, cleaning solutions, spas, pool, hot tub, soil, fruits, vegetables, and flowers.

Ear, eye, endocarditis, respira- Healthcare workers hands. Direct tory, urinary tract, peritonitis, and environmental contact. blood stream, skin.

Splash from sinks contaminating surfaces and materials.

*Table excerpted from Stout, Janet. E. Puzzled by Legionella? A Guide to Detection, Prevention, and Water Management. Pittsburgh, Pa: Special Pathogens Laboratory, 2020. https://puzzledbylegionella.com

What Should I Be Monitoring to Assess Risk?

Temperatures In general, building cold water systems offer far less risk of Legionella colonization and microbial proliferation than hot water systems. Cold water at temperatures below 68 °F (20 °C) do not favor the growth of these microbes. However, during low use and low occupancy, cold water warms up. This might require the implementation of a flushing program to move that warmer stagnant water out of the system.

On the flip side, building hot water systems offer excellent conditions for the party in our pipes. While some systems are operated to deliver water to the fixture at high temperatures to minimize growth (>130 °F), low use and low occupancy can bring those temperatures down into an optimal growth range for Legionella and other pathogens. Making matters worse, plumbing codes and state regulations have been developed to minimize the risk of scalding due to elevated hot water temperatures. This creates a unique set of challenges for facilities tasked with preventing Legionella colonization within building hot water networks.

It is important to generate and distribute water as hot as possible without the risk of scalding. The facility should monitor hot water generation temperatures, as well as temperatures at the point of use, to ensure hot water delivery throughout the building. Low temperatures can indicate a circulation issue or low-use conditions. The water safety and 38 the ANALYST Volume 28 Number 2

Managing Waterborne Pathogens: There’s a Party in Your Pipes

continued

management program should include corrective actions, such as implementation of a flushing program, to address low temperatures

Circulation Efficient hot water circulation is necessary to maintain adequate hot water temperatures at distal outlets. The water safety and management plan should include procedures and monitoring to ensure that hot water systems are circulating and fulfill the balancing requirements set forth in ASHRAE Standard 188 Section 8 (6). Most facilities incorporate continuous circulation of hot water into the design of building water systems. However, in many instances, the design of these hot water circulation systems can result in poor hot water delivery, particularly at outlets furthest from the point of hot water generation. Commonly encountered hot water system design deficiencies include undersized hot water circulation pumps, long runs of hot water circulating lines unable to maintain consistent temperatures, and excessively long branch lines connecting circulating lines to outlets.

Supplemental Disinfection Low use and low occupancy can challenge disinfection systems already in place to control Legionella and waterborne pathogens. This could be COVID-related or the result of renovation and construction.

Inadequate flow means insufficient delivery of the disinfectant, which leads to failure to control waterborne pathogens. Outbreaks have occurred due to failure to recognize this simple cause and effect.

This can be avoided by ensuring that the supplemental disinfection system is included in the water safety and management program. Monitoring disinfectant residual should be in done in the field from representative locations (typically near, mid, and far distal outlets on a weekly schedule). Certain supplemental disinfection systems might require additional monitoring, including disinfection byproduct monitoring.

The water safety program team should review monitoring results and corrective actions to ensure that the supplemental disinfection system is operating efficiently to manage the risk of Legionella. This review heads off problems before cases occur.

What Is the Risk From Construction and Renovation?

Construction events can negatively impact water quality, causing spikes in waterborne pathogens such Legionella.

Outbreaks of Legionnaires’ disease have been associated with construction events, including excavation, water main breaks, water pressure changes, brown water events, construction material changes, dormancy prior to occupancy, and ineffective disinfection during or after commissioning. Section 8 of ASHRAE Standard 188 (6) also addresses Legionella risk during major construction and renovation activities.

The Infection Control Risk Assessment (ICRA) has become a common process for identifying infection hazards associated with facility construction and renovation in healthcare facilities. This accepted process traditionally focuses on activities that impact ventilation, dust generation, and construction methods with little emphasis on water systems and waterborne pathogens.

We have recommended adding water (W) to the ICRA. Developing a Water Infection Control Risk Assessment (WICRA™)A can help secure patient safety from the consequences of waterborne disease associated with water system construction, renovation, or maintenance activity.

With a focus on building water systems, the multi-step WICRA process follows the traditional ICRA format, including: Identify the type of construction.

Identify the occupant risk group(s).

Select class of precaution.

Recommended precautions.

Implement WICRA Permit.

Worried About Stagnant Water or Areas of Low Flow?

Along with favorable temperatures, increased water age leads to conditions that can turbo-charge the party in the pipes, including causing low-disinfectant residual in building water systems. Water age is the residence time of the water in one or more locations in the building water system. Some water conservation practices and low-use/ no-use conditions increase water age. One study demonstrated that water age was an average of eight days in a LEED gold-certified facility and as long as two months in

39 the ANALYST Volume 28 Number 2

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Managing Waterborne Pathogens: There’s a Party in Your Pipes

continued

a net-zero office building (7). Disinfectant residual from the water supplier is low by the time it enters the building.

While these disinfectant residuals from the water supplier would not have prevented Legionella growth entirely, increased water age decreases disinfectant residual even further. These changes in the water system may contribute to overall increase in microbial growth.

When the water safety team identifies these low-flow high water age conditions, the program team should develop a schedule to flush distal outlets (sinks and showers) on a weekly basis. Consider flushing cold water for two minutes, and then flush hot water until maximum temperature is reached, followed by an additional two-minute flush.

If you don’t find a section in your water safety and management plan that deals with unoccupied spaces and dormancy, add it now. A robust plan needs to include recommendations and actions to follow during low- or no-flow situations.

Can Other Water-Quality Tests Determine Legionella Risk?

It has been suggested that certain water-quality parameters could be used as a surrogate for testing Legionella distal site positivity, such as keeping HPC concentration <500 colony forming units per milliliter (CFU/mL) and maintaining incoming free chlorine of >0.5 mg/L. We conducted a study to evaluate the presence of Legionella in premise plumbing systems in 28 commercial buildings (8). The overall objective was to evaluate the correlation between water-quality parameters and the presence of Legionella in water systems.

There was no correlation between Legionella distal site positivity and total bacteria (heterotrophic plate count), pH, free chlorine, calcium, magnesium, zinc, manganese, copper, temperature, total organic carbon, or incoming cold-water chlorine concentration. These findings suggest that water-quality parameters are not a suitable surrogate or substitute for sampling and testing distal sites for Legionella. We also found that the presence of Legionella in water collected from faucets or showers (distal sites) was not predicted by the presence of Legionella in the hot water return line.

“When the water safety team identifies these low-flow high water age conditions, the program team should develop a schedule to flush distal outlets (sinks and showers) on a weekly basis.”

In addition, sample collection and the test method should be discussed with the testing laboratory because results vary by sampling volume, and false positive results can occur with some test methods (9, 10). Better detection equals proactive prevention! We recently completed a study using a new culture media for NTM that will allow greater success in isolating these pathogens from water systems (11).

Even the Centers for Disease Control and Prevention (CDC) (12) states that testing could be useful for routine and nonroutine purposes, such as: Establishing a baseline measurement for performance indicators.

Validating a WMP. Evaluating potential growth and transmission sources.

Confirming success or failure of remedial treatment.

Investigating potential sources of environmental exposure for persons with disease.

Routine testing could be particularly beneficial for certain types of facilities, such as: Locations that house or treat individuals at increased risk for Legionnaires’ disease (e.g., senior communities, outpatient clinics).

Facilities unable to meet control limits consistently.

Locations with a history of associated Legionnaires’ disease cases.

42 the ANALYST Volume 28 Number 2

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Managing Waterborne Pathogens: There’s a Party in Your Pipes

continued

Reference 12 includes a CDC website address with more information on Legionella and Legionnaires’ disease.

In facilities with high-risk residents, such as hospitals and long-term care facilities, a conservative approach of sampling at least 10 distal sites is recommended.

In lower risk facilities, such as commercial or administrative buildings, sampling at least three distal sites and the hot water return could answer whether the systems are colonized and whether additional sampling is needed to assess risk. Culturing water samples for Legionella is an effective approach to assess and reduce potential disease risk, and its usefulness has been discussed in multiple guidelines.

Who Should Be on the Water Management Program Team?

Legionella and Legionnaires’ disease Building water systems Environmental testing Risk assessments Water safety and management programs Case investigations Mitigation approaches Construction and renovation associated Legionnaires’ disease

Per ASHRAE Standard 188, building owners and facility managers are responsible for implementing stronger safeguards to protect against the growth and spread of Legionella in their buildings. Water treatment providers are typically tasked with assisting building owners with developing water safety and management plans, monitoring water systems, and performing sample collection. While ASHRAE Standard 188 states that the program team shall have knowledge of the building water system design, and water management as it relates to Legionellosis, it does not require any training or certification to be part of the water safety and management program. This made sense when the ASHRAE standard was first envisioned so that there would be no barriers to adoption. However, the lack of sufficient knowledge has emerged as a real problem for effective disease prevention. How can an owner operator be certain that the team has the requisite knowledge?

Other waterborne pathogens

One of the new tools available to provide this assurance is the new standard ASSE/IAPMO/ANSI 12080, Professional Qualifications Standard for Legionella Water Safety and Management Personnel (13). This standard sets the minimum criteria for the training and certification of individuals involved in development, administration, and execution of risk assessment and water safety management programs for Legionella in building water systems. The standard is an excellent tool to verify that those on the water safety team have the necessary knowledge, and it covers all things Legionella, including:

1. Hatzenbuehler, L.A.; Tobin-D’Angelo, M.; Drenzek, C.; Peralta, G.; Cranmer, L.C.; Anderson, E.J.; Milla, S.S.; Abramowicz, S.; Yi, J.; Hilinski, J.; Rajan, R.; Whitley, M.K.; Gower, V.; Berkowitz, F.; Shapiro, C.A.; Williams, J.K.; Harmon, P.; Shane, A.L. (September 2017).

“Pediatric Dental Clinic–Associated Outbreak of Mycobacterium abscessus Infection,” Journal of the Pediatric Infectious Diseases Society 6(3), pp. e116–e122, https://doi.org/10.1093/jpids/pix065.

Final Thought

COVID has taught us many lessons about disease prevention and the role we all play in proactive prevention. COVID’s impact on building operations has magnified the risk of building-associated Legionnaires’ disease and risks from other waterborne pathogens.

There are new tools, including education and certification to the ASSE Standard 12080 (13), the CTI Guideline 159 (14), AWT’s Legionella position statement (15), and an updated CDC toolkit to help us improve water management and disease prevention even in the age of COVID. We can stop the microbial party in the pipes, and as the old saying goes “Every party has a pooper…” The authors hope you are the party pooper for the “party in the pipes”!

References

2. Mangione, E.J.; Huitt, G.; Lenaway, D.; Beebe, J.; Bailey, A.; Figoski, M.; Rau, M.P.; Albrecht, K.D.; Yakrus, M.A. (November/December 2001).

“Nontuberculous mycobacterial Disease following Hot Tub Exposure,” Emerging Infectious Diseases 7(6), pp. 1039-1042, doi: 10.3201/ eid0706.010623. PMID: 11747738; PMCID: PMC2631894.

3. Weber, D.J.; Rutala, W.A.; Blanchet, C.N.; Jordan, M.; Gergen, M.F.; (February 1999). “Faucet Aerators: A Source of Patient Colonization with Stenotrophomonas maltophilia,” American Journal of Infection Control 27(1), pp. 59-63, doi: 10.1016/s0196-6553(99)70077-5. PMID: 9949380.

4. Horberry, M. (Aug. 27, 2020). “Reopened Schools Find Health Risks in Water after COVID-19 Lockdowns,” New York Times.

44 the ANALYST Volume 28 Number 2

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Managing Waterborne Pathogens: There’s a Party in Your Pipes

continued

5. WHIO TV 7 ( July 1, 2020). “Legionella Uncovered throughout Fairmont High School; Employee Diagnosed with Legionnaires’ Disease,” WHIO TV7, Dayton, Ohio.

6. ASHRAE (2015). “ANSI/ASHRAE Standard 188 2015: Legionellosis: Risk Management for Building Water Systems,” Section 8, “Requirements for Designing Building Water Systems,” American Society of Heating, Refrigerating and Air-Conditioning Engineers, Atlanta, Georgia.

7. Rhoads, W.J.; Pruden, A.; Edwards, M.A. (2016). “Survey of Green Building Water Systems Reveals Elevated Water Age and Water Quality Concerns,” Environmental Science: Water Research & Technology, 2, pp.

164-173.

8. Pierre, D.; Baron, J.L.; Ma, X.; Sidari, F.P., III; Wagener, M.M.; Stout, J.E. (2019). “Water Quality as a Predictor of Legionella Positivity of Building Water Systems,” Pathogens 8(4), p. 295.

9. Hirsh, M.; Baron, J.; Mietzner, S.; Rihs, J.; Stout, J. (2021), Cross‐Reactivity of the IDEXX Legiolert Method with other Gram‐negative Bacteria and Waterborne Pathogens Leads to False‐Positive Assay Results,” Letters in Applied Microbiology, https://doi.org/10.1111/lam.13469.

10. Hirsh, M.B.; Baron, J.L.; Mietzner, S.M.; Rihs, J.D.; Yassin, M.H.; Stout, J.E. (November 2020). “Evaluation of Recommended Water Sample Collection Methods and the Impact of Holding Time on Legionella Recovery and Variability from Healthcare Building Water Systems,” Microorganisms 8(11), 11, p. 1770.

11. Alexander, K.J.; Furlong, J.L.; Baron, J.L.; Rihs, J.D.; Stephenson, D.; Perry, J.D.; Stout, J.E. (2021). “Evaluation of a New Culture Medium for Isolation of Non-tuberculous mycobacteria from Environmental Water Samples,” PLOS One 16(3), p. e0247166.

12. CDC (n.d.). “Legionella (Legionnaires' Disease and Pontiac Fever),” Centers for Disease Control, Atlanta, Georgia, accessible at https://www. cdc.gov/legionella/wmp/control-toolkit/routine-testing.html.

13. ASSE International (2020). “ASSE/IAPMO/ANSI 12080 for Legionella Water Safety and Management Personnel Now Available,” ASSE International (American Society of Sanitary Engineering), Mokena, Illinois, www.asse-plumbing.org.

14. CTI (Feb. 19, 2020). “Guideline (GDL) 159– Practices to Reduce the Risk of Legionellosis from Evaporative Heat Rejection Equipment Systems,” Cooling Technology Institute, Houston, Texas, www. coolingtechnology.org/single-post/2020/02/01/CTI-Releases-Comprehensive-Legionellosis-Guideline.

15. AWT (February 2019). “Legionella 2019: A Position Statement and Guidance Document,” Association of Water Technologies, Inc., Rockville, Maryland.

Endnote

WICRA is the trademarked abbreviation for a program for managing risk of waterborne pathogens associated with construction and renovation developed by Special Pathogens Laboratory, Pittsburgh, Pennsylvania. https:// specialpathogenslab.com/water-management/

A

Janet E. Stout, Ph.D., is president and director of Special Pathogens Laboratory and research associate professor at the University of Pittsburgh Swanson School of Engineering in the Department of Civil and Environmental Engineering. An infectious disease microbiologist, Dr. Stout is recognized for discoveries and pioneering research in Legionella. Her expertise includes prevention and control strategies for Legionnaires’ disease in building water systems. Additionally, she serves on the ASHRAE Legionella Standard Committee for Legionella Guideline 12 and the SPC 188 Committee for ANSI/ASHRAE Standard 188-2015, Legionellosis: Risk Management for Building Water Systems, the first U.S. standard for Legionella risk management. She is the first certified instructor of the ASSE 12080 Legionella Water Safety and Management Specialist Certification training. Dr. Stout may be contacted at jstout@specialpathogenslab.com.

David Pierre is vice president of SPL Consulting Services at Special Pathogens Laboratory. He is an expert in New York City and State regulations for Legionella risk management and ANSI/ASHRAE Standard 188. An ASSE/IAPMO/ANSI 12080 Certified Legionella Water Safety Specialist, Mr. Pierre has overseen the development of more than 200 water safety and management plans and risk assessments for healthcare, hospitality, commercial, and industrial facilities.

His background includes an understanding of the physical conditions for Legionella and waterborne pathogens in premise plumbing and cooling towers. He may be contacted at dpierre@specialpathogenslab.com.

46 the ANALYST Volume 28 Number 2

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Smaller AWT service companies that do not have manufacturing facilities might not be as familiar with current OSHA requirements. In addition, smaller member companies might be of the opinion that, having only a few employees, they are exempt from OSHA requirements to some degree. However, it is the responsibility of all employers, no matter what size, to provide and pay for personal protective equipment (PPE) for all employees who may require it. OSHA exempts companies with fewer than 10 employees for OSHA reporting requirements only. Any company that handles hazardous chemicals, even one with fewer than 10 employees, is responsible for documented hazardous communications training as well as providing PPE to all associates who may require it. The paper is helpful to AWT member water treatment service companies that might not be as aware of the OSHA requirements as one with a larger, dedicated full-time manufacturing staff.

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48 the ANALYST Volume 28 Number 2

Industry Notes

H2O Peabody Engineering Expands Its Manufacturing Footprint to the East Coast

After decades of designing and building industry-leading industrial polyethylene chemical storage tanks from its flagship manufacturing facility in Corona, California, Peabody Engineering & Supply, Inc. is ready to start growing again—on the East Coast.

With a bicoastal manufacturing presence, Peabody Engineering can readily meet consumer demands. The new production facility in Liberty, South Carolina, will be the first location for Peabody outside of California, where it was founded nearly 70 years ago. The new facility, to be located in the Pickens County Commerce Park in Liberty, is expected to be completed by midsummer 2021 and create 35 new jobs over the next five years.

“We are investing in our future growth with the opening of this new facility in South Carolina,” said Mark Peabody, CEO at Peabody Engineering. “Increased demand for our products, plus the strong labor force and the community’s value of USA-based manufacturing made this the right time and place to build our new facility.”

Peabody Engineering was originally founded as a small business selling agricultural fertilizer equipment on the West Coast and Idaho, and quickly grew into a manufacturing business of bulk storage containers for chemicals. Today, the company produces polyethylene commercial industrial storage tanks for a variety of industries, telecom cell tower antenna disguise and concealment products, fiberglass structural shapes, and other plastic products that meet the demand of a wide range of markets.

Peabody’s new facility on the East Coast will bring enormous benefits in creating an exceptional end-user experience through decreased distribution time and costs, putting it closer to some of its key customers.

H2SO4

“The demand for polyethylene storage tanks from various end-use industries continues to grow because it is exceptionally durable, lightweight, and cost effective compared to other material alternatives,” Peabody said.

“Our addition of this new facility reflects our continued commitment to supply reliable, quality, sustainable, and innovative storage solutions.”

The Coordinating Council for Economic Development awarded Pickens County a $300,000 set-aside grant for costs related to the project. Peabody’s new manufacturing facility will be purposefully built from the ground up and features: 48,000 square feet of innovative production technology and systems.

Career opportunities for 35 new production positions.

State-of-the-art technologies and machinery.

Opportunities for future plant expansion.

For more information, please contact Mark.P@4Peabody. com or visit our website at https://4peabody.com/.

49 the ANALYST Volume 28 Number 2

Industry Notes continued

ResinTech Deploys New Lab Technology

ResinTech, Inc. announced today that the company has deployed a world-class lab information management system (LIMS). The upgrade, which comes less than a year after the company's decision to offer an even wider array of water testing options to its customers, reinforces the company's goal of offering best-in-class lab services for the water treatment industry.

"We made a commitment to select and deploy an enterprise-level LIMS system capable of generating the detailed reporting those customers demand," said Tom Smith, head of ResinTech's Lab Services division.

ResinTech President Larry Gottlieb continued, "Tom has assembled an incredibly talented team of technicians and it only makes sense that we support them with the best technology."

Justin Schram Joins ResinTech Technical Sales

Ion exchange manufacturer ResinTech has hired Justin Schram to lead business development efforts for the company’s Western U.S. and Canada regions. Schram began his career in solar energy before joining the water industry, where he worked for Pentair helping distributors and dealers throughout Southern California solve their water treatment needs.

ResinTech's national sales manager, Frank DeSilva, discussed how the addition of Schram comes at a dynamic period of growth for Resintech. "Justin and I served together on the PWQA board, and I knew that his background and energy would be a great fit for the company.

The recent opening of our new factory in New Jersey has increased the demand for our MADE IN USA product, and he will help fill that need. I'm thrilled he decided to join us and I look forward to working closely with him."

Schram holds degrees in environmental management and business from Indiana University and is a past board member of the Pacific Water Quality Association, a nonprofit organization that represents consumers and businesses in the water quality improvement industry.

He will be based in San Diego and work out of ResinTech's facility in Gardena, California. For more information, visit www.resintech.com.

BioLargo and Garratt-Callahan Team Up for Product Development Project

BioLargo, Inc., developer of cutting-edge environmental technologies and a full-service engineering firm, announced that it has teamed up with Garratt-Callahan Co., a national industrial water treatment company, to co-create and develop a wastewater treatment product that will salvage usable water from commercial facilities wastewater streams.

Their mutual concern for the environment and the care and conservation of water make the collaboration between BioLargo and Garratt-Callahan a symbiotic match. BioLargo's mission to provide unique disruptive solutions to deliver clean air, clean water, and a safe environment combined with Garratt-Callahan's 116 years of experience and commitment to provide safer water 50 the ANALYST Volume 28 Number 2

Industry Notes continued

treatment and deliver unrivaled customer service, make for a formidable combination.

The shared goal is to design and manufacture a new piece of wastewater treatment equipment centered around a new patented water treatment process developed by Garratt-Callahan to reduce wastewater discharged from commercial facilities. BioLargo's engineering division (BioLargo Engineering, Science & Technologies) will design, build, and pilot a prototype of the new system.

When refined, the two organizations have agreed to offer the system commercially to Garratt-Callahan customers and select BioLargo distributors, with BioLargo serving as the equipment's ongoing manufacturer. The collaborative team targets having full-scale units in operation in mid to late 2021 or early 2022. Both companies expect strong demand for this product offering among its wastewater treatment customers.

Garratt-Callahan has signed a purchase order with BioLargo to permit work to begin. The two organizations believe this will be the first collaboration of many.

Discussions are underway between leaders at both companies regarding the future utilization of BioLargo's other technology assets to serve their customers' needs.

President and CEO of BioLargo Dennis P. Calvert commented, "This is a tremendous opportunity for BioLargo and Garratt-Callahan to work together to address customers' pressing wastewater treatment needs.

Garratt-Callahan has a great reputation and history as a reliable and innovative water treatment services company, and they recognized BioLargo as a reliable innovator in the water treatment technology space. This collaboration is a perfect fit, with shared corporate values of fairness, honesty, and integrity. We believe we will help solve important water treatment challenges that Garratt-Callahan's customers face. We look forward to sharing more information as the project progresses." For more information, visit www.BioLargo.com.

AP Tech Announces New President

AP Tech Group Inc., a leading manufacturer of solid chemistry technology for the water industry, announced the promotion of Matt Horine to president.

“Elevating Matt's role to president was an integral decision for the vision of the future success of AP Tech.

Matt has the innate ability to connect with people and foster relationships and he has been a key player in AP Tech’s growth. We recognize his many contributions to the business and look forward to his continued innovative leadership,” stated AP Tech CEO Katie Lee. Horine has 19 years of water treatment experience with AP Tech. “Having started with AP Tech early in its history, I have been able to be a part of and experience the company’s growth, participating in all facets of the business from production, product development, technical support and sales. I am extremely excited to see AP Tech continue to evolve and to be a part of the leadership team helping shape the company,” stated Horine.

Prior to his new role, Horine served AP Tech as vice president of engineering from 2009–2017, then as managing director from 2017–2021. In his new role, Horine will lead the execution of the company’s strategies for growth in its core water treatment market along with working with CEO Katie Lee to align longer term strategies for the continued growth of AP Tech. In addition, he will continue to work closely with key partners and build relationships within the industry.

Horine is a chemical engineer and graduate of the University of Cincinnati. He resides in Cincinnati with his wife and two children. For more information visit www.aptechgroup.com.

DHP Sold to Employees

DHP, Inc. has been sold to Charlie Bedford, Darrell Cunningham, and Dick Youmans, the three employees of DHP, Inc. The news was announced in February by Linda Paul, president and CEO. When David H. Paul passed away unexpectedly in June 2019, the company made a commitment to the employees and to his family that no changes would be made for one year. After the year had passed, the employees and management entered discussions about the sale of DHP to the employees. In making this announcement, Paul’s wife said that she will forever be a confidant, a supporter, and the biggest cheerleader of the company her husband founded more than 30 years ago. DHP, Inc. provides training and consulting in advanced water treatment.

51 the ANALYST Volume 28 Number 2

Industry Notes continued

Hacker Exposes Vulnerability of U.S. Drinking Water Plants

A hacker’s botched attempt to poison the water supply of a small city in Florida is raising alarms about just how vulnerable the nation’s water systems may be to attacks by more sophisticated intruders, an Associated Press (AP) article recently reported. Municipal treatment plants are often cash-strapped and lack the cybersecurity protections found at nuclear power stations and electrical utilities.

As the computer networks of vital infrastructure become easier to reach via the internet, and with remote access multiplying during the COVID-19 pandemic, cybersecurity measures are often neglected at water treatment facilities.

Cybersecurity experts said the attack at the plant 15 miles northwest of Tampa were blatant. AP reported that whoever breached Oldsmar’s drinking water plant, using a remote access program shared by plant workers, briefly increased the amount of lye (sodium hydroxide) by a factor of 100, according to Pinellas County Sheriff Bob Gualtieri. Lye is used to lower acidity, but in high concentrations, it is highly caustic and can burn. It is commonly found in drain cleaners.

The hacker’s timing and visibility seemed almost comical to cybersecurity experts. AP reported that a facility supervisor monitoring a plant console saw a cursor move across the screen and change settings and was able to immediately reverse it. The intruder was in and out in five minutes.

There’s been an uptick in hacking attempts of water treatment plants in the past year, but most were by novices, many stumbling on systems while using a kind of search engine for industrial control systems called Shodan, according to the article.

A 2020 article in the Journal of Environmental Engineering found that water utilities have been hacked by a variety of actors, including amateurs, disgruntled former employees, cybercriminals looking to profit, and state-sponsored hackers.

So far this year, the Department of Homeland Security has issued 25 advisories listing various industrial control systems that could be vulnerable to hacking. Affected

products range from 3D rendering software to security cameras to insulin pumps.

New Association for Materials Protection and Performance Launches

NACE International and Pittsburgh-based SSPC: The Society for Protective Coatings have combined to form a new association to serve the global corrosion and coatings industry.

To create a unified voice for the corrosion control and protective coatings industries, a new association was recently launched at a global virtual event. The new organization, the Association for Materials Protection and Performance (AMPP), was formed by a merger between Houston-based NACE International, The Corrosion Society, and SSPC: The Society for Protective Coatings.

AMPP’s name, logo, and other brand elements were revealed at the event led by AMPP CEO Bob Chalker and the organization’s executive leadership.

“AMPP brings together the world’s leading corrosion prevention and protective coatings organizations under one umbrella,” said Chalker. “With a vision to create a safer, protected, and sustainable world, the new association will focus on the future of materials protection and performance.”

With more than 40,000 members in 130 countries, AMPP consists of two governance structures—AMPP, a 501(c)(6), and AMPP Global Center, a 501(c)(3). AMPP provides services to members in the areas of certification, accreditation, membership, advocacy, and public affairs, and AMPP Global Center focuses on standards, technical and research activities, conferences, events, education, training, publications, and pre-professional programming.

“No other organization offers the depth and breadth of materials protection and performance information, standards, education, certification, and contractor accreditation programming that AMPP now provides,” said Tim Bieri, chair of the AMPP board of directors and vice president for Materials & Corrosion Engineering, bp America, Houston. “Through AMPP, we will be able to raise the level of excellence of our professional community and have a greater impact on society through our expanded network of members worldwide.”

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Industry Notes continued

“I’m looking forward to bringing together the expertise that’s been instrumental in developing standards, training, publications, and other technical resources that support our members and advance our industry,” said Joyce Wright, AMPP Global Center’s chair and trade manager for strategy and innovation, Huntington Ingalls Industries–Newport News Shipbuilding, Hampton, Virginia. “With one voice, contractors, owners, craftsmen, manufacturers, corrosion experts, consultants, and industry stakeholders will do more to protect society across the globe.”

While the AMPP staff has been working together seamlessly since October, some program details, such as accreditation and certification, continue to evolve.

For the near future, NACE and SSPC accreditations and certifications will remain as they are currently structured.

“For years, AMPP’s new combined membership has been aligned in one very important way, our members are dedicated to protecting infrastructure and assets from corrosion and deterioration. Guided by this common purpose we will be a stronger, more powerful voice for our industry by working together,” said Chalker.

For more information about AMPP or to view the new logo, visit www.ampp.org.

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CWT Spotlight

Peter Zielski, CWT Kurita America, Inc. Minneapolis, Minnesota

What prompted you to obtain your CWT and when did you begin the process by taking the test?

For several years, I wanted to obtain my CWT certification. The catalyst came when I was working for US Water Services, which was actively encouraging its sales engineers to obtain the CWT designation to help distinguish themselves from the competition.

How did you prepare for the test?

US Water provided in-house training on the types of questions that were offered on the test. This included similar calculation examples to prepare for the math portions of the exam. I also attended a multi-day AWT Technical Training Seminar in Cherry Hills, New Jersey, in 2008. I benefited from the knowledge of the experienced instructors, including Colin Frayne, Jim Lukanich, Jay Farmerie, and Bruce Ketrick Sr. I also attended the evening calculations workshops that were available. At the end of the training, I passed the CWT exam. In 2011, I returned to Fremont Industries. There, I encouraged Fremont representatives to obtain their certification and helped them prepare for the exam, particularly with calculations. Many of the reps took up the challenge and obtained the CWT designation for themselves.

What are the advantages of having the CWT designation?

I believe the CWT credential enables the water treatment specialist to stand out from the competition as one who has the training and experience to best meet the client’s water treatment needs. The training for the exam will give you a foundation for facing the technical challenges you will encounter while helping clients to solve and prevent their water treatment problems. The ongoing continuing education ensures you stay abreast of current advances in water treatment chemistry and equipment.

What has been your greatest professional accomplishment?

When looking back at my almost 37-year career in water treatment, obtaining the CWT designation ranks towards the top of the list. But my greatest sense of accomplishment has been the number of long-term customer relationships I have established, many of which have spanned over the decades. As the client’s businesses grew, my business grew with them. Now, I am getting great satisfaction from training and working with the sons and daughters of my long-term clients and transferring my knowledge and experience to them.

What advice would you give those thinking about taking the exam?

Take the first step and start studying. Take advantage of the training opportunities offered by AWT, such as the AWT study materials and multi-day Technical Training Seminar. Find another CWT who can mentor you through the process. Think of the journey as a learning process. Even if you fail the first time you can reflect on your experience and discover the areas that need strengthening.

54 the ANALYST Volume 28 Number 2

Making a Splash

Laith Charles Watermark, LLC Annapolis, Maryland

What prompted you to start volunteering with AWT? I have always enjoyed the AWT community, a welcoming organization comprising individual companies in friendly competition. This is a group that exhibits an interesting, competitive comradery unlike any other industry I have seen. AWT offers a wide platform of resources to help a broad range of companies from small to large. The nature of this environment and quality of personnel who take part in contributing to the greater good of the community has a contagious nature that inspired me to take part.

Why would you encourage others to become a volunteer?

When I was first starting out, I joined the Young Professionals. The happy hours were the perfect way to lure me in and get me started. If you have not attended one yet, COVID permitting, you should. This is a great event that helped me familiarize myself with some new faces, get involved in some projects, and contribute to the community. Our first assignment was to raise awareness about the water treatment community to colleges. We all know finding new talent in this market is often hard to come by, and not enough people know it is a viable career path. While working on this, I was able to work with some very knowledgeable people and to make an impact on the visibility of this market space as a feasible career path.

I also had the honor of being featured on one of AWT’s webinars, getting published in the Analyst, and speaking at the AWT Convention, which were all focused

around the treatment equipment side of the industry.

I never would have done any of this had I not taken the first step and signed up for my first AWT Young Professionals meeting. Today, I am one of the privileged people selected to take part in AWT’s technical trainings, where I assist with the hands-on section for Pulsafeeder by reviewing equipment troubleshooting tips. In this format, you can hand people parts, and they take them apart and put them back together, which helps them realize some of the issues that have plagued them in the field.

Tell us about a current project you or your committee is working on?

I am an active member of the Education Committee.

We have a great team of individuals currently working on a new education module. This module will provide a great reference to support cooling towers and some of the most common troubleshooting issues. The content is rich and interactive and only the first chapter, as the roadmap includes generating similar content for boilers, wastewater, and high purity. This new content will be made available soon and will be useful references that will stand the test of time and add value for years to come.

Exciting stuff!

I am a young entrepreneur—I run my own company, have a passion for water treatment equipment, and favor the AWT community. I welcome the opportunity to help anyone with their equipment needs. Your glass is never full, and you can always pour into somebody else’s cup.

55 the ANALYST Volume 28 Number 2

Capital Eyes

GAO Includes Toxic Chemical Control In High-Risk Report At the beginning of every new Congress, the Government Accountability Office (GAO)—the main government watchdog agency—issues a list of government programs and operations that are “high-risk” due to their vulnerabilities to fraud, waste, abuse, and mismanagement, or that need transformation. The list has led to more than $575 billion in financial benefits to the federal government over the past 15 years. In the recently released 2021 High-Risk List, GAO included the Environmental Protection Agency’s (EPA) toxic chemicals programs.

Overall Findings Overall, GAO found that EPA needs to improve its monitoring efforts to assess and control chemicals that pose risks to human health and the environment. Since the 2019 High-Risk report was issued, four criteria remain unchanged. However, the rating for monitoring decreased from “partially met” to “not met” in 2021, and ratings in three other criteria in the Integrated Risk Information System (IRIS) Program and four criteria in the Toxic Substances Control Act (TSCA) segments declined.

Details About IRIS Below is specific information and ratings for the IRIS program.

Leadership commitment: not met. This rating declined from “partially met” in 2019. GAO reported in March 2019 that the EPA administrator had not identified the IRIS Program as among his top priorities for the agency. Furthermore, the administrator’s congressional budget justification for fiscal year 2021 proposed a 34 percent cut to the Health and Environmental Risk Assessment area’s budget, approximately half of which is the IRIS

Program’s budget. Additionally, EPA’s agencywide strategic plan for fiscal years 2018 and 2022 does not mention the IRIS Program.

Capacity: partially met. Although the workforce remained stable, in December 2018, the Agency decreased the number of assessments the IRIS Program was working on from 22 to 13. In addition, EPA has not made public any information about the program’s current or future resource capacity for meeting EPA-wide needs for chemicals assessment.

Action plan: partially met. EPA has a draft strategic research action plan for the Health and Environmental Risk Assessment National Research Area, of which the IRIS Program is a part. It calls for coordinating the work of several Office of Research and Development (ORD) programs—including IRIS—that produce chemical assessments. Planning for such coordination of the various assessments ORD produces is encouraging, but reviews of the plan found that it lacks important details. For example, it did not include an implementation strategy or metrics to define progress or mention the resources the IRIS Program needs to produce chemical assessments to meet user needs. EPA neither provided an update about the plan’s status nor information on the agency’s plans for implementation.

Monitoring: not met. This rating declined from “met” for two reasons. First, despite a decline in participation in the assessment nomination process from 2018 to 2019, EPA has not assessed whether this survey is achieving its intended purpose and is generating quality information. Second, ORD’s advisory committee review of the strategic research action plan found that the plan did not include an implementation

56 the ANALYST Volume 28 Number 2

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strategy or metrics to define progress and allow for monitoring. To make progress in this area, EPA needs to include implementation steps in its strategic plan, define clear metrics for assessing program progress in meeting objectives, and show that it is monitoring the IRIS Program as a whole as well as continuing to assess specific activities to ensure they are achieving stated objectives.

Demonstrated progress: not met. The IRIS Program’s objective is to issue chemical assessments for use in EPA’s risk evaluation and management activities.

However, the program did not issue any completed assessments between August 2018 and December 2020.

Details About TSCA Below is specific information and ratings for the TSCA program.

Leadership commitment: partially met. The EPA budget request for fiscal year 2021 includes an increase of $8.5 million for TSCA implementation and $4 million for TSCA record digitization. But in May 2020, the administrator stated that EPA would not meet its deadlines for releasing the first 10 chemical risk evaluations. EPA stated that it would complete them by the end of 2020.

Capacity: not met. The 2016 Lautenberg Act provided EPA with greater authority to address chemical risks, which consequently increased EPA’s responsibility for regulating chemicals and increased its workload.

However, the Office of Pollution Prevention and Toxics (OPPT), which implements TSCA, did not meet statutory deadlines for its first 10 high-priority risk evaluations. EPA program offices have also not identified workforce needs for budget justification purposes since 1987. Additionally, OPPT expected to hire more than 50 staff members in fiscal year 2020, but had not conducted a workforce and workload analysis to demonstrate that, even with 50 additional staff, it would have the capacity to successfully implement the TSCA requirements by the statutory deadlines.

Action plan: not met. The TSCA amendments require EPA to publish a plan at the beginning of each calendar year for completing risk evaluations of chemicals already in commerce. The plan must identify risk evaluations to be initiated or completed that year; necessary resources; and an updated schedule for completing risk evaluations. However, OPPT’s annual plans did not meet the statutory requirements. The plans did not identify steps to complete future work or specify the financial and staff resources needed to initiate or complete the risk evaluations for that year.

Monitoring: not met. Although OPPT has developed annual performance goals that correspond to EPA’s long-term performance goals, the agency did not provide the underlying metrics or information on how they influenced changes to improve performance.

OPPT has done no workforce or workload planning to ensure it can meet TSCA deadlines.

Demonstrated progress: partially met. EPA did not publicly release scoping documents for its next 20 risk evaluations by the June 2020 deadline or include in its annual plans updates on its progress in completing the risk evaluations that are due by the end of 2022.

Why GAO Finds These High-Risk Problems According to the report, EPA’s ability to effectively implement its mission of protecting public health and the environment is dependent on assessing, in a credible and timely manner, the risks posed by chemicals in commerce and those that have yet to enter commerce.

EPA’s programs under IRIS and TSCA are the two segments in this high-risk area.

For more information about this report, follow this link: https://www.gao.gov/highrisk/overview.

Janet Kopenhaver is president of Eye on Washington and serves as the AWT Washington representative. She can be reached at (703) 528-6674 or janetk@eyeonwashington.com.

58 the ANALYST Volume 28 Number 2

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Tales From the Waterside

How Not to Clean a Closed-Loop System

By Gene Tonetti, Water Systems Management, LLC

When first starting my water treatment career in 1976, I was given an account to service in Evansville, Indiana.

The customer file from my manager had previous service call reports but no information about the system volumes, recirculation rates, metallurgy, and operating temperatures, among other variables.

The account was a plastics extrusion plant that had a Niagara fluid cooler with a closed loop that cooled small hydraulic oil coolers for the extrusion machines. We were using a patented all-organic corrosion inhibitor blend called Drewgard 100, and the feed rate was controlled by a titration test. I think the product also contained lignin.

One day I visited the plant and was shocked to see that the closed-loop water looked like tomato soup. Normally, it was clear or slightly cloudy white. Hard city water makeup was used for the system, and there was no meter on the makeup water line. The water sample was obtained from a large concrete sump and was so turbid that it took several minutes to filter it through Whatman #5 filter paper. What bothered me was that the total iron in the system was more than 50 parts per million (ppm).

After showing the plant process engineer the rusty water sample, he said, “Oh yeah. I forgot to tell you that we cleaned the system over the weekend and the water is usually very rusty for a few days and then it usually clears up after about a week.”

Since I was a rookie and really knew nothing about the system and the treatment history, I accepted the engineer’s response without further questioning and left the plant. But on my drive home, I had a very uneasy feeling about the dirty-looking water sample, and in particular the attitude of the process engineer.

Follow-up Visit

The next day, I received a phone call from our regional industry specialist (John), who lived in Lorain, Ohio. He asked if he could work with me the following week and wanted me to schedule calls on any accounts that were having tough technical problems. This guy had been with the company for 18 years and he really knew how to solve technical problems. Naturally, I scheduled a visit to the Evansville plastics plant.

Just before our visit, the purchasing agent from the Evansville plant, whom I had never met, called me with a question. He had recently purchased $49,000 (in 1976 dollars) worth of new heat exchangers for the closedloop system to replace the old ones that were only two years old! He wanted to know why the heat exchangers had to be replaced so soon. I was shocked and did not know how to respond. I told him that I was bringing in a technical manager and we were going to investigate the problem. Keep in mind that this customer was spending only $8,100 per year (in 1976 dollars) with my company, and the heat exchanger replacement cost would have paid for six years of water treatment chemicals.

Before we arrived, I told John about the problem and that I had no idea about the previous plant history. I also mentioned that the purchasing agent had requested a meeting after we talked with the process engineer.

Our meeting with the process engineer was eye-opening.

He first told us that they normally acid cleaned the

“But on my drive home, I had a very uneasy feeling about the dirty-looking water sample, and in particular the attitude of the process engineer.”

60 the ANALYST Volume 28 Number 2

Tales From the Waterside continued

closed-loop system once per month and used uninhibited hydrochloric acid. We found out that he dropped the pH down to 2.0 and let the cleaning solution circulate for 24 hours. He then neutralized the acid cleaning solution with lime! Yes, lime! He then flushed the system until the water was clear, and the rusty water was usually noticed the Monday after production resumed.

You should have seen the look on John’s face. He just shook his head and said, “Gene, these guys really need our help.”

We politely told the process engineer that his cleaning procedure was causing more harm than good. He did not receive this well. However, John offered to send him a detailed cleaning procedure that would specify the correct cleaning chemicals and amounts. The process engineer was amenable to this if the procedure did not require more time than his current approach.

We then met with the purchasing agent and told him we thought the heat exchanger failures may be a result of aggressive cleaning procedures and that the process engineer was going to follow our new cleaning procedure recommendations. We also explained that we were going to begin monitoring corrosion rates (this should have been done long ago) in the closed loop and fluid cooler systems.

Finally, to clean up the iron that was present from the previous cleaning, we began feeding HEDP, which not only sequestered the iron but also eliminated the turbidity in the water samples. I was not surprised when the process engineer objected to spending $500 for a drum of HEDP!

temperatures, softening the makeup water, and installing a water meter on the makeup line.

Final Thoughts

The main lessons I learned were: 1. Resurvey every account that is transferred into your territory. Know and understand the systems you are treating.

2. Do not accept the word of the previous rep on the current condition of the account. In this case, not only did the previous rep not understand the system or know of the corrosion and scale problems, but he had not met the purchasing agent or others who were aware of the problems.

3. Always monitor corrosion rates and heat exchanger approach temperatures.

4. Do not be afraid to ask questions.

Gene Tonetti is the founder of Water Systems Management. He has worked in the water treatment field for more than 41 years and has expertise in wastewater, high-purity, boiler, and cooling tower water. His experience in treating water includes treatment chemicals, chlorine dioxide, reverse osmosis, and process controllers. Mr. Tonetti is a 1973 graduate of Rose-Hulman Institute of Technology with a B.S. in biological engineering.

He is a Certified Water Technologist with AWT.

There was a happy ending to this story. We kept the account. Heat exchanger failures were eliminated, which amounted to savings of $29,500 annually, and cleaning procedures were reduced from monthly to annually. We also recommended monitoring heat exchanger approach

“Heat exchanger failures were eliminated, which amounted to savings of $29,500 annually.”

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Life Beyond Water

To Leave a Lasting Impact—Begin With the End in Mind

By Tom Hutchison, HOH Water Technology Inc.

Editor’s note: This is the first in a new series of articles that will examine issues that AWT members and others in the water industry face during their everyday lives. The idea is to provide worthwhile information from fellow water treaters who have had to deal with the topics they write about.

In 2019, at the AWT Annual Conference in Palm Springs, I presented a paper on how owners of multigenerational water treatment companies can leave a lasting impact. This presentation was subsequently published in the spring 2020 issue of the Analyst.

The intent of the spring 2020 Analyst article was to convey to business owners that the opportunity exists to leave a lasting impact with their businesses—on their family, community, customers, and suppliers—and that the opportunity is now. The article was written specifically for owners of multigenerational businesses. But all business owners have an opportunity to leave a lasting impact as we exit our businesses, whether they are part of a multigenerational family business or not.

The purpose of this article is not only to remind us of the opportunity but to also serve as a navigation tool to help achieve your goal—to help you get where you want to go. After reading this, you will hopefully have a better understanding of: The opportunity and challenge of planning and executing an exit strategy.

The options available to the one planning their exit strategy.

The next steps to take.

Begin With the End in Mind

Stephen Covey authored a best-selling book titled The Seven Habits of Highly Effective People (1). Habit #2 is Begin With the End in Mind. This habit is about imagination—creating a picture in your mind of a future reality. This future reality should be as clear as possible to chart a course that gets you there. Many of us have had a vision of what our business could be—in fact, a large part of your company’s growth has been due to your ability to communicate a picture of the future to others, who then follow you because they are excited by your picture.

Now the end approaches. You had a vision for what your company could be, and you have made that vision a reality. But you are not done—you must exit your business to complete the journey you started.

One entrepreneur put it this way: “I don’t believe you are really an entrepreneur until you’ve exited, because you haven’t completed the cycle. You’re still standing on third base. It is not about starting. Anybody can start a business. Until you’ve sold one, you haven’t touched all the bases” (2).” This may sound harsh—yes, anybody can start a business, but not many can sustain and grow a business over decades. Still, it is a true statement that you are not really done until you are out of the business.

This is the opportunity—to visualize what “the end” looks like and “begin” today to develop and execute a strategy that will get you there.

“This may sound harsh—yes, anybody can start a business, but not many can sustain and grow a business over decades.”

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Life Beyond Water continued

Your Funeral—Measuring Lasting Impact

Your funeral is not an energizing topic to contemplate— but it is an important one. If you could listen in at the wake and at the memorial service, what would you want to hear your loved ones, friends, and family say about you? “He inspired me to be a better person.” “She was always there for me.” “He was so generous with his time and money.” “I will miss her presence.” Somewhere in the conversation you would like to hear: “He was a great water treater.” “She was such a savvy businessperson.”

But no matter what is said, your hope will be that you had the greatest impact on the people in your life— family, employees, customers, and friends.

So, Step 1: As you “begin with the end in mind”—visualizing the impact you want to have in the lives of those close to you—what can you do now to move those relationships to where you want them to be?

Freedom—To Do What?

I cannot imagine the individual who would say at the end, “I wish I could have spent more time at the office.”

The good news is that you may be at a point in your career where you have the freedom to make a different choice. If so, Step 2 is important: Step away from the day-to-day grind and visualize what you want freedom to look like: Financial freedom: What do you want to spend money on? What financial goals do you want to achieve (no mortgage or car payments; college fund for grandchildren; increased charitable donations to causes that really matter to you)? How can you enjoy your financial freedom to maximize your impact on others (including your spouse!)?

Emotional freedom: For many of us, as leaders and owners, we carry a burden for other people. We worry

about their future, their job security, sometimes even their personal situations. We are the point persons for difficult, large customers, demanding banks, and auditors. What does it look like to be free from this pressure?

Relational freedom: What would it look like to have the freedom to spend more time with people we want to be with, and to be more involved with causes that really matter to us?

Yes, the good news is that you have the freedom to make choices now that will help you get to the “end you have in mind.” The bad news is that the longer you wait to make these choices, the fewer the options you will have.

Exit Strategy Options Every business owner will exit from their business, one way or another. Either during your lifetime or at death, your business will be sold, given away, or liquidated. It has been said that “death is an exit strategy.” But a “strategy” implies a desired result, so death is not a strategy!

The exit strategy options are quite clear and therefore easier to grasp than you may think. The options are: Sold to a strategic buyer Sold to key employees Sold/transferred to family members Secondary offering to private investors Liquidated The basic advantages and disadvantages of each strategic option are shown in Table A.

“Your funeral is not an energizing topic to contemplate—but it is an important one.”

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Life Beyond Water continued

Table A: Advantages and Disadvantages of Business Exit Strategies

Strategic Option Strategic Buyer

Sold to Key Employees

Sold/Transferred to Family Members

Advantages Purchase price may be the highest—your accounts and market presence are most valuable to the company that wants to get into the water treatment business or expand their market share.

Disadvantages An earn-out may be part of the deal—the smaller the acquisition, the more likely this will be. You will then depend on the new owner’s ability to keep and grow the business to get the payout you want.

Depending on the company, they may value your employees like how you value them.

Company culture will most likely change—even if the buyer understands your values, some organizational change is inevitable.

Company culture and customer relationships can continue as is—business as usual.

Typically, assets are purchased, not stock.

Any liabilities are your responsibility from the purchase proceeds.

ESOPs are expensive to set up and support—$50,000 would be a minimum.

You control the message about how you value your team—you do not have to rely on a new owner to value them like you do.

Without an ESOP, you will be receiving your distribution over time - not cash at closing.

If the strategy is an ESOP (Employee Stock Ownership Plan) there are significant cash savings which can dramatically improve cash flow.

The business must be profitable enough to afford the payments to you.

With an ESOP, you can get cash out at the time of closing (a bank provides this financing, and the ESOP pays back the bank).

Perhaps the best option to ensure that your values are continued after you exit.

The next generation is free to run the company without outside influence (private equity partner, ESOP, etc.).

Secondary Offering (Depending on your timeframe, you may choose to take on a private equity partner or “angel investor.” They have a majority interest, but you keep a minority interest for the future.)

Liquidate

“Second bite at the apple”—you get cash at closing, and then at some point in the future, the private equity partner sells the entity of which you are a minority partner—the value of those shares is the “second bite.”

Cash at closing—no earn-out.

Simple and straightforward Final—closure is assured.

You choose to accept a lower value just so the company/key employees can afford the payments.

Do the right family members exist to run the business after you are gone?

As with the key employee option, you will be paid over time—you trust the next generation to generate the profit to pay you for the business.

Family relationship dynamics need to be considered—how will this affect family members not in the business?

You take on a “partner,” but you lose control.

As a result, your culture and organization will change, even as you still are employed.

Planning is critical to take care of key employees up front.

Perhaps missed financial opportunities.

While unavoidable, relationships will be affected—clear communication will help.

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Life Beyond Water continued

Use Table A to focus your vision of the end that you have in mind. This is a very high-level view—each option will take much more investigation and work to understand and implement. But Step 3 may be committing to explore one or two of these options that most connect with you.

Here the steps that we have already discussed: Step 1: Begin with the end in mind, visualizing the impact you want to have in the lives of those close to you, and begin to think of what you can do now to move those relationships to where you want them to be.

Step 2: Step away from the day-to-day grind and visualize what you want freedom to look like.

Step 3: Commit to exploring one or two of the above options that most connect with you.

Step 4: Find a person or group of individuals who have done what you are attempting to do.

The options available to you are simple to list, but they are not easy to execute. Those whom you seek to help you in the process should specialize in these areas: accounting, financial advising, estate planning, and legal. But the most significant resource you can find is someone who has been where you are and has reached the end they envisioned. Think of this person as a coach or mentor—someone with more experience than you, who cares about seeing you achieve your vision.

One way to get this support is to create an advisory board. An advisory board is not a legal board of directors with fiduciary responsibility and liability. Instead, it is a group of advisers created to help with a specific purpose.

The advisory board can help with: Strategic Planning: Beginning with the end in mind may include a strategic plan that helps your company improve performance and profitability, thereby driving up the value of the business for whoever the potential new buyer might be. In this regard, visualizing the end may help you improve the operation now.

Personal Financial Planning: We affirm that letting go is a hard assignment. It is even harder when you

continue to have a financial stake in the company into your “retirement.” I was told by a veteran entrepreneur that “until you get your money out, you can never really let go.” This was wisdom that I needed to hear. Find the adviser who can speak this kind of truth to you.

Estate Planning: As mentioned, lawyers and financial planners can specialize in this area and be extremely helpful. But the counsel of someone like you who has already worked hard on their estate plan may help you to sift through all the options which can otherwise overwhelm.

CEO Coach: The success of executing the vision can be a heavy burden, and without a coach or mentor, the temptation to quit or procrastinate may be too tempting.

Resources

You may choose not to create a formal advisory board.

The encouragement is still to find the individuals who are willing to walk with you through the process. We all “network” with others in our industry to develop resources that will help each of us. Begin to network to find those who have executed one of the options listed above.

There are also a variety of groups that connect business owners and a lot of literature devoted to this subject. A few resources to help begin the process:

Helpful Organizations Entrepreneurial Organizations: (https://www. eonetwork.org/) Vistage: (www.vistage.com) Convene: (www.convenenow.com) EOS: (www.eosworldwide.com) Evolve USA: (www.evolveusa.org)

Final Observations

At this point in your career and life, you can look back and see the lasting impact that you have had – remember, this impact is most importantly seen in the relationships that you have influenced: family, friends, customers, industry, and community. But you are not done—as we noted, you are on third base, figuring out how to get home. This final leg will be critical to maximizing the impact you have.

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Remember that beginning with the end in mind is about imagination. Take time to imagine the impact that you will have on others, and the freedom that awaits you, and then keep taking the next step. You will look back and be glad you did!

References 1. Covey, S.R. (1989, 2004). The Seven Habits of Highly Effective People, Simon & Schuster, New York, New York.

2. Burlingham, B. (2014). Finish Big: How Great Entrepreneurs Exit Their Companies on Top, Penguin Group (USA), New York, New York.

Additional Sources Aronoff, C.E.; McClure, S.L.; Ward, J.L. (2011). Family Business Succession; The Final Test of Greatness, Palgrave MacMillian, New York, New York.

Christman, P.C. (2015). The Master Plan: Exit Strategy for Successful Business Owners, CreateSpace Publishing.

Tom Hutchison has worked for HOH Water Technology since 1979 and has been president since 1989, coming to HOH from The Trane Corp. HOH was started by his father in 1968. Based in the Chicago area, the firm has more than 90 employees with two manufacturing facilities and five warehouses with sales in more than 40 states. Mr. Hutchison earned his B.S. in mechanical engineering and an MBA in business administration from Southern Methodist University, and a master’s in Divinity from Trinity Evangelical Divinity School. He is married to his wife Beth, and they have five children and 11 grandchildren.

This article is based on a presentation given at the 2020 AWT virtual conference, which was conducted September 29–October 2, 2020.

World Leader in Supplemental Disinfection Technologies Partner with Sanipur and become your clients water hygiene expert today!

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67 the ANALYST Volume 28 Number 2

T.U.T.O.R.

Technical Updates, Tips, or Reviews

Understanding Water Treatment Markets

By Mike Henley, MD Henley & Associates

Approaching $1 trillion per year. That amount is a recent estimate of the global water treatment market from Global Water Intelligence (1). That said, one can find other opinions on the industry’s size. One will see market reports that place higher and lower estimates on annual sales.

Figure 1: Water stressed regions in the United States.

But the point of this T.U.T.O.R. article is not to dissect market reports but to examine the basics of the different components that together make up the water treatment business, which is a critical element for members of AWT. In this article, we will examine the following: What is the water treatment industry?

What are its market segments?

What are the business aspects?

Who are the end users, and how is an end user defined?’

Highlights from one recent market study.

Source: World Resources Institute/Aqueduct.

Figure 2: Global water availability.

What Constitutes the Water Treatment Industry?

Essentially, water treatment involves adjusting the quality of a water so that it is suitable for a specific use— whether that application is for drinking, a cooling tower/ HVAC, boilers, food and beverage, healthcare, steam, industrial process streams, petrochemical facilities, microelectronics, pharmaceutical plants, water reuse, or effluent discharge. This is the expanded view of the water business—it includes the treatment of a fresh stream, reclaimed water, and wastewater prepared for release into a sewage system.

The broad definition is appropriate for the industry in 2021, particularly with water shortages in some regions and the increasing move to use reclaimed water in industrial plants and elsewhere. In some regions, freshwater is not in short supply, but in other geographic locations, water is a precious commodity that because of droughts or regional weather patterns is simply in short supply. Figures 1 and 2 (2) are maps that illustrate in the United States and globally the different distributions, and those places with insufficient or ample natural supplies of water.

Source: World Resources Institute/Aqueduct.

So, to address the question at the start of this section, water treatment is partially motivated because of the need for water to meet particular quality standards for particular uses. So, one way to view the water treatment

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T.U.T.O.R. continued

field is by the following categories as listed below. Please note that this list is meant to provide an overview and is not exhaustive.

Equipment/systems suppliers Replaceable component makers Pumps and chemical feed systems Treatment chemicals Piping and valves Instruments, water-quality monitoring PLC, IoT, automation equipment Analysis laboratories Engineering firms System operation, IX resin regeneration Water management services Residential and small commercial sites Consultants, trainers, and other services

Short Overviews

Briefly, here are simplified explanations for each of these categories. Please note that many companies in this business can be involved in more than one area.

Equipment and system suppliers: The companies that manufacture the equipment that is used in treatment systems. Examples of these water purification technologies include clarifiers, multimedia filtration, activated carbon treatment, ozone generators, ultraviolet, filtration and membrane systems (reverse osmosis, nanofiltration, microfiltration, ultrafiltration, others), ion exchange vessels, vacuum degasifiers, and degassing membranes, among others.

Replaceable component makers: Makers of products like ion exchange resins, membrane filters (RO, UF, and MF), activated carbon, and cartridge filters, among others.

Pumps and chemical feed systems: Manufacturers of pumps used in water systems, including RO equipment.

A specialty area involves chemical feed pumps used to place treatment products into a water system.

Treatment chemicals: Includes specialty treatment chemicals for corrosion and scale control as well as disinfectants for biological control. Other aspects include the raw materials used to make specialty chemicals and treatment products for RO membranes, and water system cleaning.

Piping and valves: Water distribution piping and joints

(e.g., tees, elbows) and valves. Materials of construction include metals and thermoplastics with many uses, ranging from the transport of ultrapure, industrial, food and beverage, and potable water to less pure applications such as mining/natural resources water and wastewaters.

Instruments, water-quality monitoring: Sensors and instruments used to monitor important water-quality parameters, including pH, conductivity/resistivity, total organic carbon (TOC), particles, contaminants (e.g., boron, silica, arsenic), and treatment chemical concentrations. Flowmeters measure water flowrates. Sensors and instruments may be handheld or installed within the system. Additionally, this category includes colorimetric tests that can be used to monitor water quality.

PLC, IoT, automation equipment: This area is closely aligned with instruments and water-quality monitoring.

It involves programmable logic controllers (PLC) and related devices that permit onsite and offsite monitoring of water systems. Through a PLC or other smart controllers, it can be possible to determine how treatment equipment is operating, to troubleshoot, and to adjust system settings. IoT stands for the Internet of Things, and is essentially different pieces of a water system that use wireless technology and can be monitored.

Analysis laboratories: These are labs that provide water-quality monitoring for everything from wastewater effluent, drinking water, and industrial water, to high-purity water. They provide water-quality analysis reports and examine for specific contaminants, and will culture water samples to detect microbial contamination.

Associated lab services include IX resin analysis, RO membrane autopsies, and analysis to determine types of scaling. This segment includes privately run labs that serve multiple clients as well as in-house laboratories serving one or more facilities.

Engineering firms: Companies that help with the planning, design, and construction of a water treatment system. They will also offer advice on treatment technology choices.

System operation, IX resin regeneration: Businesses that, through an outsourcing contract, will operate all or a portion of a water treatment system at a facility.

Outsourcing can involve equipment makers who install

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a system and then operate it, or they will run equipment from a pre-existing system. Another variation involves Service DI. Originally, this entailed smaller IX bottles like found in labs and smaller water systems that would be replaced as needed. Today, there are services plants that regenerate IX resins off site and provide replacement vessels. These vessels are sometimes so large that they must be moved by a forklift.

Mobile water treatment: Originally known as “emergency water treatment,” these are service providers with mobile water systems (often placed in a semi-trailer) that are brought to the plant site either for long-term use or to temporarily treat water while an existing system is serviced or replaced.

Water management services: This segment is closely aligned with the concept of equipment system outsourcing, except it ties into the chemical treatment of water. This service essentially involves personnel from a treatment chemical provider who visit customers regularly to ensure that the treatment chemicals are working and to adjust as needed. Under these services, attention is paid to areas like cooling systems, boilers, and other components receiving water treatment chemicals.

Residential and small-commercial sites: Businesses that offer water treatment products and services for residential and small-commercial clients. Products can include whole house or business facility treatment equipment like softeners, small RO systems, activated carbon, cartridge filters, but on a scale appropriate for a house or small business.

Consultants, trainers, and other services: This segment includes businesses that train water system operators; troubleshoot and provide other assistance with water systems; and offer third-party services for supplying products like filters, IX resins, RO membranes, and other products. Associated areas are professional services such as legal and insurance. Even professional organizations like AWT, and sister trade groups such as the American Water Works Association, the Cooling Technologies Institute, the Water Environment Federation, and the American Membrane Technology Institute and their associated conferences fall within this category.

End users? What is an end user?

In theory, these are the customer sites that need water treatment products and services. They are the buyers and users of treatment chemicals and equipment, filters, pipes and valves, and water management services, among other items that make up water purification systems.

There is still much validity to this view, even in 2021.

But, changes in the business world that began in the last 20 years of the 20th century make it necessary to at least revisit what firms are the end users. In the classical sense, a few of the many examples would be power stations, commercial and industrial cooling tower owners, institutional HVAC systems, a local food processing plant, a large hotel, a local car wash, industrial plants, and petrochemical facilities. However, there has gradually been a change over the years about who makes the buying decision. Where once that power resided within the offices of the local end-user plant, there has been a subtle change, and now the party with the purchasing authority is not always straightforward.

A good example would be the development of the mobile water treatment business, which companies like Arrowhead (now a part of Evoqua Water Technologies, LLC), Ecolochem (now a part of Suez Water), MPW, Ionics, and others pioneered. An important part of this original business was to provide mobile and skidmounted “emergency” water treatment systems that were available within a few hours if a power station or industrial facility’s onsite water system needed to shut down for maintenance or broke down.

From that “mobile” concept, we saw the development of the whole “outsourcing” movement. Here, equipment makers and others sought to convince end-user companies to basically turn over the keys for water treatment operation to a service company that would simply provide the personnel to run the facility’s water systems (cooling tower, boilers, treatment system). In the more expansive model, the service provider would own the treatment equipment, and the end user would pay a fee for the equipment and system operation. The “buildown-operate” models have roots in this model.

This approach gained favor as corporations came to view water treatment in a different light. Instead of being considered an intricate part of the facility’s operations,

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some companies, and even municipal agencies, came to view their water treatment departments as more of a “utility.” Under this approach, one could easily decide to contract out water treatment services to a third party. In those cases, the in-house water experts would either be reassigned to other tasks or sadly, let go … sometimes under the auspices of corporate “right sizing,” “downsizing,” “early retirement,” “core competencies,” and other approaches. One result was that some companies suddenly had few in-house employees overseeing their water treatment.

Figure 3: Examples of end users in the residential and small-commercial water treatment market.

Under this scenario, suddenly the choice of equipment and components shifted to the service companies, and they came to also play a purchasing role like the water end user.

The point of these observations? It is quite simple, that in 2021, the term “end user” needs to be thought of differently. Today, end users who make buying decisions, and even treatment decisions, extend beyond the local plant.

These “quasi end users” can be chemical suppliers, equipment makers, engineering firms contracted to design and build the plant, and even third-party consultants whose opinion influences a purchasing decision.

Figure 4: Examples of end users in the ultrapure water market.

The Traditional Approach

But it is important to note that many end-user businesses did not make this change and that the decision on buying water treatment products and services is made in house.

Buying decisions vary depending on the company size and culture and may be made by top executives, a committee, or, quite simply, by the water system operator(s).

Examples of End Users

Figures 3 through 5 provide breakdowns of the types of end users found in these arenas: residential and small-commercial water, ultrapure water (UPW), and industrial water (IW). Table A gives examples of other types of water end users not listed in Figures 3 through 5.

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industrial/boiler water, and ultrapure water (microelectronics, pharmaceuticals, and utility power plants).

Desalination and water reclaim fit within this list.

Family businesses, regional and national corporations, and multinational firms make up the privately owned side of the industry, while most drinking water and wastewater utilities are government-owned.

Figure 5: Examples of end users in the industrial water market.

Over the years, the market has grown, and some market research is predicting it will soon surpass $1 trillion/year. One recent forecast by Global Water Intelligence (GWI) WaterData (1) estimates the market could grow from $832.5 billion in 2020 to $965.4 billion in 2025. This forecast is based on operating and capital spending by utilities and industrial companies and is based on water and wastewater users. The forecast is part of GWI WaterData, an online market intelligence platform. The GWI forecast is shown in Table B. Table A: Other End-User Examples

Table B: Global Water Market Projections—2020 to 2025

Municipal Drinking Water

Region

2020 capex ($ million)

2025 capex ($ million)

5-year CAGR

Desalination

North America

$209,172.9

240,811.58

2.9%

Municipal Wastewater

Latin America/ Caribbean

$40,742.79

$49,308.31

3.9%

Europe/ Central Asia

$198,522.17

$218,480.13

1.9%

East Asia/ Pacific

$289,983.82

$335,623.17

3%

Southern Asia

$27,687.99

$36,540.38

5.7%

Middle East/ Africa

$66,437.31

$84,691.13

5%

Global

$832,546.99

$965,454.69

3%

Private facility drinking water (e.g., resorts)

Industrial Wastewater Environmental sites (e.g., protection against saltwater intrusion in coastal regions) Water Reuse

Highlights From a Recent Market Study As we near the end of this overview of the water business, we will briefly review water treatment itself, which has become an important industry. In its simplest sense, the industry includes companies that offer products to adjust water chemistry to deal with corrosion, scaling, and biocontrol. At the other end of the spectrum are the businesses that offer products that physically remove contaminants from water—whether as suspended solids (measured as total suspended solids [TSS]) or dissolved solids (ions measured in total dissolved solids [TDS]).

From this simple dichotomy, the global water treatment market has risen during the past 100 or more years.

Water treatment touches many areas, including drinking water, sewage water treatment, cooling water, mining, oil and gas, food and beverage, commercial/institutions,

Source: Data courtesy of Global Water Intelligence/GWI WaterData (2020).

According to the GWI data (1), the top three largest global markets are East Asia/Pacific, North America, and Europe/Central Asia. The data show that the East Asian/Pacific 2020 sales were nearly $290 billion and are expected to reach $335.6 billion in 2025. North America, the second biggest market, has sales of $209.2 billion for 2020, which are projected to reach $240.8 billion in 2025. The European/Central Asian market posted sales of $198.5 billion in 2020. The market in this region is expected to increase to $218.5 billion in 2025. The overall projected compound annual growth rate (CAGR) for the global industry between 2020 and 2025 is 3%. Two smaller markets—Southern Asia and

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the Middle East/Africa are projected to have CAGRs of 5.7% and 5%, respectively.

Table C provides a breakdown of the major water treatment markets. The one segment not included in the data is the POE/POU market, which includes softeners and targets single-family/multi-family residences and small-commercial businesses.

Table C: Global Water Treatment Market by End-User Segments Sector

2020 ($ million)

2025 ($ million)

CAGR%

Commercial/ Institutions

$1,289

$1,649.9

5.1%

Food and Beverage

$31,102.4

$36,719

3.4%

Microelectronics

$12,908

$15,929.5

4.3%

Mining

$13,036.2

$16,239.7

4.5%

Other industries

$49,386.9

$58,404.6

3.4%

Pharmaceuticals

$8,702.4

$10,314.3

3.5%

Power generation

$33,426.6

$38,948.2

3.1%

Pulp and Paper

$14,235

$16,156.4

2.6%

Refining and Petrochemicals

$21,879.9

$25,576.3

3.2%

Upstream Oil and Gas

$33,450.8

$41,424.5

4.4%

Utility Wastewater

$292,232.8

$341,405.3

3.2%

Utility Water

$320,896.1

$362,685.2

2.5%

Total

$832,546.1

$965,452.9

3%

The global water market areas incorporated into the data used in the tables include municipal and industrial water and wastewater treatment. Categories making up the market figures consider treatment chemicals, equipment/ treatment systems, cooling water, services to end users (e.g., outsourcing), filters, membranes, IX resins, components (pumps, instruments, piping/valves), and engineering/design/construction services. The data does not include the home drinking/small-commercial segment.

Final Thought

The aim of this article is to provide a holistic overview of the water treatment business. The water business can be examined from the perspective of the types of business categories, or it can be looked at in the context of end users. It should be noted that, while end users have traditionally made their purchasing decisions, in recent decades, companies active in the water business have come to have greater influence in these choices.

References 1. GWI WaterData (2020). GWI WaterData Online Service, Global Water Intelligence, Oxford, England, www.globalwaterintel.com.

2. WRI (December 2020). “World Water Stress Map” and “Water Stressed Areas of the United States,” World Resource Institute/Aqueduct, Washington, D.C., www.aqueduct.wri.org.

Source: Data courtesy of Global Water Intelligence/GWI WaterData (2020).

Table C shows that the largest market segment is utility water, which had global sales of almost $320.9 billion in 2020 and is expected to reach $362.7 billion in 2025.

The next biggest market is utility wastewater at $292.2 billion in 2020. It is expected to rise to $341.4 billion in 2025. In 2020, drinking water and municipal wastewater utilities accounted for $613.1 billion of the world water treatment market. In 2025, they are expected to account for almost $704.4 billion. The remaining markets include upstream oil and gas, refining and petrochemicals, pulp and paper, commercial/institutional, food and beverage, microelectronics, mining, other industries, pharmaceuticals, and power generation. According to Table C, the four water industry business segments with the fastest growing percentage growth rate are commercial and institutions (5.1%), Mining (4.5%), Upstream oil and gas (4.4%), and microelectronics (4.3%).

Mike Henley provides consulting services through MD Henley & Associates and serves as technical editor of the Analyst. He formerly was editor of Ultrapure Water Journal for 27 years and has been active in different aspects of water treatment and the associated businesses for more than 30 years. Mr. Henley’s background includes helping with the organization of the technical programs at more than 60 UPW conferences, including Water Executive Forums.

74 the ANALYST Volume 28 Number 2

2021 ANNUAL CONVENTION & EXPOSITION SEPTEMBER 22-25, 2021 Rhode Island Convention Center | Providence, Rhode Island

Join us in person at the AWT 2021 Convention & Exposition. At this event 1,200 industry leaders learn new ways to lead high-performing companies, improve sales, and better understand the challenges facing all of us. These interactions with one another are vital to staying current and energized. The three-day educational program includes knowledgeable subject-matter experts to ensure that you get the essential updates, fresh strategies, and practical advice you need.

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Business Notes

Giving Critical Feedback Is Even Harder Remotely

By Therese Huston

Delivering constructive feedback is nerve-wracking in the best of times. After all, most managers don’t want to crush their employees’ spirits. These tough conversations are even harder to have as multiple crises and their side effects wear on, which can make the negativity bias that normally affects our perceptions even worse. To top it all off, the switch from in-person to remote office settings has removed the nuance that can help soften the blow of bad news.

As Roy Baumeister and John Tierney explain in their recent book “The Power of Bad,” negativity bias is the “universal tendency for negative events and emotions to affect us more strongly than positive ones.” In other words, the bias shapes how we receive feedback, leading us to ruminate over criticism and brush past praise.

Negativity bias can be a challenge in any feedback conversation, but it’s particularly problematic right now because of the chronic stress many people are experiencing as a result of the COVID-19 pandemic. Research has shown that chronic stress is tied to a stronger negativity bias. Right now, in what has been a trying time for so many people, employees may be even more likely to focus on the negative in your message. If you say, “I need you to redo that report,” they might hear, “Your work is really slipping,” or worse yet, “I’m not sure you belong in this job.” You’re trying to help them improve, but they think you’re judging them, and harshly.

Managers I’ve interviewed note that when they’re giving feedback in person, they can adjust the context to communicate the severity of the news. One midlevel manager at a tech company with an open office plan used to pull employees into a focus room when he wanted a private feedback conversation. He’d pick a room with comfy, colorful chairs and a low coffee table if he wanted the environment to feel relaxed and casual, and he’d pick a conference room with chairs around a big formal table

if he wanted to communicate a more serious tone. With his employees now working at home, he can’t control the setting that way.

Many managers now find themselves unable to rely on nonverbal cues when having tough conversations. The stress that’s increasing negativity bias and the circumstances that are keeping the workplace at home are likely to persist for a while longer. Taking a few steps to be more strategic about how you deliver constructive feedback can help prevent negativity bias from distorting how your employees receive your feedback.

1. START BY ASKING QUESTIONS: Begin your constructive feedback conversation by asking your interlocutor about his perspective. You might ask, “What did you think of that report?” or even, “How did that go?”

You want to learn about that person's experience and what he thinks of his work — maybe he has never worked so hard on a three-page document before. It will be easier to raise your concerns if the employee has already mentioned the issues at hand.

What if someone says he thinks the project you asked about went well and doesn't voice any concerns? You might be dealing with an “unaware underperformer.”

If you observed the problem directly, you can say, “I ask because I noticed X,” and if you didn’t observe the problem yourself, try, “I ask because I heard X.” In either case, you’re hoping the employee is willing to brainstorm ways to handle the situation differently in the future. Be clear that each employee is being evaluated on results, not effort.

2. OFFER APPRECIATION BEFORE YOU OFFER CRITICISM: In their research, Harvard Business School's Leslie John, Alison Wood Brooks, and Jaewon Yoon have found that individuals are more receptive to constructive criticism if they’re first told what specifically

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Business Notes continued

they did well. Your goal here isn’t a simple “You do good work.” Instead, make it as concrete as the concern you’re about to raise—for example, “It’s clear you have a mastery of the data.” If there isn’t much you can praise about a person's work, acknowledge the individual's willingness to keep improving.

3. STATE YOUR GOOD INTENTIONS: John has also found that explicitly stating your good intentions goes a long way toward improving how the other person hears bad news. Try, “I’m in your corner,” or “I know you’re trying to improve your writing and I want to help you get there,” or even, “I want to be able to use this report as a model for the rest of the team.”

person to email you by the end of the day with his three takeaways. It’s better to correct any misunderstandings in the moment, but the same day is better than letting your employees ruminate overnight or over the weekend.

While the ongoing stress brought about by the pandemic can make your employees take constructive feedback even harder than usual, taking care to deliver it with clarity and sensitivity will help them focus on the reality of your message, even in a remote environment.

Therese Huston is the author of "Let’s Talk: Make Effective Feedback Your Superpower."

© 2020 Harvard Business School Publishing Corp.

4. CLARIFY AND CONTRAST: Helene Lollis, the CEO of Pathbuilders, a firm that helps women fulfill their leadership potential, finds that contrasting statements can bring clarity. After you’ve raised your concern or suggestion, follow it with, “What I mean is X. What I don’t mean is Y.” For instance, “What I am saying is that I’m concerned you don’t have the bandwidth right now. What I am not saying is that you lack the ability.

Uniphos 2020.pdf I know this would be easy for you under other circumstances.” You can preemptively address any negative impressions that the other person might entertain.

5. HAVE THE OTHER PERSON STATE THE KEY TAKEAWAYS FROM YOUR CONVERSATION: Save time at the end of the conversation to ask, “What are your top three takeaways?” It may feel redundant, but you’ll learn if your interlocutor is taking a negative nosedive and if so, you will have the ability to reframe the message. Sandy Anuras, vice president of global marketing technology at Expedia Group, observes that when you’re giving feedback remotely, it’s far easier for the other person to end a call abruptly than it would be if the conversation took place in person. If someone urgently needs to get off the call, ask that

1 4/23/2020 3:57:49 PM

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77 the ANALYST Volume 28 Number 2

Advertising Index 33 American Water Chemicals, Inc.

19 North Metal & Chemical Company

47 AMSA, Inc.

13 Pulsafeeder, Inc.

57 AquaPhoenix Scientific

45 QualiChem, Inc.

61 Bio-Source, Inc.

67 Sanipur US LLC

43 Brenntag North America

71 ScalingUp H20

78 Browne Laboratories, Inc.

35 Sigura

53 Chem-Met Company

25 SOLUGEN

59 CHEMetrics, Inc.

80 Special Pathogens Laboratory

2

77 Uniphos, Inc.

Environmental Safety Technologies, Inc.

18 IDEXX

79 Walchem, IWAKI America Inc.

6

7

Innovative Waters, LLC

WaterColor Management

40 Myron L. Company

People crafted solutions since 1976.

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423.698.7777 | BrowneLaboratories.com 78 the ANALYST Volume 28 Number 2

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