The Centers for Disease Control and Prevention (CDC) has published a request for information (RFI) on effective methods for achieving implementation of water management programs (WMPs) intended to reduce Legionella growth and transmission in buildings at increased risk. CDC notes that, while a consensus standard (ASHRAE) and guidance exist regarding development and implementation of WMPs, there are gaps regarding the most effective methods to encourage WMP implementation. CDC will use the information it receives to inform efforts to prevent Legionnaires disease and other diseases caused by waterborne pathogens.
Since the most useful information will come from healthcare facilities that have implemented WMPs, APIC encourages our members to respond individually about their own facilities’ experiences. The RFI includes instructions for responding; but we recommend the following tips:
· Please read the RFI.
· Draft your response in a separate document, then upload that document to the CDC docket (Docket No. CDC-2017-0069).
· Write your response on your organization’s letterhead, or include contact information.
· Submit your response via the federal government’s rulemaking portal at http://www.regulations.gov.
o On the home page, type CDC-2017-0069 in the search box and click the “search” button on the right side of the box.
o The next page will have a “Featured Result” box at the top. Just below the box on the right side of the page, click the “Comment Now!” button.
o In the Comment box, note that you are attaching your facility’s response to the RFI on water management programs to reduce Legionella growth.
o Below the comment box, click the “Choose files” button to upload your document.
o Provide all required information on the rest of the page.
o The bottom of the second page notifies you that all comments submitted as part of the docket are publicly available. Under this statement, click the “I read and understand the statement above” box, then click the “Submit Comment” box at the bottom right corner of the page.
o You will receive a confirmation that your comment has been submitted.
o Comments are due on or before October 17, 2017.
o If you have questions or need assistance, please contact Nancy Hailpern at APIC at email@example.com or 202-454-2643.
CDC is requesting input on any or all of the following questions:
(1) What existing standards or guidance does your organization use for the prevention of Legionella growth and transmission?
(2) Are there other standards or guidance for the prevention of Legionella growth and transmission that you would find useful but do not exist or are not currently available to you? If so, what information should those standards or guidance contain?
(3) What is your organization’s role, and your role within the organization, in achieving implementation of WMPs by owners and managers of buildings at increased risk for Legionella growth and transmission?
(4) In your organization’s experience, what are the principal barriers to implementation of WMPs by building owners and managers?
(5) Where there are barriers, what has your organization done to overcome these barriers?
(6) Where implementation of WMPs has gone smoothly, what factors (e.g., resources, guidance, activities) contributed to this success?
(7) Has your organization had experience with approaches to WMP implementation that are specific to certain settings (e.g., hotels, hospitals) or devices (e.g., cooling towers, potable water)? If so, have you learned anything from these different approaches that could be used to improve WMP implementation? Have you looked for or experienced any unintended consequences related to a WMP?
(8) A limited number of jurisdictions have implemented regulations to reduce the risk of Legionella growth and transmission (e.g., New York, New York City). In your state or local jurisdiction, should building codes or other types of public health regulation or legislation be used to help prevent Legionnaires’ disease? Why or why not?
(9) Are there other approaches to reducing the risk of Legionnaires’ disease that your organization has found to be useful besides implementation of WMPs?
(10) What additional considerations are relevant to developing guidance for preventing Legionnaires disease?
(11) Has your organization implemented specific approaches to reducing the risk of disease due to other opportunistic waterborne pathogens besides Legionella? If so, please explain. Do these approaches conflict in any way with your approaches to reducing the risk of Legionnaires disease?