A Step-by-Step Guide to Creating a Compliant Water Management Plan (WMP)

Protecting Your Facility from Legionella and Meeting 2024 Joint Commission Standards

A well-designed Water Management Plan (WMP) is your facility’s best defense against Legionella outbreaks, and as of 2024, it’s a requirement for most healthcare and extended care organizations under the Joint Commission’s updated standards. But creating a truly effective and compliant WMP can be overwhelming if you’re unsure where to begin.

This guide walks you through the essential components of a strong WMP and how Legionella Specialties can help you stay ahead of regulatory demands while ensuring patient and staff safety.

Step 1: Assemble Your Water Safety Team:

A WMP starts with the right people. Form a multidisciplinary team that includes facility engineers, infection control personnel, and building managers. This group will be responsible for developing, implementing, and maintaining the plan.

Tip: Not sure who should be on your team? We help facilities identify and train internal team members to ensure accountability and effectiveness.

Step 2: Map and Analyze Your Water System:

Understanding your plumbing infrastructure is critical. Your team should create schematics of all water systems, identifying critical control points such as:

• Water heaters

• Cooling towers

• Decorative fountains

• Ice machines

• Showerheads

• Medical equipment using water (e.g., hydrotherapy tubs)

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Step 3: Identify Risks and Control Locations:

Using your system map, assess where Legionella growth is most likely to occur. These are areas where water may stagnate, temperatures are ideal for bacterial growth (77–113°F), or disinfectant levels may be low.

Control locations often include:

• Dead legs or unused pipes

• Storage tanks

• Mixing valves

• Points of aerosolization

Step 4: Define Control Measures and Set Limits

Each risk area must have defined control measures (like temperature monitoring, ORP/disinfectant residual checks, and flushing schedules) and acceptable limits for those parameters.

For example: Hot water should be stored at ≥140°F and distributed at ≥124°F. Disinfectant residuals should stay within a target ppm range depending on system type.

Step 5: Monitor, Document, and Validate:

Consistent monitoring is key. All control measures should be documented, and routine testing (including Legionella sampling) should validate the effectiveness of your plan.

Legionella Specialties provides monthly, quarterly, or annual testing services with full lab reporting and corrective action recommendations.

Step 6: Establish Corrective Actions:

If control limits are not met say, low chlorine levels or a positive Legionella result, your WMP should define specific corrective steps, such as:

• Flushing or hyperchlorination

• Shock disinfection

• System remediation or secondary disinfection

  
  

We assist clients in rapidly responding to exceedances and implementing solutions like AquaGuard MO, our proprietary, low-impact mineral oxychloride treatment.

Step 7: Review and Update Your Plan Annually:

An effective WMP is not a one-time document. It should be reviewed at least annually and whenever there are:

• Changes in system design

• New regulations

• Legionella-positive findings

• Shifts in building usage

Need Help Building or Updating Your WMP?

At Legionella Specialties, we specialize in developing customized, Joint Commission-compliant Water Management Plans tailored to your facility’s needs. From system surveys to testing and treatment, we support every step of the process.