New Ohio Hospital Legionella Regulations

In September 2024, Ohio updated its hospital licensing regulations to include explicit requirements for preventing Legionnaires’ disease. Under Ohio Code 3701-22-07, hospitals must implement a water management program (WMP) aimed at reducing waterborne pathogens, including Legionella. Below, we break down these new rules, including testing timelines, remediation steps, and the role AWT members can play in helping hospitals achieve compliance.

Ohio Hospital Regulations: Key Changes to Ohio Hospital Legionella Regulations

• Effective Date: September 14, 2024
• Relevant Rule: 3701-22-07, which applies to basic hospital functions
• Section K: Requires hospitals to establish a comprehensive approach to infection prevention, antibiotic stewardship, and new water management protocols.

Water Management Program (WMP)

Hospitals must create and maintain a water management program that addresses the risk of waterborne pathogens, especially Legionella. The program should follow CDC guidance for monitoring and managing building water systems.

Key Components of the WMP:

• Risk assessment of water systems and equipment (e.g., cooling towers, therapy spas, decorative fountains).
• Written plan detailing monitoring procedures and corrective actions.
• Regular reviews and updates based on test results or system changes.

Validation Water Sampling: What’s Required for Ohio Hospital Legionella Regulations

Within the first 12 months of the WMP’s implementation, hospitals must conduct two sets of validation water samples specifically testing for Legionella.

1. Scope of Sampling
   • All hot potable water loops.
   • Any water source identified in the WMP’s risk assessment (e.g., cooling towers, ornamental fountains, therapy spas).
2. Accredited Laboratory
   • Testing must be performed by a certified or accredited lab to ensure accurate results.
3. Frequency
   • If a hospital’s systems measure more than 1 CFU/mL of Legionella for two consecutive years, it may reduce sampling to once annually.

Reporting & Investigations

• Hospitals must use the CDC’s Legionella Environmental Assessment Form (LEAF) during any case investigation.
• After an investigation, the hospital must submit WMP documents and one year of testing results to the Ohio Department of Health.

Remediation Protocol for Ohio Hospital Legionella Regulations

If Legionella is detected, hospitals should take immediate remediation actions, such as:

1. Adjust Water Temperatures
   • Increase temperatures in hot water storage tanks or recirculation systems to levels that inhibit bacterial growth.
2. Improve Water Flow
   • Eliminate stagnation by regularly flushing unused water lines.
3. Short-Term Remediation
   • Disinfect and flush affected systems.
4. Permanent Disinfection Systems
   • Consider installing chlorine dioxide, copper-silver ionization, or other long-term solutions.

Communication & Resampling

• Notify Patients, Staff, and Visitors: Provide clear updates on the issue and corrective steps.
• Post-Remediation Testing:
  • First test: 48 hours after remediation.
  • Second test: 48 hours plus 10 days after remediation.

Ohio’s updated hospital licensing regulations mark a significant step toward reducing Legionnaires’ disease outbreaks. By establishing a robust water management program, conducting validated testing, and implementing prompt remediation measures, hospitals can protect patients, staff, and visitors from waterborne pathogens. For seamless compliance, partnering with knowledgeable water treatment experts ensures consistent, effective Legionella prevention strategies.