07/16/2026

Survey Tip of the Week: Water Flow Diagrams

According to State Operations Manual, F880, facilities must be able to demonstrate its measures to minimize the risk of Legionella and other opportunistic pathogens in building water systems such as by having a documented water management program. Water management must be based on nationally accepted standards (e.g., ASHRAE (formerly the American Society of Heating, Refrigerating, and Air Conditioning Engineers), CDC, U.S. Environmental Protection Agency or EPA) and include an assessment to identify where Legionella and other opportunistic waterborne pathogens (e.g., Pseudomonas, Acinetobacter) could grow and spread.

Resources are available to develop and implement a water management program, such as: 

• The ASHRAE Standard 188 - Legionellosis: Risk Management for Building Water Systems. 
• The CDC toolkit to facilitate implementation of the ASHRAE Standard titled Developing a Water Management Program to Reduce Legionella Growth & Spread in Buildings: A Practical Guide to Implementing Industry Standards; and 
• The EPA's Technologies for Legionella Control in Premise Plumbing Systems: Scientific Literature Review.

The Long-Term Care Survey Process instructs surveyors, through interviews, to determine whether the facility has assessed (e.g., description of the building water systems using text and flow diagrams) where Legionella and other opportunistic waterborne pathogens can grow and spread.