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What Is The PBS’s National Order For Drinking Water Quality Management?
The U.S. General Services Administration (GSA) Public Building Service (PBS)’s national order, “Drinking Water Quality Management”, for effectively managing and overseeing drinking water (PBS 1000.7A) requires baseline testing of drinking water and implementation of various water quality management best practices to identify and address potential issues at 1,400 federally owned facilities and approximately 6,000 leased spaces. The baseline testing will assess the presence of lead, copper, and bacteria, including total coliforms (E. coli) and Legionella. Water testing at specific building locations will be communicated by GSA at the local level.
Who is Required to Adhere to GSA’s Baseline Water Testing?
The GSA baseline water testing requirements apply to all active and occupied federally owned and leased facilities under the jurisdiction, custody, and control of the GSA with drinking water systems that are over 1,000 sq. ft. and require that at least 10% of cold-water outlets primarily designed for human consumption (drinking fountains, bottle fillers, kitchenette faucets) and showers must be tested for lead, copper and total coliform bacteria (including E. Coli). Additionally, there is a need to sample a representative number of hot and cold-water outlets for the presence of Legionella.
Test results that exceed the applicable federal, state, or local thresholds, must result in remediation actions to reduce concentration levels. Post-remediation water testing on failed outlets must be conducted before resuming their use.
What Qualifications and Requirements to Conduct Baseline Water Sampling Under PBS 1000.7A?
RHP has qualified professionals with experience in environmental, industrial hygiene, or engineering consulting with a minimum of two years of onsite experience in conducting potable water sampling, including microbiological sampling methods for Legionella, and are well positioned to conduct the PBS recommended baseline water sampling. GSA requirements indicate that preference must be given to qualified professionals that hold either an ASSE 12080 certification, a certified industrial hygienist (CIH) designation, or a health and safety professional working under the supervision of a CIH or an ASSE 12080 certified individual. RHP has qualified professionals which hold both a CIH and ASSE 12080 certification.
What is GSA’s Drinking Water Quality Management?
The Desk Guide for Drinking Water Quality Management, GSA’s Drinking Water Quality Management order was initially established due to the occupancy and utilization impacts on buildings during and after COVID-19. The adoption of and acceleration of remote work changes in building utilization has highlighted the importance of managing building facilities to prioritize the health and well-being of their occupants and visitors. The changes in building utilization, combined with the best practices learned during the pandemic, necessitate the assurance that building potable water systems are providing fresh water at point-of-use outlets.
Water stagnation can occur within building water systems when water remains still within the plumbing network due to non-usage, leading to the development of water quality issues. Stagnation events can occur in buildings with the overestimated design capacity, during season building use (e.g., schools during summer), construction activities, periods between occupancy, natural disasters, and changes to building operations.
To address concerns, federally owned and leased facilities, including facilities operating under a GSA delegation of authority, regardless of occupancy levels, must implement the PBS Guidance to Maintain or Restore Water Quality if they fall within the following criteria:
- Buildings over 50,000 sq. ft. with water booster pumps (both conditions must apply); or
- Buildings over six (6) stories
As part of the guidance, a qualified contractor must assess the building’s plumbing system and is responsible for developing a water sampling and flushing plan, unless a building specific ASHRAE 514 water management program (WMP) or ASHRAE 188 water management plan has already been developed and implemented for the potable water system. All contractors involved in the development of WMP must posses the ASSE 12080 Legionella Water Safety and Management Specialist Certification or its equivalent.
RHP professionals have received ASSE 12080 training certification and extensive experience in WMP development and validation to reduce the growth and spread of building-related Legionella following best-practice guidance as noted by ASHRAE® Standard 188 for public and commercial buildings.
Contact RHP Risk Management to conduct the required Baseline Water Sampling and Development of Water Management Plan Under PBS 1000.7A
RHP Risk Management’s staff of scientists represent various fields of practice including environmental engineering, industrial hygiene, exposure science, and human health risk assessment.
RHP’s Certified Industrial Hygienists (CIH) have received ASSE 12080 training certification and have experience in responding to suspected and confirming outbreaks of waterborne pathogens (e.g., Legionella) and guided management with response actions to identify root-causes, implement corrective actions, and create policies and procedures (e.g., water management plans) to prevent future recurrences.
Contact RHP Risk Management for baseline water sampling and development of water management plans in compliance with PBS 1000.7A by calling (866) 481-8188.