BY SUSAN KLACIK, BS, CRCST, CIS, CHL, ACE, FCS
The Joint Commission (TJC) released a new water management standard (EC.02.05.02. EPs 1-4), which took effect on January 1, 2022. Water quality is a very important component of medical device processing. While this new standard is designed to improve the quality and safety of care provided to immunocompromised hospital patients, it also contains water management measures that impact medical device processing.
This new standard requires that an individual or team be responsible for oversight and implementation of the water management program, including but not limited to development, management and maintenance activities. Author’s note: Because water is fundamental to medical device processing, it is advisable to have representation from the sterile processing department involved in interdisciplinary activities that address water management. The standard also specifies required elements to be included in the water management program, such as a basic diagram that maps water supply sources, treatment systems, processing steps, control measures and end-use points. The water risk management plan is based on the information in the diagram and includes an evaluation of the physical and chemical conditions of each step of the water flow diagram. There is also a requirement for an annual review of the water management program (and whenever changes occur); this includes having a plan for addressing the use of water in areas of buildings where water may have been stagnant for a period (e.g., areas that have temporarily closed due to COVID-19).
Documentation is essential
Individuals or team members responsible for the water management program should document results of all monitoring activities, corrective actions and procedures to follow whenever a test result falls outside acceptable limits (this includes when a probable or confirmed waterborne pathogen indicates action is necessary). It is important to document corrective actions that were taken when control limits are not maintained; when changes have been made to the water system that would add additional risk; when new equipment or at-risk water systems have been added that could generate aerosols or be a potential source for Legionella; and when a new wing or building has been commissioned.
Health care facilities’ water systems are often comprised of complex distribution pathways with areas of stagnation, exposure to a variety of plumbing materials, and wide variability in temperature, pH, and disinfectant types and levels. These conditions can promote the development of biofilm and opportunistic pathogens such as Legionella, nontuberculous mycobacteria, and Pseudomonas species. Because of the nature of water systems in health care settings, water exposure while in the facility can place patients at risk for infection from waterborne pathogens (or even at the risk of outbreak exposure). Further, the Centers for Disease Control and Prevention (CDC) has conducted outbreak investigations that demonstrate how most problems leading to healthcare-associated infection outbreaks could be prevented by effective water management programs. To prevent issues related to poor water quality, TJC adopted this standard as part of an effective water management program that includes individual or team oversight, evaluation of water supply sources, water monitoring protocols and corrective actions.
Additional resources are available that describe the water quality requirements for medical device processing, including AAMI TIR34:2014, Water for the reprocessing of medical devices, which is currently under review and is being upgraded to a standard. Water quality is also addressed in the AORN 2022 Guideline for Care and Cleaning of Surgical Instruments.
To download the new Joint Commission water management standard, visit: https://www.jointcommission.org/-/media/tjc/documents/standards/r3-reports/r3-report-water-management-final_nov1.pdf.
– Susan Klacik, BS, CRCST, CIS, CHL, ACE, FCS, serves as a clinical educator for the Healthcare Sterile Processing Association (HSPA) and has served as the HSPA (formerly IAHCSMM) representative to the Association for the Advancement of Medical Instrumentation (AAMI) since 1997.
