Established in 1949, the General Services Administration (GSA) is an independent agency that manages and supports more than 60 Federal departments and agencies. GSA manages government buildings and real estate, provides product and service procurement support, and develops policies and regulations.

With the health and safety of federal employees always a top priority, the GSA has established a proactive approach and guidance for managing drinking water quality, including conducting Legionella testing in GSA-controlled spaces.

GSA Guidance for Legionella Testing

The GSA Order: Drinking Water Quality Management (PBS 1000.7A), mandates regular testing and provides a framework for baseline assessments, helping identify potential issues before they become public health concerns.

This testing program assesses the effectiveness of water treatment systems and allows facility managers to detect Legionella early on. The directive requires federal building operators to partner with experts who conduct tests on-site and provide real-time data for effective and efficient decision-making.

GSA’s water quality management strategy is designed to align with the industry’s best practices. They leverage and incorporate the Centers for Disease Control and Prevention resources for Legionella, EPA regulations for Public Water Systems as a threshold, and ASHRAE Standards 188 & 514, in addition to Guideline 12.

The Do’s and Don’ts of GSA Order PBS 1000.7A

Do’s: Key Requirements for Water Quality Management

1. Conduct comprehensive baseline testing: Under the GSA order, all government-controlled properties over 100 square feet must complete a baseline water quality test by the end of fiscal year 2024. Testing includes a thorough assessment of contaminants like Legionella, E.Coli, lead, and copper, which are crucial for identifying potential health risks.
2. Documentation and annual reporting: Documentation plays a crucial role in compliance. All federally owned or managed facilities with Community Water Systems (CWS) must publish an annual Consumer Confidence Report (CCR). These reports provide occupants with insights into local water quality, helping to build trust through transparency.

Don’ts: Avoiding Common Compliance Pitfalls

1. Don’t overlook small facilities: While smaller buildings may not be held to every standard of a larger facility, they are still subject to testing and maintenance requirements. Facilities of any size–particularly those serving vulnerable populations must not overlook baseline testing and routine maintenance.
2. Avoid water stagnation in key areas: Allowing water to stagnate can lead to combination, especially with bacteria such as Legionella. Weekly flushing and monthly aerator maintenance must be part of the routine to prevent bacterial growth. This is especially vital for areas with high occupant interaction, like showers and healthcare units.

Considering The Use of Legionella Filtration

The risk of Legionella and other opportunistic waterborne pathogens is something that must be taken seriously. Implementing point-of-use and in-line ultrafilters within your water management plan is crucial in protecting building occupants.

It’s important to have filters capable of bacteria retention (e.g., Legionella) installed on equipment that can expose building occupants to contaminated water, such as sinks, showers, ice machines, drinking water fountains, bottle fillers, decorative water features, and beverage-dispensing appliances.

In the event that sinks and showers report positive counts of Legionella or if an outbreak occurs, having a solution that is both fast and reliable is crucial. Point-of-use infection control filtration is a cost-effective, easy-to-install solution to safeguard building occupants. In-line water filters integrate seamlessly into water distribution systems and afford flexible application into a wide variety of fixtures and equipment.

Nephros infection control products are all 510(k)-cleared as FDA Class II filters, ensuring the highest standards of in-use performance testing, accountability, and water safety.