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Maintaining drinking water quality and Legionella testing in apartment buildings and other mixed-use properties

8-minute read

Apartment buildings in inner-city locations typically house not only apartments but also shops and businesses, which share both a common drinking water installation as well as the facilities provided by this drinking water installation. There various types of usage also give rise to a wide range of requirements. For the company managing a large apartment building, it is especially important to raise tenant awareness about action to maintain water quality. For this reason, the tenancy agreement itself should include a clause that requires the tenant to take steps to ensure a regular and complete exchange of water. In the following, hygiene expert Dr Peter Arens summarises some key aspects.

Room schedule is critical when planning apartment building drinking water installations

There is still something yeti-like about the room schedule (cf. VDI 3810 Part 2, VDI 6023 Part 3) for the HVAC and sanitation industry. Many have heard of it, but fewer believe they have actually seen one. And yet, it is made available to every planner – though maybe not under this name – and includes the room requirements and the fit-out spec from the client. However, before these are entered, general requirements for the type and scope of usage (fig. 1) are typically queried, as per the VDI template in annex A. This is because these general requirements influence all of the fit-out items that involve the use of water. Consequently, the second line in the room schedule should be used to specify the typical usage times and days. One line down, and the subject here is potential interruptions in use, such as will be the case in mixed-use properties, apartment buildings or schools, and one line further on, whether accessibility is required.

These general questions work to initiate the dialogue between the fit-out planner and the apartment building client, and offer a good opportunity to raise the issue of measures for maintaining water quality with this client. Not least because VDI 6023 Part 1, “5.3.1 Minimum content requirements for the room schedule” reads as follows:

“Specified normal operation must be must properly planned here, so as to ensure that a complete exchange of water takes place at each usage point in the drinking water installation by drawing-off within a maximum of 72 hours. The room schedule must also take into account that a failure to exchange water for more than 72 hours is considered a service outage. This must be avoided or compensated for by means of technical and/or organisational measures (VDI 3810 Part 2*VDI 6023 Part 3).”

T-piece installations with simple and straightforward flow paths as per the 2023 German Drinking Water Ordinance

Parts of the industry are still of the opinion that the piping layout and final flushing stations are sufficient to ensure the maintenance of water quality. Yet section 10 of the 2023 Drinking Water Ordinance (TrinkwV) clearly defines the “point of compliance with requirements” as the “point of exit from the drinking water tapping points” or “the safety device necessary according to generally recognised codes of practice.” Here – and not at the flushing station – is also where the water samples for the prescribed tests are drawn off and the results then compared with the values set out in the Ordinance. Accordingly, if a tapping point, such as in a large apartment building, is not used regularly enough, a ‘dead pipe’ will be created up to the outlet for the tapping point, even if a through wall bushing is present. And section 5.3.8 of VDI 6023 Part 1 does not mince its words when it comes to ‘dead pipes’: “Bypass lines, where no throughflow is ensured after no more than 72 hours, are considered non-compliant with this code, as are dead pipes with sealed ends as well as unused tapping points. The last are considered especially critical, as they interface with the environment and microorganisms could potentially enter the installation against the direction of flow (retrograde contamination).”

Many contemporary piping layouts must therefore be questioned in light of the above. Not least because, if every tapping point must in fact be used, then simple and straightforward flow paths are always to be preferred. This is especially true of T-piece installations with comparatively low water content and small surface areas. Small surfaces areas passively protect the PWC line against excessive heating. Incidentally: T-piece installations have never lost their status as generally accepted industry practice.

So, effectively, this means individual solutions are needed. As one example, tapping points that have periods of seasonal non-use (e.g. garden watering) should be made part of a loop. When using mini tankless water heaters, planners should also reduce piping dimensions accordingly, as plug-and-play devices require a calculated flow of only 0.03 l/min – less than half the flow required by ‘normal’ tapping points (0.07 l/min). Without taking this into account, the feeder lines to mini instant water heaters would be over-dimensioned by more than 50%.

Varying requirements in large, mixed-use apartment buildings

High street grocer

The ground floor of inner-city apartment block properties is often home to businesses serving day-to-day needs, such as grocers, for example. Generally, these shops are open six days a week for more than ten hours, so that, in this case, an adequate exchange of water can be assumed, simply as a result of regular usage. Hand hygiene is especially important on these premises, however, as shop staff frequently handle food products – whether packaged or loose. Special attention should therefore be paid to keeping facilities for personnel well-lit, pleasant and (above all) clean, to encourage good personal hygiene. In these circumstances in particular, contactless fittings minimise the potential for contamination that could be spread via the hands. These fittings not only help to improve food safety but also reduce cases of illness among shop workers.

Offices

In office spaces, it is the customer and staff WCs that need to impress their users by being both clean and modern. In smaller facilities, large mirrored surfaces with lighting around the edges create the illusion of space while brightening the room (fig. 2). Since offices may also close for long weekends or over Christmas and the New Year, this results in interruptions in use, that need to be compensated for with organisational or technical measures (VDI 6023 Part 1). This is because substandard water quality during these interruptions in use can also impact the use of the overall water installation by other tenants in a mixed-user apartment building.

Healthcare facilities

Alongside pharmacies, other kinds of healthcare services may also be found in larger apartment complexes, such as orthodontic practices and dialysis centres, for example. More stringent requirements apply to the quality of the water installation in these healthcare facilities. Apart from testing for Legionella, for example, drinking water must also be analysed for the presence of Pseudomonas aeruginosa. In these kinds of high-risk settings, it may even be advisable to use active cooling for drinking water if passive methods are insufficient (see the guide ‘How do I keep PWC cold?’ from the German BTGA association). In some parts of a doctor’s practice, for example, tapping points for drinking water may need to be present although the room temperature is kept constant at 24–27 °C. In this case, an exchange of water would not itself be enough to keep temperatures at a safe level and therefore ensure water quality. Even with active cooling, however, a regular exchange of water must nonetheless be assured.

In the modern healthcare practice, almost all taps are now electronic fittings that help to ensure good hand and drinking water hygiene. However, clauses in the property insurance policies will require both the power and water supply to be interrupted outside business hours (at night, at weekends, during company holidays), typically with a key switch. Despite this requirement, power still needs to be supplied to fittings for scheduled stagnation flushes and the main shut-off valve for the drinking water installation must also be kept open – not always easy to achieve in practice. The SCHELL SWS Water Management System (fig. 3) plus SWS leak protection fittings (fig. 4) provides a set of carefully coordinated components that help business owners ensure a high level of operational safety and avoid problems from Legionella testing conducted by landlords, for example.

2023 German Drinking Water Ordinance on Legionella testing: duties for apartment building owners

A brand-new version of the German Drinking Water Ordinance (TrinkW) was adopted in 2023. The new law now governs the maintenance and monitoring of drinking water quality from the water utility catchment area through to the supply of drinking water to the consumer by the building owner – including apartment buildings. The amended legislation once again focuses on the duty of operators to mitigate the risk of contamination from Legionella.

Important for facility managers:

  • Mandatory inspections: In large facilities where drinking water is aerosolised – in showers, for example – inspections are mandatory. The same applies to new drinking water installations in premises on public, semi-public and commercial premises.
  • Risk assessment: risk assessments now supplant the earlier hazard analysis and have the aim of focusing on the key risks involved in renovations. These can also be completed without testing for Legionella.
  • Sampling points: Building operators must ensure suitable sampling points are available.
  • Duty to notify: Building operators must notify consumers when limits have been exceeded.
  • New technical action value: the detection of 100 colony‑forming units/100 ml is now the limit at which a risk assessment must be carried out.

New technical action value for Legionella limits (table)

Previously, the action value for Legionella (now included in annex 3 part III) for properties – including apartment buildings – was set in excess of 100 colony-forming units (CFU)/100 ml, triggering the procedure now redefined as a ‘risk appraisal’. Now, however, the exact figure of 100 CFU/100 ml is sufficient – with all the consequences thereby implied. One of these is the preparation of a risk appraisal pursuant to section 51 as well as corollary measures to protect consumer health. An example of such a measure is the use of sterile filters at tapping points. At face value, the technical difference of 1 CFU/100 ml may not sound particularly challenging. However, labs may well detect Legionella in a single millilitre of the test sample even if nothing is found in the filtered sample of 80 ml (for example) – although a Legionella level 80 times higher would have been expected. There are various reasons for this – ranging from incidental findings during Legionella testing to the masking of Legionella colonies by other bacterial flora present in drinking water, which prevent the detection of CFUs in the filtered sample. The Federal Environment Agency has set out new requirements to provide better statistical safeguards for the consequences of this new law (Federal Health Gazette 2023, p. 218). With the entry into force of the new action value, Legionella testing in the laboratory must detect at least three colonies of Legionella spp. for the value to be considered officially exceeded. Accordingly, additional – expensive – sampling is not required, merely a moderate increase in cost and effort on the part of the lab, resulting from a second sample preparation and a different type of analysis.

Summary

Maintaining drinking water quality in large apartment buildings and mixed-use properties can only succeed if the owner and all of the tenants know their duties and fulfil them to the full. This is because unused or rarely used parts of the drinking water installation can impact the use of other parts of the system in the building – where food may be sold or patients treated, for example. Accordingly, the first step is for fit-out planners to advise the client in this respect, followed up by including a clause requiring the regular and complete exchange of water in the tenancy agreement. Ultimately, however, while raising awareness in this way is an important initial step, it cannot replace technical and organisational measures for the exchange of water across all tapping points.
Author: Dr Peter Arens, Expert for Drinking Water Hygiene at SCHELL

Have questions about SCHELL products and solutions for maintaining drinking water quality in multi-use/apartment buildings? Our SCHELL Service Team looks forward to hearing from you.

 

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