Drinking Water Quality Management

Purpose

This Order establishes national U.S. General Services Administration (GSA) Public Building Service (PBS) requirements for effectively managing and overseeing all building water (BW), as well as drinking water (DW) (a subset of BW) systems to help ensure the well-being of building occupants, contractors, and visitors in federally owned facilities and leased space under the jurisdiction, custody, or control of GSA, including federally owned facilities operating under a GSA delegation of authority for operations and maintenance (delegation of O&M). 

Any local guidance or deviations from the policy that are less stringent must be submitted for approval, in advance, to the PBS Office of Facilities Management Director of Risk Management.

Background

PBS is committed to providing safe and healthy spaces for building occupants, contractors and visitors in federally owned facilities and leased space under the jurisdiction, custody, or control of GSA (including federally owned facilities operating under a delegation of O&M). Public water systems (PWS), usually municipality-owned and operated, are responsible for continuously providing safe water to the public that meets the U.S. Environmental Protection Agency’s (EPA) National Primary Drinking Water Regulations of the Safe Drinking Water Act. However, a PWS may be publicly or privately owned. A PWS provides water for human consumption through pipes or other constructed conveyances to at least fifteen (15) service connections or serves an average of at least twenty-five (25) people for at least sixty (60) days a year. 

EPA has defined three types of PWS:

1. Community Water System (CWS): A PWS that supplies water to the same population year-round.
2. Non-Transient Non-Community Water System: A PWS that regularly supplies water to at least twenty-five (25) of the same people at least six months per year. Some examples are schools, factories, office buildings and hospitals which have their own water systems.
3. Transient Non-Community Water System: A PWS that provides water in a place such as a gas station or campground where people do not remain for long periods of time.

Private water systems, such as private water wells, serve individual households or small groups of people and are not regulated under the EPA Safe Drinking Water Act. These systems usually serve fewer people and are often found in rural or remote areas. However, in cases where a State has the primary authority to enforce regulations for PWS, the State’s definition of a PWS may differ from the EPA’s definition and could include certain types of private water systems. It is also important to highlight that while the EPA sets federal water standards and regulations, individual states or local authorities can also establish their own water requirements, which may be more stringent than the Federal standards. Water systems are obligated to comply with regulations at the Federal, State, and local levels.

The quality of a facility’s water can be influenced by various factors, including the design and condition of the building’s plumbing system, maintenance and operational practices, construction and occupant activities, and issues related to the PWS that the facility receives water from.

Facilities often have limited control over water quality issues originating from the PWS and in those situations can only implement control measures in response to notifications from the appropriate authority. The primary responsibility for maintaining and delivering safe water lies with the PWS, which manages the water source, treatment, and distribution systems. Facilities rely on the PWS to provide clean and safe water for their operations.

Once a facility receives acceptable water from the PWS, it becomes the responsibility of the facility’s controlling authority (whether it is PBS, a lessor, or an agency with delegated O&M) to provide potable water at point-of-use outlets that meet EPA’s National Primary Drinking Water Regulations per the U.S. Department of Labor - Occupational Safety and Health Administration Sanitation Standard (29 C.F.R. § 1910.141). The implementation of a national GSA Water Quality Management Order will help GSA ensure that this occurs in GSA controlled facilities.

Applicability

This Order, and the companion desk guide, apply to federally owned facilities under the jurisdiction, custody, and control of the GSA, including facilities operating under a GSA delegation of authority. Limited aspects of this Order also apply to space leased by GSA and are dictated by the provisions of the lease.

Cancellation

Drinking Water Quality Management, PBS 1000.7A (November 16, 2023).

Summary of Changes

The policy updates requirements for water quality management in alignment with the consensus standards and guidelines referenced herein. Additionally, the policy updates roles and responsibilities to align with GSA’s organizational structure. 

Roles and Responsibilities

1. PBS Office of Facilities Management Facility Risk Management Division is responsible for:
   1. Issuance of this Order and subsequent updates.
   2. Providing national guidance and training in support of this Order.
   3. Supporting Service Centers, Field Offices and individual buildings in BW program management activities.
   4. Overseeing compliance with the BW management program and this Order throughout the entire portfolio.
   5. Providing technical BW program support and training to Facility Managers, Facility Operations Teams, Project Managers, Lease Administration Managers, and any additional internal customers as needed.
   6. Reviewing BW reports and documentation for accuracy and completeness and providing recommendations to responsible offices as needed.
   7. Providing review and input on mitigation and corrective action efforts in buildings where sources of poor BW are identified.
   8. Coordinating and overseeing the conducting of Child Care Center water testing and documenting results in IRIS OSH.
2. PBS Office of Facilities Management - Facilities Operations is responsible for:
   1. Implementing, and providing national program oversight for ensuring our compliance with ANSI/ASHRAE Standard 188, Legionellosis: Risk Management for Building Water Systems which establishes minimum legionellosis risk management requirements for building water systems, ensuring that ASHRAE 188 plans are effectively applied, as applicable, across various federally owned facilities to maintain water safety and prevent stagnation-related issues.
   2. Ensuring that GSA-controlled facilities use the U.S. Department of Health and Human Services - Centers for Disease Control and Prevention’s (CDC) Water Management Program Worksheet, Identify Buildings with Increased Legionella Risk, to determine when the ASHRAE standard will apply.
   3. Ensuring the O&M master specification incorporates the most current, applicable BW requirements.
   4. Ensuring that energy efficiency and water conservation requirements in future O&M contracts do not conflict with this policy and the water safety guidance.
   5. Ensuring that Delegated Agencies are complying with this Order and the accompanying desk guide.
3. PBS Office of Facilities Management Child Care Center Program is responsible for:
   1. Facilitating an understanding of State and local Child Care Center water requirements, coordinating with the PBS Office of Facilities Management Risk Management office for Child Care Center BW testing, and communicating with Child Care Center providers regarding any BW matter.
   2. Providing oversight of the Child Care Provider to ensure that it is flushing water weekly (on the first business day of each week) as required.
4. PBS Office of Engineering is responsible for ensuring that updates to the PBS Interim Core Building Standards for the Public Buildings Service incorporate the most current, applicable BW requirements.
5. PBS Office of Leasing is responsible for ensuring that updates to the standard, national lease contracting language incorporate the most current, applicable BW requirements in leases.
6. PBS Office of Program and Project Management Design and Construction and Project Delivery Divisions are responsible for ensuring post-installation flushing, sanitization and BW testing are included in applicable projects, and the deliverables are received after construction and prior to use.
7. PBS Office of Facilities Management Facility Managers are responsible for:
   1. Implementation and compliance in their building, if applicable, with ANSI/ASHRAE Standard 188, Legionellosis: Risk Management for Building Water Systems which establishes minimum legionellosis risk management requirements for building water systems in owned facilities to maintain water safety and prevent stagnation-related issues.  Specifically ensuring that their GSA-controlled facility uses the CDC’s Water Management Program Worksheet, Identify Buildings with Increased Legionella Risk, to help determine if and when the ASHRAE standard will apply.
   2. Ensuring post-installation flushing, sanitization and BW testing are included in applicable projects, and the deliverables are received after construction and prior to use.
   3. Ensuring BW incidents, complaints, and emergencies are promptly investigated and reported to the Risk Management Industrial Hygiene Program Office.
   4. Documenting initial BW incidents, complaints, and emergencies submitted through the O&M Contractor and Facility Manager in the PBS National Computerized Maintenance Management System (NCMMS).
   5. Communicating to affected occupants of any relevant information about DW-related incidents or emergencies per PBS 2400.1 Risk Management Notification (January 8, 2021) guidance.
   6. Posting notifications at any Child Care Center related to BW testing as necessary.
   7. Ensuring the completion of mitigation and corrective action efforts in  buildings where sources of poor BW are identified.
   8. Ensuring building systems, including backflow prevention devices, are maintained in accordance with the existing O&M specification, site-specific building operating plans, and preventive maintenance programs.
   9. Ensuring any federally owned or operated water systems that may be in their building are maintained per applicable Federal, State, or local regulations.
8. PBS Office of Facilities Management Service Centers and Field Offices are responsible for providing BW oversight to all the buildings in their individual areas of responsibility for the following items:
   1. Ensuring post-installation flushing, sanitization and BW testing are included in applicable projects, and the deliverables are received after construction and prior to use.
   2. Ensuring BW incidents, complaints, and emergencies are promptly investigated and reported to the Risk Management Industrial Hygiene Program Office.
   3. Documentation of initial BW incidents, complaints, and emergencies submitted through the O&M Contractor and Facility Manager in the PBS NCMMS.
   4. Communication to affected occupants of any relevant information about BW-related incidents or emergencies per PBS 2400.1 Risk Management Notification (January 8, 2021) and internal GSA water quality notification guidance.
   5. Ensuring the posting of notifications at Child Care Centers related to BW testing.
   6. Ensuring the completion of mitigation and corrective action efforts in buildings where water quality issues have been identified.
   7. Ensuring building systems, including backflow prevention devices, are maintained in accordance with the existing O&M specification, site-specific building operating plans, and preventive maintenance programs.
   8. Ensuring any federally owned or operated water systems, under GSA’s jurisdiction, custody, or control, in their areas of responsibility are maintained per applicable Federal, State, or local regulations.
9. PBS Leasing Specialists / Lease Contracting Officers / Lease Administration Managers are responsible for:
   1. Ensuring the most updated BW clauses are added for new, replacing, succeeding, and superseding leases.
   2. Collaborating with the Lessor and, if necessary, escalating any issues to ensure that the lease provisions are applied in addressing DW concerns raised by GSA or other Federal occupants in GSA-controlled leased space.
10. Delegated Agencies must comply with this Order and the accompanying desk  guide. 

Policy

1. Maintaining DW. The following items must be used to proactively reduce DW problems.
   1. PWS. In federally owned and leased facilities under the jurisdiction, custody, or control of GSA (including facilities operating under a GSA delegation of authority) where the facility is also the operator of a PWS, it is the responsibility of the party or parties responsible for the water system to ensure compliance with applicable Federal, State or local DW regulations. In cases where there is no separate party responsible for the water system, the obligation falls upon the controlling authority of the facility. Depending on the facility, this would be the responsibility of PBS, a lessor, or an agency with delegated authority to operate and maintain the facility.
   2. Non-PWS water systems. In federally owned and leased facilities under the jurisdiction, custody, or control of GSA (including facilities operating under a GSA delegation of authority) where DW is sourced from non-PWS water systems such as a private DW well, it is the responsibility of the party or parties responsible for the water system to ensure compliance with applicable State or local DW requirements. In cases where there is no separate party responsible for the water system, the obligation falls upon the controlling authority of the facility. Depending on the facility, this would be the responsibility of PBS, a lessor, or an agency with delegated authority to operate and maintain the facility. 

For awareness, federally owned and leased facilities under the jurisdiction, custody, or control of GSA may own or operate CWS, Non-Transient Non-Community Water System, Transient Non-Community Water System, and private water systems in limited instances. 

In addition to meeting the State or local DW requirements, proper documentation is essential. This includes, but is not limited to: sanitary surveys, operator certification, and drilling logs. It is the responsibility of the water system provider or controlling authority to maintain these documents. 

3. Consumer Confidence Reports. The EPA requires CWS to issue a Consumer Confidence Report, also known as an annual DW quality report, publicly available or to send it to their customers. These reports provide information about the local DW quality. The water system must publish these reports each year by July 1.The O&M Contractor for all federally owned facilities under the jurisdiction, custody, and control of GSA (including facilities operating under a GSA delegation served by a CWS) must review these reports annually and, if any issues are noted, provide notification to the GSA Contracting Officer’s Representative and document the issue in NCMMS. The O&M Contractor will also ensure that a copy of each new Consumer Confidence Report received by the provider is put in the NCMMS. GSA or the agency with delegated authority to operate and maintain the facility must provide notification of the issues noted to each affected occupant agency point of contact. PBS Industrial Hygienists must also review each Consumer Confidence Report annually for each building location they are responsible for.
4. Baseline Water Testing. In Fiscal Years 2024 and 2025, an initial baseline DW quality testing by a qualified professional was required for all active and occupied federally owned facilities and certain leases that were greater than 1,000 square feet, had DW systems, and fell under the jurisdiction, custody, and control of GSA (including those operating with delegated authority from GSA).
5. Child Care Centers.
   1. Hot and cold water point-of-use outlets with the realistic potential to be used as a drinking water source must be flushed weekly by the Child Care provider. It is recommended that this be on the morning of the first regular business day of the week. Aerators must be cleaned or replaced monthly (if damaged) by the O&M provider in owned locations, or by the Lessor in leased locations. It’s important to note that if aerators are replaced with laminar flow devices, monthly aerator maintenance will no longer be necessary.
   2. In open Child Care Centers, DW outlets must be sampled and evaluated for lead and copper by a qualified professional annually at a minimum. This testing must include all water outlets with the realistic potential to be used as DW sources, such as those used for human consumption and washing. Test results that exceed the applicable Federal, State, or local thresholds must result in response actions to reduce concentration levels to below the action level. It is essential to conduct additional water testing on failed outlets by a qualified professional to ensure the response actions were successful. 

The Risk Management program office responsible for DW will use their professional judgment to decide whether additional testing at fixtures outside of those within the Child Care Center’s demised space is necessary based on the annual test results.

3. Any Child Care Center closed for thirty (30) consecutive calendar days or more must be sampled and evaluated for lead and copper by a qualified professional within three weeks before reopening and with sufficient time for PBS to review the results and act on any issues before operations commence at the Child Care Center. This testing must include all water sources with the realistic potential to be used as DW sources, such as those used for human consumption and washing. Test results that exceed the applicable Federal, State, or local thresholds must result in response actions to reduce concentration levels to below the action level. It is essential to conduct additional water testing on failed outlets by a qualified professional to ensure the response actions were successful. 

Additionally, all water outlets primarily designed for human consumption (such as drinking fountains, bottle fillers, and faucets in kitchenettes) must be tested by a qualified professional for the presence of Legionella. If systems are controlled (either well or poorly as defined by CDC guidance), no further action is required. However, if systems are uncontrolled, further response action is needed. 

4. All newly installed outlets with the realistic potential to be used as a DW source must be thoroughly flushed for a minimum of 10 minutes.
   1. Use a detectable level of disinfectant residual to indicate that flushing has been successful for cold water.
   2. Use the maximum hot water temperature allowed by regulations and codes, or between 105°F (41°C) to 109°F (43°C) to indicate that flushing has been successful for hot water. For outlets with automatic mixing valves, flush until the water temperature stabilizes as the water will be premixed with cold water.
5. All newly installed water outlets with the realistic potential to be used as a DW source, such as those used for human consumption and washing, must be tested for lead, copper, and total coliform bacteria (including E. coli) by a qualified professional before use. Test results that exceed the applicable Federal, State, or local thresholds must result in response actions to reduce concentration levels to below the action level. It is essential to conduct additional water testing on failed outlets by a qualified professional to ensure the response actions were successful.
6. Water Testing After New Installations. All federally owned facilities under the jurisdiction, custody, and control of GSA (including facilities operating under a GSA delegation) must conduct post-installation water flushing, disinfection and testing in accordance with the International Plumbing Code when certain components of the water system are impacted during repair or renovation projects.
7. Hot Water Tank Storage Requirements.  Hot water tanks at all federally owned facilities under the jurisdiction, custody, and control of GSA (including facilities operating under a GSA delegation) should be maintained at 140°F at the tank and ensure hot water delivery within code compliance per ASHRAE Guideline 12.  Energy efficiency and water conservation requirements in future O&M and other contracts should not conflict with this guidance.
8. Incidents, Complaints, and Emergencies. In response to incidents, complaints, and emergencies related to DW, it is the responsibility of GSA, the Delegated Agency, or the Lessor (if a provision of the lease) to promptly investigate such complaints in federally owned and leased facilities under the jurisdiction, custody, or control of GSA (including facilities operating under a GSA delegation). The investigation process must include:
   1. Efforts to identify the nature and source of the suspected DW issue, which may involve conducting confirmatory water testing by a qualified professional.
   2. If the investigation confirms the presence of a DW issue, appropriate corrective action must be initiated to address and remediate the source of the problem and notification to each affected occupant agency point of contact must occur per the requirements of PBS 2400.1 Risk Management Notification (January 8, 2021).
      1. Follow-up testing by a qualified professional must be conducted after implementing corrective actions to ensure the effectiveness of the measures taken.
      2. To ensure that the problem is confined to the original incident area, the PBS Industrial Hygienist responsible for DW will use their professional judgment to decide whether additional testing outside of the initial area of concern is required.
   3. In federally owned facilities under the jurisdiction, custody, and control of GSA, initial DW incidents, complaints, and emergencies reported through the GSA O&M Contractor or PBS Office of Facilities Management Facility Manager channels must be documented and maintained in NCMMS for record-keeping purposes.
9. Tenant Access. Many of the activities in this Order require access to tenant spaces. While access cannot always be guaranteed, through the use of documented notification to occupant agencies, GSA will make every effort to secure access so that water management activities can be performed.

Authority

1. U.S. Department of Labor - Occupational Safety and Health Administration: 29 C.F.R. § 1960, 29 C.F.R. § 1910.141, & General Duty Clause (Section 5(a)(1) of the Occupational Safety and Health Act) (29 U.S.C. § 654).
2. U.S. Environmental Protection Agency (EPA): Safe Drinking Water Act (42 U.S.C.§ 300f, et seq.).
3. EPA: National Primary Drinking Water Regulations (40 C.F.R.§ 141) including Lead and Copper Rule (40 C.F.R. § 141 Subpart I).
4. EPA: National Primary Drinking Water Regulations Implementation (40 C.F.R. § 142).
5. EPA: Other Safe Drinking Water Act Regulations (40 C.F.R. § 143) including Use of Lead-Free Pipes, Fittings, Fixtures, Solder, and Flux for Drinking Water (40 C.F.R. § 143 Subpart B).
6. Applicable State and local Drinking Water authorities.
7. Applicable Federal, State, and local plumbing codes.

Organizations, Consensus Standards, and Guidelines Used in the Development of the Order

1. EPA: “3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities”.
2. U.S. Department of Health and Human Services - Centers for Disease Control and Prevention (CDC): “Toolkit for Controlling Legionella in Common Sources of Exposure”.
3. ASHRAE: Standard 514 Risk Management for Building Water Systems: Physical, Chemical, and Microbial Hazards.
4. ASHRAE: Standard 188 Legionellosis: Risk Management for Building Water Systems.
5. ASHRAE: Guideline 12 Managing the Risk of Legionellosis Associated with Building Water Systems.
6. American Industrial Hygiene Association: Recognition, Evaluation, and Control of Legionella in Building Water Systems 2nd Edition.
7. American Water Works Association: Responding to Water Stagnation in Buildings with Reduced or No Water Use.

PBS Desk Guide for Water Quality Management

The PBS Desk Guide for Water Quality Management serves as a practical resource for national implementation of the PBS Water Quality Management Order. It provides additional guidance, procedures and best practices for addressing specific DW issues and managing DW programs effectively and is linked below.