New Jersey Legionella Regulations: Key Insights, Importance, and Strategic Implementation
NJ Legionella Regulations
New Jersey’s Senate Bill 2188. Signed into law on September 12, 2024, after passage by the Assembly and Senate on June 28, 2024, this bill establishes stringent requirements for public water utilities, the New Jersey Department of Health (DOH), the New Jersey Department of Environmental Protection (DEP), and building owners.
This article provides an overview of the key provisions of Senate Bill 2188:
Important information for building operators and owners:
Due to the increased risks that legionella imposes on the population and the rise in cases that New Jersey has had. has signed in this bill, which gives the DOH and building owners alike more responsibilities
The DOH must:
1. Investigate Reported Cases
- Conduct epidemiologic investigations for all reported cases of Legionnaires’ disease.
- Review public water system disruptions related to each case.
2. Inspect Water Systems
- Examine water systems at locations where infected individuals resided or visited 14 days before symptom onset.
3. Increase Transparency
- Post all reported cases of Legionnaires’ disease on a publicly accessible website.
4. Mandate Building Owner Actions
- Require building owners suspected of harboring Legionella to notify at-risk individuals, test water systems for legionella , and complete remediation as per DOH standards.
5. Launch Public Awareness Campaigns
- Collaborate with DEP to educate the public about Legionella risks and prevention.
Building Owners and Operators
Building owners and operators must:
1. Develop Legionella Water Management Programs (WMPs)
- Implement water management plans for systems that may release water aerosols, including:
- Whirlpool spas
- Swimming pools
- Cooling towers
- Indoor ornamental fountains
- Misters, humidifiers, and similar devices
- Ensure all water systems comply with ASHRAE 188 and CDC recommendations for water management.
2. Create and implement water safety management plans
- Mandate WMPs for:
- Healthcare facilities, nursing homes, and correctional facilities
- Hotels, senior housing, and residential buildings with six or more floors
- Any building linked to a Legionnaires’ disease outbreak
3. Provide Documentation and Notices
- Post visible notices indicating that a Legionella WMP has been implemented.
- Maintain thorough documentation of the plan's execution and results.
Why this bill is very significant
1. Comprehensive Coverage Across Building Types
New Jersey is the first state to require Legionella water management plans for all building types and water systems under ASHRAE Standard 188.
By comparison:
- New York mandates water management plans only for healthcare facilities and cooling towers.
- Virginia focuses exclusively on schools.
- Other states primarily target healthcare facilities.
2. Rigorous Case Investigations
The requirement for the DOH to investigate every reported case of Legionnaires’ disease is unprecedented. In most states, investigations are limited to outbreaks (two or more confirmed cases). New Jersey’s approach increases accountability for building owners to create a robust water management plan.
