7 editable documents: the full Water Management
Plan built to the seven ASHRAE 188-2021 §6.2 elements, the monitoring
and sampling log set, corrective-action forms, an annual-review
checklist, and the New Jersey S2188 and New York City LL159 supplement
sheets — each mapped to the exact section it satisfies, with a stated
retention period and a plain-English fill-in guide.
Retention: Keep the current WMP on the building premises for immediate inspection; in New Jersey retain the WMP and all implementation records at least 5 years (N.J.S.A. 26:1A-140 §6.f.2). Update on any material system change and review at least annually.
Regulation / standard this document satisfies:
ANSI/ASHRAE — ANSI/ASHRAE Standard 188-2021, §6 (esp. §6.2)
General Requirements — §6.2 sets the seven required Water Management Program elements: (1) program team, (2) description of building water systems with process flow diagrams (§6.2.2), (3) hazard analysis / control locations, (4) control measures with control limits, (5) monitoring, (6) corrective/management response, (7) verification and validation; §6.2.8 covers the Legionella-testing decision.
ASHRAE 188-2021 is copyrighted; the pack maps each template section to the standard's element structure and cites it, but does not reproduce the standard's normative text. Buyers must hold a licensed copy of the standard. Purchase/preview: https://www.ashrae.org/technical-resources/bookstore/ansi-ashrae-standard-188-2021-legionellosis-risk-management-for-building-water-systems. The 2021 edition replaced permissive with enforceable language.
Requirements for Building Water Systems — potable and nonpotable system-specific requirements (operating manuals §7.3.6, water features §7.4, etc.) that the plan's control measures and monitoring must cover.
ANSI/ASHRAE — ANSI/ASHRAE Standard 188-2021, Normative Appendix A
Health Care Facilities — additional normative water-management requirements for hospitals and other health-care buildings (the 2021 edition renamed the 2018 'Annex A' to 'Appendix A').
Infection-control Conditions of Participation — the enforceable basis CMS reads as requiring a Legionella water management program: §482.42 (hospitals — sanitary environment + active infection-control program), §483.80 (LTC — infection prevention & control program), and §485.635(a)(3)(vi) (critical access hospitals — system to identify, report, investigate, and control infections).
This is the standing enforceable authority for CMS-certified facilities regardless of the QSO memo's expiry. §483.80 is at https://www.ecfr.gov/current/title-42/section-483.80 and §485.635 at https://www.ecfr.gov/current/title-42/section-485.635 .
Retention: Retain monitoring, temperature, disinfectant, flushing, and cooling-tower Legionella sampling records at least 5 years in NJ (§6.f.2); NYC cooling-tower records must be producible on demand and retained per 24 RCNY Ch. 8.
Regulation / standard this document satisfies:
ANSI/ASHRAE — ANSI/ASHRAE Standard 188-2021, §6 (esp. §6.2)
General Requirements — §6.2 sets the seven required Water Management Program elements: (1) program team, (2) description of building water systems with process flow diagrams (§6.2.2), (3) hazard analysis / control locations, (4) control measures with control limits, (5) monitoring, (6) corrective/management response, (7) verification and validation; §6.2.8 covers the Legionella-testing decision.
ASHRAE 188-2021 is copyrighted; the pack maps each template section to the standard's element structure and cites it, but does not reproduce the standard's normative text. Buyers must hold a licensed copy of the standard. Purchase/preview: https://www.ashrae.org/technical-resources/bookstore/ansi-ashrae-standard-188-2021-legionellosis-risk-management-for-building-water-systems. The 2021 edition replaced permissive with enforceable language.
Requirements for Building Water Systems — potable and nonpotable system-specific requirements (operating manuals §7.3.6, water features §7.4, etc.) that the plan's control measures and monitoring must cover.
New York City (DOHMH) — NYC Local Law 159 of 2025; 24 RCNY Chapter 8 (cooling towers)
New York City cooling-tower Legionella rule — as of 2026-05-07, Legionella culture testing must be performed on every cooling-tower system at least once every 31 days during the operating season (replacing the 90-day interval under LL77); each test date must be reported to DOHMH within 5 days; culture analyses must use a NYS ELAP-certified lab; a Maintenance Program & Plan (MPP) must be kept on site and certified annually. LL159 adds to, and does not replace, Local Law 77 of 2015.
Conforming amendments to 24 RCNY Chapter 8 took effect 2026-05-08. Enhanced summer disinfection Jul 1-Aug 31; a cooling tower is 'in operation' once filled/partially filled; failure to produce records on request is prima facie evidence the requirement was not met; penalties increased (most doubled), starting at $10,000/violation.
Retention: Retain each corrective-action / management-response record with the WMP; at least 5 years in NJ (§6.f.2).
Regulation / standard this document satisfies:
ANSI/ASHRAE — ANSI/ASHRAE Standard 188-2021, §6 (esp. §6.2)
General Requirements — §6.2 sets the seven required Water Management Program elements: (1) program team, (2) description of building water systems with process flow diagrams (§6.2.2), (3) hazard analysis / control locations, (4) control measures with control limits, (5) monitoring, (6) corrective/management response, (7) verification and validation; §6.2.8 covers the Legionella-testing decision.
ASHRAE 188-2021 is copyrighted; the pack maps each template section to the standard's element structure and cites it, but does not reproduce the standard's normative text. Buyers must hold a licensed copy of the standard. Purchase/preview: https://www.ashrae.org/technical-resources/bookstore/ansi-ashrae-standard-188-2021-legionellosis-risk-management-for-building-water-systems. The 2021 edition replaced permissive with enforceable language.
Retention: Retain each completed annual review with the WMP; at least 5 years in NJ (§6.f.2).
Regulation / standard this document satisfies:
ANSI/ASHRAE — ANSI/ASHRAE Standard 188-2021, §6 (esp. §6.2)
General Requirements — §6.2 sets the seven required Water Management Program elements: (1) program team, (2) description of building water systems with process flow diagrams (§6.2.2), (3) hazard analysis / control locations, (4) control measures with control limits, (5) monitoring, (6) corrective/management response, (7) verification and validation; §6.2.8 covers the Legionella-testing decision.
ASHRAE 188-2021 is copyrighted; the pack maps each template section to the standard's element structure and cites it, but does not reproduce the standard's normative text. Buyers must hold a licensed copy of the standard. Purchase/preview: https://www.ashrae.org/technical-resources/bookstore/ansi-ashrae-standard-188-2021-legionellosis-risk-management-for-building-water-systems. The 2021 edition replaced permissive with enforceable language.
Infection-control Conditions of Participation — the enforceable basis CMS reads as requiring a Legionella water management program: §482.42 (hospitals — sanitary environment + active infection-control program), §483.80 (LTC — infection prevention & control program), and §485.635(a)(3)(vi) (critical access hospitals — system to identify, report, investigate, and control infections).
This is the standing enforceable authority for CMS-certified facilities regardless of the QSO memo's expiry. §483.80 is at https://www.ecfr.gov/current/title-42/section-483.80 and §485.635 at https://www.ecfr.gov/current/title-42/section-485.635 .
Retention: Retain the WMP and all procedure, testing, and implementation records on premises at least 5 years (N.J.S.A. 26:1A-140 §6.f.2).
Regulation / standard this document satisfies:
State of New Jersey — N.J.S.A. 26:1A-140 (P.L.2024, c.66 / S2188), §6
New Jersey Legionnaires' disease law — owners/operators of covered buildings must DEVELOP a water management program consistent with ASHRAE 188-2018 (or subsequent versions) within 24 months of the 2024-09-12 effective date (= 2026-09-12, §6.a) and IMPLEMENT it within 27 months (= 2026-12-12, §6.f.1); post a public notice on the premises (§6.c); retain the WMP, all procedure/testing records, and implementation documentation on premises at least 5 years (§6.f.2); civil penalties $2,000 / $5,000 / $10,000 (§6.g).
Codified N.J.S.A. 26:1A-139 to 142 + 58:12A-12.10 to 12.13. Eight covered criteria (§6.a(1)-(8)): hospitals; nursing/assisted-living/residential care/dementia homes; buildings with whirlpool/spa/pool/cooling tower/fountain/mister/humidifier; correctional facilities with centralized hot water; residential high-rises (6+ floors) with centralized water heaters; hotels/motels (25+ units, centralized hot water); subsidized/senior residential (25+ units); and any building DOH ties to an outbreak. Excludes residential properties of 4 or fewer dwelling units.
ANSI/ASHRAE — ANSI/ASHRAE Standard 188-2021, §6 (esp. §6.2)
General Requirements — §6.2 sets the seven required Water Management Program elements: (1) program team, (2) description of building water systems with process flow diagrams (§6.2.2), (3) hazard analysis / control locations, (4) control measures with control limits, (5) monitoring, (6) corrective/management response, (7) verification and validation; §6.2.8 covers the Legionella-testing decision.
ASHRAE 188-2021 is copyrighted; the pack maps each template section to the standard's element structure and cites it, but does not reproduce the standard's normative text. Buyers must hold a licensed copy of the standard. Purchase/preview: https://www.ashrae.org/technical-resources/bookstore/ansi-ashrae-standard-188-2021-legionellosis-risk-management-for-building-water-systems. The 2021 edition replaced permissive with enforceable language.
6. New York City LL159 / LL77 Cooling-Tower Supplement
Source file:nyc-supplement.md
Retention: Maintain the Cooling Tower Maintenance Program & Plan on site, certified annually; keep testing/inspection records producible on demand per 24 RCNY Chapter 8.
Regulation / standard this document satisfies:
New York City (DOHMH) — NYC Local Law 159 of 2025; 24 RCNY Chapter 8 (cooling towers)
New York City cooling-tower Legionella rule — as of 2026-05-07, Legionella culture testing must be performed on every cooling-tower system at least once every 31 days during the operating season (replacing the 90-day interval under LL77); each test date must be reported to DOHMH within 5 days; culture analyses must use a NYS ELAP-certified lab; a Maintenance Program & Plan (MPP) must be kept on site and certified annually. LL159 adds to, and does not replace, Local Law 77 of 2015.
Conforming amendments to 24 RCNY Chapter 8 took effect 2026-05-08. Enhanced summer disinfection Jul 1-Aug 31; a cooling tower is 'in operation' once filled/partially filled; failure to produce records on request is prima facie evidence the requirement was not met; penalties increased (most doubled), starting at $10,000/violation.
Retention: Reference document; retain the current adopted standard/rule versions and in-use templates for the life of the program. All underlying records: at least 5 years in NJ (§6.f.2).
Regulation / standard this document satisfies:
ANSI/ASHRAE — ANSI/ASHRAE Standard 188-2021, §6 (esp. §6.2)
General Requirements — §6.2 sets the seven required Water Management Program elements: (1) program team, (2) description of building water systems with process flow diagrams (§6.2.2), (3) hazard analysis / control locations, (4) control measures with control limits, (5) monitoring, (6) corrective/management response, (7) verification and validation; §6.2.8 covers the Legionella-testing decision.
ASHRAE 188-2021 is copyrighted; the pack maps each template section to the standard's element structure and cites it, but does not reproduce the standard's normative text. Buyers must hold a licensed copy of the standard. Purchase/preview: https://www.ashrae.org/technical-resources/bookstore/ansi-ashrae-standard-188-2021-legionellosis-risk-management-for-building-water-systems. The 2021 edition replaced permissive with enforceable language.
Historical surveyor guidance requiring Medicare/Medicaid hospitals, critical access hospitals, and long-term care facilities to develop and implement a Legionella water management program considering ASHRAE 188 and the CDC toolkit. CMS marked this memo EXPIRED on 2025-09-02; the enforceable basis now runs directly through the infection-control Conditions of Participation it cited.
[VERIFY] QSO-17-30 is EXPIRED as of 2025-09-02. Confirm the current replacement guidance number before citing QSO-17-30 as live in marketing copy. The underlying mandate is unchanged and enforceable via the CoPs (see cms-cop citation). Logged to DECISIONS-NEEDED.md.
Infection-control Conditions of Participation — the enforceable basis CMS reads as requiring a Legionella water management program: §482.42 (hospitals — sanitary environment + active infection-control program), §483.80 (LTC — infection prevention & control program), and §485.635(a)(3)(vi) (critical access hospitals — system to identify, report, investigate, and control infections).
This is the standing enforceable authority for CMS-certified facilities regardless of the QSO memo's expiry. §483.80 is at https://www.ecfr.gov/current/title-42/section-483.80 and §485.635 at https://www.ecfr.gov/current/title-42/section-485.635 .
State of New Jersey — N.J.S.A. 26:1A-140 (P.L.2024, c.66 / S2188), §6
New Jersey Legionnaires' disease law — owners/operators of covered buildings must DEVELOP a water management program consistent with ASHRAE 188-2018 (or subsequent versions) within 24 months of the 2024-09-12 effective date (= 2026-09-12, §6.a) and IMPLEMENT it within 27 months (= 2026-12-12, §6.f.1); post a public notice on the premises (§6.c); retain the WMP, all procedure/testing records, and implementation documentation on premises at least 5 years (§6.f.2); civil penalties $2,000 / $5,000 / $10,000 (§6.g).
Codified N.J.S.A. 26:1A-139 to 142 + 58:12A-12.10 to 12.13. Eight covered criteria (§6.a(1)-(8)): hospitals; nursing/assisted-living/residential care/dementia homes; buildings with whirlpool/spa/pool/cooling tower/fountain/mister/humidifier; correctional facilities with centralized hot water; residential high-rises (6+ floors) with centralized water heaters; hotels/motels (25+ units, centralized hot water); subsidized/senior residential (25+ units); and any building DOH ties to an outbreak. Excludes residential properties of 4 or fewer dwelling units.
New York City (DOHMH) — NYC Local Law 159 of 2025; 24 RCNY Chapter 8 (cooling towers)
New York City cooling-tower Legionella rule — as of 2026-05-07, Legionella culture testing must be performed on every cooling-tower system at least once every 31 days during the operating season (replacing the 90-day interval under LL77); each test date must be reported to DOHMH within 5 days; culture analyses must use a NYS ELAP-certified lab; a Maintenance Program & Plan (MPP) must be kept on site and certified annually. LL159 adds to, and does not replace, Local Law 77 of 2015.
Conforming amendments to 24 RCNY Chapter 8 took effect 2026-05-08. Enhanced summer disinfection Jul 1-Aug 31; a cooling tower is 'in operation' once filled/partially filled; failure to produce records on request is prima facie evidence the requirement was not met; penalties increased (most doubled), starting at $10,000/violation.
Every building-specific value is a merge field. Fill each one once and
it flows through the pack. Required fields must be completed before a
document is inspection-ready.
Merge fields — required
Field
Token
Example
Building owner / operator legal name
{{company_name}}
Riverside Senior Living LLC
Building / facility name
{{building_name}}
Riverside Tower A
Building street address
{{facility_address}}
500 Riverside Dr, Newark, NJ 07104
State / city jurisdiction (drives supplement)
{{jurisdiction}}
New Jersey
Water management program team leader (name / title)
{{program_manager}}
Pat Nguyen, Director of Facilities
Program team members + roles
{{team_members}}
J. Rivera (Engineering), M. Cole (Water Treatment Vendor)
Plan effective / adoption date
{{effective_date}}
2026-08-01
Prepared by (name / title / credential)
{{prepared_by}}
Pat Nguyen, CWT
Reviewed / validated by (name / credential)
{{reviewed_by}}
Dr. L. Foster, PE
Merge fields — optional / per-record
Field
Token
Example
Water treatment contractor / lab
{{water_treatment_vendor}}
AquaSafe Treatment Co. (ELAP #12345)
Cooling tower ID(s) (NYC registration no.)
{{cooling_tower_ids}}
CT-2026-0042
Next scheduled annual review date
{{review_date}}
2027-08-01
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ASHRAE 188 Water Management Plan Pack
A complete, editable Water Management Plan built to the seven required elements of ANSI/ASHRAE 188-2021 (§6.2), plus the monitoring logs, corrective-action forms, annual-review checklist, and NJ S2188 + NYC LL159 supplements — mapped section-by-section to the standard.
$399 one-time
vs $2,995/yr HC Info LAMPS subscription / generic free CDC PDF for the incumbent
Water Management Plan template — all 7 ASHRAE 188-2021 §6.2 elements
Program team roster + roles/responsibilities (§6.2.1)
System description + process flow diagram worksheets (§6.2.2)
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