Navigating New Jersey’s S2188: A Practical Guide to Legionnaires’ Disease Prevention

In an effort to tackle growing concerns over waterborne illnesses, particularly Legionnaires’ disease, New Jersey has  enacted Senate Bill S2188, an important step forward in public health protection. Effective September 12, 2024, the law mandates that specific facilities implement comprehensive water management plans to monitor and mitigate the growth of Legionella bacteria in their building water systems.

Who Needs to Comply with S2188?

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Not all buildings fall under the law’s requirements, but several high-risk facility types do, including:

• Hospitals and specialty medical centers

• Long-term care facilities, such as assisted living and nursing homes

• Hotels and motels with 50+ rooms using centralized hot water

• Residential complexes for seniors or people with disabilities (25+ units)

• Buildings with cooling towers, whirlpools, or decorative fountains

• Correctional institutions

• Facilities previously associated with Legionnaires’ disease outbreaks

  
  

In addition, public water systems must also meet minimum disinfectant standards and maintain regular testing schedules.

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Core Requirements of the Law:

1. Develop a Water Management Plan

Every affected building must prepare a water management plan tailored to its system’s unique characteristics. The plan should:

• Map out all water system components

• Identify potential hazard points (e.g., stagnation zones, optimal temperatures for Legionella)

• Set target ranges for disinfectant levels, temperature, and flow

• Align with industry best practices such as ASHRAE Standard 188

  
  

2. Monitor and Test Regularly

Routine inspections and testing must be scheduled to ensure water quality remains within the defined safety range. Any deviations must be documented and resolved quickly. Key parameters include:

• Legionella presence

• Chlorine/chloramine residuals

• Temperature control

  
  

3. Document and Report

The written water management program along with thorough records of all testing, maintenance activities, and corrective actions must be kept for at least five (5) years. This documentation ensures readiness for inspections and supports a rapid response to any potential outbreaks. These documents must be made available immediately upon request to the Department of Health.

4. Incident Reporting

If system conditions change such as pressure drops or disinfectant loss or Legionella is detected, the facility must promptly notify the appropriate health authorities.

5. Compliance Timeline

• September 12, 2024: Law takes effect

• 24 months: Develop the water management plan

• 27 months: Full implementation required

Why This Matters

Legionnaires’ disease is a potentially deadly respiratory infection caused by inhaling contaminated water droplets. By enforcing proactive management and testing, New Jersey is not only protecting vulnerable populations but also setting a standard other states may choose to follow.

How to Get Started

Building owners should collaborate with certified water treatment professionals to ensure proper plan development and long-term compliance. Experts can:

• Conduct a system assessment

• Define appropriate control measures

• Implement routine testing and provide emergency response support

Final Thoughts

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S2188 isn’t just another regulation it’s a call to action for facilities to take their water safety seriously. With effective planning, ongoing monitoring, and professional support, compliance with the law not only avoids penalties but ensures a safer environment for everyone inside your building.

📞 Need expert assistance? Contact our team at NuChem Corp to start building your custom water management plan today.