Hot-Water Temperatures -
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Date: June 3, 1998 DSL-BQA 98-020
To: Community Based Residential Facilities CBRF-06
Updates DSL-BQA-97-047
From: Judy Fryback, Director, Bureau of Quality Assurance
In November 1997, we mailed DSL-BQA-97-047 advising all
community-based residential facilities of the requirements for hot-water temperatures
found in section HFS 83.41(5)(d)2, Wis. Administrative Code. This code states,
"The temperature of water at fixtures in showers and tubs used by residents shall
be automatically regulated by valves and may not exceed 110 degrees Fahrenheit, except for
Community Based Residential Facilities (CBRFs) exclusively serving residents recovering
from alcohol or drug dependency or clients of a governmental corrections agency."
In addition, we noted that similar temperatures should be found at sinks used by
residents, pursuant to the requirements in sec. HFS 83.21(4)(w), Wis. Admin. Code. This
code requires the CBRF to provide a
"safe environment…The CBRF shall safe-guard residents who cannot fully guard
themselves from an environmental hazard to which it is likely that they would be exposed,
including both conditions which would be hazardous to anyone, and conditions which are
hazardous to the resident because of the resident’s condition or handicap."
From March through May 1998, the Bureau of Quality Assurance cited and assessed
forfeitures against 33 CBRFs for hot water temperatures that ranged between 130-160
degrees F. At these temperatures, severe, full-thickness scalding that causes irreversible
second and third-degree burns can occur in 1 to 30 seconds. At 140 degrees, first-degree
burns can occur in less than 2 seconds. Too-hot water may be particularly dangerous for
the elderly and handicapped who may have circulatory or neurological disabilities that
prevent instantaneous recoil from too-hot water. As a result, they may more easily be
burned than other people. Recently, at least three CBRF residents and one adult family
home resident in Wisconsin have received serious injuries from hot-water burns.
Hot water heaters must have a temperature of 125 to 130 degrees F, as required in HFS
83.41(5)(d)2, Wis. Administrative Code. Newer research, however, is showing that a
temperature of at least 140 degrees is necessary to kill Legionella. As a result, we will
not cite facilities for maintaining a hot water heater temperature of 131 to 140 degrees.
However, because the temperature of the water heater must be at least 15 degrees higher
than the temperature at the tub and shower, a method for tempering the water temperature
is required to ensure water of 110 degrees at the tub and shower and a "safe"
temperature at the sink. The Department of Commerce has advised us of several ways
facilities may meet HFS 83 requirements and at the same time be in compliance with the
state plumbing code.
1. Facilities may install a thermostatic mixing valve on the cold and hot water
lines that lead from the water heater to the fixtures. A thermostatic mixing valve tempers
the water such that water temperature will not exceed the temperature at which the
thermostat is set. The mixing valve will control the water temperature at sinks, tubs, and
showers served by the water line.
Because a thermostatic valve will allow hot or cold water to continue flowing if it fails,
facilities may, in addition, choose to install a "fail safe" valve between the
mixing valve and the faucets to which the water line is leading. Generally, these are
solenoid-actuated valves that shut down the hot water supply to the shower or tub (or
sink) if the water exceeds 110 degrees. Although these valves are generally quite
expensive, they are they only way to guarantee that unsafe water will not reach any of the
faucets served by the water line. However, neither HFS 83, Wis. Administrative Code, nor
the state plumbing code requires this type of valve in a non-health care facility. You
should be aware that the Department of Commerce is looking at the possibility of including
CBRFs under their definition of a health care facility. If this occurs, new CBRFs
would be required to have a "fail safe" valve.
The size of your piping and the manufacturer model design both affect the cost of a
thermostatic mixing valve and a fail-safe valve. If you purchase a thermostatic mixing
valve or a thermostatic mixing valve and a fail-safe valve, we urge you to shop around. We
have heard that estimates may vary greatly.
Other ways facilities may meet the requirement for 110-degree water include the
following. Each of these options, if not used in combination with a mixing valve, requires
the installation of devices at each individual sink, tub, and shower that is used
by residents.
2. Install a shower valve at each shower used by residents that complies with the
intent of the "fail safe" system. The Department of Commerce has currently
approved one such valve – the Chicago 2500 TempShield Tub and Shower faucet valve.
This valve controls water temperatures at the tub and shower and shuts off the water if
the temperature exceeds 110 degrees. It does not control water temperatures at the sinks
and there is not an approved counterpart for installation at the sink. Another method will
be required to control water temperatures at the sinks.
3. Install a faucet with an adjustable hot-limit safety stop at each sink used by
residents. Safety stops keep water at the faucets at a pre-set temperature by blending the
amount of cold and hot water. If the water heater malfunctions, however, and heats the
water even higher than where it had been set, a safety stop will still continue blending
the same amount of hot and cold water. As a result, water temperatures at the faucet will
be hotter than what is expected and burns could occur.
4. Install, at each sink, shower, and tub used by residents, a
temperature-actuated flow reduction valve. Depending on the faucet, these valves cost
between $6 and $30 and can be easily retrofitted onto each shower, tub, and sink fixture.
These valves reduce the flow of water to a trickle when the water temperature is
approximately 115 degrees F. or above. We cannot recommend brand names; however, such
valves are available at local plumbing or hardware stores. Because we do not have
experience with the reliability of these valves, we suggest that you monitor the
temperature of water coming from faucets on which these devices have been installed. In
addition, these devices only limit the hot-water temperature to approximately 115 degrees
F. Facilities using this option on tubs and showers will need to request a waiver of the
110-degree hot water requirement for tubs and showers.
To maintain compliance with HFS 83.41(5)(d) 2 and HFS 83.21(4)(w), Wis. Administrative
Code, we ask that you:
-
Routinely check the temperature of water at various fixtures used by residents;
-
Take appropriate responsive action if the temperature is above 110 degrees; and
-
Regularly clean the mixing valve(s) because liming from the mineral deposits found in
water may eventually cause mixing valves to malfunction.
If you have questions, please contact the Regional Field Operations Director to whom
your facility is assigned. Their names and phone numbers are [via Regional
Offices, ask for Assisted Living Supervisor]:
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