A water management plan protects people only when the facility uses it to guide decisions. Dr. Abe Cullom, Director of Water Safety & Management at Pace Analytical, joins Trace Blackmore, CWT, to examine why Legionella programs break down—and how testing, communication, and consistent implementation can strengthen them.
Implementation Is the Bottleneck
Five decades after Legionella was identified, researchers understand much more about the organism, its ecology, the conditions that support its growth, and the interventions available to control it. However, Dr. Cullom identifies implementation—not a lack of science—as the primary bottleneck.
Many plans remain in filing cabinets or operate on autopilot. Teams collect measurements and samples, yet no one connects the results into a complete picture of the building water system. Process failures, limited follow-up, budget constraints, and unclear communication can allow a developing problem to remain hidden behind repeated low-level corrective actions.
Testing Must Inform Risk
Culture remains a dominant testing method, although the typical wait for results can complicate decisions during an investigation or operational change. qPCR provides faster results but may detect genetic material from both living and dead cells. Dr. Cullom also explains viable but non-culturable cells and why recent heat treatment, supplemental disinfection, oxidative stress, or prolonged stagnation can affect culture results.
The goal is not automatically to drive every Legionella result to zero. Instead, teams should interpret findings using the species detected, distal site positivity, the facility's population, and the limitations of the testing method. Dr. Cullom explains why testing only for Legionella pneumophila may make sense in some systems, while healthcare facilities may require a broader view because highly immunocompromised patients can develop infections from other Legionella species.
Ownership, Communication, and Continuous Review
Water management plans often fail when responsibility for corrective action has not been assigned. Dr. Cullom calls one version of this breakdown the "milkman approach": a consultant or water treater delivers results, but the facility expects that outside party to organize a response that was never included in the scope.
Effective programs clearly define authority, assign actions, and give engineers, infection prevention professionals, facility leaders, consultants, and water treaters a shared vocabulary. When reviewing a program, examine its records, verification and validation activities, corrective-action documentation, and long-term data trends.
Dr. Cullom recommends giving someone at least 30 minutes each month to consider what the results reveal and whether the plan needs to change. He closes with a direct priority: validate every plan through testing—at least once and, ideally, routinely.
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Timestamps
08:40 — Trace introduces Dr. Abe Cullom and begins a practical examination of water safety, risk assessment, and Legionella outbreak prevention.
11:30 — Dr. Cullom defines opportunistic premise plumbing pathogens and explains why vulnerable building occupants face greater infection risks.
13:10 — Building water systems emerge as complex microbial environments shaped by chemistry, hydraulics, construction materials, pathogens, and antibiotic resistance.
14:40 — Fifty years of Legionella research have produced strong scientific guidance, but inconsistent implementation remains the central bottleneck.
16:40 — Process failures, poor communication, limited follow-up, and plans running on autopilot can undermine otherwise sound water management programs.
18:50 — Dr. Cullom compares culture and qPCR testing, including turnaround time, sensitivity, and the challenge of detecting DNA from dead cells.
20:50 — Testing only for Legionella pneumophila may reduce unnecessary responses in some systems, but healthcare facilities may need broader species testing.
22:30 — Viable but non-culturable cells can complicate sampling after heat, disinfection, oxidative stress, starvation, or prolonged stagnation.
24:10 — "Zero Legionella" and "zero cases" represent different goals, requiring teams to manage health risk instead of reacting identically to every positive result.
26:10 — Distal site positivity measures the percentage of sampled outlets testing positive and helps teams interpret building-level risk.
27:50 — Corrective actions can stall when authority, responsibilities, and expectations between facilities, consultants, and water treaters remain unclear.
30:00 — Plans, diagrams, and training should give multidisciplinary program teams a shared vocabulary for productive water-management decisions.
33:10 — Pseudomonas aeruginosa and nontuberculous mycobacteria deserve greater attention as additional building water pathogens.
34:20 — Public health, regulatory responsibilities, and the cost of outbreak mitigation can help professionals make the case for proactive water management.
36:50 — A program review should examine documentation, verification, validation, corrective actions, data trends, and how facility leaders interpret the results.
38:00 — Dr. Cullom previews "Clinical Crossroads: The Risk Burden of ST-108," addressing water quality, sterile processing, and new areas of liability.
39:40 — Program teams should dedicate time each month to reviewing data, challenging assumptions, and updating their understanding of the system.
41:30 — The Legionella Awareness Month lightning round covers essential resources, common communication failures, and routine testing as a driver of improvement.
Connect with Dr. Abe Cullom 
Phone: 913-948-3948
Email: abe.cullom@pacelabs.com
Website: People Advancing Science®: Transforming Environment & Health
LinkedIn: https://www.linkedin.com/in/abraham-cullom-46b04385/
https://www.linkedin.com/company/paceanalyticalservices/
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