By Phenelle Segal, RN, CIC, FAPIC, Founder, Infection Control Consulting Services
ANSI/AAMI ST108:2023 represents the current nationally recognized consensus standard for water used in medical device processing — and ambulatory surgery centers that have not yet developed a formal water management plan are carrying real compliance risk. I have been working with ASC clients on sterile processing and infection prevention for over 40 years, and for the past two-plus years, AAMI ST108 and the need for a comprehensive water management plan has been a consistent part of that conversation. What I am seeing is a growing number of surgery centers recognizing that this is no longer something they can defer.
What Changed with ST108
ST108 replaced AAMI TIR34 — a technical information report that offered useful guidance but carried no formal enforcement weight. ST108 is different: a ratified ANSI standard that accreditation bodies are already treating as a benchmark during surveys.
For Joint Commission-accredited organizations, water quality management may be addressed within the facility's broader water management program under Environment of Care standard EC.02.05.02. ST108 provides detailed guidance for the medical-device-processing portion of that program. Many AAAHC-accredited centers are evaluating ST108 as part of their water quality and reprocessing programs. Surveyors are increasingly asking organizations for their plans to demonstrate how water quality risks are assessed and managed.
There is no single hard compliance deadline, which some ASC administrators interpret as permission to wait. I would caution against that.
While CMS and accrediting organizations do not specifically mandate compliance with ANSI/AAMI ST108, facilities should be prepared to demonstrate that their approach to water quality management is based on nationally recognized guidance, accepted standards of practice, IFUs, and a documented risk assessment. Awareness of ST108 among surveyors and accrediting organizations continues to grow, and surveyors are increasingly referencing it during surveys — making now the right time to get a program in place.
What We Are Seeing with ASC Clients
When ST108 was published in 2023, I began proactively reaching out to my ASC clients to make sure they understood what it required and what it meant for their facilities. Most were aware of the standard but not yet treating it as urgent. Over the past year, surgery centers have been coming to us specifically to develop water management plans, and that work is now active with our centers across the country.
What the development process consistently surfaces is that most ASCs are managing their reprocessing water through a combination of vendor relationships, equipment maintenance schedules, and informal practices. Unfortunately, they often fall short of what ST108 requires: a formal, risk-based program with defined water quality classifications, documented monitoring, corrective action protocols, assigned responsibilities across the interdisciplinary team — infection prevention, sterile processing, facilities and engineering, and leadership — and a structured review cycle. Most facilities have pieces of this. Getting to a coherent, defensible whole is a different undertaking.
This work sits squarely in infection prevention, not just facilities management. Infection prevention plays an important role in program oversight, risk assessment, and ongoing review as part of the multidisciplinary team. Water quality failures — residue or contamination on reprocessed instruments, compromised sterilization, equipment damage from mineral deposits or biofilm — are infection prevention consequences. That is the lens through which this program has to be built and maintained, and it is where ICCS brings specific expertise that a water treatment vendor alone cannot.
What a Water Management Plan Covers
The programs ICCS develops for ambulatory surgery centers are facility-specific and built around the full scope of water used in medical device reprocessing: manual cleaning, automated washer-disinfectors, ultrasonic cleaning, endoscope reprocessing, final rinsing, and sterilizer steam generation where applicable. ST108 takes a risk-based approach, which means the program reflects the actual complexity of your facility's water systems and workflows, not a generic framework.
The plan defines water quality classifications — utility water, critical water, and steam — with requirements aligned to each stage of processing and to device manufacturer instructions for use (IFUs). It assigns cross-functional responsibilities. It establishes a monitoring and verification structure, with defined sampling locations and frequencies based on risk assessment. It includes corrective action protocols for when results fall outside acceptable parameters, preventive maintenance requirements for water treatment systems, and staff training and competency documentation. The program is reviewed at minimum annually and updated whenever there are significant system changes or water quality incidents.
How ICCS Can Help
Water management plan development under ST108 is a direct extension of ICCS's infection prevention work with ASCs. It requires understanding ASC operations, reprocessing workflows, device-specific requirements, and the accreditation environment your facility operates in. That is the foundation we bring to every engagement.
The programs we develop meet the requirements of ST108 and the water management expectations of The Joint Commission, CMS, AAAHC, other accreditation organizations, and applicable state regulations. We are actively doing this work with surgery centers nationally, and that current, hands-on experience informs everything we develop.
If your ASC does not yet have an ST108-compliant water management plan — or if you are not confident your current documentation holds up — reach out to ICCS before your next accreditation survey, not after.
Ready to develop an AAMI ST108 water management plan for your surgery center? Contact ICCS.