 So, well, thank you very much, John. So, I've been asked to talk about a document that was issued by Public Service in Percumin, Canada. But what I did as I was listening to presentations this morning and some of the questions I've tried to, you know, add to some of the slides a little bit to address some of these questions. And what I did also was to look at other regulations also in Canada in terms of as is related to Legionella and drinking water also. So, I want to put a disclaimer up because I did not work on this document. I did not prepare this document. I'm just doing it on behalf of Public Service in Percumin, Canada, basically. In Canada, generally speaking, regulations are either under federal jurisdiction or provincial jurisdiction. And we have what we call provinces and territories. So, under the federal regulations for Legionella, there's nothing really specific. The only thing we have is the Occupational Health and Safety Code that basically said if there is a potential for this, there's a duty to investigate and to remediate. The National Building Code talks about minimum design, but again, does not address specifically Legionella. And anything that's federally regulated will be under federal regulations like bang and transportation and so on. And then you have the provincial regulation, and I think that will be the equivalent to the state regulation here. And different provinces and territories varies in their requirements for Legionella, but it's mostly reactive. So, if you have an outbreak, you have to do testing and follow-up and so on, but there's nothing in terms of preventive, per se, except for Quebec. Quebec has a regulation or a réglement for the surveillance of cooling towers, and that is to follow on the very bad outbreak they had in about 2012-2013. And there's also provincial or municipal building code depending on where you are. So, that's the general gist for regulations in Canada. So, I put this on, sorry, so that's the other thing. My slides are really, really packed. And the intent is that I'm going to talk, you can read much faster than I talk. So, I'm just going to highlight the slides, but the slides like will be available for you to review, and the information is there if you want to look at it. So, in terms of drinking water, we have maximum allowable concentration for microbial, chemical, and other things. And we have guidelines, but for testing for drinking water in buildings, we only require to test lead, E. coli, total coliform, and sometimes the pH. And as you can see, the Federal Provincial Territory Committee on drinking water basically said that there's no need to establish a guideline for chlorine in drinking water. And they suggest that basically it's, you know, you can use it, you can decide on a certain concentration depending on the configuration of the system, and, you know, taking into account aesthetic concerns and things like that. In Ontario, we have specific guidelines for special system. And under that guideline, sorry, regulation, take that back, it's a regulation. It's applied to daycare and hospitals. So, it's what it's considered a special or higher risk system basically. But again, it's not specific to Legionella. So, specifically this document, so it's referred to as the Mechanical Directive 15161, originally published in 2013 by PFPC, which is Procurement Service, Public Service and Procurement Services Canada, or in the US, again, as the equivalent to GSA. And it was following the outbreak that they had in Quebec City. So, the federal government, feeling a little bit insecure about the whole thing in Quebec City, has published this document after. So, just a quick notice, what the PFPC is the federal department, and it provides federal employees with Workspace. So, it's managed federal facilities basically. So, it can go from the Parliament of Canada to typical office building for public servants to people working on ships and so on. This particular document address buildings, basically office, mostly office building. So, the document is a standard because it used the language you shall. And there's some recommendations sometimes that they should, you should be doing this, but most of the time you shall be doing this type of thing. And it provides a minimum requirement for design, operation, maintenance and testing for Legionella specifically. And the bacterial validation testing focused on total Legionella genophilum, and the target audience is property manager, property owners, maintenance personnel. So, this is important to keep in mind. This is targeting people that manage buildings. At this point in time, this document applies to all crown owned buildings that are managed by PFPC. And it's mostly office building, and very specifically it does not apply to remote residential housing because of the territories we wanted to make sure that any installation that they have up north, this document does not apply to. One of the things I really like from this document is talk about the role and responsibility of different people. And this is just not an exhaustive list, but you can see, okay, so the director general is responsible for monitoring compliance with standards and so on. And there's, you know, it goes and provide training, and then the regional director is responsible for this, and the facility managers are responsible for different things. So, it's very detailed in terms of role and responsibility. And it starts with a basic principle, which I really like. And I think that I, you know, as I listen to John and so on, I see, you know, that other document has been taken into account, like the LA document and so on. So, but it's basically, it has to be based on a national billing code. It has to be, you know, consistent with the latest industry standard, have to comply with provincial regulations and so on. And one of the things that I find interesting is that they really want to have consistency throughout the board. So, they really want you to use checklists and laws and so on standardized forms so that eventually they can have some sort of database, and that would be great if everything is consistent in terms of managing this whole thing. And the other thing they talk about is personal protective equipment. So, this is not new. I think we have heard about the management plan in other documents, basically. So, what it says is that each facility shall have its own management plan. And, you know, with all these conditions and how it's upkeep. And a little bit like the LA documents requirements, it is a living document, so you have to keep it updated if there's changes and so on. As I say, you know, we talk about schematics, about operation manual, about checklists and laws. So, the document provides the checklist, basically, and provides the laws. In practice, establishing this plan is not that easy. And I can talk about that a little bit later on, but the document itself leaves, you know, to say, well, go and establish a plan with a group of people who may know about the building system. Okay. So, when we do these things, you know, we typically like to work with plumber or plumbing engineers, because some of these documents say, well, the engineer should be there. Well, I'm a mechanical engineer by trade. I don't know anything about plumbing. So, you know, you need to make sure that it's clear in terms of who needs to be there. And it's not that obvious to talk about schematic when you cannot find drawings for the building or the latest drawings date back to 1962, when the building is in built, right? So, you don't know what's going on. So, and the other thing is, what are the performance indicators of these building water systems? A lot of time, they don't know how they want these systems to be performed. They just kind of, well, we hired a consultant to come and maintain these units and we hope for the best. I mean, hopefully it's maintained and it does what it's supposed to do. But we don't really know what the in-house, they don't know what the key performance indicators are. So, the document talks about the audio system, you know, the cooling towers, the open water system, the HVAC component, the domestic hot and cold water system. But what I know is when we were doing the establishing the plan, people ask us, well, what about the water coolers? What about the ice machine? What about the emergency eye wash and so on? Do we need to include that in the plan? And if so, what are the steps that we need to take to do, basically? So, again, you know, I have put in some of the slides that talk about the difficulty of doing these plans because it's not always that obvious when you try to do an inventory of all the equipment. One of the things that we've noticed, which is really interesting, and some people would say, well, but I have tenants, so tenants maintain their own equipment. And I maintain the building, so where's the line, right? I mean, and sometimes, you know, you have people with different age of equipment, have different labels, it's been labeled three times, different ways. So, you're just trying to figure out how all of this inventory is done can be pretty intensive, basically. And to respond to what Chuck was asking, I'm just going to show, so there's a risk label that's attached to not only each of the building water systems, but to the facility itself. So I'm just going to show you what it looks like. So for cooling towers, it says that, okay, so if you have a cooling tower that is located less than 10 meters from the air intake, it's considered to be a higher risk level. And they go through that for cooling towers, for HVAC systems, and for domestic hot water and so on, and there's characteristics that you have to take into account. But even more interesting is that once you've done each of these water systems, the documents say now the facility get labeled. So if the facility contains any high risk system, the facility is considered to be a high risk system. So that's an interesting difference that I'm seeing with other documents. Each of the systems, basically for each of the water systems and the documents, there's design requirements. If you are building new or you're replacing the equipment, there are requirements and considerations that you have to take into account. The section on spread out, shutdown, commissioning of systems, operation and maintenance, water treatment, and minimal bacterial testing requirements. In normal operation, in emergency operation, and also they get a little bit specific on the location where to take this test. So this is what it looks like for cooling towers. For operation and maintenance, you have to do an inspection. That's the minimum frequency, how often you have to clean, how often you have to disinfect, and so on. So they get very specific on that. And then on the testing. So it's got a little bit better over the years, because it's been five years now that these documents come out and they have tried to implement it. But again, how to test, where to test, what do you do next, and for how long. And there's still a lot of questions about if I get sort of positive results, what do I do, and who do I report to, and what does it mean. And what is interesting is, based on that, they have published a second document talking about communication. And I will talk about that a little bit later on. But you know, one of the documents I really like is the Quebec document about sampling protocol. And they explained it very specifically, you know, how to do it and where to do it with pictures, which is always helpful for building operators, basically. So in terms of testing, there's three ways. They want you to do deep slice, they want you to do culture, and they do want you to do QPCR. And I'm going to go in more detail in each of these. So these are the action levels for the different system types. And the code is, sorry, I'm just going to show the code. Oh, where's the code. So the code is green is continue normal operation, yellow is review and adjust, orange is clean, red, well, obviously, you know, the surgeon. So, but you can see, I mean, we see the same, the same sort of numbers, the thousand, the 10,000. What I found interesting is that the level are different for cooling towers and humidifier, for example. So that's for what? For what volume? I don't know what the volume is, but probably in the document. But the volume is the same, right? So relatively, the volume that they take for the cooling tower will be the same for the volume for the drain plan. It's just I'm not sure how they got to that number. What I can tell you is I try to contact the author of the document, but I haven't heard back. So I don't know if he has to ask for permission or he doesn't want to talk to me. So I asked where these numbers come from, right? And it's based on what? But I just want to show you basically what they define as action level and not no action level. So this is the testing, the minimum frequency of each of the testing that needs to be done specifically for cooling tower in terms of this size, in terms of culture, in terms of two PCR. So the PCR with less than 100 G copies per mil? Yep. And I don't know where these numbers come from. So this is the code level that I talked about. So I know it's really small, but basically they have fairly detailed process into what you need to do based on these levels. So based on, for example, I don't know if you see here, weekly testing with the dislodged, if it's green, you go straight to keep operating and there's no additional testing that's required. But if you are doing weekly testing as an orange, then you need to really clean and then you need to notify people and so on. So it's just a good process, I think. So what I did here is I took the document itself and I did a little bit of comparison with other document that's out there and tried to highlight, again, as I say, it's really in tiny writing, but I wanted to cram as much information as I can. And I compare it with the ASHRAE standard 188. And, you know, we know that the MD15161 is a standard, but ASHRAE standard, I think it's not a standard unless it's, you know, being incorporated in the building code or it's accepted basically. So it's just referred as a standard, but it's not really a standard until then. And what is interesting is the ASHRAE document talks about establishing the risk assessment, the document per se, but I don't think it talks much about the actual testing. It just says, you know, establish a plan and based on what the team that established the plan say the testing shall be, then go and do the testing, basically. So, and there's no communication plan, basically, in the ASHRAE document, though it's addressed more system than the MD15161. So this one, the document is the document from the American Industrial Hygiene Association. Again, the AHA document is a guidance document. It's a best practice document. It looks from a public health point of view. And the difference is that they talk about a competent professional when ASHRAE talk about, you know, a team when the MD15161 talk about a professional engineer. So there's different qualification, if you want, from each of these documents. They talk about waterborne and surface sampling in the AHA document. They don't recommend airborne sampling at all. They really would like to focus on viable sampling and the AHA document focus heavily on the sampling plan and the action based on the results. So I looked briefly about comparing the documents from EPA about different technology for treatment for control of Legionella in premise plumbing. You know, we talk about portable water only as opposed to the MD15161 that talks about cooling tower. You don't really drink water from cooling tower, hopefully. But, you know, they talk about the EPA, talk about the impact of different technology and how it can be used to control Legionella and so on. And so I look at the Canada Occupational Health and Safety Regulation. It does not talk about Legionella at all, but it talks about the duty to make sure that there's no risk and you have to make sure that you investigate and keep record and so on. So in effect, Legionella could be under that as just considered to be a risk and have to be dealt with. So province and territory, as I was saying, Ontario seems to be aware. Most of the provinces and territories, we have done a survey of their public services and they seem to be aware, but they refer to the national building code and the national plumbing code, which we know are minimum requirement and do not address Legionella per se. And, you know, they have some sort of statement about Legionella, but not really anything in terms of mandatory design or operation and for testing, except obviously Quebec. And Ontario recognize that health care or facility house are more susceptible to installation for Legionella, but they don't have any specific recommendation needed. And this is the Quebec regulation, and I'm sure the regulation itself is in French. So I tried to put a few things on there. One of the interesting things is that it's required that if you are an owner of a cooling tower, it has to be registered with the building department, basically, and that there have to be a regular maintenance program established and results need to be, testing results needs to be sent to the building regulatory body, basically. And they use 10,000 and a million. So above a million, you literally have to notify the health department right immediately and then, you know, they shut down everything and you retest and everything else. Under 10,000 UFC, there's nothing you don't have to do anything. In between the two, you have to do some cleaning and make sure that everything is passed again. So I want to go into the highlight of the MD15161. It was implemented in about 2013. That's when we start doing these risk evaluation of these documents, of these buildings. And it was done for about 360 buildings, basically. And they started monitoring compliance in 2014, making sure that the Legionella control management plan is in place and testing is being done. This is basically information from Jeff that basically said that Jeff Mofat, who is basically from PSPC. And what they say is like they have increased monitoring and they have basically validation and auditing of compliance in their own facility. And what they see is that other federal department and other provincial department are starting to adapt the document, the process described in the document also. So again, these are results from Jeff Mofat shows the results that they got after they implement the MD15161 in their building. So that's that. So that data is, sorry, let me just go back. Is the number of culture hits that precipitated than the cleaning? Yes. So then that's, from what I can see, that's only applied to 200 cooling towers. He doesn't have, he doesn't seem to have any data for anything else but the cooling towers, basically. So he sent us to this link, basically, that's the public health agency of Canada. And what I did was I pulled out the number of the percentage of cases since 2014, just to see, you know, make any difference with public works, implementing their things or not, basically. And, well, in 2015, not really. But what he said was interesting is that he said there's no reported case of lesionillosis in PSPC. So the increase is somebody else, basically. So I touched briefly on the communication protocol after, you know, after the implementation of the MD15161, what they found is that, okay, people get results back and now what they don't know what to do with it and they create all kinds of misunderstanding. And so how, who do you communicate and how do you communicate? And so what they did was they create a pretty elaborate chain of communication, basically. And it shows, again, these are the levels where you need to communicate. And basically, you've seen this. So this is very, I just took one of the communication protocol. And they say, well, if it's yellow for this slide, you need to, you know, go back to this section, you need to talk to these people, you need to make sure that you adjust the operation and you need to make sure that different people are being notified of what's going on. So, as I was saying earlier, implementing the plan is sounds easy on paper, but it's not that easy to do on the, you know, foot to the ground basis, basically, because a lot of it is left to the building operator. The device testing is left to the building operator, because it's too freaking and too costly to have somebody in a third party come in every week to do the testing and keeping track of everything, basically. And so that's where we find that that was one of the weak point of the document, basically. I put a few slides that talk about difficulty when the plan talk about, you know, shutting down a cooling tower in an emergency situation. When you can't really shut down a cooling tower, it's hard to shut down. One, because if you have a problem, it's because mostly it was operating. It was operating because it needed to be in operation. So, you know, there's other things than just shutting down system and take them offline, basically, to clean or to test. Same thing goes with HVAC system. We found that a lot of time when we do inspections that the standalone air conditioning unit for computer rooms are not taken into account. So, maybe in any process, it needs to be clarified a little bit better. One of the things that we see really now, and I don't have much data and have not been able to find much data on it, is basically non-potable water storage for planned watering and for green walls. A lot of the water for green walls or bio walls they're referred to are recycled water. They cannot be treated because, you know, you can't coordinate because the plants are fragile and a lot of these plants on these bio walls are not in soil. Basically, the roots are exposed. And what we found is that as, yeah, so, you know, you can't do a lot, but it's bio material. So, and from what I heard, apparently PSPC have put in their procurement requirements for all new buildings that they should contain a bio wall. So, you know, one of the things that we've noticed also is in high performance building, they are stepping away from a very large water tank, like big boilers tank and so on, and they have these tiny little tanks point of use basically under the sink and so on. There's no way of controlling the temperature in these things. There's no thermometer or anything and you have to find them and you have to maintain them. So, that's great a difficulty, especially if you have very large office building and so on. And a lot of things we talk about like sprinklers, what happens to sprinkler system, what happens to hose div and so on. That's not being really addressed and there doesn't seem to be any data about that either. What I hear from building operators and owners is that, well, how much does it cost to do all of this? Because there's not a lot of cost being addressed in these plants. It's like, well, you shall do this and just go ahead and just test. So, for example, in the emergency mode, PSPC told us that they want 12 weeks worth of sampling, culture and QPCR. And it cost money to do so. So, how long do you keep testing? So, if the 12 weeks, instead of 12 weeks, clean, no concentration whatsoever, what happens? You do 12 weeks and within one week of that, you get a hit. Do you do another 12 weeks after that? How do you keep testing forever? Basically, in terms of how do you clear a system that's been deemed contaminated or have potentially a problem? And the other thing is, can laboratory meet demand? Because we know that our laboratories are not able to handle that kind of testing with not only one building, but all the other buildings that's going on at the same time. So, that's the kind of questions that we have received. There was questions about QPCR. Public PSPC has encouraged new technology because they know that their requirements are pretty intensive and pretty cost-intensive. They have sponsored a portable QPCR piece of equipment, and that did not go well. So, basically what it says is that the QPCR result came back with a lot more contamination than their culture samples. And somehow it made it to the media and somehow created a white panic in the city that, my goodness, whatever building is contaminated and public PSPC is not doing anything. So, at this point in time, they're trying to stay away from QPCR. They're sticking to the culture pretty much. I'm not sure what's the status on that, but that's the latest that I heard from that unit in particular. So, it was a great document when it was first published in 2013. It's been a good reference document as far as we're concerned. It needs to be normalized even more. And I'm not sure how much PSPC is keeping track of everything. From all the data I've seen, they seem to have data for cooling tower, but not the other systems that they were recommending that testing be done. We find that we are in the second iteration, if you want, of redoing these management plans, because 2013-2018, basically, in most buildings, it's a five-year sort of updating plan. And we find that it gets better because people use the document and they're like, oh, no, that location really, it's hard to sample and so on. So, we did this better. We don't like this and so on. So, it's got better with each iteration on how to prepare these risk assessments. One other thing is we found that despite everything training for the building operator and for the general, if you want the people involved with the maintenance of the building and operation of the building, the training is not there. It's not standardized, so it's hard to make sure that they understand everything in the same way, basically. And it's hard to keep simple. It's not easy to keep a document simple because a water system in a building is hard. Where you can sample, how you can sample, it's really difficult to determine. And I think we, maybe we need regulations like Germany. Okay, all right, good for me. Good. Thank you very much. All right. This, Michelle, have a question? Okay, Michelle, you get to go first, since I cut you off last time. Sorry, I'll be short. Yeah, just a few comments. Hi, how are you? It's not for the Quebec regulations. So, we have the same concerns on just a few points of clarification regarding the ability of the labs to pick up and carry out the analysis. But after a year, everything was basically done and there's been no, this is good business. And so, if you have a standard method that's mandatory and specified like it is in the Quebec regs, the labs follow suit and they just get organized to do it. So that part I think it's been shown in the US as well can be tackled. A second point that's quite important, the Quebec regulations, they target all cooling towers and more than the capacity I forgot exactly, but anything that's significant. So basically, it's quite a bit of data. They have generated the data. They have not published it. And for a subset, they've done parallel QPCR by the government and culture. I have the data in the Middle East preparing a table that I will be able to share with the government's approval. So you'll see when we do both what it does and actually QPCR has really been proven to be useful to detect the towers that are going out of compliance before they hit the high numbers by culture. And it was the final one for, yeah, the levels are per, the levels are per leader. So they seem high. They are high. They're basically 10 fold higher than the European numbers. The low level where you need to look at your tower, the 10,000 to a million, that's 10 times higher. It's lower than the levels that are tolerated elsewhere. And the reason for these high numbers, I can tell you, I sat on that committee when they wrote that regulation, they freaked out that everybody would be out of compliance. So they put a higher number. And now the numbers are reported when they're in compliance, but they are reported when they're lower. And they do serve to find the towers that are in default. We had too many outbreaks last summer in a city in Quebec, and they could find the faulty towers within the day and act upon it. So that was my additional info for the cooling tower part. Yeah. Thanks, Michelle. Michelle, the QPCR versus culture report, is that something that will be available to the committee anytime soon? Activated my sound again. Yes, it will. Probably next week. I was reviewing the table earlier. So it's not published in an official paper or anything, but it's shared by the government. So that could be helpful. That's fine. That'd be great. And the investigation of the numbers, the values found in the cooling towers during this outbreak, that's in a report as well? Sound back again. No, it's not. And that's that that part, they're more they're more reluctant to share on the numbers. So you're looking for evidence of infectious dose. Now, they match these trains. They've done this now three times, but they have not shared publicly the numbers in the cooling towers that were found to be the most probable source Quebec and now those two events in 12 years. So I can ask, but I'm not sure they will at this point, because there might be some kind of inquiry of what why the regulations are not strict enough. So they're kind of they're in court right now for the last outbreak. So they're kind of right. Touchy about that. Okay, thank you. All right. Other committee. Chuck? Yeah. I'm really starting to wonder what sort of procedures are in place to to follow the control on laboratory testing the environment. Is there a certification process? From what I understand, I'm sorry. From what I understand, I think they refer to the elite. And then also AIJ has a laboratory certification for microbiology. I think it's MLAB or something like that. But it's referred to. Yes. There's one point there. The elite program does no qualification. Yes. That's just a present asset. So there's nothing been done in terms of lines. Anything that sort of just in general, I mean, is that publication? Well, is there any data on lines with sample performance, the laboratory quantification DGNL? There is one. It depends on the provinces. Yeah. Well, Shantini shows that they've been sampled up. Right. Yeah. Yeah. And they're in the lab. Yes. That's right. I think there's some publication. There's a CDC publication, but yeah, that one has some issues. But to Michelle's point, we had one occasion where we sent the two separate labs, and at the time they're both CDC elite. And they had completely diametrically opposed results. That's like John Lee's 2011 study and subsequent ones that he talked about. I think it'll be useful for us to get some of the limited data just showing the performance of the blood in general. Now, reflect what's here in North America. The other issue there with the elite labs is that I believe it is in the program, proficiency program, exactly what's going on. They have routinely quantified, by the way, Wisconsin state health laboratory. They've always quantified. So I don't think the elite lab has changed. Next. Yeah. Just looking at the report on an appendix C and D. It's talking about the units in those labels reflected. It's there at C if you per mill. Per mill. Yeah. Can we put that slide up? Because then I saw another one that said per liter on her slide. Yeah. Well, I'm reading the report. It says per liter. Well, now it's per mill. It's slide 23. I'm trying to figure out what's slide 23. I'm reading the notice to it. In the main report, it's just a confirmation of the main report of appendix C. Okay. And you'll see there's a leading error in C if you per mill and genome copies per mill. Okay. So that's where we had. Yeah. Yeah. I had genome copies per mill. Yeah. But then there was a use F C slide that said 10 to the fourth, the 10 to the fifth per liter in the presentation. I presumed they met CFUs and it was just reversed. I don't know what you see it. CFUs, right? Okay. Sorry, let me just pull out. It's CFUs in French. That's what I thought. I thought with CFUs. I just, all right. No, that's not the one. This is general. That's okay. There are three levels of this slide. Yeah. Yeah. With that whole culture by the legionella method, which is a 50 per mill and then the QTDL. Why is it not? As you say, it's per mill. Yeah. Per mill. Yeah. Guys, you can look at that. The table from the guidance is in the May presentation that we did together. And I think those are, since they're copied, there's no confusion there. They're on slide, slide, slide, slide, slide. Yeah. We're in there. Actually, I took the, yeah. I said they're all like the text from slide six of the presentation in May shows the numbers out of the, directly out of the guidance. Yeah. So there are pens, the, the, the. Per mill. Per mill. But, but, but you've got, I can understand the dip, dip slide because that's probably the limited detection. Yeah. But then you've got, when a QPCR test results indicate GEs, I presume that's genetic equivalence. Okay. That's 100. That's 10 of the two. And then the QPCR says, 10 CFE per mill. I don't think we should, we shouldn't go over it too much. But then there was another slide that said, And then the report per leader. This is not clear. I don't think we should concentrate over it. Yeah. I just wanted to try to clarify it. There you go. Just add, okay. I think we can go back to this. Okay. Some other questions? Comments? Before we take a break. Okay. Thank you very much.