Which ASHRAE 188 records does the owner keep, and the vendor?

This split covers buildings that follow ANSI/ASHRAE Standard 188 by choice, by contract or under an adopting code. State, city, national or accreditor rules on records and retention decide where they are stricter. Standard 188 is sold by ASHRAE, so the split below comes from public summaries and is marked as inference where the standard text was not seen.

Who owns the water management program records under ASHRAE 188, the building owner or the water treatment vendor?

The building owner owns the ASHRAE 188 water management program records, because the Program Team that develops and maintains the program is designated by the owner, and the vendor works inside that team. A public summary of the standard defines the Program Team as "a group or individuals designated by the building owner or designee to be responsible for developing, implementing and maintaining the Program" (Garratt-Callahan, 2015). The same summary lists documentation and recordkeeping among the program elements: establish documentation of all procedures and maintain records (Garratt-Callahan, 2015). That summary was written for the 2015 edition; the 2021 edition, according to ASHRAE, replaced permissive language with enforceable language (ASHRAE, 2021).

The CDC toolkit, which interprets Standard 188 for building owners, names "Equipment or chemical suppliers" and "Contractors/consultants" as possible team members next to the building owner (CDC toolkit version 1.2, 2025). A vendor on the team therefore produces records for the owner's program; it does not run a separate program of its own. This is an inference from the team duty, since the standard text itself was not reviewed for this article, but it matches the one rule found that states ownership outright: in New York City, "The owner must keep records for each cooling tower for at least 3 years" (24 RCNY §8-07(a), NYC DOHMH, accessed 2026).

Which ASHRAE 188 records does a water treatment vendor produce for the owner?

A water treatment vendor typically produces the monitoring results, chemical addition logs, service reports, Legionella test arrangements and its share of corrective action records, while the owner's Program Team produces the program documents themselves. The table below decides which side holds each ASHRAE 188 record and what the service contract has to fix. Produced by and Kept by are inferences from the Program Team duty unless a cell cites a rule; contract wording and time limits are illustrative.

Read the table by asking, for each row, who could rebuild the record if the other party disappeared. The owner can rebuild the team list and system description; only the vendor and the laboratory can rebuild monitoring data and test reports, which is why those rows need a delivery clause. The row to settle first in a contract is monitoring results: the vendor writes them, but the owner should hold the original. New York City requires the owner to keep 3 years of water treatment, test and corrective action records for each cooling tower (24 RCNY §8-07(a), NYC DOHMH, accessed 2026).

Where should vendor service reports and Legionella test results be kept under ASHRAE 188?

Vendor service reports and Legionella test results should be kept in the owner's program records, where the Program Team can review them, and not only in the vendor's files or customer portal. CDC tells owners to write the program down because "This information will be important to improve your program and if you or others want to review your records" (CDC toolkit version 1.2, 2025). A record that only the vendor can open fails that purpose when the vendor changes.

The same CDC section lists what the written program should hold, including the Program Team, the water system description, control measures, confirmatory procedures, and the sample collection and transport method and the laboratory used when environmental testing is done (CDC toolkit version 1.2, 2025). For Legionella testing, ASHRAE added Normative Appendix B through Addendum e to Standard 188-2021, setting minimum requirements when the Program Team chooses testing (ASHRAE, 2021).

New York City adds format rules for cooling towers. A Legionella result must be recorded in a final laboratory report that includes the signed chain of custody and the laboratory's ELAP certification number (24 RCNY §8-05, NYC DOHMH, accessed 2026). Electronic records requested at an inspection must be shown on a device provided by the owner, with copies in a commonly available format such as PDF (24 RCNY §8-07(a)(3), NYC DOHMH, accessed 2026). For the practical choice between a portal and email for delivering reports, see Is an SDS portal better than email for SDS and service reports?.

What should a water treatment contract say about ASHRAE 188 records?

A water treatment contract should say which ASHRAE 188 records the vendor produces, in what form and how fast it delivers them to the owner, who notifies whom when a control limit is missed, and what the vendor hands over when the contract ends. Standard 188 does not supply contract wording, so these clauses are a checklist derived from the record duties above, not quotations from the standard.

1. Scope: list the records the vendor produces, by the same names the program uses.

2. Delivery: a fixed time from each visit to delivery of the service report and test data, for example 5 working days (illustrative).

3. Format: files the owner can open and keep without a vendor login, such as PDF.

4. Laboratory reports: sent to the owner directly, with chain of custody where the jurisdiction requires it, as New York City does (24 RCNY §8-05, NYC DOHMH, accessed 2026).

5. Out of limit results: who is told, within what time, and who records the corrective action.

6. Annual review: the vendor attends and confirms its part of the program.

7. Exit: all records and the program sections the vendor drafted are handed to the owner.

In Lubinpla's Field Care, a water treatment vendor shares service reports and test results item by item with the customer contact and can unshare them at any time, so clause 3 still matters: the owner saves its own copies.

How ASHRAE 188 record duties compare with the CDC toolkit and local cooling tower rules

ASHRAE 188 sets the program and its records, the CDC toolkit explains how owners build it, and local rules such as New York City's cooling tower chapter add binding retention periods and formats. A building can sit under several of these at once: a New York City hospital with a cooling tower answers to the city rule, to CMS and to whatever its program adopts from Standard 188. In that case the strictest record duty on each point is the one to plan for. The table compares where each source puts the record duty.

The key row is New York City: it is the only source here that names the owner as record keeper and fixes a period, 3 years per tower (24 RCNY §8-07(a), NYC DOHMH, accessed 2026). CMS expects Medicare and Medicaid certified hospitals, critical access hospitals and long-term care facilities to have water management plans that consider the ASHRAE industry standard and the CDC toolkit (CMS QSO-17-30, revised 2018).