October 2017 Update: Following an industry roundtable held in September 2017, NSW Health are working on finalising proposed changes to the Public Health Regulation, as well as supporting documentation and training requirements.
A presentation based on the one made by NSW Health at the recent industry round-table has been made publicly available on the NSW Health website.
July 2017 Update: NSW Health has released a report on the discussion paper regarding the proposed further regulation of building cooling towers to help reduce the risk of Legionnaires’ disease.
The report, incorporating the feedback from 53 stakeholders, is available online here).
Legionnaires’ disease has hit the Sydney spotlight in 2016 following positive Water Cooling Tower tests in the Sydney CBD in March and May. Detections of Legionella bacteria in over 15 water cooling towers, serve as a warning for water cooling tower operators who do not comply with the state’s strict cleaning regulations.
This also heightens the likelihood of regulatory changes which are expected early in 2017 following recommendations made by an Expert Panel recently.
Current NSW Cooling Tower Regulations
The operation of cooling towers is regulated by state based legislation throughout Australia. In New South Wales, legislation requires that cooling towers must currently:
- Be registered with the local council;
- Have a certified, operating disinfection procedure, designed to control microbial growth, with appropriate responses to be promptly undertaken in the event of any adverse bacterial result;
- Have safe and easy access for cleaning, inspection and maintenance;
- Use a NATA accredited laboratory for all microbial testing; and
- Be maintained in accordance with Australian Standard AS/NZS 3666.
NSW Health, together with an Expert Panel have been formulating a new regulatory framework to improve the management of Legionella risks associated with the operation of cooling tower systems.
Potential changes to the NSW Cooling Tower Regulations
Greencap understands the potential changes may include:
- A requirement for building owners to have a risk management plan in place for each cooling tower system, which would influence the operational program required
- An obligation for building owners to demonstrate compliance with the outcomes of the risk management plan by an independent audit to be tracked by local councils
- Minimum frequencies (at least monthly) for laboratory analysis of cooling water samples for legionella and heterotrophic plate count
- Minimum frequencies for inspections to be determined by the RMP
- Obligations for testing laboratories to report elevated adverse bacterial results to the local council; i.e. Legionella results of > 1,000 cfu/mL and HCC results of >5,000,000 cfu/mL
- Provision for local councils to require an online disinfection and/or additional testing
Following a consultation period on the proposed changes, NSW Health expects regulatory changes to be made in the first part of 2017.
NSW Health is now inviting stakeholders to provide feedback on the suggested legislative changes that are likely to be brought into effect during 2017. Greencap will be making a submission in response to this in due course. Building Owners and Facility Managers with responsibilities in NSW are encourage to review the discussion paper (available online here) and either respond directly to NSW Health, or alternatively contact Greencap and we could include their feedback as part of our response.
Greencap has many years of expertise in cooling tower risk management
Greencap consultants have been assisting clients with Legionella and cooling tower risk management throughout Australia for more than two decades. Our team of property risk consultants have a wide range of experience around plant and equipment including a variety of heating, ventilation and air conditioning (HVAC) systems, particularly in the area of Legionella risk and cooling tower consultation. Our consultants understand the legislative provisions associated with management of building water systems including cooling towers and are experienced in writing, reviewing and auditing cooling tower Risk Management Plans / Risk Assessments.
Online Solutions provide 24/7 tracking of the risks associated with cooling tower systems
Greencap offers value-added initiatives such as access to ContinueONE (our proprietary online reporting system) which enables clients to have 24/7 tracking of all associated cooling tower system risks.
Contact us to find out how Greencap is able to assist with managing health and cooling tower risks for your people and your business.
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Contact: Tim Brumby
Mobile: 0402 909 390
 NSW Public Health Act 2010 and NSW Public Health Regulation 2012
What is Legionnaires’ disease?
Legionnaires’ disease is generally considered to be acquired through the inhalation of aerosols contaminated with Legionella bacteria. Symptoms can include fatigue, muscle pains, headache, fever, non-productive cough, shortness of breath, nausea, abdominal pain, vomiting and diarrhoea. Legionellosis (which includes Pontiac fever) has a low attack rate and is more likely to affect individuals with an underlying illness or a weakened immune system, including people with lung diseases, the elderly and smokers. (See Legionnaires’ disease – frequently asked questions published by NSW Health)
Legionella bacteria is able to grow rapidly in building water systems, particularly when temperature and other conditions are favourable. Although this can include warm water systems, spa pools and even decorative fountains, outbreaks are often attributed to cooling towers, which can potentially disperse contaminated aerosols to a wide area.