In 2018, the NSW Government changed the cooling tower regulations because of the outbreak of a number of Legionnaires disease cases due to the cooling towers in the previous few years. The new regulations follow the Risk Management approach.
The Risk Management approach has adopted the philosophy of prevention being better than cure. When your cooling towers have been found to breach compliance, it is much more difficult to get them back up to code and restore your operations to run at safe levels. The Risk Management approach ensures that your water systems do not cause contamination, risks and outbreaks compromising public safety through legionnaires disease risk assessment.
Why is it the best approach?
By developing a Risk Management Plan (RMP) for every cooling tower makes minimum the risks of outbreaks of Legionnaires disease. It will alert you to problems possible in your towers in the future and the reparations required to prevent them such that operating costs of your tower are kept down.
Developing RMP
Create your RMP as per NSW guidelines and use the approved and mandatory templates, which address all key points that will reduce the burden of managing your cooling towers.
- A competent person to conduct risk assessment:
You must conduct risk assessment of all cooling towers every five years by a competent person. The recent amendments to the guidelines now define a ‘competent person’ as someone who ‘has had suitable training or experience (or both) in the pertinent subject, who is sufficient to offer safe and satisfactory performance.
A Yearly audit of Risk Assessment
Every 12 months, an independent auditor will review the compliance with the regulations. The audit must be carried out by a person approved by the Secretary and who is not:
- The individual who conducted the risk assessment.
- The occupier.
- A qualified person who set up the water cooling system in the last 5 years.
- A duly qualified person who maintains or operates the water cooling system in the last 5 years.
- A person, who operates the lab which carried out monthly testing of water cooling system in the last 5 years.
Selecting the right provider
It is a fact that RMP is created and audited by industry professionals, who evaluate improvements in the prevention of risk to public health. From a strictly managerial point, in case of water treatment industry, the additional burden of compliance may be tough for some water treatment providers to implement.
EHOs (Environment Health Officers) will, without doubt, focus on discouraging non-compliance. The bulk of their focus will be in investigating:
- Missing paperwork
- Failed audits
- Very high results of water tests
EHOs and consultants follow similar patterns. If there is a specific contractor or provider who has been found to be corrupt on one site, he will be investigated on other sites. Thus, if you choose the wrong provider of water treatment, it can hence cause your cooling towers and facilities to come under unnecessary scrutiny. The company Legionella Regulations is a great source.
Digital reporting
Choose a provider who has a digital reporting system and can provide access via a portal to five years of reporting, right at your fingertips, avoiding the big risk of non-compliance.
Consult Legionella Regulations for its risk management service delivery model, which provide multiple levels of assurance. This includes the element of clarity, which collects the digital information linked to the microbiological results, water chemistry, and corrosion results all in one portal.
Legionella Regulations 