Cooling towers are termed as a ‘regulated system’ under the Public Health Act, 2010. During their operation, they create a warm environment, which favors the growth and proliferation of bacteria like Legionella.
Because of this, the Public Health Act 2010 and Public Health Regulation 2012 specify needs for chilling water systems and other regulated systems to minimize the risks of outbreaks of Legionnaires disease cooling towers.
Legionella bacteria can cause a kind of pneumonia (a lung infection), which is often fatal called Legionnaires disease and/or Pontiac fever (a mild illness like flu). The disease has an incubation period from 2 to 10 days for the manifestation of symptoms after inhaling the bacteria. This bacterium spreads via aerosols.
Outbreaks of the disease occur from time to time but can be prevented. These bacteria can multiply in poorly maintained and operated water cooling systems and warm water systems. This is especially true of systems, which are not maintained in clean conditions and treated continuously with a biocide to control the bacteria, biofilms, and algae.
Public Health Regulation 2012 has been amended recently to need a performance-based approach to manage water chilling systems. Each system can be managed based on its risk of Legionella contamination.
Now, building operators are required to ensure that the following six safeguards are in position for water chilling systems:
- Risk evaluation of Legionella contamination documented in an RMP (Risk Management Plan), every five years.
- Independent audit of compliance with RMP and Regulation (every year).
- Offer certificates of RMP Completion and Audit Completion to the Council.
- Conducting testing and sampling for Legionella bacteria and Heterotrophic Colony Count every month.
- Notifying lab test results to the Council.
- Display of UIN (Unique Identification Numbers) on all water chilling towers.
The six safeguards permit each system to be managed as per its risk of Legionella contamination. These six safeguards offer multiple levels of oversight and ensure that problems are pre-empted, de-escalated and responded on time.
The changes reflect full-fledged feedback from local govt., industry, major industry associations, and independent experts. The changes bring NSW in line with a number of jurisdictions in Australia and the world, which recommend or follow a risk management approach for controlling legionnaires disease cooling towers.
The Public Health Act of 2012 needs six approved forms to be utilized to document certain aspects of water chilling systems:
- Audit report
- Risk Management Plan
- Monthly report
- Notified results of reportable tests
- Application for approving audit water chilling systems.
- Notification of change in particulars.
Who Are the Key Stakeholders?
There are many crucial roles in managing a chilling water system:
- Occupiers must ensure that the water chilling system is managed as per the 2012 Act.
- Duly qualified persons manage the water chilling system on a routine basis.
- Competent persons undertake a risk assessment and prepare an RMP.
- Independent auditors to conduct an audit
- Labs to test microbial samples
- Authorized officers with the power to ensure that all stakeholders comply with the Act.
- Local govt. authorities.
These are all aspects of the new NSW regulations for cooling towers.