Cooling water systems must be managed safely for preventing growth and transmission of Legionella bacteria. Infection by these bacteria may cause Legionnaire’s disease, which is a potentially serious and life-threatening condition.
The NSW government has amended its Public Health Regulation 2012, to stipulate a risk management approach to manage cooling water systems.
As of August 2018, building occupiers are required to implement some key safeguards in their cooling water systems for the sake of legionnaires disease risk assessment:
- Risk evaluation of contamination by Legionella to be documented in a Risk Management Plan (RMP), every five years.
- Annual independent auditing of compliance with the RMP.
- Monthly sampling and testing for Legionella count
Five Considerations to Develop Your RMP
• Select an RMP consultant who will collaborate with the client
While selecting RMP consultant, the client must choose one that works according to his budget and timeline. Failure to implement recommendations of the RMP consultant regarding cooling towers implies a failed audit. Don’t be forced to make changes that one cannot afford or complete before an audit.
• Put priority on eliminating major Legionella risks
The risk of contamination can be reduced much by:
- Having cooling tower checked professionally
- Implementing automated dosing controls to improve water
The risk of disease can be reduced by minimizing transmission of water droplets to people like:
- Minimizing drift
- Minimizing the number of people close to cooling tower (tough, because droplets can travel up to 500 m)
• Get things in order
The client must ensure that he is compliant with regulations by tidying the area surrounding the cooling tower and getting his paperwork in order.
EHO’s and consultants will focus on the paperwork. A missing report will amount to a failed audit. The best solution is to keep digital records which are easily accessible and safe in one’s hands regarding legionnaires disease risk assessment.
• Select a highly reputed water treatment provider:
The first question asked by a Health Inspector is who your water treatment provider is. In case the client has tied up with a provider who has experienced failed audits in the past, it is sure that the cooling towers will be subject to a tougher audit at every step of the process.
Begin wisely by choosing a provider which is recognized for a high quality of service and reputed to be a leader in the industry.
• Ensure safe access
As part of inspections, EHO’s will focus on safe access to the cooling towers. All handrails and walkways must be designed to meet the relevant needs of AS/NZS 1657: 2013.
This implies access to the location of the cooling tower. For instance, if it is located on a rooftop, how will one access the roof? Has one installed safety measures (scaffolds, handrails, walkways) to prevent falls from heights? What is the condition of such prevention measures?
Safe access also implies access to cooling tower components, which must be serviced by the mechanical contractor and water treatment provider, such as 1) eliminators of drift, fill and basin; 2) Drain and valves; 3) Safe removal of access panels and hatches.
Health inspectors take safety precautions seriously and treat breaches to safety compliance as strictly as any other breach. Make sure that at all times, access to the cooling towers is safe for anyone needing access.
These are all top facts about compliance with NSW regulations for cooling water systems.