Recent outbreaks of Legionellosis (Legionaire’s disease) have been traced to the uncontrolled release of Legionella Bacteria in mists generated from operational cooling towers and evaporative coolers (cooling units). Respiring or breathing in this bacteria can result in a pneumonia-like infection of the lungs which can prove fatal for people with compromised immune systems such as children, senior citizens, smokers and individuals with various respiratory issues. Legionella growth in cooling towers can occur due to improper water conditioning and maintenance. In response to an August 2015 outbreak of Legionellosis in the Bronx, New York during which 119 cases of Legionellosis were reported with 12 fatalities occurring, the New York State Department of Health issued emergency regulations of sources of Legionella bacteria; most typically this included cooling towers and evaporative coolers. The most current version is a revised regulation was adopted on July 16, 2016. Most notably, this regulation differentiates requirements for hospitals and health care facilities compared to all other facilities. Covered Health Care facilities in addition to requirements listed below must also perform in a environmental assessment of their facility using a form provided by the NYSDOH, see link at the bottom to the form.
Cooling Units are used in industrial operations on a year round basis and can be associated with HVAC equipment which generally is used during the cooling season (May – October) at schools, office buildings and apartment complexes. As New York moves into spring, it is time once again to evaluate your cooling system and determine if it includes a cooling tower, and if so, evaluate if you are in compliance with NYSDOH Legionella rule (section 225 (5)(a) of the the NY State Public Health, Part 4 of Title 10). At this point, with two full cooling seasons since the legionalle regulations were adopted, ignorance of the rule will likely not be an effective defense to compliance. Under the rule effective July 6, 2016 the following actions must be taken, listed as follows:
- Owners of Cooling units operating in the state of New York must register them with the NY State Department of Health.
- Owners must obtain a “Cooling Tower Legionella Prevention Maintenance Plan” prepared specifically for their facility by a NY State Professional Engineer
- A Pre-Startup physical and chemical disinfection must be performed on the cooling units, using a power washing device and USEPA registered biocide.
- During operations, cooling units water must be routinely dosed with a USEPA registered biocide too prevent regrowth of Legionella bacteria (by maintaining a consistent biocide concentration). This can be achieved through a automated in-line dosing system or manually controlled (e.g. floating chemical dispenser Conduct regular water analysis for Legionella (at seasonal start up and every 90 days during operations) and report their finding to to NYSDOH electronically
- Identify Emergency procedures for Cooling Unit Cleaning should bacteriological sampling results indicate presence of Legionella
- Conduct regular inspection of the Cooling Units and keep records of maintenance and inspection preformed. Inspections shall coincide with each 90-day Legionella water analysis sampling event.
With the coming of the 2017 cooling season the NY State DOH anticipates renewed enforcement activities of cooling units including inspections, owner inspection monitoring and review for labortory sampling results. Consensus standards have been developed and published by the American National Standards Instute (ANSI) covering operations and maintenance at Legionellosis: Risk Management for Building Water Systems (ANSI/ASHEAE 188-2015), 2015 final approval date June 26, 2015. Knowledge of these guidelines is critical to making your O/M plan effective. If you or your company operate a single or multiple cooling units and you have not yet completed all Operational requirements it is not to late to do so. Please feel free to call Walden to discuss your units and how to get them into compliance. Review new NYSDOH assessment form for cooling units at health care facilities here.
If you require assistance making sure your cooling system is in compliance, please give Walden a call at 516-624-7200.