Cooling Tower SystemsRoles and Responsibilities

Presented by:

Catherine Donoghue and Zina Maaliki

Environmental Health Officers

Welcome

• Introduction – Legionnaires’ disease

• Cooling tower systems

• Roles and Responsibilities

– Department of Health– Land owners– Responsible person– Registration holder– Others

Fear in the community

History and outbreaks of Legionnaires’ disease

• 1976 - First identification due to an outbreak in Philadelphia 221 people sick

• 1985 - Stafford District Hospital UK 175 people sick

• 1999 – Netherlands 200 people sick source was traced to a whirl pool and humidifier

• 2000 – Melbourne Aquarium 125 people sick

Legionnaires’ disease - Victoria

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Cases and Costs

United States of America

• 10,000-50,000 cases annually (United States Department of Labour)

• Costing $100-321 Million annually (Centres of Disease Control and Prevention)

Australia

• ~300 cases annually

What is Legionnaires’ disease ?

High Risk Groups

• Age 50+

• Smoking

• Male

• Heavy Alcohol intake

• Chronic medical conditions

• Immune-compromised

Legionella bacteria

Can be found in:

• Creeks

• Hot springs

• Seawater

• Soil

Problems occur when…

Un-natural environments:

• Cooling towers

• Warm water systems

• Car / truck washes

• Spa baths

Cooling tower systems

Cooling tower systems

Cooling tower systems

Cooling Tower Systems

Department of Health

Our Role:

- Case Investigation

- Compliance Inspections

Location of Cooling Tower Systems

Case Investigation

Compliance Inspection

• Targeting

- sites that have failed to pay their registration

- no audit

- non compliant audit

- previous issues (Legionella detections)

- sites that have never been inspected

Sampling

• Legionella is detected in 4-5% of our cooling tower samples

• Notification via MDU – 7 to 10 days

• System is required to be disinfected

• We re-sample the system

• Can highlight problems

Legal Responsibilities

•Public Health and Wellbeing Act 2008

•Public Health and Wellbeing Regulations 2009

Public Health and Wellbeing Act and Regulations

Land owner

Responsible person

Registration holder

Public Health and Wellbeing Act 2008

owner, in relation to land—

(a) which has been alienated in fee by the Crown and is under the operation of the Transfer of Land Act 1958 (other than land in an identified folio under that Act), means the person who is registered or entitled to be registered as proprietor, or the persons who are registered or entitled to be registered as proprietors, of an estate in fee simple in the land;

(b) which has been alienated in fee by the Crown and is land in an identified folio under the Transfer of Land Act 1958 or land not under the operation of the Transfer of Land Act 1958, means the person who is the owner, or the persons who are the owners, of the fee or equity of redemption;

(c) which is Crown land reserved under the Crown Land (Reserves) Act 1978 and managed or controlled by a committee of management, means the Minister administering that Act;

(d) which is any other Crown land, means the Minister or public authority that manages or controls the land;

Public Health and Wellbeing Regulations 2009

Public Health and Wellbeing Regulations 2009

Responsible person means the person who owns, manages or controls a cooling tower system …..

Public Health and Wellbeing Act 2008

S80) Cooling tower system must be registered

The owner of any land on which there is a cooling tower system must ensure that the cooling tower system is registered with the Secretary at all times that the cooling tower system is in operation.• In the case of a natural person, 120 penalty units;• In the case of a body corporate, 600 penalty units.

Public Health and Wellbeing Act 2008

S87) Secretary to be notified of certain changes

(2) Within 30 days after the date of the change in the ownership or in the address or other contact details, the owner of the land must notify the Secretary in writing of the change.• In the case of a natural person, 10 penalty units;• In the case of a body corporate, 50 penalty units.

Public Health and Wellbeing Act 2008

S88) Secretary to be notified of other changes

(1) A person who holds a certificate of registration in respect of a cooling tower system must notify the Secretary within 30 days after—• (a) the addition or removal of a cooling tower to, or

from, the cooling tower system;

• (b) the removal, or decommissioning, of the cooling tower system;

• (c) the relocation of the cooling tower system on the lot of land on which it stands.

– In the case of a natural person, 10 penalty units;

– In the case of a body corporate, 50 penalty units.

Public Health and Wellbeing Act 2008

S91) Owner must ensure risk management plan prepared

(1) The owner of any land on which there is a cooling tower system must take all reasonable steps to ensure that a risk management plan exists in respect of the cooling tower system at all times that the cooling tower system is in operation.• In the case of a natural person, 60 penalty units;• In the case of a body corporate, 300 penalty units.

Public Health and Wellbeing Regulations 2009

R51) Risk management plans for cooling tower system

For the purposes of section 91 of the Act, risk management plans must address the risks associated with—

• (a) stagnant water, and

• (b) nutrient growth, • (c) poor water quality,

• (d) deficiencies in a cooling tower system,

• (e) the location of, and access, • (f) any matters identified

Public Health and Wellbeing Act 2008

S92) Owner must ensure risk management plan reviewed

(1) The owner of any land on which there is a cooling tower system must take all reasonable steps to ensure that the risk management plan is reviewed, and, if necessary, updated, at least once in each 12 month period.• In the case of a natural person, 60 penalty units;• In the case of a body corporate, 300 penalty units.

Risk Management Plan (RMP) Review

Trigger events

• 2 or more Legionella detections in 12 months

• Legionnaires’ disease associated with CTS

• Control measures no longer effective

• Significant change

- Environmental conditions- Operation of the CTS- RMP not addressing prescribed risks

Risk Management Plan Review

A review should be in writing and include:

• Name/title person responsible for review

• Date of review

• Next scheduled review date

• Reason for the review, particularly if trigger event

• RMP amendments required

Public Health and Wellbeing Act 2008

S93) Owner must ensure risk management plan audit conducted

(1) The owner of any land on which there is a cooling tower system must take all reasonable steps to ensure that an audit is conducted annually in relation to the risk management plan prepared in respect of a cooling tower system.• In the case of a natural person, 60 penalty units;

• In the case of a body corporate, 300 penalty units.

Public Health and Wellbeing Regulations 2009

R53) Maintenance of cooling tower systems

The responsible person must ensure that any cooling tower system that the responsible person owns, manages or controls is maintained and tested in the manner set out in this Part, unless the system is shut down, or is otherwise not in use.

• 20 penalty units.

Public Health and Wellbeing Regulations 2009

R54) Cooling tower water quality and treatment

The responsible person must ensure that the water of the cooling tower system is continuously treated with—

• (a) one or more biocides to effectively control the growth of micro-organisms, including Legionella; and

• (b) chemicals or other agents to minimise scale formation, corrosion and fouling; and

• (c) a bio-dispersant.– 20 penalty units.

Public Health and Wellbeing Regulations 2009

R55) Disinfection, cleaning and re-disinfection of cooling tower water

The responsible person must ensure that—• (a) a chlorine-compatible bio-dispersant is added to the

recirculating water of the cooling tower system; and• (b) the system is then disinfected, cleaned and re-disinfected—

– (i) immediately prior to initial start up following

– commissioning, or any shut down period of greater than

– one month; and

– (ii) at intervals not exceeding 6 months.» 20 penalty units.

Public Health and Wellbeing Regulations 2009

R56) Routine service and testing of cooling towers

(1)The responsible person must ensure that the cooling tower system is serviced at least once each month to check that the system is operating without defects.

– 20 penalty units.

Public Health and Wellbeing Regulations 2009

R56) Routine service and testing of cooling towers

(2) The responsible person must ensure that at least once each month a sample of the recirculating water of the cooling tower system is taken and is delivered to a laboratory for testing and reporting on for heterotrophic colony count.

– 20 penalty units.

Public Health and Wellbeing Regulations 2009

R56) Routine service and testing of cooling towers

(3) The responsible person must ensure that at least once every three months a sample of the recirculating water of the cooling tower system is taken and delivered to a laboratory for testing and reporting for Legionella.

– 20 penalty units.

Public Health and Wellbeing Regulations 2009

R57) High heterotrophic colony count detected in cooling tower system

(1) Within 24 hours of receiving a report from a laboratory that any sample of water taken from the cooling tower system has a heterotrophic colony count exceeding 200 000 colony forming units per millilitre, the responsible person must ensure that the following procedure is implemented—

• (a) the water of the system must be manually treated with additional quantities of biocide or with an alternative biocide; and

• (b) the water treatment program, tower operation and maintenanceprogram of the system must be reviewed; and

• (c) any faults must be corrected; and• (d) any changes necessary to prevent a re-occurrence of those faults

must be implemented.

Public Health and Wellbeing Regulations 2009

R58) Legionella detected in cooling tower system

(1) Within 24 hours of receiving a report that Legionella has been detected in a water sample taken from a cooling tower system, the responsible person must ensure that the following procedure is implemented—

• (a) the cooling tower system must be disinfected; and

• (b) the water treatment program, tower operation and maintenanceprogram of the system must be reviewed; and

• (c) any faults must be corrected and any changes necessary to prevent a re-occurrence of those faults must be implemented.

– 20 penalty units.

Public Health and Wellbeing Regulations 2009

R57) High heterotrophic colony count detected in cooling tower system

R58) Legionella detected in cooling tower system(2) Between 2 and 7 days after the water has been treated under subregulation (1)(1(a)), the responsible person must ensure that a further sample of the recirculating water of the system is taken and is delivered to a laboratory for testing andreporting on for heterotrophic colony count.

Public Health and Wellbeing Regulations 2009

R60) Records to be kept in respect of cooling tower systems

(1) The responsible person must keep records in respect of each cooling tower system that is owned, managed or controlled by the responsible person that records details of

– (a) all maintenance and corrective activities

– undertaken in relation to the system during

– the preceding 12 months; and– (b) all microbiological test results of samples

– taken from the system during the preceding

– 12 months.» - 20 penalty units.

Summary

• Consider the extent of your responsibility

• Keep registration details current

• Ensure registration fees are paid on time

• Carefully consider contract arrangements

• Read service reports and be proactive

• Look for opportunities to implement better practice

• Contact Department with any queries

Public Health and Wellbeing Regulations 2009

Further Information

Website• www.health.vic.gov.au/legionella

Email• legionella@health.vic.gov.au

Registration and Licensing• 1800 248 898