In 2021 NYC made three (3) updates to Cooling Tower Compliance that affect Building Owners & Operators:
- Remote Audits: Owners of cooling towers are being asked to digitize their cooling tower logbooks and submit them to the DOHMH.
- Summertime Hyperhalogenation: Each summer, cooling tower owners must perform and document a disinfection procedure called hyperhalogenation to reduce the risk of Legionella growth.
- No More Grace Period For Violations: For compliance issues found during a remote cooling tower inspection, there will be no grace period in which to address these issues before they become fined violations.
Today, we will give you the basics of each update along with resources that can help you stay in compliance and learn more.
Because of Covid-19, the DOHMH halted in-person inspections of operational records. In an effort to resume inspections, they have started emailing building owners about remote cooling tower audits.
Building owners are now being asked to convert their cooling tower logbooks into digital formats and to submit them to DOHMH. This places responsibility on building owners and operators to maintain records if they want to avoid violations and fines.
These remote Inspections appear as an email sent to the building owner/operator. From the moment you receive it you have seven (7) days to submit the required information. It includes two (2) attachments that outline what documents need to be compiled with instructions on how to format the data so it can be accepted by DOHMH.
After submission, if you have filed correctly and have no violations, you will likely receive nothing back from the DOHMH, and you can consider it a job well done.
What Do I Have To Submit?
The DOHMH distills the inspection down to two main sections: Attachment A and B, which include subsections that must be completed and filed as separate files.
Attachment A is where you file your maintenance records for approval. It is due within 7 days of inspection notification.
Attachment B asks you for the building’s condenser water loop details on your chiller, cooling tower, and other components. Since it’s more time-intensive, this attachment is due within 60 days of inspection notification. You may need to gather intel from your building engineers or water treatment vendor.
Who Gets Inspected?
Owners of cooling towers can expect to receive an email for a remote audit. The owner is the person listed as Owner to the associated building identification number (BIN) within the NYC Cooling Tower Registry Portal. If you are an owner of multiple buildings with cooling towers, you will receive a different inspection request email for each building.
When Will I Be Inspected?
Like in-person inspections, remote inspections are conducted at random. You can expect to be inspected at least once a year.
When Will These Remote Inspections Stop?
This won’t replace on-site inspections. However, going forward, remote inspections could supplement them. The DOHMH has made no indication that they will stop these remote audits anytime soon. For now, it’s best to act as if these inspections will continue even after the pandemic’s influence has subsided.
What If I Don’t Have All Of The Required Information?
Submit what you have within a seven (7) day window. The inspector may follow up asking for more information.
There is a lot of material and information to gather and supply during this process. For help doing so, check out the following resources.
To learn exactly how to handle your cooling tower remote inspection, download our Roadmap for Success e-book
If you want a video walkthrough of the remote inspection process and requirements Request a Recording of our Remote Inspection Webinar
Summertime Hyperhalogenation Requirement
The new summertime disinfection requirement mandates that each cooling tower operator performs and documents a disinfection procedure called “Summertime Hyperhalogenation”. This additional preventative maintenance requirement is meant to safeguard against any potential growth of Legionella that is common in the warmer months.
To comply with summertime hyperhalogenation, owners/operators must follow these steps:
- Operators introduce a higher-than-normal biocide dosage into the cooling tower between July 1st and August 31st.
- Three (3) to 45 days after introducing the biocide dosage, collect a post-hyperhalogenation Legionella sampling. These samples can be collected after August 31st if owners have complied with the sampling time frame (3 - 45 days).
- Within 30 days of completing the procedure, you must submit a record of it using this NYC DOHMH Form.
No More ‘Grace Period’ for Violations
The DOHMH recently sent this email to building owners/operators:
“As of January 1, 2020, the Office of Building Water System’s Oversight has revised our reporting process to provide a single Inspection Report, which replaces the two prior reports titled Inspection Summary Report and Violation Deficiency Report.”
Prior to this change, building owners/operators would receive an Inspection Summary Report that outlined any cooling tower compliance issues. The operator then had 30 days to correct the issues before they festered into fined violations. On day 30, the operator would receive a Violation Deficiency Report, which outlined the issues that turned into fined violations.
Now, after you submit your materials for a remote cooling tower audit and the DOHMH assesses your records and materials, you will receive only one Inspection Report with your violations attached. There is no more grace period.
Reach Out If You Need Help
These updates often bring stress to building owners. You already have a lot on your hands and it’s tough finding room on your schedule to deal with new compliance changes.
That said, please reach out if you need any help managing your remote inspections or cooling tower compliance. We would be happy to discuss your situation and how we might be able to remedy it.