When New York City Local Law 77 was enacted in 2015, building owners and managers did their best to remain compliant with its regulations meant to prevent the growth and spread of Legionella bacteria and consequential outbreaks of Legionnaires' disease. These proved to be quite complicated, however, and, as leniency toward violators quickly runs out, many are still struggling to maintain compliance—evident in the 75,000 violations in 2017, alone.
Thanks to Vitralogy, that number is sure to shrink.
When the manager of a large retail space in the NYC metropolitan area received his first set of violations, he wasn't terribly worried initially. He was confident that he would be able to pay the fines, address all of the inspector's concerns, and be compliant by the next inspection.
The second inspection ended, though, with the same result—and more fines. Still, he was determined to fix his building's processes on his own.
By the third set of violations, the manager had had enough.Despite his best efforts, he was still at a loss for where his current protocols were going wrong, and made the decision to get in touch with Vitralogy.
He presented the team at Vitralogy with his most recent violations, in the hopes of learning what they could do to help him remain compliant in the future.
His most recent inspection cited 10 violations, including:
- Seven instances of failing to conduct or document routine maintenance according to his Maintenance Program and Plan (MPP), a procedure for Legionella management that all buildings must have
- One instance of failing to take corrective action based on bacteriological results
- Two instances of failing to collect and analyze samples before system start-up
These violations were also accompanied by a list of comments about issues that, if not addressed, would turn into violations.
Several comments concerned:
- Missing signatures on documents
- Missing or outdated samples
- Instance of corroded or broken equipment
- Levels of Legionella bacteria that were heightened, but within a safe limit
His situation, while frustrating, is not uncommon. It becomes especially so when one considers the nature of his violations and comments. In this case, the manager's building was in violation not for having dangerous levels of Legionella bacteria or being the source of an outbreak, but for consistently failing to follow the specific process mandated by the law.
We've seen this many times. Considering how comprehensive Local Law 77 is, it's no surprise that so many buildings are receiving violations. Maintaining compliance is not simply confirming that bacteria levels are within safe limits. It's a continuous process of testing, documenting and reporting that requires the coordination of multiple stakeholders, who must all stay informed on what tasks need to be accomplished, who is responsible for them, and when each must be completed.
The Vitralogy team was happy to inform the manager that it's exactly this type of centralized stakeholder collaboration Vitralogy was designed to facilitate, and that none of these violations would have happened if he'd been on the platform earlier.
- Forms for maintenance and repair appear weekly for each cooling tower a client manages
- Corrective actions are documented, and the Vitralogy account management team confirms that the water treatment company will perform disinfections within 24 hours
- Legionella tests, among other tasks, such as a disinfection and inspection, are mandatory parts of the cooling tower start-up sequence
The Vitralogy team also offers assistance in addressing additional comments, to ensure these do not become violations in the future.
The manager decided it was time to enlist Vitralogy, and he's been a client ever since. Today, he doesn't worry about his compliance. He rests easy and is able to focus more on his other responsibilities, knowing that Vitralogy is making Legionella compliance simple.