In New York City, cooling tower maintenance compliance is determined by Local Laws 76, 77, and Chapter 8 of the City Rules; in New York State, it’s mandated under the state sanitary code.
Here is a useful breakdown of cooling tower maintenance requirements for both:
- Registration & Annual Certification
- Maintenance Plan & Program (MPP)
- Logging Your Proof of Testing & Disinfecting
- Official Inspections
Registration & Annual Certification
The city requires annual certification of all cooling towers after the initial registration; the state demands registry updates every 90 days.
Healthcare facilities that accept Medicare or Medicaid payments are required to develop a water safety plan.
Maintenance Plan & Program (MPP)
Once you’ve registered your cooling tower, you must prepare a Maintenance Plan and Program (MPP), which the New York City (NYC) Department of Health defines as “a detailed plan customized for a cooling tower system that describes operational and administrative strategies and process control measures to be taken to prevent and control the growth of Legionella.” In New York State, you need an MPP in place before you start up your cooling tower.
For both the city and state, your MPP must meet ASHRAE 188-2018 Legionella prevention standards, which outline the bare minimum to prevent the spread of Legionella in your water system. Before activation, you must clean and disinfect your cooling towers in accordance with city guidelines.
Your plan needs to include:
- Team member information, including offsite management
- Cooling tower system data, including schematics and diagrams
- Risk management assessment
- Procedures for cleaning, testing, inspecting for, and mitigating Legionella:
- Who will inspect and test your water system
- The specific tests you’ll conduct
- Corrective actions you’ll take if you find Legionella in your water system
- Water system flushing procedures
- Start-up and shut-down procedures
- Notification and communication protocols
Your MPP must be developed by one of the following:
- A professional engineer, licensed and registered in New York State
- A certified industrial hygienist
- A certified water technologist experienced in developing MPPs and conducting compliance inspections
- An environmental consultant with at least two years of experience in planning, operation and maintenance
You may also hire a qualified person to execute your MPP, but if you do, make sure they have operations and mitigation experience. (Vitralogy, for example, offers dip slide testing in New York City so you have one less task to worry about.)
Logging Your Proof of Testing & Disinfecting
Part and parcel of your MPP is performing regular testing, disinfecting, and maintaining all records in your cooling tower logbook. That last part is essential: Every dip slide test, every chlorine flush has to be recorded in a department of health-approved logbook, and you have to be able to produce it and prove that you’re following compliance directives whenever requested.
You need to have proof of the following:
- Routine maintenance
- Compliance inspections
- In New York City, you must test your water supply at least once a week for heterotrophic bacteria and at least once every 90 days for Legionella.
- Deficiencies and any lapses in compliance
- Corrective actions taken for any lapses in compliance or high volume of Legionella
- Water treatments
- New York State requires disinfection be performed by a certified commercial pesticide applicator or pesticide technician qualified to apply biocide in a cooling tower. Any biocide used in New York State must be registered with the New York State (NYS) Department of Environmental Conservation.
- Test results
- Cleaning and disinfection (before start up and at least twice a year thereafter)
This is also where a digital solution can come in handy: Access to a department of health-approved compliance binder on your phone, for example, will keep you prepared whenever inspectors decide to drop by.
New York City requires annual inspections by city officials; New York State mandates owners perform inspections every 90 days and after all routine maintenance. City inspections will be performed by its health department’s Office of Building Water Supply Oversight.
You need to provide proof of your MPP and all associated measures taken—including testing, any lapses in compliance, and corrective actions.
Failure to comply can result in hefty fines, Legionnaires’ disease outbreaks, and untold damage to your reputation, along with other consequences.
Vitralogy’s SmartCompliance tracks custom KPIs, alerts if you’re in danger of falling out of compliance, and helps ensure you never miss a deadline, thanks to scheduled push notifications. Contact us today to get started.