New York City Cooling Tower Compliance
In summer 2015, New York City was the center of one of the worst Legionnaires’ outbreaks in U.S. history, with 138 confirmed cases and 16 deaths. In response, both the city and state implemented laws based on ASHRAE 188 standards requiring owners to test and maintain their cooling towers in order to prevent the spread of legionella bacteria.
In New York City, two laws dictate cooling tower compliance: Local Law 77, implemented in 2016, and Local Law 76, implemented in 2020. Compliance requirements are as follows:
- Yearly registration of all cooling towers in use
- Implement a Qualified Person-developed Maintenance Plan Program
- Proof of inspection and mitigation plans located at the cooling tower at all times
- Quarterly inspections and legionella testing by qualified individuals
- Weekly water tests
- Maintain at least three years of documentation
- Allow all members of the public to access your documentation
VITRALOGY WILL allow you to remotely assign tasks to your team, track to-dos, and maintain access to documentation at all times, which means you can comply no matter where in the world you are.
Healthcare Water Safety Plan Implementation
In 2017, the Centers for Medicare & Medicaid Services mandated that all healthcare facilities that accept Medicare and Medicaid must develop water safety plans, including cooling tower compliance, due to the outsized threat legionella presents for immunocompromised individuals, smokers, those with underlying health issues such as diabetes or kidney disease, and those over 50 years of age.
The CMS water safety plan mandate requires that all hospitals, critical access hospitals, and long-term care facilities who accept Medicare and Medicaid payments develop plans that align with both ASHRAE 188 and CDC guidelines. Non-compliance could result in citations and even loss of the ability to accept Medicare and Medicaid. Compliance requirements are as follows:
- Develop and implement a water management program for cooling tower compliance and domestic water
- Identify at-risk populations and areas in the facility that are at higher risk for developing legionella
- Determine control measures and regularly monitor water quality against those controls
- Implement risk mitigation strategies and interventions when controls are not met
- Surveil at-risk patients for signs of waterborne disease
- Prepare contingency plans for the possibility of water restriction
- Document all activity and keep accurate records
We designed our platform to follow industry requirements to prevent the spread of legionella.
VITRALOGY WILL allow you to manage your customized cooling tower compliance and domestic water plans.
Industry Best Practices
As Legionnaires’ disease continues to spread, legionella compliance laws are becoming more common, and where the law is lagging, litigation is stepping in.
Victims of Legionnaires’ disease outbreaks frequently sue building owners and managers for negligence, sometimes for millions of dollars. So even if your industry doesn’t require legionella management, enacting a plan to control legionella could save you millions of dollars.
The golden standard of Legionnaires’ disease prevention is the ASHRAE 188 Legionella Compliance standard, upon which both New York Cooling Tower Compliance and healthcare water safety regulations are based.
The ASHRAE 188 Legionella Compliance “standard applies to human-occupied commercial, institutional, multiunit residential, and industrial buildings.” The standard is applicable to any building that has:
- Open or closed circuit cooling towers
- Evaporative condensers that cool the HVAC system
- Whirlpools or spas
- Humidifiers
- Ornamental fountains
- Misters or atomizers
- Any other “nonpotable water systems or devices that release water aerosols”
So whether you’re a hotel, a spa or commercial gym, a commercial real estate rental company, or anywhere else where large numbers of people gather, 188 is the standard by which you should measure your plan.
ASHRAE 188 requirements are as follows:
- Have a Qualified Person develop a water safety plan (usually water quality specialists, catchment and water managers, environmental engineers, and/or public health experts)
- The plan should include: appropriate testing for water quality, monitoring systems and controls, and plans for mitigating any elements (e.g. algae, temperature, etc.) deemed outside of the set limits
- Create workflows to make the plan diagrammatic and implementable
- Regularly monitor water quality via dipfly testing, sight tests, and other measures as deemed appropriate
- Plans for corrective actions if water is deemed dangerous (e.g. pH balance is outside of control limits, presence of algae detected, temperature is outside of control limits)
- Implementation verification
- Documentation of water safety plan and proof of implementation of the plan
VITRALOGY WILL allow you to control the proliferation of legionella in your water systems, so you can take care of the health and safety of the people in your building and avoid expensive mitigation or litigation.
