New Regulatory Requirements for Cooling Water Systems

NSW Health has issued an update advising it has strengthened laws around managing cooling water systems. The new laws require a performance based approach to managing these systems.

A cooling water system can contain one or more cooling towers which are used as part of a buildings’ air conditioning system.

In its Fact Sheet, NSW Health says that:

Effective management of cooling water systems is essential for protecting public health.

Poorly managed cooling water systems can provide ideal conditions for the growth and transmission of Legionella bacteria.

People can become infected by inhaling fine airborne aerosols generated by cooling towers. Infection may cause Legionnaires’ disease, a serious and potentially life-threatening condition.

NSW Health recently changed the Public Health Regulation 2012 (the Regulation). Members should be aware also that cooling water systems must also comply with the Public Health Act 2010.

The Regulation now requires cooling water systems to be managed according to Australian/New Zealand Standard (AS/NZS) 3666 Part 3 (2011 edition).

NSW Health advises that this risk management approach requires the individual characteristics and unique risks of each cooling water system to be assessed and controlled.

The Regulation previously allowed a prescriptive or “one size fits all” approach. This required specific actions to be taken, regardless of the system design or risk of Legionella contamination, and was based on AS/NZS 3666 Part 2.

In the fact sheet, NSW Health says the new Regulation, which commenced 1 January 2018, requires:

  1. assessing risk of Legionella contamination and preparing a Risk Management Plan (RMP) – every 5 years (or more frequently if required)
  2. independent auditing of compliance with the RMP and Regulation – every year
  3. providing certificates of RMP completion and audit completion to the local government authority
  4. sampling and testing for Legionella and heterotrophic colony count – every month
  5. notifying reportable laboratory test results (Legionella count ≥1,000 cfu/mL or heterotrophic colony count ≥5,000,000 cfu/mL) to the local government authority
  6. displaying unique identification numbers on all cooling towers.

Members may also find the Guidelines on Legionella Control useful.