Every year, at some time during the 12 month maximum audit period, there needs to be a review of the performance of the cooling tower performed.     In the event that on two occasions within a 12 month period positive Legionella counts occur, the  RMP must immediately be reviewed.   The risk assessment component of the RMP revisited to ensure the assessment is appropriate.  The stringency of the control measures of the RMP including the water quality testing should be increased until it has been possible to demonstrate that good control of Legionella has been achieved.  As some Cooling Tower RMP’s  include operational programs where legionella testing routinely will occur only every 3 months obtaining two positive legionella readings raises a serious concern as to for how long and at what level has the legionella been present in the tower.    How much of a risk then does the tower pose to people nearby, employees, public, or people servicing and maintaining the tower?

What should be covered in a review?

The review should examine the HCC and Legionella results over the preceding 12 month period and satisfy the question, are Legionella and HCC levels being adequately controlled with existing measures?

If inadequate control is identified, then an upgrading of the chemical dosing systems would be advisable.    It may be advisable to increase the control measures in place so that a tower identified as being a low risk Category D should be treated as a Category C, B or even A tower, or that it be more frequently cleaned.

If adequate control is identified, unless there are changes occurring in the workplace, the site, or neighbouring sites which may negatively impact on the operation of the cooling tower there is probably no reason to change the RMP document.

If for example, neighbouring sites were going to be affected by earthworks and construction which would generate a lot of dust, it might be necessary to improve the level of control by for example increasing the frequency of tower cleans which by law should be carried out every 6 months, but may be increased to every 4 or 3 months, or in extreme circumstances, monthly.   Once adequate control can be demonstrated it might be possible to relax the control gradually and identify control strategy that consistently delivers good HCC and Legionella count outcomes.

Cooling Tower RMP Review documents can involve a very detailed re-doing of the formal risk assessment task using the template document provided by the Department of Health.   They may simply consist of minutes of a meeting called to review the performance of the Cooling Tower RMP.  There are advantages, though obviously it has to be paid for if you engage a third party to do a review of your Cooling Tower RMP annually or at least every 3 or 4 years.  If you want a professional review performed on your tower you can contact EnvirosapHe.

With EnvirosapHe’s  existing auditing clients, while we cannot do the reviews as well as the audits by law, we can provide advice on how you can do an in-house review .   An external third party review, possibly by the water treatment company or another consultant, involving again the risk assessment of the tower is recommended at least every 3 years or when significant changes are made to the cooling tower system.

Note:  Envirosaphe is said as envirosafe.

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These three questions are:

1. whether the RMP incorporates all the key risk factors in determining the risk posed by the tower and an operational plan has been developed;
2. whether the operational program is being implemented as outlined in the RMP; and
3. whether the performance of the Cooling Tower in terms of cleanliness or level of biological contamination is reviewed annually.

Ideally the RMP operational plan is appropriate to or more rigorous than required for the actual risk identified in the Risk Assessment process preparing the RMP and the Department of Health provides benchmarks or minimum standards on such risk based operational programs.   Operational programs which are less rigorous than the minimum recommended by the Department of Health present a risk to the business owner or operator or property owner.  They  could  be liable in the event of a Legionnaire’s disease outbreak being determined as being caused by the owner or operator’s cooling tower.    All documents would be discoverable in the legal processes associated with a court case.

The auditor, in addition to issuing the audit certificate, provides statistical information to the Department of Health and the Department carries out random and targeted inspections of cooling towers as well as audits the auditors.

EnvirosapHe can assist you either through providing auditing services.   EnvirosapHe was one of the first Cooling Tower RMP auditing services in Victoria.    EnvirosapHe can provide you with advice,  implement periodic performance reviews of your RMP,  or in developing your RMP from scratch with a new tower installation.

Note:  Envirosaphe is said as envirosafe.

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In 2013 the Medical Journal of Australia published a study which identified a potential new large outbreak of Mesothelioma associated with home renovation by homeowners, unaware or the risks or of needed safety measures to protect the health of homeowner renovators and their families.

If you need advice to do with asbestos risks with a house you have purchased, have been living in for some time, are renting, you can contact Michael Beale of EnvirosapHe Consulting for further information.   Mobile 0417398850

Useful link to Asbestosawareness             http://www.asbestosawareness.com.au/

Note:  Envirosaphe is said as envirosafe.

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The author purchased auto fuses at a discount store to replace a similarly rated fuse which had failed.   The author acknowledges he failed to check for a reliable local company on the packaging of the product to endorse and be responsible for the quality of the product.   The author also failed to ensure that the discount store retailer was appropriately identified on the receipt.    Trading name on receipt was not registered with ASIC.

The upshot was a car with burnt-out electricals and a fuse which showed clear evidence of over-heating of the plastic without the active metal fuse element actually failing.   The author has notified  Consumer Affairs Victoria about the faulty product with details of the brand.

Potentially there are many people, possibly thousands of people out there who have installed such fuses in their cars.   It is highly likely that when there is a need for the protection these fuses will fail.   The cynic may think that for auto-electricians, this provides them with more business as cars are either repaired at great expense as auto-electrician businesses are well paid and the repairs can take a whole day or longer to complete.    It can cost thousands of dollars.  Otherwise cars go to the wreckers for recycling.    Potentially however there could be car fires which may put people’s lives at risk.

Consumer Affairs Victoria made it clear in a letter sent on the 14th of April 2015 that they were not prepared to look into this matter .  As a public interest exercise I am prepared to name the product.   I have elected not to go to VCAT to claim compensation for the damage because of the protracted time in being able to identify who is responsible for offering that product for sale, the lack of an obvious Australian importer of the fuses, the costs involved in preparing expert evidence to present, and the fact that the vehicle had a much greater use value than monetary value.

The offending product is under the brand name “Legion Tools”  Item No. T608-H with the label “10 PIECE AUTO PLUG-IN FUSES”  This product is labelled “MADE IN CHINA”.

Hopefully no-one else has this problem, but if any others who have a similar problem make a complaint to Consumer Affairs Victoria, it is possible that C.A.V. will take it more seriously.

For those of you who need to buy fuses for your car my advice would be to steer clear of the Legion Tools brand.

Note:  Envirosaphe is said as envirosafe.

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There is evidence that the number of people in Australia who die, or are seriously ill as a consequence of exposure to chemicals is of a scale larger than that associated with motor vehicle accidents.   More than 2000 people a year die of illnesses caused by workplace chemicals.   Probably hundreds of thousands of people have long-term health problems relating to their chemical exposures at work.

Many of these chemical related health problems are not easily recognised by the legal processes if people attempt to get workers’ compensation for their illness.   Prevention is crucial.   Determining whether there is excessive exposure to chemicals may require measurement of airborne concentrations of chemicals, and a knowledge of the symptoms people might experience if levels are are causing health problems.

Information on the chemicals contained within workplace substances can be found in Safety Data Sheets (SDS’s), which by law should be provided to workplaces and available in workplaces.   SDS’s should be recent (less than 5 years old) and specific to the chemical or substance which is being used or stored in the workplace.   These SDS’s should have relevant exposure standards listed within the document.

Exposure standards (as concentrations of chemicals in the air) relevant to the inhalation of chemicals exist for more than 700 of the more common toxic chemicals.   A risk assessment of exposure to any of these chemicals may involve monitoring of concentrations of the chemical in the air.    This is a specialty of occupational hygienists who have studied another scientific or engineering discipline before becoming an occupational hygienist.

EnvirosapHe has been involved in monitoring of airborne concentrations of a wide range of chemicals in a variety of situations.    Michael Beale, the principal consultant with EnvirosapHe did a major report on exposure to cutting oil mists in the Ammunition factory in Footscray back in 1986 and has monitored for chemicals detailed in the the “Our Services” part of this website.

Note:  Envirosaphe is said as envirosafe.

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Increasingly small businesses cases focus on establishing a basic OH&S management system, documenting decision making processes and responsibilities and establishing checklists to be completed and registers to be maintained covering risks, management plans, certification and training of employees, management and contractors.

Worksafe Victoria has undertaken a tender process for ongoing consultancy services. EnvirosapHe no longer is involved with the Program.   We believe it was a great initiative.  We wish Worksafe Victoria well in providing assistance to small and medium sized businesses.

Note:  Envirosaphe is said as envirosafe.

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Dust exposure of neighbouring residents to grain handling facility.

Victorian residents located within close proximity to a grain handling facility were exposed to dust associated with the operation of the facility including from the many trucks delivering to the site.    After years of complaining to the EPA legal action was initiated against the grain handling facility owner based upon environmental monitoring undertaken by independent monitoring services provider.

The lawyers acting on behalf of the complainants and having been advised by the EPA and a private provider of environmental monitoring services had already commissioned some environmental monitoring base upon a SEPP with a benchmark of 4 g/m2/month above which dust levels were deemed to be an unacceptable nuisance by the time Envirosaphe was involved.    The brief was to develop methods to be able to a mathematical method using existing and future data to be able to determine the likely past exposure levels experienced on the site.

Key issues.

1. Only SEPP used as basis to assess performance of Grain handling facility is one applicable to quarries and mining.
2. Based on the SEPP grain handling facility owner not required to commission any modelling of off-site dust exposure or atmospheric monitoring to determine whether acceptable emissions of dust were occurring because of the annual tonnages involved did not meet a threshold even though the rate over a harvest period was high, if applied over a year would require such an assessment.
3. The implementation of the SEPP deemed by the EPA to apply in the situation of off-site impacts of grain handling operations applies to new, not existing facilities even if existing facilities significantly increased the quantities handled on site.
4. EPA role in situation of people affected by emissions making a complaint is weighted towards the enterprise generating the emissions being able to continue with minimum restrictions.   Jobs (employment) have a priority over protecting environment of neighbours.
5. After complaints from local residents the EPA required action of grain handling facility owner to undertake measures to reduce dust generated on site, but there was no requirement for the grain handling facility to demonstrate compliance to any benchmark.   No testing. Not required by SEPP or EPA.   Testing has to be done at complainant’s expense.
6. Difficulty for anyone adversely affected by emissions to demonstrate any injury from the emissions or unacceptable dust emissions.
7. Difficulty of determining practical but appropriate monitoring methods, location of monitoring to assess off-site impacts in order to demonstrate nuisance or health impacts by monitoring for dust deposition rates.   Physical limitations of site, proximity to roads.
8. Inability of endorsed atmospheric emission modelling methods to determine likely off-site dust exposures given they are based upon fixed point emissions and gas behaviour, not multi-point multi-parameter dust emissions with diffuse variable location emissions.   While complex and comprehensive they answer a different question to that of a real world question such as, what levels of environmental contaminants will be experienced off-site at a particular location.
9. Appropriate modelling methods to determine likely past exposures to dust using atmospheric monitoring and bureau of meteorology data combined with daily truck delivery data and individual truck loads to extrapolate to generate minimum likely and average likely dust deposition rates.

The Model

The Model was based on the understanding that the cumulative dust deposited in excess over background dust depositions over a 30 day period would be the sum of each individual truck delivery and the conditions existing when that delivery was made over that period.

The developed Model was based upon the following formula.

M is the dust level above the background dust level over a 30 day period.

N is the number of trucks per day.

W is the wind direction averaged over each working day.

T relates to the types of trucks.

D is the tonnage of grain transported,

S is the effectiveness of dust suppression.

The model is based upon the following understandings and assumptions.

M is the dust level above the background dust level over a 30 day period.

N is the number of trucks per day.

W is the wind direction averaged over each working day.

T relates to the types of trucks.

D is the tonnage of grain transported,

S is the effectiveness of dust suppression.

Existing modelling employed by most consultants and recommended by the EPA do not address the issue of dust settling rates which are cited by the EPA as a way of evaluating dust generation and its impact off site.   Normal modelling is based upon airborne concentrations of contaminants including dusts but there is no simple relationship between the dust settling rates over a given area (units gm/m2) and the average airborne concentrations expressed as milligrammes per cubic metre.   That would mean that no way could be developed to link any monitoring results to the existing modelling methods recommended.   A new approach had to be developed especially if the question asked of the researcher related to previous years of deliveries to the site and the likely off-site effects.

The result of the work was that the independent air sampling company the results which found excessive dust settling levels generated in the 2013/2014 harvest period when dust suppression measures were being implemented.   The modelling did suggest that dust levels prior to dust suppressions would have been higher for a significant number of harvest periods on previous years based upon truck movement data and wind direction and speed data from the Bureau of Meteorology from a weather station closely located to the site in question.    The matter was settled not tested in the courts but an out of court agreement with damages was negotiated.

If you are interested in further information on this investigation please contact Michael Beale at EnvirosapHe.

Note:  Envirosaphe is said as envirosafe.

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For people buying and selling properties it is now an issue which needs to be addressed as part of legal due diligence.  Property owners, tenants, business premise occupants need to know whether asbestos materials are present in a home, factory, shop or office building.  People purchasing homes constructed before 1987 need to know about asbestos in the house/home they are likely to renovate, especially given the trend for home renovation promoted on TV.

If asbestos is present owners and occupiers need to know where this asbestos is located, what product has been used that contains asbestos, and whether it presents an immediate risk to health.   They also need to know whether, depending upon the planned future of the specific building the risk can be managed before it is expedient to remove it because of redevelopment of the building or site, or by  around 2030 if this date is accepted to be the point at which all buildings in Australia must be asbestos free.

Envirosaphe has been involved in performing asbestos inspections-audits since 1996.   If you are selling a property, purchasing a property, about to lease a property you may want to arrange an inspection so you can be informed in the potential risks you, your family, your colleagues, your employees face from asbestos.

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Sometimes perceived problems have nothing to do with the air-conditioning.   It may be poor quality lighting causing eyestrain and headaches or over time disorientation.   It may be associated with stressors at work, which are difficult to quantify given they often relate to individual human interactions and power relations.  It is only by a process of eliminating potential physical contributing factors that the psycho-social factors can become clearer.

Increasingly people are becoming ill, or believing they are ill as a result of spending so long in an indoor work environment.   This has been termed Sick Building Syndrome.    Sometimes assessing for different indicators can identify a cause.    Other tests can indicate the thermal comfort within the temperature conditioned environment.

Regular indoor air quality testing, while recommended in Australian and New Zealand Standards on Ventilation, is not mandated by the law, however it is good practice.   Some owners and managers of commercial and business accommodation commission Indoor Air Quality testing, sometimes through the contractors responsible for maintaining the air handling units.    There is an advantage in having this performed by an independent monitoring business because it avoids potential conflicts of interest or appearance of a conflict of interest, where those responsible for maintaining air handling units may be sensitive about any problems identified in such tests and may imply or apply pressure on the organisation performing the testing to achieve successful results.

The following are common tests performed on indoor air environments with benchmarks:

• carbon dioxide;  (less than 1,000 ppm (ASHRAE) but less than 850 ppm indicates conformance with ANZS 1668 Part 2)
• carbon monoxide; (less than 8.7 ppm)
• volatile organic compounds;(less than 0.5 mg/m3)
• dust levels;   (less than 0.3 mg/m3)
• temperature;  (between 20 and 25 degrees depending upon the season)
• humidity; (between 35 and 60 percent)
• viable bacteria; (less than 1,000 cfu/m3)
• viable yeast spores; (less than 150 cfu/m3)
• viable mould spores; (less than 150 cfu/m3)
• viable actinomycetes  (less than 150 cfu/m3).

Testing of air-handling units can assist in identifying problems of microbial contamination before they become apparent through air quality monitoring.   Surface contamination can be determined by taking swabs from chiller drip trays or chiller coils, heating coils, or other surfaces in the air handling units, and having them cultured in a laboratory.    Benchmarks sometimes applied are 1,000 cfu/10cm2 for bacteria and yeasts and moulds.   These benchmarks indicate whether the air-conditioning plant  areas sampled are “clean” or not and levels in excess of the 1,000 cfu/10cm2 figure do not necessarily mean that the surfaces indicate a direct health problem resulting from exposure to air from that system.    They are indicative of a potential problem which may become evident at some stage in the sampling of airborne microbial contaminants.   A more useful approach where a number of units have been tested is to focus efforts on cleaning up and diagnosing the causes contributing to the bad performance of these air-handling units, and generally moving towards achieving lower test results with future tests.

While monitoring over a number of days would provide a good picture of atmospheric contamination to monitor a number of locations continuously over time would be very costly.    Identifying peak loads on systems and hence situations where things are likely to be worse rather than better, and conducting a number of tests over may different locations within such a high load situation would ensure that if problems with the systems did exist, they would be apparent in testing and if the conditions under high load were still acceptable, then at other times of less load, the conditions should be even better.   Focussing carbon dioxide testing to a day and time when most people are at work would be a good test of whether sufficient fresh air is provided by the ventilation system.

Situations recently confronted have been office buildings where old and expensive to recondition or replace air-conditioning systems were replaced with split systems as a cost cutting exercise.    These delivered heating and cooling to an office, but not fresh air.   Monitored carbon dioxide levels in such situations resulted in levels well in excess of the 1,000 ppm level.

Carbon monoxide levels can be high if there is leakage of air into the building from underground or poorly ventilated car-parks, or processes such as cooking or heating with gas or other flammables with incomplete combustion.    Sometimes in older buildings, fresh air intakes to air-conditioning systems has been located in the basement of the building in an area near underground parking.

While it is possible for anyone to perform IAQ testing with the right equipment it is important that independent testing free of any potential conflict of interest is performed.   EnvirosapHe provides a competent, independent monitoring service.

Note:  Envirosaphe is said as envirosafe.

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Asbestos fibres were used widely in building materials before the mid-1980s. If your house was built or renovated before the mid-1980s, it is likely to contain asbestos cement building materials.

You may be surprised at the various types of products that were made from bonded asbestos cement included fibro sheeting (flat and corrugated), water drainage and flue pipes, roofing shingles and guttering, even the backing of vinyl sheet floor coverings.

In NSW, the use of asbestos was discontinued in all fibro sheets and products by the mid-1980s. After this, asbestos continued to be used principally in friction products, for brake and clutch linings. The manufacture and use of asbestos products was banned nationally in Australia from 31 December 2003.

The Importance of Safely Managing Asbestos in and Around the Home

Most people can’t tell whether building materials contain asbestos just by looking at them

Unless you take the required safety precautions and follow regulations, Dont cut it! Dont drill it! Dont drop it! Dont sand it! Dont saw it! Dont scrape it! Dont scrub it! Dont dismantle it! Dont tip it! Dont waterblast it! Dont demolish it! And whatever you do… Dont dump it!

If you do need to work with any material that may contain asbestos, always work so there is minimal dust or small particles released from the asbestos materials

Only scientific testing of a sample of material by an accredited National Association of Testing Authorities (NATA) asbestos testing laboratory can confirm the presence of asbestos. For information on testing and accredited laboratories in your area, visit www.nata.com.au or call 1800 621 666  Asbestos materials that are in good condition are unlikely to release  asbestos fibres if left undisturbed

If asbestos materials are in good condition, paint them and leave them alone.

Useful link.

Asbestos Education Committee                  http://www.asbestosawareness.com.au/

Note:  Envirosaphe is said as envirosafe.

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