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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