How to be ahead of the Legionella "Curve": NYC Style

Posted by Matthew Bronley

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The treatment of Legionella in NYC is a challenging conquest that takes a lot of patience and understanding to prevent the harmful effects that could afflict the population of the city "that never sleeps." Legionella, specifically the pneumophila strain, can cause diseases such as Pontiac fever and Legionellosis aka Legionnaire’s disease. For those whom become exposed to the bacteria they may experience a respiratory illness with symptoms similar to the flu and pneumonia within a week of exposure. Looking at recent cases, such as in the Sheraton Hotel in Atlanta and in Chesterfield County, Virginia; great care must be given towards the various sources of exposure that pose a risk in harming those individuals that are immunocompromised or at an age group that have a weakened immune system. The Legionella bacterium use droplets from aspirated water as a vector of transmission and are most commonly seen within shower fixtures, hot tubs and cooling towers, that are excellent habitats for growth due to their temperature and lack of proper treatment.

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Since 2015, NYC provided such protection with laws that were enacted to protect residents from harm, such as the Local law 77 and Chapter 8 of Title 24. This law required not only for a Water Management Plan to be developed, based on ASHRAE 188-2018, but also for the registration, chemical treatment, routine sampling, cleaning and maintenance of all cooling towers. For building owners, maintaining a treatment program is indeed an investment. However, disobeying or ignoring such requirements can be costly and violations of the law can total as much as $10,000 or more! New York State has also followed suit by providing their own law (Title 10 Part 4) to protect commercial businesses and residents, as well as healthcare facilities from exposure to Legionella. Still mandating a Water Management Plan to be developed, New York State’s requirements are less stringent and don’t obligate building owners to conduct routine monitoring of their system on a weekly basis. In order to stay ahead of the curve, you need to be diligent with record-keeping, communication and always stay up-to-date with changes in regulations. There is a lot of additional  for the "responsible party" including a water quality assessments done three times a week, weekly heterotrophic bacteriological testing, weekly equipment monitoring, and a monthly maintenance schedule. Compliance inspections and Legionella sampling are the responsibility of the consultant on a 90 day basis. In order for a cooling tower to be in compliance, it is the consultant’s responsibility to teach the team involved with the upkeep of the water management plan, train new members of the team as they are added and conduct routine reviews of the records. Any deficiencies that are observed, such as missing paperwork at that time can be addressed and corrected prior to the arrival of an inspector from the Department of Health thus preventing any violations from being incurred. Communication between consultant and those responsible for the upkeep of the Water Management Plan is key to preventing violations. For example, when a Legionella sample collected is cultured positive, you need to provide the report to the responsible party as soon as positive in order to issue a response. This is extremely time sensitive since all actions are needed to remediate within 24 hours. Instructions have to be carefully laid out to the responsible party on providing the reports to the Department of Health if and when necessary. When a sample comes back much higher than normal, such as over 1000 CFUs/mL, the customer must inform the Department of Health (DOH) as well as upload proof of the remediation that occurred within a 24 hour period. Communication is also necessary in order to correct any possible deficiencies and agree on timing for a shut-down of a cooling tower system in order to complete any emergency disinfection and cleanings of the system. Lastly, any questions brought about by the responsible party at any time must be answered promptly for a proper resolve and consistency within the system.

Regulations change over time and one most adapt to the changes when they occur. By attending seminars and workshops led by the DOH, you can stay informed of revisions within the current law. For example, Local Law 76 came into play on October 25th 2019. When this law was enacted, all inspection reports must be uploaded to the DOH for public viewing within 5 days of their completion. This goes back to utilizing communication with the responsible party of this law, as well as support the maintenance of the water treatment program.

By combining the three elements of consult towards record-keeping, as well as regular communication with the responsible party and adaptation to changes in the law; not only do violations brought about by inspectors become negligible but Legionella can be controlled and never become a hazard to the public. As complicated as it may seem to provide all the right care in the densely populated City of New York, we at Rochester Midland Corporation are subject matter experts, we can offer such due diligence with the best guidance and treatment. 

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Topics: legionella, cooling tower, legionella risk minimization, water treatment risk

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