As a result of the Legionnaires Disease outbreak that occurred in the Bronx in August of 2015, both the State of New York and New York City Department of Health and Mental Hygiene have passed the first US regulations specifically for testing cooling towers (and drinking water systems in healthcare facilities) for legionella bacteria. These NYC and NYS legionella compliance and regulations were developed for the health and safety of citizens. The regulations specify action levels for requiring cooling tower disinfection. In addition, the US Centers for Disease Control and Prevention (CDC) recommends routine monitoring for Legionella in all hospitals in the US that perform bone marrow and organ transplants. Routine monitoring in hospitals is required or recommended in NY, TX, MD, Los Angeles County, and Allegheny County PA.
Canada has guidelines for monitoring healthcare facilities and certain provinces in Canada have regulations for monitoring government-owned or leased buildings. On June 26, 2015, The American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE) passed ASHRAE Standard 188 for the prevention of legionellosis in buildings. While this voluntary standard of practice doesn’t specifically address Legionella testing, it does offer basic recommendations for establishing a building water safety plan.
Regulations Regarding Sampling And Analysis
New York State requires that cooling tower water system owners conduct sampling and analysis of their potable or non-potable water sources by having a professional:
Take 1000 ml Samples
Taking 1000 ml samples of potable water or a 250 ml sample for non-potable water. Be sure to use sterile bottles containing a chlorine neutralizing agent. Since biofilms are the actual reservoirs for the bacteria, it is also recommended to take sterile swab samples of biofilm in areas where it is present. Samples should be shipped overnight to a lab on freezer packs.
Analyze Samples For Legionella Bacteria
The analysis of water sources in environmental samples is difficult and time-consuming. Therefore analysis should be conducted by a certified and trained professional. These culture tests have a turnaround time of 10 business days and provide confirmed identification and enumeration of the organism. Unfortunately, the culture test cannot be rushed. Testing by Polymerase Chain Reaction (PCR) takes 2 to 3 days and may be useful for providing fast, presumptive results when a case or outbreak is encountered.
Violation Deficiency Reports
If needed, a violation deficiency report requires you to take immediate action to resolve violations and provide proof you have taken action. Failure to take action will lead to fines and health hazards. After the Inspection Summary Report has been issued, the report is then sent to the Department of Health’s Compliance Team, where it will be reviewed and the findings of any violations will be recorded in a Violation Deficiency Report (VDR). This report is also delivered by email to the registered building owner, generally within 7 days of the onsite inspection. The VDR will note what specifically garnered the violation and the cure period if there are any. Legionella Compliance Solutions will be able to help you address this violation or VDR.
We know what the inspectors want and what regulations require. We have evolved with regulations and understand what the laws are and the DOH inspectors are looking for. Contact us today if you have any questions or concerns.
Contact Legionella Compliance Solutions Today
Failure to comply with New York City and New York State legionella regulations can result in steep consequences and fines. Since the inception of legionella specific regulations in 2015, both the New York State and New York City Departments of Health have made several modifications to the legislation and are foreshadowing that future legionella services will need to be validated by a company independent of their existing water treatment company. Keeping up with all of these changes can be time-consuming.
Legionella bacteria can cause serious illness, including pneumonia and lung infections. Protect yourself and others in your residential building from these harmful maladies, including Legionnaires Disease, by adhering to best practices provided by Legionella Compliance Solutions. Inquire about our NYC and NYS legionella compliance and regulations services. For more information about legionella compliance or cooling tower water cleaning, please call us at (212) 729-9361 or schedule a consultation online.