Legionella Risk Management Plan Template by vrp48568


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									  Legionella Link
  Managing the health risks
  November 2003

                                                   • follow-up of 1159 Risk Management Plans
  Legionella                                                                                         Risk Management Plans
                                                     that had reported non-compliance issues
  strategy update                                  • over 1000 site inspections or
                                                                                                     Under the Building Act 1993, a Risk
                                                                                                     Management Plan (RMP) for a cooling
                        Dr Robert Hall               investigations by departmental officers
                                                                                                     tower system is a document that identifies
                        Director Public Health     • 150 improvement notices issued                  risks associated with the system and that
                        and Chief Health Officer     under the Building Act 1993                     sets out steps to be taken to -
                        Department of
                        Human Services             • survey and investigation of domestic          • manage the risks; and
                                                     cooling tower system risks
                                                                                                   • ensure compliance with any requirements
                                                   • electronic mapping system linked to the         relating the system imposed by or under
                                                     Cooling Tower System Register. It is now        the Building Act 1993, Health Act 1958 and
                                                     much easier for investigating officers to       regulations under both of these Acts.
  The government’s Legionella Reform                 identify cooling tower systems linked with
                                                                                                     The Building Act 1993 requires the owner
  Strategy, which took effect back in                cases of Legionnaires’ disease.
                                                                                                     of any land on which there is a cooling
  March 2001, involves a working partnership
                                                     Although implementation of the strategy         tower system to take all reasonable steps
  between the Department of Human
                                                     is now complete, the Legionella Program         to ensure that an RMP is prepared,
  Services, Building Commission, Plumbing
                                                     will continue its education, monitoring and     in respect of each cooling tower system
  Industry Commission and industry groups.
                                                     investigation work, to further reduce the       on the land. In most cases, separate
  Each phase of the strategy’s                       incidence of Legionnaires’ disease.             RMPs are necessary for each cooling
  implementation has seen a reduction                                                                tower system. One exception may be a
                                                     This issue of Legionella Link aims to:
  in the number of Legionnaires’ disease                                                             system consisting of a number of identical
  notifications in Victoria.                       • provide feedback from the first round
                                                                                                     evaporative condensers, located in close
                                                     of Risk Management Plan audits,
  Currently, about 5,500 cooling tower                                                               proximity to each other.
                                                     including the most common reasons
  systems (6,531 cooling towers) are                                                                 To meet the requirements of the Act,
                                                     for non-compliance
  registered with the Building Commission.                                                           both for an RMP and an RMP audit,
                                                   • offer examples of good and bad practice
  The past 12 months have seen the                                                                   the document must address the risks
  following achievements:                          • encourage consideration of these                specified in the Building (Legionella Risk
                                                     issues during the coming annual plant           Management) Regulations 2001.
• an accredited independent auditor
                                                     maintenance/shut down period.
  training program for cooling tower                                                                 The Act does not specify whom may
  system Risk Management Plans                       For more details on Legionella risk             prepare an RMP but, for high risk or
                                                     management, please feel free to contact         complex sites, or where large workforces
• training and certification of
                                                     the Legionella Program on 1800 248 898.         are involved, the department recommends
  125 independent auditors
                                                     Dr Robert Hall                                  that a risk management consultant is used.
• the commencement of annual
                                                     Director Public Health                          The department published A Guide
  auditing of Risk Management Plans
                                                     and Chief Health Officer                        to Developing Risk Management Plans
• 260 audits completed by Department                 Department of Human Services                    for Cooling Tower Systems to assist
  of Human Services (DHS) officers                                                                   landowners, cooling tower system
2 Legionella Link

  owners and managers to provide a safe       • operational programs will be commenced        Important points are that:
  environment for their staff, contractors,     from the commencement date of the RMP       • the requirements refer to the entire cooling
  customers and the public, and to comply     • proposed system improvements will be          tower system, not just the cooling tower
  with Victorian legislation.                   completed by the end of the following       • the person responsible for meeting the
  The Guide incorporates an RMP template,       audit period.                                 requirements is not the water treatment
  to be completed when a risk assessment                                                      service provider, but the “responsible
  has been carried out and decisions            Legionella legislation                        person” (“the person who owns,
  made on appropriate risk management           The Victorian Government is committed         manages or controls the system”)
  measures. At least 90 per cent of current     to minimising the risk of Legionnaires’
                                                                                            • the owner or manager of the system must
  RMPs use the template, or a modification      disease in the community. Legislative
                                                                                              ensure that the routine maintenance and
  of the template.                              requirements in the Building Act 1993
                                                                                              testing of the system, as well as any
                                                and various regulations, including the
      Remember: The RMP (plus                                                                 required remedial action and record
                                                Health (Legionella) Regulations 2001,
      implementation plan or schedule)                                                        keeping, address the risks of the
                                                were introduced in 2001.
      must be a practical, easy-to-read                                                       system and meet the requirements
                                                The department administers this               of the regulations.
      document, that has been dated
                                                legislation in partnership with the
      and reflects the owners’ intentions.                                                    More on sampling, remedial action
                                                Building Commission and the Plumbing
                                                                                              and record keeping can be found
                                                Industry Commission. The Department’s
  When developing an RMP, it is                                                               later in this issue.
                                                website www.legionella.vic.gov.au/
  important that recommendations
  be translated into statements of
                                                has links to all the relevant Acts            RMP reviews
                                                and Regulations.
  the owners’ intent, together with                                                           The Building Act 1993 requires that all
  appropriate timelines. The department’s       Health (Legionella)                           RMPs be reviewed, and if necessary
  view is that recommendations not yet                                                        updated, at least once annually prior
                                                Regulations 2001
  accepted by the owner of the land or                                                        to renewal of registration.
                                                These Regulations specify:
  system are not part of the RMP.                                                             This may happen at any time, but an RMP
                                              • definitions for cooling tower, cooling        review should be considered following:
  When a risk assessment or a draft
                                                tower system, biocide, clean, disinfect,
  RMP document has been prepared,                                                           • changes to the water system or its use
                                                HCC, Legionella, responsible person
  it is important that:
                                                and warm water system                       • changes to the use of the building in
• all statements in the document referring                                                    which the system is installed
                                              • continuous treatment to control the
  to proposed system improvements and
                                                growth of microorganisms, including         • the availability of new information
  the system’s operational program reflect
                                                Legionella, and to minimise scale             or technology
  the owner’s intentions and include
                                                formation, corrosion and fouling;           • results indicating that control measures
  timelines, or
                                                ongoing maintenance and testing of            are no longer effective
• it is accompanied by an implementation        cooling tower systems; six-monthly
  plan or schedule, setting out the                                                         • a case of Legionnaires’ disease possibly
                                                cleaning and disinfection of systems;
  owner’s intentions, timelines for                                                           associated with the system
                                                HCC testing at least monthly
  system improvements and the                                                               • unusual factors, for example demolition
                                              • remedial action for high HCC readings
  system’s operational program.                                                               or construction of buildings on or near the
                                                or when Legionella is detected
  Schedules help document the locations,                                                      site, or road works or other construction
                                              • notification requirements when Legionella     activities likely to generate dust
  risk classification, proposed actions
                                                is detected in 3 consecutive samples
  and timelines for removal/activation                                                      • a change in number, or level of
  of ‘dead legs’.                             • maintenance and testing of                    vulnerability, of people who may be
                                                warm water systems                            exposed to aerosols from the system.
  The department’s view is that,
  unless relevant timelines have been         • record keeping requirements.
  specified in the RMP, the document
  should be read as though:
                                                                                                                             Legionella Link 3

  The process should include,                 Undertaking a review prior to an                What the auditor needs
  as a minimum, a review of:                  RMP audit means:
                                                                                              To assess whether the RMP addresses
• risks and risk categories associated      • maintenance and testing records can be          the risks, the auditor requires a copy
  with the system                             assembled and checked by the owner              of the RMP, to check that it contains
• results of microbiological and chemical   • the records are available for the audit         references to the the risks specified in
  tests for the previous 12 months                                                            the regulations. The auditor is not required
                                            • an assessment can be made as to
                                                                                              to determine the extent to which the
• details of service records for the          whether the plan is still relevant to
                                                                                              risks are being managed.
  previous 12 months                          the risks, or requires an update
                                                                                              To form a view that the RMP is being
• the environment surrounding the           • issues can be addressed by the owner,
                                                                                              implemented, the auditor will require
  system and                                  before the audit.
                                                                                              repair, maintenance and testing records,
• changed conditions, if any, under which     The review should be documented and             together with any other relevant records
  the system is operating                     attached to the RMP, which may or may           for the interval between the previous
                                              not require re-drafting.                        registration renewal date and the audit.
      Risks specified in the                  The review can be conducted in-house,
      Building (Legionella                    with the assistance of the water treatment      Choosing an auditor
      Risk Management)                        service provider, or by a consultant.           The Building Act 1993 specifies that
      Regulations 2001                        In more high risk or complex sites,             audits may only be conducted by
                                              or where large workforces are involved,         approved auditors. See the Legionella
   • stagnant water (including the
                                              the department recommends that an               website for a list of approved auditors:
     lack of water recirculation in a
                                              independent consultant be engaged to            www.legionella.vic.gov.au/
     cooling tower system and presence
                                              conduct the review.
     of dead-end pipework and other                                                           Check with the auditor about the level
                                                                                              of service provided; some may provide a
     fittings in a cooling tower system)      RMP audits                                      single contact-only service, which does
   • nutrient growth (including the
                                              Legal need                                      not provide the opportunity to locate
     presence of biofilm, algae and
                                                                                              missing documents. With this service,
     protozoa in a cooling tower system,      Each cooling tower system RMP requires
                                                                                              there is an increased risk of the auditor
     water temperature within a range         an annual audit.
                                                                                              forming the view that the RMP is not
     that will support rapid growth of
                                              Section 75FA of the Building Act 1993           being implemented.
     micro-organisms in a cooling tower
                                              states: “The owner of any land on
     system, and the exposure of the                                                          Note To avoid conflicts of interest,
                                              which there is a cooling tower system
     water of a cooling tower system                                                          the auditor cannot be the owner of the
                                              must take all reasonable steps to ensure
     to direct sunlight)                                                                      land or the cooling tower system, or be
                                              that a risk management plan audit is
                                                                                              associated with the water treatment
   • poor water quality (including the        conducted in relation to the risk
                                                                                              service for the system, the design of the
     presence of solids, Legionella and       management plan prepared in respect of
                                                                                              system, or the development of the RMP.
     high levels of micro-organisms in        the system in the 3 months before the
     a cooling tower system)                  registration of the system is due to expire.”   Timing
   • deficiencies in the cooling tower
                                              Purpose                                         The RMP audit is best undertaken
     system (including deficiencies in
                                                                                              early in the three months before the
     the physical design, condition and       The audit determines two things:
                                                                                              registration is due to expire. This helps
     maintenance of a system)               • whether the RMP addresses the risks             ensure that the audit is completed within
   • the location of and access to a          specified in the regulations                    the registration period.
     cooling tower or cooling tower         • whether the RMP is being implemented.
     system (including the potential
     for environmental contamination
     of the system and the potential
     for exposure of people to aerosols
     from the system)
4 Legionella Link

  Efficient audits                                Outcomes                                       Testing also provides feedback on the
                                                                                                 effectiveness of the biocidal treatment
  To keep costs down and to assist                The auditor will provide a certificate for
                                                                                                 program, which owners pay for as part
  with compliance:                                each RMP, stating whether it addresses
                                                                                                 of the water treatment service contract.
• Make sure that the RMP is clearly set           the critical risks and whether it is being
  out, addresses the the risks specified          implemented. The auditor’s reasons for
                                                                                                   Water samples must be
  in the regulations, is dated and is signed      a finding of non-compliance will be
                                                                                                   representative of the
  off by the responsible person for the           stated on the certificate.
                                                                                                   circulating water system
  cooling tower system. If the RMP                Where an RMP is non-compliant, a copy
  has been reviewed and changes made,             of the certificate will be forwarded by the
                                                                                                 Sampling points
  a record of this should be kept and             auditor to the department for follow-up.
  attached to the RMP.                                                                           Inspectors are still seeing systems
                                                  A non-compliant audit may have
                                                                                                 where the samples are taken immediately
• Ensure that target dates or timelines are       adverse effects on site industrial
                                                                                                 downstream of the biocide dosing point.
  shown for all proposed actions:                 relations, quality programs and
                                                                                                 In some other poor examples, the samples
  – If any action is undated in the RMP, it is    site/business insurances.
                                                                                                 are taken from the cooling tower basin in
    expected that the action be completed                                                        which the biocide is added. The results of
                                                  Audit feedback
    by the end of the following audit period.                                                    testing may have little meaning, as the
                                                  To date, the department has received           samples are not representative of the
  – If the RMP states that an action is
                                                  notices of 1159 non-compliant audits.          circulating system.
    required within a timeline – such as
    every fortnight, or monthly – ensure that     Many were non-compliant because they           Sampling should be taken from a point
    the timeline is complied with.                lacked documentation (such as missing          near the area of highest risk. For cooling
                                                  service reports, test results, invoices or     tower systems, the highest risk of release
• Work towards showing the relevant
                                                  proof of work) to show that the RMP had        of aerosols containing Legionella is from
  registration (CTS) number on all
                                                  been fully implemented.                        the drift or exhaust of a cooling tower. It is
  maintenance and testing records –
  avoid using local names for each                Where management believes that an              appropriate to sample near this release of
  cooling tower system, unless the auditor        activity has occurred, but is not able         aerosols to the atmosphere. A sampling
  is provided with a link between the CTS         to locate the record for the audit,            point on the return line close to the
  numbers and the local names.                    the service provider should be                 cooling tower would be best.
                                                  contacted to obtain a copy.                    The Australian Standard AS 3666.3
• Where possible, keep all service records
  etc for a cooling tower system separate         In some cases, photographs have                Air-handling and water systems of buildings
  from other cooling tower systems on             been included in the records showing           - Microbial control Part 3: Performance-
  the site.                                       specific actions taken - such as the           based maintenance of cooling water
                                                  removal of redundant pipework or               systems and Code of Practice for Water
• Keep these records on-site in
                                                  installation of signage.                       Treatment Service Providers (Cooling Tower
  chronological order, and make sure
                                                  Keeping better and more practical              Systems) also support this approach.
  they are each dated and identify the CTS
  number. If records are sent off-site for        records will ensure a higher success           Until a sampling point is installed on
  audit, copies should be kept on-site with       rate in future audits.                         the return line, it is better to sample
  each respective RMP.                                                                           falling water from just below the fill –
                                                  Microbiological                                rather than from the basin, if that is
• Some complex sites with multiple systems
  have employed an auditor to conduct the         sampling                                       where the dosing occurs.

  first audit on-site. While not required under                                                  Identify and label this preferred
  the legislation, some companies have
                                                  Purpose                                        sampling point, as a cooling tower
  found advantages in this approach.              Testing the microbiological quality of the     system may have many potential
                                                  water in a cooling tower system is an          sampling sites.
                                                  integral part of any RMP, as it measures the
                                                  microbiological performance of the system.
                                                                                                                      Legionella Link 5

                                            HCC and the new                            It is expected that HCC results will
  HCC sampling                                                                         fluctuate during the year, taking into
                                            Australian Standard method
  Heterotrophic Colony Count (HCC)                                                     account different patterns of use
                                            (AS/NZS 4276.3.2 (2003)                    of the cooling tower system and
  is a measurement of the number of
  bacteria that are able to grow in a       A new standard method for the              climatic variations.
  general-purpose growth medium at          determination of HCC in waters
                                                                                       Some concerned owners have contacted
  37ºC. The department adopted the          containing biocides has been published.
                                                                                       the department after adverse HCC or
  limit of 100,000 cfu/mL in the new        This method uses a different growth
                                                                                       Legionella results have been obtained.
  legislation (down from 500,000            medium (R2A agar) for bacterial
                                                                                       An adverse result presents an opportunity
  cfu/mL) to be consistent with             enumeration. Biocide treatments of water
                                                                                       for the owner to discuss the reasons for
  Australian Standards (AS/NZS              injure or stress bacterial cells and R2A
                                                                                       such a result with the water treatment
  3666.3) and levels adopted or             agar was introduced, as it is a better
                                                                                       service provider. It may also be an
  to be adopted by other states.            recovery medium for such cells.
                                                                                       opportunity to review the RMP and
  The measurement of bacteria by            The impact of the use of R2A agar on       put improvements in place.
  the HCC method does not include           the HCC levels of cooling tower water
                                                                                       Owners and managers of systems
  Legionella, which has very specific       is not known and the department
                                                                                       should periodically assess the performance
  growth requirements for testing in        has not moved to adopt this method.
                                                                                       of their water sampling programs,
  a laboratory. There is no direct          Most laboratories use Plate Count Agar
                                                                                       including any remedial action required.
  correlation between HCC levels            for cooling tower HCC tests.
  and Legionella concentrations.
• For engineers or operators, HCC is a
                                            DHS test results                           There is potential for false sampling
                                                                                       to mask sub-standard maintenance.
  measurement of the microbiological        DHS is currently compiling a summary
                                                                                       The department is monitoring for
  control in a cooling system; high         of Departmental cooling tower system
                                                                                       instances of improper practice, and
  HCCs can lead to bio-fouling and          water sample test results for HCC and
                                                                                       would consider legal action if
  poor heat transfer, particularly at the   Legionella, with the view to providing
                                                                                       examples came under notice.
  condenser tubes or heat exchangers,       information for industry.
  resulting in system failure.                                                         Microbiological testing is an
                                            A summary of the results will shortly
                                                                                       important measure in assessing
• From the microbiological                  be available at the DHS website
                                                                                       the performance of water treatment
  perspective, a rising or high HCC is      www.legionella.vic.gov.au and these
                                                                                       programs. These programs are
  a warning of a lack of system control     will be periodically updated.
                                                                                       vital in managing the risk of
  and provides an opportunity to
                                            Taking an interest in results              Legionnaires’ disease.
  correct this. There are often simple
  reasons for this rise – a sudden          There have been reports of samples being
  intake of dirt-laden air, a large piece   taken immediately after disinfection or    There are no penalties for a single
  of dirt/sludge/bio-film dislodged         dosing with biocide – without waiting      high test result. The penalties
  into the system, the biocide              the legislatively prescribed 2-4 days.     provided by the regulations are
  reservoir has been depleted,              This practice reduces the meaning of the   for failing to take the prescribed
  or the biocide pump has failed.           results and is also not supported by the   remedial action.
• From the risk management                  Australian Standards (AS/NZS 3666.3).
  perspective, additional bacteria
  in the system shows a lack of
  microbiological control, the presence
  of nutrients and a possibility that
  Legionella could be developing in
  the system.
6 Legionella Link

                                                   • have an agreement with the water               • Details of any alternative maintenance
      Legionella testing                             treatment service provider (WTSP)                or testing methods approved under
      The time taken for Legionella testing          under which the WTSP would attend                regulation 24.
      (up to 10 days) is considerably longer         within 24 hours, including public
                                                     holidays and weekends or                         WHERE must these records
      than for HCC. In the absence of a
      Legionella result, it is often appropriate   • be able to self-treat the cooling tower          be kept?
      to take action in the meantime on a            system, (and know which biocide to use,          These records must be kept on the site
      high HCC result. This action should            where to locate it, how much to use, and         where the cooling tower is located and
      also have an effect on any Legionella          how and where to dose the system) or             be available for inspection upon request
      present. It is hoped in the future that      • have an agreement with the WTSP under            by an authorised officer.
      there will be rapid tests developed for        which the WTSP would provide telephone           They may be stored in the site kit provided
      Legionella detection.                          advice on self-treatment.                        by the Building Commission at the time of
      In 2000, the Legionella Working Party          Consider sampling at a time that takes           the system’s initial registration. Records
      did not support mandatory routine              into account:                                    must be kept for at least seven years.
      Legionella testing for all cooling tower
                                                   • the required delivery time to the laboratory     WHY must these records
      systems, because of long delays
                                                     (no longer than 24 hours from sampling)
      before test results become available,                                                           be kept?
      the costs involved and the potential         • the required laboratory incubation period
                                                                                                      The auditor requires the above records,
      for negative results to give a false           of 48 hours
                                                                                                      plus a copy of the RMP, to enable the
      sense of security. It was decided that       • sufficient opportunity for the WTSP              annual RMP audit. Presenting the auditor
      a risk management approach should              to respond within normal work hours.             with all of the required records in an
      be taken on maintenance of cooling                                                              orderly sequence will help achieve a
      tower systems and that discussions             The who, what and                                compliant audit result and expedite
      regarding Legionella testing be made
      according to the risk classification of
                                                     where of records for                             the auditor’s work.
                                                                                                      Requirements for record keeping are
      the system.                                    cooling tower systems
                                                                                                      specified in the Health (Legionella)
                                                     WHO keeps the records?                           Regulations 2001, Building (Legionella
  The legislation identifies disinfection
                                                                                                      Risk Management) Regulations 2001
  actions if Legionella is detected in samples       The owner, manager or operator of
                                                                                                      (as amended) and the Building Act 1993.
  taken. Given the time delay in obtaining           the cooling tower system is responsible
  test results, the concentration in the             for maintaining records and keeping
                                                                                                        REMEMBER: maintain complete
  system could have changed considerably             them current.
                                                                                                        records and keep them on-site.
  in the meantime and rapid action is
  required to ensure the risk is reduced.            WHAT records must be kept?
                                                   • Microbiological test results of water            Decommissioning or
  Remedial biocide                                   samples (copies of laboratory reports
                                                                                                      recommissioning a
  dosing for high HCC                                for HCC and Legionella tests). To assist

  Under the Health (Legionella) Regulations
                                                     with monitoring the process, identifying         cooling tower system
                                                     trends and assembling documentation for          Disused cooling tower systems remain
  2001, the responsible person must,
                                                     reviews and audits, it is useful to maintain     registered with the Building Commission
  within 24 hours of receiving a report that a
                                                     a spreadsheet or summary, showing dates          until they have been appropriately
  sample of cooling tower system water has
                                                     of the samples and results of the tests.         decommissioned.
  an HCC count exceeding 100,000 cfu/mL,
  manually treat the water of the system           • Repair, maintenance and corrective               The Building Act 1993 requires the
  with additional quantities of biocide or           activities (monthly servicing, cleaning,         land owner to notify the Commission
  with an alternative biocide.                       disinfection, installation or upgrading of       within 30 days of the removal or
                                                     drift eliminators or signage, removal of         permanent decommissioning of
  To fully meet this requirement, the
                                                     ‘dead legs’ and so on).                          a cooling tower system.
  responsible person would need to either:
                                                                                                                               Legionella Link 7

  When the land owner contacts the                Under the Building Act 1993, the owner of     The Australian Institute of Refrigeration
  Commission, they will be asked to               the land is required to notify the Building   Air Conditioning and Heating (AIRAH)
  confirm that the following steps have           Commission within 30 days of any of the       accreditation program for water treatment
  been undertaken, according to the               following changes:                            technicians is now being implemented in
  Guide to Developing Risk Management           • ownership of the land on which the            Victoria, and the first participants have
  Plans for Cooling Tower Systems:                cooling tower system is located               recently been awarded their certification.
• the cooling tower system has been             • addition or removal of a cooling tower        “The accreditation program gives added
  drained in accordance with any advice           to or from the cooling tower system           credibility to water treatment companies,
  from the local water authority                                                                by confirming that their technicians
                                                • removal or permanent decommissioning
• the chemical dosing tanks (where fitted)                                                      are skilled. By accrediting technicians
                                                  of the cooling tower system
  have been removed                                                                             individually, the program gives confidence
                                                • relocation of the cooling tower system        in the ability of each and every technician
• both power and water supplies                   on the lot of land on which it stands.        that is accredited,” says Jennifer Pelvin,
  have been disconnected
                                                  A Cooling Tower Systems Change                CEO of AIRAH. “It also confirms,
• if the cooling tower has not been removed,      Form may be downloaded from                   for customers, that a company’s
  a sign has been placed on the tower             www.buildingcommission.com.au/                service forces as a whole have
  indicating that it must not be re-activated                                                   achieved that standard.”
  without first contacting the department
                                                    Further information on                      As part of the technician-level program,
  or the Building Commission.
                                                    registration of cooling tower               participants are given a self-paced
  A Decommissioning a Cooling Tower                 systems may be obtained at                  workbook to complete, along with a
  System Form may be downloaded                     http://www.buildingcommission.              copy of AIRAH’s DA18 - Water Treatment
  from the Commission’s website                     com.au/                                     manual. The workbook includes questions
  www.buildingcommission.com.au/                    or by contacting the                        on state regulations and tests participants
  Before a decommissioned cooling tower             Registrations Coordinator at                on the Victorian Code of Practice for Water
  system is re-commissioned:                        (03) 9285 6498                              Treatment Service Providers (Cooling Tower
                                                    or email                                    Systems) and the Guide to Developing
• it must be registered/re-registered
                                                    ctreg@buildingcommission.com.au             Risk Management Plans for Cooling Tower
  with the Building Commission
                                                                                                Systems. Once the workbook has been
• it must have a chlorine compatible                                                            completed, the participants sit an exam to
  bio-dispersant added to the                     AIRAH accreditation                           demonstrate their understanding of the
  re-circulating water, and then
  be disinfected, cleaned and
                                                  program for water                             content of the manual and workbook.
                                                                                                “The advantage of having both the
  re-disinfected according to the                 treatment technicians                         workbook and exam is that it gives water
  Health (Legionella) Regulations 2001
                                                  Jennifer Pelvin                               treatment companies an independent
• a Risk Management Plan must                     CEO AIRAH                                     assessment of each technician -
  be developed and implemented                                                                  a benchmark of their progress,”
  for the system.                                                                               remarks Ms Pelvin.
                                                                                                “The workbook ensures that new
  Cooling Tower
                                                                                                technicians cover the important aspects
  Systems Register                                                                              of water treatment in detail. The course
  The Building Commission maintains                                                             is also suitable for those who are tertiary
  a register to ensure that cooling tower                                                       qualified, as there is no tertiary course
  systems can be promptly identified and                                                        that assesses practical water treatment
  investigated in the event of a case or                                                        knowledge.”
  outbreak of Legionnaires’ disease. It is
  essential that this information is current.
8 Legionella Link

  The course content also includes:
                                                 Legionella contact information
• the need for water treatment
• safety in water treatment                      Department of Human Services
• characteristics and chemistry of water         Website:                                           www.legionella.vic.gov.au/
                                                 LRMP address:                                      lrmp@dhs.vic.gov.au
• overview of cooling water systems
                                                 Past issues of Legionella Link                     www.legionella.vic.gov.au/resources.htm
• understanding control methods                  Telephone:                                         1800 248 898
• maintenance, sampling, testing and             Facsimile:                                         (03) 9637 4657
  “This is the first step of the accreditation
                                                 Building Commission
  process” explains Ms Pelvin. “We are           Website:                                           www.buildingcommission.com.au/
  looking forward to implementing the            Telephone:                                         (03) 9285 6498
  program for supervisors and managers           Facsimile :                                        (03) 9285 6497
  and the accreditation of water treatment
  companies, which will include independent      Plumbing Industry Commission
  verification of each company’s                 Website:                                           www.pic.vic.gov.au/
  compliance with the Code of Practice”.         Telephone:                                         (03) 9889 2211
  For further information or to register,        Facsimile :                                        (03) 9889 2244
  phone Lea at AIRAH on 1300 308 838
  or email education@airah.org.au

  Plumbing Industry
  The Plumbing Industry Commission
  is responsible for licensing and registering
  people who construct and maintain
  cooling towers and cooling tower
  The standard of work must comply
  with the Plumbing Regulations, which are
  made under the Building Act 1993, and
  place into regulation the AS/NZS 3666
  series of specifications.
  Cooling tower work, as defined by the
  Plumbing Regulations, does not include
  water treatment.
  The Commission supports the continual          DHS Legionella Team. Back row: Philip Montalto, Anthony (AJ) Simon, Stuart Adcock, Mark D'Agostino,
                                                 Natalie Blyth and Stephen Waddington. Front row: Bernie Zwolak and Ray Goudey (A/Manager).
  improvement of knowledge and skills
  within the industry, through targeted
  training and information. This is critical
  if the safe construction and maintenance
  provisions for the cooling towers are to
  be met. It also recognises the importance
  of AIRAH, with the accreditation program
  for water treatment technicians as integral
  to the total approach towards safer
  cooling towers.

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