Until now, cooling tower owners in NSW were not required to test for Legionella or HCC – which has made the maintenance regime in NSW quite different to other jurisdictions. The majority of cooling tower owners conduct some HCC and Legionella testing – although many have not been testing monthly.

On Friday 1 December 2017, the NSW Health Minister introduced regulations requiring:

  • Monthly testing for Legionella and Heterotrophic Colony Count (HCC) of all cooling tower systems in NSW from 1 January 2018
  • Reporting of any test results that exceeds 1,000 CFU/mL Legionella or 5,000,000 CFU/mL HCC to the Local Government by the occupier of premises on which the cooling tower is installed

These changes are two of the six recommended improvements to the existing regulations made by the Expert Panel and Legionella Steering Committee established by NSW Health in July 2016.

Short Timeline for Implementation!

NSW Health was keen to implement part of the new framework prior to the start of 2018. Given the regulation was passed on 1 December 2017 with a start date of 1 January 2018, and the time of year, there will be some hard work getting all stakeholders on board. HydroChem’s Account Management team will be working closely with our client base to get this significant change up and running by January.

Adverse HCC and/or Legionella Results

With increased testing comes a possible increase in the incidence of high results. HydroChem manages monthly testing regimes across all jurisdictions outside NSW and many clients in NSW already conduct monthly testing. However, the new Regulations will be a change for some cooling tower owners.

HCC: for results greater than 100,000 CFU/mL a remedial action must be taken as soon as practicable.

Legionella: for results greater than 10 CFU/mL a remedial action must be taken as soon as practicable.

Remaining Recommendations

The remaining recommendations of Expert Panel and Legionella Steering Committee are yet to be introduced with NSW Health finalising the details:

  1. Risk Management Plans developed for each cooling tower system
  2. Independent auditing conducted every year
  3. Certificate of RMP completion & audit completion lodged with Local Government
  4. Unique identification number to be displayed on every cooling tower

We will advise the detail and timing of these changes once they pass into law.