in New York City, Local Law 77 requires landlords to register, inspect, clean, and maintain cooling towers to prevent the growth and spread of Legionella bacteria. Here is a detailed guide to help NYC landlords comply with cooling tower registration and maintenance requirements.
1. Cooling Tower Registration
- Initial Registration: All landlords who own or operate a cooling tower in NYC must register it with the NYC Department of Buildings (DOB) within 30 days of installation. Registration is done through the NYC Cooling Tower Registration Portal.
- Access the Registration Portal:
- Go to the NYC Cooling Tower Registration Portal and create an account.
- Complete all required fields, including the building’s address, owner information, and details about the cooling tower system.
- Obtain a Registration Number: Once registered, each cooling tower will be assigned a unique registration number. This number is required for maintenance and inspection reports.
- Annual Renewal: Re-register the cooling tower every year by November 1, ensuring all information is current.
2. Routine Maintenance and Inspection
- Monthly Inspections:
- Visual Inspections: Inspect cooling towers for any signs of biological growth, unusual noises, leaks, or corrosion.
- Recordkeeping: Document all findings in a log book or digital record, which should be maintained for at least three years.
- Bi-weekly Testing for Legionella and Other Indicators:
- Collect water samples every two weeks to test for Legionella and other water quality indicators (e.g., pH, biocide levels).
- Testing must be conducted by a laboratory certified by the NYC Department of Health and Mental Hygiene (DOHMH).
- If Legionella is detected above acceptable levels, the landlord must notify DOHMH immediately and take corrective action.
3. Cleaning and Disinfection Requirements
- Twice-Yearly Cleaning:
- Cooling towers must be cleaned and disinfected at least twice a year, typically before the start and end of cooling season.
- A qualified professional should perform these services, as improper cleaning can lead to contamination or system damage.
- Use DOHMH-approved chemicals and follow proper safety protocols.
- Post-Cleaning Certification:
- After each cleaning, submit a certification to DOHMH through the Cooling Tower Registration Portal, confirming that the cooling tower has been properly cleaned.
4. Routine Maintenance Program
- Develop and Implement a Maintenance Plan:
- All landlords must have a maintenance program and plan (MPP) in place, which should detail schedules for inspections, cleaning, chemical treatment, and emergency response.
- Include details on the control measures for Legionella and other bacteria, ensuring compliance with NYC standards.
- Ensure Proper Biocide Use:
- Regularly apply biocides to control microbial growth. Adjust frequency based on water testing results and seasonal conditions.
- Use only DOHMH-approved biocides and record all applications, noting the type, dosage, and date of application.
5. Annual Certification of Compliance
- Submit Annual Certification: By November 1 each year, certify that all cooling tower requirements (inspections, cleaning, and testing) have been met. Submit this certification via the Cooling Tower Registration Portal.
- Penalties for Non-Compliance:
- Failure to comply with inspection, cleaning, or reporting requirements can result in significant fines. The DOHMH or DOB may impose penalties or even shut down cooling towers if compliance is not maintained.
6. Responding to Legionella Detection
- Immediate Notification: If Legionella bacteria are found at levels above the acceptable threshold, notify DOHMH within 24 hours.
- Remediation Plan: Work with a water treatment specialist to take corrective actions, which may include disinfection, increased biocide application, or additional testing to ensure bacterial levels are reduced to safe standards.
- Follow-Up Testing: After remediation, conduct follow-up testing to confirm that Legionella levels are back within safe limits.
7. Record-Keeping Requirements
- Maintain Comprehensive Records: Keep records of all inspections, cleaning, maintenance, water testing, and corrective actions. These records must be available for inspection by DOHMH and DOB upon request and should be kept for at least three years.
- Digital and Physical Storage: NYC landlords are encouraged to store records both digitally and in hard copies to ensure they are accessible in case of audits or inspections.
8. Best Practices for Cooling Tower Management
- Regularly Train Staff: Ensure building staff are familiar with cooling tower regulations, signs of system malfunctions, and emergency procedures for Legionella control.
- Engage Licensed Professionals: Use certified professionals for inspections, cleanings, and chemical treatments. Qualified contractors are essential for compliance and effective tower maintenance.
- Stay Updated on Regulations: Cooling tower regulations can evolve. Stay informed about updates from DOB or DOHMH to ensure ongoing compliance.
Maintaining compliance with NYC’s cooling tower regulations not only avoids costly penalties but also protects tenants and the public from health risks associated with improperly maintained cooling towers.
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