Legionella Control

The occupier must notify Council of the new installation within 1 month by completed and submitting Form 6 Notification of Installation or Change in Particulars together with a site plan showing the location of the new system.

A risk assessment must be completed before a newly installed system starts operating. Further information on risk assessments and risk management plans is found below.

Unique Identification Numbers (UID)

When Council's Environmental Health team are notified of a new cooling water system, a unique identification number will be provided for each tower on the system.

The Regulation requires the UID to be displayed on a sign affixed to all cooling towers. The sign must be:

• Minimum size of 148mm by 210mm (A5 size);
• Clearly visible to a person examining or inspecting the cooling water system; and
• made of a durable material.

The Public Health Regulation 2022 requires that occupiers to ensure that:

• A competent person undertakes a risk assessment of the cooling water system every five years (or more frequently if required);
• A competent person documents to risk assessment in an RMP and prepares a certificate of RMP completion; and
• The certificate of RMP completion is provided to Council within 7 days of completing the risk assessment.

The frequency that a new risk assessment is undertaken of a system is determined by the competent person.

Other instances in which a new risk assessment shall be completed are:

• The risk of the system has changed and the previous risk assessment is no longer valid. If so, a new risk assessment must be completed within 30 days of identifying the change in risk; and
• An authorised officer notifies the occupier to complete a risk assessment. If so, a new risk assessment must be completed within 30 days of the notice being given.

Occupiers are required to ensure all cooling water systems are sampled and tested on a monthly basis for Legionella and heterotropic colony count (HCC).

If a reportable test result of Legionella count is ≥1,000 colony forming units per mililitre (cfu/mL) or HCC ≥5,000,000 cfu/mL is obtained, the occupier is responsible for notifying Council within 24 hours of receiving the result. The results must be provided by completing Form 4 Notification of reportable test result.

Audits of the Risk Management Plans are to be conducted on an annual basis. The occupier must engage an independent auditor to audit compliance with the RMP and Regulation.

The audit must be conducted within two months after the end of the 12 month audit period. The audit will include review of the following documents:

• Current valid RMP for the cooling water systems;
• Monthly reports (Form 3) which are completed by a Duly Qualified Person;
• Records of actions required to be completed by the RMP during this audit period;
• Records of actions taken to address non-compliance identified by previous audit; and
• Records any any notifications made to Council.

A list of approved auditors can be found on the list of NSW Health approved auditors of cooling systems.

The occupier must submit the Certificate of Audit Completion to Council within 7 days of the completion of the audit. Council's EHOs will review the certificate of audit completion and will investigate systems that do not comply with the RMP and Regulation.

The occupier must notify Council of the decommissioning of a cooling water system within 7 days by completing Form 6 Notification of installation or change in particulars.