Throughout the United States and beyond, improper HVAC system maintenance may pose a health risk not only to immediate workers, but the surrounding community as a whole. Legionella bacteria (Legionella) were first discovered by public health officials in 1976, with their name stemming from a pneumonia-like outbreak following a large gathering of American Legion members in the city of Philadelphia. The illness caused by Legionella bacteria was officially named Legionnaires’ Disease. This discovery led health of- ficials to make the connection that Pontiac Fever, which had been the subject of a mysterious illness less than ten years prior in Michigan, was also caused by Legionella. Another significant Legionella outbreak occurred within The Bronx in New York City during the summer of 2015 where well over one hundred individuals were sickened, leading to twelve deaths. This outbreak was bookended by two separate, however much smaller out- breaks occurring in 2015. The 2015 outbreak heightened awareness of the dangers Legionella poses to public health, and highlighted how densely populated commu- nities are at high risk. According to a 2003 study titled A Community- Wide Outbreak of Legionnaires Disease Linked to Industrial Cooling Towers—How Far Can Contaminated Aerosols Spread? by Nguyen et al., Legionella bacteria can be transferred via aerosol particles at up to six kilometers (about 3.7 miles) from the source. The bacteria thrive in warm to hot environments, multiplying quickly in stagnant water. “What legislation protects the public from Legionella risks?” The 2015 New York City outbreak prompted New York State to de- velop legislation requiring action to prevent Legionella risks. Prior to this point, the only provision for general worker protection was set forth by Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (OSHA), which mandates that employers provide their workers an “employment and a place of employment which are free from rec- ognized hazards that are causing or are likely to cause death or serious physical harm.” However, the lack of a specific reference to Legionella and its related diseases in OSHA made it difficult to enforce compli- ance with the issue. In addition, despite historic Legionella outbreaks The Connection Between Cooling Towers and Legionella Transmission: How Can We Effectively Reduce the Risk? By Lou Goldstein
Exhaust fans located at the top of a typical cooling tower.
dating back over 40 years, no federal or state laws directly addressed Legionella risks. As a result, Legionella protection measures were a low priority for lawmakers and consequently many facility managers, as well. Specific legislation on preventing transmission of Legionella within building systems was rather slow to develop. No formal regulations were initiated until pressure was brought on by the Bronx outbreaks. InAugust 2015, Governor Andrew Cuomo of NewYork announced the immediate adoption of emergency regulations intended to prevent fu- ture Legionella outbreaks and to promote better hygiene with respect to maintenance of building water systems. These emergency regulations developed into the first-of-their-kind New York State Department of Health (NYSDOH) Protection Against Legionella regulations in early 2016, which described steps to prevent bacterial transmission in build- ing water systems, referencing ANSI/ASHRAE Standard 188–2015, Legionellosis: Risk Management for Building Water Systems, which was published at a similar time. Both items have been updated since, and New York City has additionally adopted their own set of rules. The Centers for Disease Control and Prevention (CDC) and similar organizations currently have guidelines directly and indirectly related to Legionella prevention, but there are no additional further regulations on the federal level or in the other 49 states. How did the 2016 Protection Against Legionella Regulations immedi- ately affect building owners and property managers within NewYork State? The New York State regulations came with a collection of preventative and monitoring-based requirements for building owners whose facility contains one or more on-site cooling towers, evaporative condensers, or other wet cooling devices. The following items were immediately required: • Registration of all wet cooling devices that are being actively operated, including equipment/system specifications - Active updates to the NYSDOH registry with testing results, startup/shutdown date, etc. • Preparation of a Maintenance Program and Plan which describes all
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