HVAC Products sales & Project manager, Manfred Jarchow, believes cooling tower regulations are not being enforced creating unnecessary risk.
Cost cutting is favoured over best practice and complacency by cooling tower owners highlights the need for greater enforcement and regular audits.
Victoria regulates cooling tower systems to manage the risk of legionellosis. This is because over the past 10 years there has been an increase in reported cases of legionellosis beyond what would be expected relative to population growth.
Recently I was involved in an audit, it was a risk assessment associated with cooling towers across a number of significant sites.
Why is an audit needed? The purpose of the audit is to confirm that the RMP addresses the critical risks prescribed in the Public Health and Wellbeing Regulations 2009 including stagnant water, nutrient growth, poor water quality and/or deficiencies in the cooling tower system, including access for maintenance.
These site visits were shocking, and they were at locations with a high level of public traffic.
I was shocked these organisations failed to meet many of the requirements set down by the Health Department.
Even the person showing me the site, had little knowledge or understanding of cooling towers, a recent graduate engaged by management to get quotes.
There was absolutely nothing in place from an Occupational Health & Safety perspective – no warnings, no need to sign-in at the site or any PPE was provided.
The Health Department recommends and advises that restricting access to essential staff and contractors to reduce the number of people who may be exposed to aerosols.
Identifying those people who require access to the area and establishing a security system is one method of restricting access.
There was no reference to AS1657 for (Fixed platforms, walkways, stairways and ladders - design, construction and installation) – anywhere for cooling towers.
Contractors should have a safe and stable area for maintenance and access to the cooling tower system, this doesn’t always happen.
I got the impression during the audit that price was more important than meeting AS1657 standards and National Construction Code recommendations for best practice.
Basically, compliance with the National Construction Code (NCC) was completely missing.
Interestingly, Code Mark Certification Scheme, a voluntary third-party building product certification scheme that authorises the use of new and innovative products in specified circumstances in order to facilitate compliance with Volumes One and Two of the NCC, also known as the Building Code of Australia or BCA, is not well recognised by the Industry.
Over the past 10 years there have been an average of three deaths per year from legionellosis, a 10-year average mortality rate of 3.4 per cent per notifiable case. In line with guidance from the Office of the Commissioner for Better Regulation, a Value of a Statistical Life figure of $4.5 million has been adopted per death.
The only way to eliminate the risk from Legionnaires’ disease associated with a cooling tower is to remove the cooling tower.
If best practice isn’t being enforced maybe alternative solutions should be promoted and encouraged more. There are hundreds of successful alternative Hybrids installed in the field or adiabatic technology which is available from cooling tower companies .
The benefits are no registration requirements, no requirements for water treatment, up to 80% water savings and heat rejection of approximately 1200 kW per unit.
Another option is to increase annual registration fees for cooling towers from $110 per annum to $1,000 per cooling tower, maybe that will have an impact.
Consulting Engineers need to place more emphasis on specifying alternatives and educating clients about the risk factors associated with cooling towers.