Federal and New York Legionella Updates

Federal Regulatory Updates
The U.S. Environmental Protection Agency (USEPA) recently released a 97 page draft document titled Technologies for Legionella Control: Scientific Literature Review. This document was prepared by the USEPA as a technical resource for governing agencies, building water system operators, and building owners to consider as they evaluate technologies to respond to the risks associated with Legionella colonization of building plumbing. A public review webinar was conducted in November where several experts and interested parties discussed the merits and faults of the Draft. The document can be downloaded in PDF form from this website: https://www.epa.gov/sites/production/files/2015-10/documents/drafttechlegionellaoct2015.pdf

Next phase will submit the document to independent external peer review, which is anticipated to begin by the end of March. The peer review comments will be considered and revisions made to the document that is expected to be published by summer of 2016.

Federal EPA has historically been quiet on the issue of Legionella control techniques; this document is an indication that there is a movement towards more Federal involvement. However, as it stands now, USEPA is explicitly leaving decisions to state primacy agencies on when a building must comply with Safe Drinking Water Act (SDWA) requirements.

New York Regulatory Updates
New York (City and State) have mandated that building owners that have cooling towers must have a water management plan in place by March 1, 2016. The plan is specific to cooling towers (except for healthcare facilities) and must include cleaning, inspections, certification and reporting of significant bacteria occurrences. Portions of the maintenance program and plan have incorporated section 7.2 of ASHRAE 188-2015. The increase in regulation is due solely in part to the Legionnaires disease outbreak that occurred during July of 2015 which included 133 infections and 16 fatalities.

An interesting counterpoint written by the Cooling Tower Institute points out discrepancies in the investigation and calls for closer analysis into multiple sources of bacteria exposure (potable hot water), if another outbreak condition occurs.

New York City is considering even more stringent requirements for the water management plan than the current NY State regulations. New items under consideration for incorporation into the rules include: Legionella sampling, automatic feed of biocides, daily testing of biocide residuals (free and total chlorine), pH, conductivity and temperature. The proposed changes are under review and are expected to be finalized in the next few months. These new set of proposed requirements are another indication of increasing regulation and awareness towards public health regarding Legionella.

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