NEW Cooling Tower 90-Day Reporting Requirements

The first new NYC rules of 2020 are here, and they’re all about cooling towers.

Local Law 76 of 2019 adjusts LL 77/2015 (one of the the original cooling tower documentation laws) to add requirements for submitting 90-day inspection dates to the DOHMH via the online portal.

90-day inspections are the compliance inspections performed by your “qualified person” and typically include observations of the tower, water makeup quality, equipment functionality, reviews of the routine maintenance records, and (of course) Legionella sampling tests.

As a reminder, qualified persons are NYS licensed and registered professional engineers, certified industrial hygienists, certified water technologists with training and experience, or environmental consultants with operational experience in water management planning and operation. They’re typically third party vendors or consultants hired by your organization. This is a different role than your “responsible person,” who may be an onsite staff member designated to perform regular maintenance routines for the cooling tower.

This requirement is in effect now – that means your qualified person will have to report the Legionella sampling date within 5 days of collection, whenever your next sampling is due. For example, if your next 90-day sample is due next week and performed on Friday, your qualified person will have to submit that Friday date online within 5 days of sample collection.

Per previous rules, sampling dates and results are still required to be kept onsite and made available to the DOHMH during their inspections.

While the DOHMH will be posting more information about this new requirement in the coming weeks, they’ll also be hosting information sessions in early January. See the Resources section below for information on how to register.


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About the Author

Kristen Hariton

Kristen Hariton is the Vice President, Product Engagement at SiteCompli, focused on exploring new solutions and innovations in property operations tech. When she's not sharing the latest industry trends, changes, and updates, she's planning her next adventure to Walt Disney World.