Cooling Towers

Policy

The purpose of this policy is to ensure all risks associated with cooling towers within schools are identified and managed.

Summary

• TheOccupational Health and Safety (OHS) Act 2004 (Vic) requires the department to provide or maintain, systems of work and a working environment that is, so far as is reasonably practicable, safe and without risk to health — including the management of cooling towers.
• The Public Health and Wellbeing Act 2008 (Vic) requires building owners to register their cooling towers, develop a cooling tower risk management plan and have it audited by a cooling tower auditor.
• The principal and/or their delegate must ensure that risks associated with cooling towers are identified and controlled.
• Under the OHS Act 2004, employees while at work must take reasonable care for their own health and safety and the safety of others who may be affected by their actions or omissions.
• Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well, including access to the OHS Advisory Service and local OHS regional officers, who can provide free advice on managing risks related to cooling towers.
• The Cooling Towers Procedure (in the Procedure tab) must be followed, and sets out the practical step-by-step instructions for implementing this policy.
• This policy forms part of the department’s OHS Management System, see OHS Management System (OHSMS) Overview for further information.

Details

The principal and/or their delegate must ensure that:

• cooling tower(s) installed at the school are registered with the Department of Health and Human Services (DHHS)
• a cooling tower risk management plan is developed for the school found on the DHHS risk management plan template on the same website
• a planned program of maintenance and microbial testing is established and followed for the cooling tower(s) by a qualified contractor
• cooling tower(s) are installed and positioned (if applicable) so that testing and maintenance can be conducted safely at all parts of the cooling tower(s)
• all microbial test certificates and maintenance records are retained on file
• the cooling tower risk management plan is audited by a cooling tower auditor on an annual basis
• a review is performed of the cooling tower risk management plan on an annual basis which is scheduled on the OHS Activities Calendar (XLSX)
• the DHHS is notified if Legionella is detected in 3 consecutive water samples from the same cooling tower.

Definitions

Cooling tower
A cooling tower is a heat reducing system used in air conditioning when water is used to cool the air. As water is stored in cooling towers, they can be a breeding ground for Legionella and other bacteria to grow. An evaporative air cooler or evaporative air-conditioner is not a cooling tower.

Cooling tower auditor
An auditor certified by the DHHS to undertake an annual cooling tower system audits.

Cooling tower risk management plan
A risk management plan should contain a number of basic components, namely:

• site and contact details
• assessment of each of the critical risks
• summary of the overall risk classification
• details of the system collected during the risk assessment process
• attachments or reference to other documents such as operational plans or shut-down procedures.

The purpose of the risk management plan is to apply and document best practices to effectively control the growth and transmission of Legionella bacteria while considering the risks that are unique to the cooling tower being assessed.

Related policies

• Occupational Health, Safety and Wellbeing Management in Schools
• OHS Risk Planning and Management

Relevant legislation

• Occupational Health and Safety Act 2004 (Vic)
• Public Health and Wellbeing Act 2008 (Vic)
• Public Health and Wellbeing Regulations 2009 (Vic)

Cooling Towers Procedure

The Cooling Towers Procedure must be followed and provides the practical step-by-step instructions to implement this policy.

It contains the following chapters:

1. Risk Management Plan
2. Cooling Tower Installation
3. Cooling tower testing and maintenance
4. Audit of Risk Management Plan
5. Record risk controls
6. Monitor and Review Controls
7. Notifying the Department of Health and Human Services
8. Legislation, codes of practice, standards and guidance

1. Risk management plan

The principal and/or their delegate must ensure that the cooling tower risk management plan addresses the following risk factors:

• stagnant water, for example, lack of water circulation is likely to result in solids in the system settling as sludge encouraging the formation of microbial growth
• nutrient growth, including the presence of algae that can encourage more rapid bacterial growth
• poor water quality, for example, cleanliness, presence of corrosion products, scale and fouling
• deficiencies in the cooling tower(s), including issues with physical design (such as leaks and dead legs – pipes that are full of water and have little or no flow through them) condition and maintenance of the system
• the location of, and access to, a cooling tower system or cooling tower systems, including the potential for environmental contamination of the system and the potential for exposure of people to the aerosols of the system.

1.1 Assess the risks

The principal or their delegate, in consultation with relevant parties (including Health and Safety Representatives or HSR and contractors, where applicable) must ensure that:

• the risk of cooling tower related hazards are assessed using the Risk Management Plan Template or equivalent template
• the risk management methodology as outlined in the Risk Management Procedure is followed to assess the level of risk
• document the hazard in the ‘Hazard Description’ column of the OHS risk register (XLSX) (for example, biological hazard).

2. Cooling tower installation

In the event cooling tower(s) is to be installed at the school, the principal and/or their delegate must ensure that the cooling tower(s) is installed and positioned so that competent persons (such as qualified contractors) conducting the testing and maintenance can easily and safely access all parts of the cooling tower.

3. Cooling tower testing and maintenance

The principal and/or their delegate must ensure a planned program of maintenance (preventative maintenance) and microbial testing is established and followed for the cooling tower(s) by a qualified contractor. All cooling tower test reports/certificates and maintenance records must be retained on file.

4. Audit of risk management plan

The principal and/or their delegate must ensure that:

• the risk management plan is independently audited on a yearly basis as part of the annual independent audit of cooling tower system management
• a review of the risk management plan is performed on a yearly basis
• the audit and review is scheduled on the OHS activities calendar (XLSX)
• the risk management plan be made available to an authorised officer of the Department of Health and Human Services on request.

5. Record risk controls

The principal and/or their delegate, in consultation with the health and safety representatives and employees must record identified and implemented risk controls to manage cooling tower risks on the OHS risk register (XLSX).

6. Monitor and review controls

The principal and/or their delegate, in consultation with the health and safety representatives and employees must review the controls implemented to ensure their effectiveness in managing the risk, and incorporate any changes to controls on the OHS risk register (XLSX).

7. Notifying the Department of Health and Human Services

The principal and/or their delegate must ensure that the Department of Health and Human Services is notified if Legionella is detected in 3 consecutive water samples from the same cooling tower(s) system.

8. Legislation, codes of practice, standards and guidance

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• Public Health and Wellbeing Act 2008 (Vic)
• Public Health and Wellbeing Regulations 2019 (Vic)
• Building Act 1993 (Vic)
• Building Regulations 2018 (Vic)
• Plumbing Regulations 2018 (Vic)
• AS/NZS 3666 Air handling and water systems of buildings – Microbial control
• Department of Health and Human Services: A guide to developing risk management plans for cooling tower systems (Victoria)

Resources

Templates relevant to this policy and procedure

• Cooling tower risk management plan
• Health and safety representative guide (DOCX)
• OHS activities calendar (XLSX)
• OHS risk register (XLSX)