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


  • TheOccupational Health and Safety (OHS) Act 2004 (Vic)External Link 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)External Link requires building owners to register their cooling towers, develop a cooling tower risk management planExternal Link 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.


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 planExternal Link 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 CalendarExternal Link
  • the DHHS is notified if Legionella is detected in 3 consecutive water samples from the same cooling tower.


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.

Relevant legislation

Department policy on managing risks associated with cooling towers in schools

Reviewed 06 September 2022

Policy last updated

15 June 2020


  • Schools
  • School councils


OHS Advisory Service

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