November 2018

Legionella Taskforce

Changes to the Public Health Regulation 2012

Summary of presentation

Overview of changes and timeframes

Flowchart and definitions

Monthly testing and laboratories

Risk management plan (RMP) implementation

Unique identification numbers

Overview of changes and timeframes

Precursors to the Legionella Taskforce

Two outbreaks of Legionnaires’ disease (March, May 2016)

Expert Panel convened by Chief Health Officer (~June 2016)

Discussion Paper (December 2016 to February 2017)

Legionella Taskforce formed (February 2017)

n=53

The “six safeguards”

1. Risk Management Plans (RMPs) developed every five

years (or once every year for high risk systems)

2. Independent auditing conducted every year

3. Certificate of RMP completion & audit completion lodged

with local council

4. Laboratory testing for Legionella and heterotrophic colony

count every month

5. Notification of reportable test results to local council

6. Unique identification number to be displayed on every

cooling tower

Regulation commencement

Preparation

Remainder of

regulation published

Monthly testing

commenced

RMP

group 1

due

RMP

group 2

due

RMP

group 3

due

Regulation implementation

Monthly testing commenced on 1 January 2018

– Higher incidence of Legionella cases over summer months

– Monthly testing is a key control strategy to reduce outbreaks

Remaining requirements (RMP, auditing, unique identification

numbers) commenced on 10 August 2018

– RMP requirement to be staged in three groups

– Allows time for local councils and industry to prepare

– Allows time for TAFE NSW to roll out training and

communication

Flowchart and definitions

Occupier of premises or a part of premises means:

• The owner of the premises or part

• The person entitled to occupy the premises or part

• The owners corporation under a strata scheme.

Duly qualified person installs, operates or maintains

a regulated system.

Independent auditor is:

• Approved by the Health Secretary as an auditor

• Not the risk assessor

• Not the occupier

• Not the duly qualified person

• Not the laboratory that carried out monthly testing.

Competent person (risk assessor) has:

• Appropriate training, and

• Practical experience in the subject

• Sufficient to provide safe and satisfactory

performance.

Can supervise junior staff to perform part of the risk

assessment, but must finally sign off on the RMP.

Cooling Water System

Occupier

Water treatment,

mechanical services

& industry

(“duly qualified person”)

Independent

Auditor

Risk Assessor

(“competent person”)

Installation &

Decommissioning

(“duly qualified person”)

Yellow boxes indicate activities for which local councils may set fees

Cooling Water System

Occupier

Water treatment,

mechanical services

& industry

(“duly qualified person”)

Independent

Auditor

Risk Assessor

(“competent person”)

Risk Management Plan

(at least every five years)

Independent Audit

(every year)

Inspection, chemical

analysis, microbial testing

(every month)

Local

Government

Authority

Installation &

Decommissioning

(“duly qualified person”)

Notify local government

Laboratories

Issue unique identification number

Maintain register of cooling towers

Support, training, advice

Develop & provide training

Investigate outbreaks

Maintain list of approved auditors

NSW Health

Investigate and inspect

Notify reportable

test results

Certificate of

RMP completion

Certificate of

audit completion

Monthly testing and laboratories

Monthly testing requirement

Monthly testing commenced on 1 January 2018

Occupier must notify local council of elevated

Legionella count ≥1000 cfu/mL and HCC ≥5,000,000 cfu/mL

Response to elevated test results

RMP must use control strategies in Australian Standard to

ensure Legionella count <10 cfu/mL and HCC <100,000 cfu/mL

RMP implementationand frequency

RMP requirement

Risk management plans (RMPs) to be reviewed:

– For low and medium risk systems – up to every five years

– For high risk systems – every year

RMPs to be completed in a staged manner

– Local councils to allocate systems in their area into three

groups, resulting in three deadlines

– RMPs to be completed by the three deadlines

Guidelines for developing RMPs and allocating the three groups

– Developed by NSW Health and available online

– Having three groups helps to evenly distribute RMP workload

throughout calendar year (not based on Legionella risk alone)

RMP implementation

RMP Group B

Certificate of disinfection Initial registration date RandomiseRisk rating

RMP Group A RMP Group C

Medium

Risk

Low

Risk

High

RiskLine Listing

NSW Health publishes

Regulation

Local governments

allocate RMP priority

Local governments

issue unique

identification number

Allocation of groups by each local council

based on local needs, capacity, number of cooling towers, etc

Unique identification numbers

Unique identification numbers (UIDs)

UIDs to be provided by local councils, after occupier notifies

council that a new cooling tower has been installed

UIDs to be displayed by occupier on each cooling tower, within

30 days after local council provides UID

UIDs should be:

– Clearly visible to a person examining or inspecting the system

– Minimum size 148 mm by 210 mm (A5 size)

– Made of a durable material

Guidelines for developing and allocating UIDs are available

online

UID implementation

This UID shows that within the City of Sydney local government area,

this is the eighth cooling water system that was installed or registered,

and this is the second cooling tower in that system

XXX XXXX XX– –

Local government

acronym

Cooling water

system number

Cooling tower

number

COS 0008 02– –

City of Sydney local

government authority

Eighth cooling water system registered

in this local government area

Second cooling tower

within this system

UID implementation

Alternative proposed by some councils using existing licensing and

registration system

Summary

Changes to the Public Health Regulation 2012 commenced on

1 January and 10 August 2018

– Monthly testing

– Risk management plans

– Independent auditing

– Unique identification numbers

Guidelines have been developed by NSW Health to support

stakeholders in their roles and responsibilities

Communication and roadshows taking place throughout 2018

Training to be provided by TAFE NSW for key stakeholders