Recommended 188 Compliance Procedures of All Cooling Towers
In the summer of 2015, Legionnaire’s Disease outbreaks in New York City prompted the City and the State of New York to pass legislation that mandates the registration, inspection, and testing of Cooling Towers. Not only has Homeyer Consulting Services, Inc. been commissioned to author hundreds of 188 Plans in New York City and New York State, but we are also writing plans for concerned clients across the country.
Legionella Testing to be Mandated in New York State per ASHRAE Standard 188
Robert Homeyer, President of Homeyer Consulting Services, Inc. reported to IDEA the “first-in-the-nation requirement by New York State and New York City to apply the new ASHRAE Standard 188—the risk management standard for Legionella minimization in building water systems—to every cooling tower in New York State by March 1, 2016.” Homeyer Consulting Services, Inc. is a member of the International District Energy Association (IDEA).
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New York State Requirements
ASHRAE 188-2015 Plan
Homeyer Consulting Services, Inc. assembles a team that will be responsible for preparing compliance documentation. At a minimum, the team consists of the owner’s representative with fiduciary control, a Homeyer Consulting Services, Inc. representative, a building engineering representative, and a water treatment vendor representative. Homeyer Consulting Services, Inc. will facilitate the process by coordinating the team activities and publishing the final document.
Quarterly Inspections
Homeyer Consulting Services, Inc. provides quarterly tower inspection reports for the owner to upload to the NYS and NYC reporting portals to meet the quarterly reporting requirements.
Legionella Testing
Homeyer Consulting Services, Inc. provides quarterly Legionella testing to meet the New York State quarterly reporting requirements of Legionella test results and actions taken in accordance with any required response protocol.
Plant Logs
The Homeyer Consulting Services, Inc. Dashboard is an internet-based system that provides the ability to manage the verification and validation data necessary to document compliance with your ASHRAE Standard 188-2015 program. The engineers and water treatment vendors, as well as Homeyer Consulting Services, Inc., maintain the data reported in the system. In the event that the building changes water treatment vendors, the data remains intact.
Tower Cleanings & Remediation
The Water Treatment Vendor Representative will perform needed tower cleanings and remediation. Homeyer Consulting Services, Inc. will assist in development of a cooling tower Water Safety Plan (WSP), compliant with ASHRAE Standard 188-2015, to be in accordance with the NYS and NYC legislation.
Certificate of Compliance
Homeyer Consulting Services, Inc. provides annual certification documentation to meet the NYS and anticipated NYC reporting requirements.
Plan Renewal
Homeyer Consulting Services, Inc. provides plan renewals and updates following Certification.
Related Articles:
NYC - New Rules April 2016 [PDF]
NYS - Final Rules July 2016 [PDF]
