Legionella Taskforce - NSW Health · this is the eighth cooling water system that was installed or...
Transcript of Legionella Taskforce - NSW Health · this is the eighth cooling water system that was installed or...
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