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Cooling towers: the notification duty that gets missed

If your premises has a cooling tower or evaporative condenser in the UK, the local authority must be told. It is a simple duty, but during outbreak investigations it is one of the first things checked.

Cooling towersHSG274 Part 1Compliance

Cooling towers and evaporative condensers remain the systems most often linked to large Legionnaires' disease outbreaks, because they can throw a fine aerosol over a wide area. That is why the UK has had a specific legal duty since 1992 to notify the local authority of these devices.

The Notification of Cooling Towers and Evaporative Condensers Regulations 1992

Under these regulations, the person in control of premises must notify the local authority in writing of any cooling tower or evaporative condenser on site, giving the location and the details of the device. Changes, including a tower being taken out of use or removed, must also be notified. Local authorities keep a register, and during an outbreak investigation it is the first document public health teams reach for.

In our experience the duty is most often missed when:

  • A building changes hands and the new occupier assumes the previous one notified.
  • A tower is replaced and the new unit is never registered.
  • A tower is decommissioned but the register still shows it live, which invites an unnecessary visit.

What good control looks like

HSG274 Part 1 covers the control of Legionella in evaporative cooling systems. The essentials are a current risk assessment, a written scheme that names the responsible person and the water treatment regime, routine monitoring of the chemical and microbiological condition of the water, and regular cleaning and disinfection of the tower and pack. Cleaning is normally at least six-monthly, with additional cleans when the system has been off line or results indicate a problem.

Republic of Ireland

There is no direct equivalent of the 1992 notification regulations in the Republic of Ireland, but the HPSC National Guidelines set out the same expectations for risk assessment, treatment, monitoring and cleaning of cooling towers, and the Health and Safety Authority expects them to be followed. Cross-border operators should not assume a lighter regime south of the border.

A quick check for site managers

  1. Is every cooling tower and evaporative condenser on site on the local authority register, with your current details?
  2. Do you have a risk assessment for it that is less than two years old or has been reviewed since any change?
  3. Can you show the last two cleaning and disinfection certificates?
  4. Are your monthly Legionella sampling results and weekly water treatment checks filed and reviewed?

If any of those is a no, we can help put it right.