Independent Cooling Tower Auditor
In the State of New South Wales an independent Cooling Tower Auditor is a person who has:
- completed training specified by NSW Health
- demonstrated appropriate qualifications and experience
- received approval from the Health Secretary.
The auditor must be independent of the occupier, risk assessor, duly qualified person, and laboratory. The Regulation requires an auditor to assess whether the occupier demonstrates compliance with the actions, control strategies, monitoring and timeframes required by the RMP, and mandatory actions required by the Regulation.
The auditor does NOT assess the quality of the risk assessment or compliance with any optional recommendations in the RMP that do not affect the risk of Legionella growth or transmission.
The occupier must ensure that an audit takes place for each 12 month period, with no gaps between periods. The audit period commences on the first day of the month following the month in which the RMP was completed.
As the audit is a retrospective review of documents generated within the 12 month period, the Regulation allows for the audit to be completed within two months after the end of the audit period. For example, if the RMP was completed on 15 January, the audit period would commence on 1 February and end on 31 January the following year. The audit for this period would need to be completed by 31 March, using data and documentation from the 12 month audit period. The audit is a document-based review. It is not mandatory for the auditor to conduct an on-site inspection of the premises where the cooling water system is located.
There are seven key steps in the audit process:
- collect all documents generated within the 12 month audit period
- list all actions required by the RMP and Regulation
- assess compliance with actions required by the RMP and Regulation
- assess compliance with the timeframes for actions required by the RMP and Regulation
- determine whether the system is compliant, and make recommendations for addressing non-
compliance - prepare an audit report using Approved Form 2, and provide the Certificate of audit completion
to the occupier - local government authority may investigate non-compliant systems.
For the 12 month audit period, the independent cooling tower auditor should review:
- current RMP – Approved Form 1
- monthly reports covering inspection, maintenance (including servicing), chemical analysis, and
microbial testing – Approved Form 3 - records of any actions taken to meet RMP requirements or address non-compliance identified by
previous audit – Approved Form 2 - records of any notifications made to the local government authority (e.g. for a reportable test
result). – Approved Form 4
The auditor should obtain these records from the occupier or the duly qualified person(s).
When conducting an audit, the auditor should review:
- actions, control strategies and monitoring required by the RMP
- sampling and testing for Legionella count and heterotrophic colony count, every month
- notifying the local government authority of a reportable test result, within 24 hours of receiving the
result - providing the local government authority with a certificate of RMP completion and certificate of
audit completion, within 7 days of receiving the document - preparing a monthly report of inspection, maintenance (including servicing), microbial testing, and
chemical analysis, every month.
The auditor must document their findings in the Audit report (Approved Form 2). This includes a Certificate of audit completion which notes the outcome of the audit (compliant or non-compliant). The occupier must provide the certificate to the local government authority within 7 days of completion of the audit. The occupier may engage another person, such as the auditor or duly qualified person, to make this notification on their behalf.
