Australian Cooling Tower Compliance Services

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Cooling Tower Audits

Legal Responsibilities


The Public Health and Wellbeing Act 2008 and the Public Health and Wellbeing Regulations 2019 are now in effect, resulting in a number of important changes relating to the registration and management of cooling tower systems.

The Public Health and Wellbeing Act 2008 requires that:
The owner of the land on which there is a cooling tower system is to ensure that each cooling tower system on that land is registered with the Department of Health at all times that the cooling tower system is in operation.
The Department of Health is notified within 30 days of:

  • A change in the ownership of the land;
  • A change in their mailing address or their contact details;
  • A change in the numbers of cooling towers in a cooling tower system;
  • The removal or decommissioning of the cooling tower system; or
  • The relocation of the cooling tower system on land.


A risk management plan is developed for the cooling tower system and continues to exist at all times the system is in operation. The plan must:

  1. Address five critical risks prescribed in respect of cooling tower systems.
  2. Address any matters raised in a report from any person engaged by the owner of the land or the owner of the cooling tower system which refers to control measures being inadequate or requiring improvement;
  3. Set out the steps to be taken to ensure compliance with the maintenance, service and testing requirements.
  4. The risk management plan is reviewed, and, if necessary, updated, at least once in each 12 month period; or if Legionella is detected in the cooling tower system on 2 or more occasions in any 12 month period; or there are any significant changes to the environment or operation of the cooling tower system.
  5. The risk management plan is audited annually by an independent auditor.


The Public Health & Wellbeing Regulations 2019 requires the person who owns, manages or controls a cooling tower system to ensure that:

1. The water in the system is continuously treated with:

  • One or more biocides to effectively control the growth of microorganisms including Legionella;
  • Chemical or other agents to minimise scale formation, corrosion and fouling;
  • A biodispersant.
  • A chlorine-compatible biodispersant is added to the recirculating water of the cooling tower system; and the system is then disinfected, cleaned and re-disinfected;


2. Immediately prior to initial start-up following commissioning, or any shut down period of greater than one month; and

    at intervals not exceeding 6 months.

  • The system is serviced at least once each month.
  • A water sample is taken from the cooling tower system at least once each month and sent to a laboratory for an HCC count.
  • A water sample is taken from the cooling tower system at least once every three months and sent to a laboratory for a Legionella test.


The regulations also require the person who owns, manages or controls a cooling tower system to take certain actions following a high HCC result or the detection of Legionella. These are summarised in the flow charts in Appendix 2.
The Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2017 require an employer to maintain a safe working environment. This responsibility extends to the health and safety of the public and can be related to the safe operation of cooling towers and the provision of safe access for maintenance of cooling towers and associated equipment.


For further information on workplace safety visit the Worksafe Victoria website: www.worksafe.vic.gov.au


Informative Reference Documents

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An Informative Reference Document is only for information and guidance.

  • AS/NZS 3666 Air-handling and Water Systems of Buildings – Microbial Control 2011
  • The AS/NZS 3666.1 Standard specifies minimum requirements for the design, installation and commissioning of air-handling and water systems of buildings for the purposes of microbial control. Operation and maintenance requirements are given in AS/NZS 3666.2, AS/NZS 3666.3 and AS/NZS 3666.4.
  • A Guide to Developing Risk Management Plans for Cooling Tower Systems. This Guide is designed to assist industry develop risk management plans to control Legionella growth in cooling towers.

Risk Management Plans (RMP) 

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In 2001, the Victorian Government developed a comprehensive strategy to reduce the incidence of Legionnaires’ disease by strengthening the regulatory framework and improving the maintenance standards for cooling tower systems. The Victorian Legionella Risk Management Strategy has been successful in reducing the number of cases of Legionnaires’ disease. The legal responsibilities of landowners and managers of cooling tower systems have been incorporated into the Public Health
and Wellbeing Act 2008 and the Public Health and Wellbeing Regulations 2009. 
The key elements of the strategy remain in place today, and the Victorian Government is committed to continuing this regulatory framework. Implementing the strategy is the responsibility of the Department of Health and Human Services.

The Key Aspects of the Strategy are to:

  1. Ensure that cooling tower systems are maintained at a high level.
  2. Ensure that a comprehensive register of cooling tower systems is maintained.
  3. Require the owners of any land on which there is a cooling tower system to prepare and implement an RMP for the effective maintenance of the system.
  4. Require an annual audit of each RMP
  5. Provide for inspections of cooling tower systems on the basis of risk assessment or information received through audits.
  6. Provide an outbreak investigation service through the department.