Public comments for: Amendment of Buildings Penalty Schedule Cooling Towers Registration

Comments

Comment:
See attached for supporting document in support of "no predictive value for HPC or ATP" in Legionella assessments of cooling towers.
Agency: OATH/ECB
Comment:
I commend the City and State of New York for taking these actions to improve public health. Specific comments: 1. Make expressly clear that total bacteria counts (heterotrophic plate count bacteria) either by plate of "dip slide" cannot be used or interpreted as a measurement predictive of either the presence or absence of Legionella. Consequently HPC can only be used to indicate trends in effectiveness of water treatment on the bacteria detected by this test. Legionella is not detected by this test. Both high and low HPC results have been obtained when Legionella is present in both high and low (or none) concentrations. Legionella testing by standard culture method - on a quarterly or schedule to be determined - is the least expensive and most reliable method for evaluating the effectiveness of the water treatment program for controlling Legionella.
Agency: OATH/ECB