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Since the Legionella outbreak in Warstein in 2013, which resulted in numerous cases of illness and one death, it has been widely recognized that microbiologically contaminated aerosols from cooling towers and cooling systems can pose a health risk to the public.
With the 42nd Federal Immission Control Ordinance (42. BImSchV) [1], the associated recommendation of the German Environment Agency [2], and VDI 2047, Part 2 [3], there are now legally binding regulations in place to ensure the hygienic operation of such systems.
For example, all systems subject to the 42. BImSchV are required to be registered. Their operators must regularly commission laboratory tests to assess the microbiological condition of their systems, with a primary focus on Legionella contamination. The revised version of VDI 2047 from January 2019 now also includes dry systems with occasional wet operation and systems with adiabatic pre-cooling, which were previously considered relatively harmless. When commissioning testing services, operators must ensure that sampling and analysis are carried out by an institution accredited under the 42. BImSchV. Ideally, both procedures should be conducted by the same institution, as the German Environment Agency recommends that responsibility for the entire process always lies with the testing laboratory.
To reinforce this requirement, the Federal/State Working Group on Immission Control issued the technical module 42. BImSchV [4] in its resolution of April 11, 2018, which defines the requirements for compliant sampling and analysis. A laboratory accredited under this module not only possesses the necessary expertise for sampling and analysis but also demonstrates the required independence through its accreditation. This independence – alongside the reliability of the testing institutions – is one of the main concerns of the immission control resolution. It is, for example, not ensured if the sampling personnel and the testing body are organizationally, economically, or personally connected to the system operator. Sampling by biocide service providers, plant manufacturers, or maintenance companies is explicitly excluded, and the commonly offered “all-in-one service package” will no longer be permitted in the future.
To ensure continued acceptance by regulatory authorities, it is therefore important that operators of cooling systems become aware of their own responsibility, which does not end with simply registering the systems. This includes, among other things (according to VDI-MT 2047, Part 4), training their own employees and selecting a qualified accredited institution to carry out the necessary sampling and analyses. Short distances and close communication with the laboratory ensure a compliant start of the analysis process and help with the evaluation of results, which can sometimes be complex. They also enable operators to respond quickly to exceedances of test or action values through timely sampling.
Thus, the technical module 42. BImSchV represents another step toward establishing a nationwide registry that makes it possible to identify the source of infection in the event of a Legionella outbreak and to quickly contain the risk.
Please do not hesitate to contact us if you have any questions on this topic or require further information. We are happy to advise you! Your competent laboratory in the region: Horn & Co. Analytics GmbH.
Horn & Co. Analytics GmbH
Otto-Hahn-Straße 2
57482 Wenden-Hünsborn
Contact:
Phone: +49 (0) 2762 / 9740-0
Fax: +49 (0) 2762 / 9740-11
Email: anfrage-analytics@horn-co.de
[1] 42nd BImSchV, July 12, 2017 – Ordinance on evaporative cooling systems, cooling towers, and wet separators
[2] Recommendation of the German Environment Agency on sampling and detection of Legionella in evaporative cooling systems, cooling towers, and wet separators, May 19, 2017
[3] VDI 2047, Part 2, January 2019 – Ensuring hygienically safe operation of evaporative cooling systems (VDI cooling tower guidelines)
[4] Technical module 42. BImSchV as per the resolution of the Federal/State Working Group on Immission Control dated April 11, 2018
