Many cooling tower operators assume that if routine servicing is occurring, compliance is under control. In reality, we regularly speak with site managers who are unaware that their Annual RMP Review & Audit is a separate legal obligation. Often, this only becomes apparent when an audit deadline approaches or documentation is requested.

An Annual RMP Review & Audit is not optional. It is a regulatory requirement.

Under the Public Health and Wellbeing Regulations 2019, every registered cooling tower system must have a compliant Risk Management Plan in place, must undergo an annual review of that plan, and must be audited annually by an approved independent auditor. At the time of the audit, the Certificate of Registration for the cooling tower system must also be produced. These requirements apply regardless of whether servicing is outsourced. The legal responsibility remains with the responsible person for the system.

Understanding what the Annual RMP Review & Audit actually involves is critical to avoiding unnecessary compliance risk.

A review focuses on whether the plan itself remains fit for purpose. It requires technical assessment of the system, its operation, and its risk controls. An Annual RMP Review should also be conducted whenever the system is modified, when a Legionella result exceeds regulatory thresholds, when an audit identifies deficiencies, or when operating conditions change. Without an up to date and accurate RMP, compliance cannot be demonstrated.

Beyond verifying that documents are present, the auditor assesses whether records are consistent, complete, and reflective of actual system management. They consider whether actions were taken within allowable tolerances for risk and whether regulatory requirements have been met in practice. An audit is therefore not a paperwork exercise. It is an evidence based assessment of how your system has been controlled.

A compliant and current Risk Management Plan underpins the entire Annual RMP Review & Audit process. If the RMP does not accurately reflect the system, deficiencies will inevitably be identified.

An Annual RMP Review & Audit should never be treated as two isolated administrative requirements. Together, they form a structured compliance cycle designed to continuously strengthen risk control rather than simply confirm that documentation exists. The independent audit looks backward, assessing how the cooling tower system was managed over the previous audit period and identifying any gaps, deficiencies, or areas for improvement. Those findings are not simply compliance notes. They provide a clear picture of where processes, documentation, or control measures may not be fully aligned with regulatory expectations.

The annual review then shifts the focus forward. It provides the opportunity to formally incorporate audit findings into the Risk Management Plan, update system descriptions where required, refine control measures, and ensure monitoring and corrective action procedures remain appropriate. When the review is conducted promptly after the audit, necessary changes can be embedded within the plan while there is still adequate time to implement improvements before the next audit cycle begins.

This sequencing is critical. When sites delay the review until just before the next audit, pressure increases and compliance becomes reactive. Documentation must be assembled quickly, corrective works may need to be expedited, and there is limited opportunity to demonstrate that improvements have been integrated into routine management. By contrast, a well managed Annual RMP Review & Audit cycle provides a clear twelve month window to address identified risks, strengthen documentation practices, and confirm that control measures are operating effectively. Proactive scheduling reduces compliance risk, improves audit outcomes, and allows responsible persons to demonstrate due diligence with confidence.

Under the Public Health and Wellbeing Act 2008 (Victoria) and the Public Health and Wellbeing Regulations 2019 (Victoria), the responsible person for a registered cooling tower system remains legally accountable for its management and compliance. The legislation makes clear that the duty holder must ensure a compliant Risk Management Plan is in place, that an Annual RMP Review & Audit is completed within required timeframes, and that records are accurate and available for inspection by authorised officers.

For many facilities, keeping track of compliance deadlines alongside operational demands can become challenging. Audit due dates approach quickly, documentation must be assembled, and coordination with independent auditors takes time. Without a structured system in place, an Annual RMP Review & Audit can shift from a controlled process to a reactive exercise.

Tandex assists clients by conducting structured Annual RMP Reviews, coordinating independent audits with approved auditors, confirming documentation readiness in advance, and implementing corrective actions where required. We monitor compliance timelines and contact you before your Annual RMP Review & Audit is due. Once confirmed, we manage the process through to completion so your cooling tower system remains compliant, audit-ready, and aligned with regulatory expectations.

If you would like support with your Annual RMP Review & Audit, contact us to discuss how we can help you maintain compliance with confidence.

When water systems in buildings are not properly maintained, a serious risk can develop quietly: the bacterium Legionella and the illness it causes, known as Legionnaires’ disease. This isn’t just about ticking compliance boxes. Legionnaires’ outbreaks can and do happen, even in modern, well-run facilities. In 2024, Melbourne recorded 71 cases, and the outbreak’s first death as health authorities worked to identify the source (The Guardian). Recently, there has been an outbreak in Melbourne’s northern suburbs with six reported cases before the source was addressed. Similar alerts have been issued in previous years as clusters appeared across Victoria and New South Wales (news.com.au).

Outbreaks like these are a sobering reminder that Legionella control is about prevention, vigilance and responsibility, not reaction once something goes wrong.

In Victoria, cooling-tower maintenance is regulated under the Public Health and Wellbeing Regulations 2019. These set out clear obligations for the responsible person, defined as anyone who owns, manages or controls a cooling tower system. The land owner must register the cooling tower system with the Department of Health, perform an annual audit of their Risk Management Plan (RMP), and be able to produce evidence of that plan in action at any time upon request. They must also comply with all directives and allow authorised inspectors free access to assess the system’s condition and records.

As your service partner, we help ensure those obligations are met and your system operates safely:

The aim is not just to pass an audit, but to prevent an outbreak through disciplined, evidence-based maintenance and testing. For more insight into testing frequencies, interpreting Legionella results, and the specific response procedures required under Victorian regulations, visit our Legionella FAQ.

By keeping water systems clean, balanced and well-monitored, you can prevent conditions that allow Legionella to grow and protect both people and property. Here are the essentials to remember:

If your cooling tower has not been reviewed, serviced or tested recently, or if you are not confident in your current maintenance provider, contact us today. We’ll inspect your system, review your RMP and testing program, and design a maintenance plan that keeps you compliant, protects occupants and ensures the long-term safety of your facility.

It’s surprisingly common for cooling towers to lack a safe and practical way to reach the drift eliminators. Whether due to missing ladders, corroded walkways or poor tower placement, restricted access not only makes scheduled cleans more difficult, but it can also directly impact compliance, performance and safety.

During a cooling tower clean, technicians must inspect and clean the drift eliminators. This step is essential to ensure the eliminators remain free of scale, corrosion, and biofilm, allowing them to capture water droplets and minimise the risk of Legionnaires Disease. When safe access is unavailable, cleaners can’t complete this element of the cleaning process, leaving the site exposed to both mechanical and compliance risks.

Under Victoria’s Public Health and Wellbeing Regulations 2019 and associated Risk Management Plan (RMP) requirements, drift eliminators must be inspected and maintained during each scheduled tower clean. These inspections are a non-negotiable compliance task because they directly influence Legionella control and system safety. If cleaners cannot safely reach the eliminators, they cannot inspect or verify their condition. Over time, this can result in incomplete records, repeated non-compliance findings, and even the potential for an RMP audit failure. According to the Department of Health, all components of a cooling tower system, including eliminators, must be safely accessible for inspection and cleaning.

Repeated findings of “inadequate access” may require notification to the local health authority or lead to a direction for rectification under the Act. In practice, the absence of safe access is often identified as a systemic issue that must be addressed through engineering modification, rather than an administrative workaround.

Tandex technicians assess cooling tower access as part of regular water treatment visits and service reviews. If the team identifies unsafe or impractical access to drift eliminators, this is clearly documented and discussed with the site’s maintenance representative. Our goal is prevention. We support customers in resolving physical access barriers before they escalate into non-compliance or audit failure. By maintaining strong communication between service technicians, tower cleaners, and site management, these issues can usually be resolved through straightforward engineering solutions.

For sites without safe access to drift eliminators, the path to compliance is straightforward. Taking the following steps ensures maintenance can be performed safely and inspections can be completed every time:

1. Review your cooling towers to confirm whether drift eliminators can be safely reached for inspection and cleaning.
2. Engage a qualified engineer or tower manufacturer to design compliant access points if they’re missing.
3. Coordinate upgrades with your next scheduled tower clean or refurbishment to minimise downtime.
4. Document the changes in your Risk Management Plan and include photos of new access structures for audit evidence.
5. Verify compliance by confirming the new access allows cleaners to inspect eliminators safely every time.

Before making any upgrades, it helps to step back and look at what really matters most when it comes to safe access. Here are a few quick takeaways to keep in mind:

If access to drift eliminators has been identified as a concern at your site, addressing the issue early can help avoid complications during future cooling tower cleans and RMP audits. Identifying access limitations before they become a compliance issue allows corrective works to be planned and completed in a controlled manner.

For advice on creating or improving safe access to drift eliminators, or to discuss options for cooling tower compliance support, contact us today.