Auditors - Legionella risk management plans

Information for cooling tower system risk management plan (RMP) auditors and for anyone preparing for a RMP audit. RMP auditors are required to follow the Guidelines for auditing risk management plans for cooling tower systems.

Should you have any questions, contact the Legionella team.

Certified auditors - cooling tower system risk management plans

The Public Health and Wellbeing Act 2008 requires that only people approved by the department can be engaged to conduct cooling tower system risk management plan audits.

Auditors can be found using the department’s public register.

Guidelines for auditing risk management plans for cooling tower systems

The Guidelines for auditing risk management plans for cooling tower systems are intended to assist approved auditors in their role of auditing cooling tower system risk management plans. The document contains templates that can be used in the auditing process and a spreadsheet to use to notify the department of all audit results. This document explains how to put the auditing requirements of the Act into practice. Following the directions in this document is a condition of certification as an approved auditor.

The department has developed an electronic notification system for all audits and non-complying audits. Auditors should use the RMP audit summary template to advise the department of all completed audits by email to the Legionella Team.

The department must be notified of all audits within 7 days of completion.

Please email the department’s Legionella team with any queries regarding audit or registration dates.

Where any difficulty is encountered in the audit process auditors are encouraged to contact the department for advice.

A copy of the guidelines and associated templates can be downloaded.

RMP auditor certification and Automatic Mutual Recognition

Section 94 of the Act allows the Secretary to certify that a natural person is competent to conduct a risk management plan audit and approve that person for the purposes of the Act.

In the past Auditors have been required to satisfactorily complete the Cooling Tower Auditor's course (SBE269) developed by the department in conjunction with Melbourne Polytechnic. Due to the lack of interest in the Auditors Course it has not been viable to run the course.

Alternatively, people that are certified cooling tower risk management plan auditors in another state or territory can work as an auditor in Victoria under Automatic Mutual Recognition (AMR).

AMR allows a person who is licenced or registered for an occupation in one jurisdiction to be considered registered to perform the same activities in another jurisdiction, without the need to go through further application processes or pay additional registration fees.

AMR for certified cooling tower risk management plan auditors will be available in Victoria on 1 July 2021.

To find out how it will work, who is eligible and how to notify the Victorian Department of Health for AMR, read the information on the AMR page.

Application to become a certified approved auditor of cooling tower system risk management plans

Certification of approved auditors

Section 94 of the Act allows the Secretary to the department to certify that a natural person competent to conduct an audit of a cooling tower system risk management plan and approve that person for the purposes of the Act.

Section 95 of the Act requires that a person must not conduct a risk management plan audit unless he or she is an approved auditor. A penalty of up to $9,900 applies to offences against this section.

Certification process

An application can be made to the department to become a certified auditor.

Typically, approvals are granted for 1 year and subject to the auditor complying with certain conditions such as compliance with the Guidelines for auditing risk management plans for cooling tower systems. Once a person has been certified as an auditor, they will receive a Certificate of Approval to act as an approved auditor.

There is currently no fee for certification.

Revoking certification

Section 94 of the Act allows the Secretary to revoke a person's certification as an approved auditor if the Secretary is satisfied that:

1. the certification was granted on the basis of fraud, misrepresentation or the concealment of facts; or
2. the person is not a suitable person to be an approved auditor; or
3. the person has failed to comply with any requirement imposed by this Act or the regulations on approved auditors; or
4. the person has unsatisfactorily carried out 2 or more risk management plan audits; or
5. any other ground which is prescribed for the purposes of this section applies.

Before a certificate is revoked the Secretary must give the person an opportunity to be heard.

At the time of printing no other ground had been prescribed under (e).

Conflict of interest to be avoided

The purpose of s. 97 of the Act is to ensure that risk management plan audits are conducted by an independent person. The Act says that an ‘interested person’ must not conduct a risk management plan audit.

An interested person is defined in s. 97 of the Act as:

(a) the owner of the land on which the cooling tower system stands;
(b) the owner of the cooling tower system;
(c) a person who was involved in the construction or installation of the cooling tower system;
(d) a person who was involved in the maintenance or testing of the cooling tower system during the period covered by an audit;
(e) a person who has written, or has assisted in the writing of, a risk management plan for the cooling tower system;
(f) a person who has reviewed, or has assisted in the reviewing of, the risk management plan for the cooling tower system.

If an auditor is unsure whether they are an interested person for a particular audit, they may contact the Legionella Team to discuss the matter.

A penalty of up to $9,900 applies to offences against this provision.

The Legionella Team is responsible for conducting an investigation where reviews and audits have not been conducted within the relevant timelines.

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