Cooling Towers: Maintenance Program and Plan

The Maintenance Program and Plan (MPP) is a detailed plan customized for a cooling tower system that describes operational and administrative strategies and process control measures to be taken to prevent and control the growth of Legionella.


MPPs must provide a comprehensive description of actions (i.e., step-by-step instructions), including details, contacts, and information. These management and maintenance requirements must include, at a minimum:

  • Management and maintenance team member information
  • Cooling tower system information
  • Risk management assessments for the cooling tower systems
  • Cooling tower operation procedures:
    • Routine monitoring and compliance inspection procedures
    • Routine operation, monitoring and maintenance procedures
    • Details of the water treatment program
    • Water quality sampling and testing procedures
    • Corrective action procedures
    • Startup and shutdown procedures
  • Notification and communication procedures

Plan Preparer and Other Qualified Persons

Building owners must retain a qualified person to develop and implement the MPP in accordance with Local Law 77 of 2015 (PDF) and Chapter 8 of the Rules of the City of New York (PDF). A qualified person can be a:

  • New York State licensed and registered professional engineer
  • Certified Industrial Hygienist
  • Certified water technologist with training and experience developing MPPs and performing compliance inspections in accordance with current industry best practices, published standards and regulatory requirements
  • Environmental consultant who has at least two years of operational experience in water management planning, operation and maintenance

In addition to a qualified plan preparer, building owners may also retain certain qualified individuals with the appropriate experience and certifications to conduct cleaning, disinfection, compliance inspections or sampling. Before hiring a qualified person, you should ask them about their experience in environmental remediation, licenses/permits, customer references, and any other matters of concern.

The websites listed below can help you develop your cooling tower management and maintenance team. These websites do not include every qualified person or company available in the city.

Additional Resources

More Information