- June 15, 2026
Cooling Tower Owners: Don't Wait Until November
For many property owners, cooling tower compliance doesn’t receive much attention until the annual certification deadline is approaching. Unfortunately, waiting until the last minute can create unnecessary complications.
Owners of properties with cooling towers are required to submit an Annual Certification by November 1st of each year, confirming that the cooling tower and associated maintenance program comply with New York City’s requirements.
While November may seem far away, the summer is when it may be easiest to perform many of the inspections, testing, maintenance activities, and recordkeeping requirements that are necessary for the certification.
Property owners should confirm that:
Required inspections and maintenance are being performed
Legionella testing and water quality monitoring are up to date
Records are being properly maintained
Any deficiencies identified during inspections are being addressed
One of the most common issues we encounter is failure to maintain complete records.
Cooling tower compliance became a major focus of City enforcement following Legionnaires’ Disease outbreaks in New York City, and the reporting and maintenance requirements remain in effect today.
7/16/26 update:
On 6/15/26 we discussed the inspection and testing requirements for Cooling Towers. Our closing paragraph read: Cooling tower compliance became a major focus of City enforcement following Legionnaires’ Disease outbreaks in New York City, and the reporting and maintenance requirements remain in effect today.
Since then there has been an outbreak of Legionnaires’ disease on the Upper East Side. There have been 63 confirmed cases. The Department of Health has been investigating these cases.
There are 76 buildings in which the Legionella bacteria has been found. These properties have been ordered to immediately remediate their cooling towers. Extra scrutiny on all cooling tower records can be expected.