Chair Schulman on Local Law 159 implementation and enforcement preparation
Schulman asks how DOHMH prepared to implement and enforce her 2025 law requiring monthly cooling tower testing. Schiff describes updating guidance, developing regulations, sending notices, holding training sessions, and conducting outreach starting in late 2025.
Local law 159, which was my law of 2025, went into effect in May of this year, requiring more frequent cooling tower testing and additional biocide treatment during warm weather conducive to Legionella growth.
How did DOHMH prepare to implement and enforce the bill leading up to its effective date?
In many ways, in fact, the preparations happened long before the May 8th law was promulgated.
Let me hand it to Deputy Commissioner Crenship to share more.
Yes, we began preparing for that May 8th effective date late in 2025.
We knew that there would be no grace period and we wanted the regulated
to be prepared to implement.
So in late 2025, we began updating the guidance on our website.
We would be letting the operators know that there was new information for them.
We developed the new detailed regulation to implement your local law chair.
We sent out notices when that regulation was open for comment.
That's an opportunity not only to gather comments from the regulated community, but it's also a time to notify them that this was coming.
We notified them again when it became final.
We held training sessions.
We sent out reminders.
So there was a lot happening.
We started talking about it at inspections well before May 8th.
And it is a new requirement.
We know that not everyone's going to be in compliance immediately upon an effective date, but we wanted as many people to be ready to go right on May 8th.
What additional outreach needs to be done ahead of the next cooling season to ensure greater compliance with local law 159?
We will be continuing.
It's part of our, you know, the inspection is a, we think of it as a teachable moment, and we will be continuing to conduct education at the inspection and to do other ongoing outreach.
Owners will receive violations if they're not in compliance.
That is another way of providing them feedback and an incentive to comply.
What support does DOHMH need from other agencies or from the council to conduct outreach for building?
owners and you should think about that and come back to us because we can obviously help with folks in our particular districts.
Yeah, that's a very good point.
We will think about that in circle back.
Okay, great.