Jan Horn of Cooling Technology Institute opposes 10 CFU Legionella threshold
Jan Horn, president of the Cooling Technology Institute, opposes lowering the Legionella reporting threshold to 10 CFU/mL. He argues policy should follow demonstrated public health benefits, says major technical guidance emphasizes comprehensive water management over a single low test result, and offers CTI as a technical resource.
Next is Ian Horn.
You may begin.
Ian Horn.
Yes, I'm trying to unmute.
Can you hear me?
Yes, we can hear you now.
Yes, thank you so much.
We have submitted a written testimony along with our application.
I'm going to present to you a very short summary of that.
Good morning, Chairperson Shulman and members of the City Council Health Committee.
My name is Jan Horn, and I'm the president of the Cooling Technology Institute.
I come before you today in opposition of proposed legislation to amend New York City's reporting requirements for Legionella test results.
We ask that you do not lower the Legionella reporting threshold to 10 CFU per milliliter as proposed by this bill.
I am also offering our services as a technical resource on the topic of Legionella control and prevention.
We are here at your service.
CTI is an independent nonprofit organization dedicated to advocating and promoting for the benefit of the public safe use of all environmentally responsible and energy efficient cooling technologies.
Our organization is responsible for drafting many internationally recognized standards and guidelines.
We appreciate the Council's commitment to protecting New Yorkers from Legionnaires disease and we share that objective.
However, we believe that policy decisions should be based on demonstrated public health benefits.
Major technical guidance documents, including CTI Guideline 159, ASHRAE Standard 188, and ASHRAE Guideline 12, emphasize comprehensive water management practices in investigation of system conditions rather than the reliance.
on one single low Legionella test result.
While Legionella concentrations are one important indicator of system performance, no single concentration has been demonstrated to reliably predict human illness across all building types, operating conditions, and exposed populations.
To our knowledge, peer-reviewed research has not demonstrated that reducing the reporting threshold to 10 CFU improves Legionnaires'disease prevention or public health outcomes.
For that reason, CTI strongly encourages continued emphasis on robust water management programs, timely investigation of elevated results, epidemiology-guided outbreak investigations, and operator training.
CTI also believes Legionnaires'disease investigations are most effective when they evaluate all potential environmental sources, including entire building water systems, as well as all incoming potable water systems.
supplies.
In conclusion, CTI asks that you do not lower the recording detection limit to 10 CFU, and we are available to you as a technical resource on this topic.
I thank you for your time.