Philip White recommends full monthly Legionella reporting in support of Intro 1094

Philip Stewart White.

You may begin.

Hey, good morning.

So my name is Philip White.

I'm from Vancouver, Canada, where I co-designed and ran the City of Vancouver's Coolant Tower Registry for six years.

I'm now an independent consultant to government on building water safety.

I support Introduction 1094, and I would suggest one change.

Require every monthly result to be reported.

Not only those at or above 10 CFU.

A threshold-only rule tells you when there's a problem, and full reporting tells you the testing is actually happening.

And a missing report is in itself the signal.

You cannot enforce a testing requirement you cannot see.

10 CFU is the right threshold.

Vancouver's number from day one and the CDC's line for a poorly controlled tower.

At 10 CFU, something is amiss and the operator needs to look for the culprit.

A threshold by itself prevents nothing, though.

What reduced elevator results from repeat systems 86% in the city of Vancouver in four years was the follow-up.

We tracked the repeated systems and focused our efforts there.

They drove two-thirds of the citywide decline.

We didn't send an inspector to every number.

We sent one when the numbers repeated, and we sent them to look at the system, not just the water result.

In Vancouver, it was nearly always a

mechanical or an operator fault.

That's prevention, not reaction.

Finding out at 1000 CFU or after the outbreak versus knowing the sample was taken and reported.

You can't act on the number you never see.

So here I'm telling you that regulation works, Vancouver's program works, and we have the data to prove it.

In New York City, when a child's blood lead comes back at 3.5, you find the lead and the owner is ordered to remove it.

It used to be 15, a level where the damage is already irreversible.

10 is a 3.5 of coolant towers.

Find the fault and fix it.

You build the program around the system, not just the coolant tower, and your efforts will be rewarded.

Thank you.

Thank you so much.

We really appreciate your testimony and you agreeing to do that today.

And we'll be in contact with you, too, because we want to do something with this.

Thank you so much.

Thanks.