How to Register Cooling Towers in NYC and New York State: A Complete Guide
- The NuChem Crew
- Aug 26
- 13 min read
In the wake of the Harlem Legionnaires’ disease outbreak in July 2025, the general public, building owners, and property managers across NYC are on high alert about Legionella prevention. Proper cooling tower registration and maintenance is not just procedural paperwork. It’s a critical public health measure, especially after past Legionnaires’ disease outbreaks. Both New York City (NYC) and New York State (NYS) have strict regulations requiring building owners to register their cooling towers, adhere to maintenance schedules, and certify compliance annually. In this guide, we’ll walk building owners, facility managers, and consultants through:
· Step-by-step instructions for registering cooling towers in NYC and NYS.
· Compliance deadlines you need to meet in each jurisdiction.
· Penalties for non-compliance under NYC and NYS rules.
· Key differences and overlaps between NYC and NYS requirements.
Let’s ensure your cooling tower is fully compliant with both city and state law, avoiding heavy fines and helping keep our communities safe.
Why Cooling Tower Registration Matters
Cooling towers commonly found on commercial, industrial, and even large residential buildings can harbor Legionella bacteria if not properly maintained. A major Legionnaires’ disease outbreak in NYC in 2015 was traced to contaminated cooling towers. In response, Local Law 77 of 2015 in NYC and corresponding NYS Department of Health regulations (10 NYCRR Part 4) were enacted to prevent such outbreaks. These laws require proactive registration, water treatment, testing, and reporting to reduce Legionella risk. Compliance is not optional – it’s the law, with substantial civil penalties for neglect. Now, let’s dive into how to get your cooling tower registered in NYC and NYS.
Registering a Cooling Tower in New York City (NYC)
NYC’s cooling tower registration process is administered by the Department of Health and Mental Hygiene (DOHMH) via an online portal. All cooling towers, evaporative condensers, and fluid coolers in NYC must be registered with the City’s Cooling Tower Registration Portal.
1. Access the NYC Cooling Tower Registration Portal: Navigate to the official NYC Cooling Tower Registration Portal.
2. Create an Account: If you’re a first-time user, you’ll need to set up an account. Provide a valid email and create a password. The portal will guide you through account creation or you can also email DOHMH at ctcompliance@health.nyc.gov for technical help.
3. Enter Building and Owner Information: Once logged in, start a new cooling tower registration. Fill in all required fields about the building and owner (B). This includes the building address, Building Identification Number (BIN) if known (A), owner or property manager contact details, and the specific location of the cooling tower within the building (e.g. rooftop). Ensure the information is accurate, as it will be used for compliance tracking and inspections.
4. Enter Cooling Tower Details: Provide details for each cooling tower unit . NYC requires each cooling tower system to be registered, including fluid coolers and evaporative condensers. You’ll likely need to input the cooling tower’s make and model, capacity, and installation date, along with any other technical details requested. (If you have multiple cooling towers on the same building, register each one separately.)
5. Submit the Registration: Review your entries for accuracy and submit the registration. Upon successful registration, the system will issue a Cooling Tower Registration Number for each tower. Make note of this number. NYC requires that the cooling tower’s DOB registration number be posted conspicuously on the tower or at the building. This number will also be used in inspection reports and annual certifications.
6. Initial Registration Deadline: New cooling towers must be registered before they begin operation. Building owners in NYC are required by law to register their cooling towers. If you discover an unregistered older tower, register it immediately to avoid penalties.
7. Annual Certification: NYC requires an annual certification for each cooling tower. By November 1 of each year, owners must certify through the portal that each cooling tower was inspected, tested, cleaned, and maintained according to regulations.
After registering, maintain a copy of your registration confirmation. If at any point you permanently discontinue using a cooling tower (or remove it), you must update the portal by filing a decommissioning notice within 30 days and ensure the tower is cleaned and disinfected before shutdown. NYC DOHMH staff can assist in inactivating registrations for removed towers upon request.
Registering a Cooling Tower in New York State (Outside NYC)
New York State’s cooling tower registry is separate from NYC’s system. All cooling towers throughout NYS (including ones in NYC) must be registered with the New York State Department of Health (NYSDOH) via its statewide electronic registry. This means if your building is in NYC, you need to register with both the NYC portal and the NYS portal. Below are the steps for the NYS registration:
1. Create a NY.gov Account: The NYS Cooling Tower Registry is accessed through the NY.gov online services platform. If you do not already have a NY.gov account, you’ll need to create one. Go to the NYS Cooling Tower Registry login page (https://ct.doh.ny.gov) and click “Create an Account: First Time Users”. Follow the prompts to set up your NY.gov username and password. (Tip: Use an email you check regularly, and remember your credentials – you’ll use this account for ongoing cooling tower reporting.)
2. Log in to the NYS Cooling Tower Registry: After creating your account and verifying any confirmation email, log in at ct.doh.ny.gov with your new credentials. If you have trouble logging in, note that you must access the specific cooling tower registry page (ct.doh.ny.gov) – bookmarking the correct URL.
3. Start a New Cooling Tower Registration: Once logged in, you will see options to add or register a cooling tower. Click to register a new cooling tower. The system will prompt you to enter information in several sections (often organized by “Property Information” and “Equipment Details”).
Property Information: Enter the name of the building or facility, the address, and owner information. This creates a record for the location that will house one or more cooling towers.
Equipment Details: Enter details for the cooling tower itself, each individual cooling tower unit requires its own entry in the state system. You’ll need to provide details such as the cooling tower’s manufacturer, model, capacity (e.g. tonnage), location on the property, and the date of initial operation. Ensure you fill all required fields (marked with an asterisk *). If you have multiple towers on site, you will repeat this process for each tower one by one.
Keep in mind that if a tower was previously registered by a former owner, you should still register it anew under your account if ownership changed. (NYSDOH currently cannot auto-transfer NYC tower data to the state public registry, so double-registration is necessary.)
4. Submit Registration and Obtain Tower ID: After entering the cooling tower details, submit the registration. The NYS system will generate a unique Equipment ID for the tower. This ID is used in state records and when reporting any updates.
5. Registration Deadlines: Under NYS regulations (10 NYCRR 4-1.3), you must register a cooling tower prior to its initial operation. Additionally, if ownership of a cooling tower changes, the new owner must register the tower anew under their name in the NYS system. Failing to register or update ownership is a violation of state health code.
6. Ongoing Use of the State Registry: Owners are required to use it for ongoing compliance reporting. Every 90 days (at minimum), you or your water treatment consultant must log in and report recent maintenance activities (latest inspection date, bacteriological sample date, and Legionella sample date and results). Remember to also update the registry if you decommission a tower, there’s a field to enter the date of permanent removal or discontinued use.
By following the above steps, you will fulfill the basic registration requirements for New York State. Now, let’s look at the compliance deadlines and tasks you must stay on top of for both NYC and NYS.
Compliance Deadlines and Requirements in NYC vs NYS
Once your cooling tower is registered, the work isn’t over. Both NYC and NYS have ongoing compliance requirements with specific deadlines to ensure towers are maintained safely.
NYC Compliance Deadlines and Tasks
Annual Certification by November 1: Every year, by November 1, NYC building owners must certify in the NYC portal that their cooling tower has been properly inspected, tested, cleaned, and maintained in accordance with the law. November 1 is a hard deadline – missing the annual certification will put you out of compliance and can trigger a violation.
90-Day Compliance Inspections: NYC requires that a qualified person (e.g. a water treatment provider, consultant) perform a compliance inspection at least once every 90 days (quarterly) while the tower is in use. The findings must be documented in your records. In practice, your water treatment consultant or qualified inspector will enter the Legionella sample collection date within 5 days of each sampling in the NYC portal. This aligns with state reporting.
Regular Water Testing: While registration itself doesn’t require uploading lab reports, NYC rules compel you to perform Legionella culture testing at least every 90 days when the tower is operational, and bacteriological (e.g. heterotrophic plate count) testing every 30 days. If a Legionella test result is high (≥ 1,000 CFU/mL), you must notify the NYC Health Department promptly and take immediate corrective actions (disinfection) per your plan.
Maintenance and Cleaning Schedule: A Maintenance Program and Plan (MPP) is required. As part of this plan, routine monitoring of key parameters should be done weekly, and tower cleaning and disinfection is required at least twice a year (usually before initial startup of the cooling season and after shutdown, or as needed). If the tower operates year-round, plan on at least two cleanings per year. Each cleaning and disinfection must be logged, and a “summertime hyperhalogenation” must be performed and a declaration form submitted to DOHMH within 30 days of that treatment.
Reporting Changes: If you remove a cooling tower or permanently shut it down, NYC law requires you to notify the Department of Buildings within 30 days and update the registration portal. You must also certify that the tower was cleaned and disinfected prior to removal. Additionally, if there is a change in building ownership or management, the new owner/manager should update the contact information in the portal. (While NYC doesn’t explicitly require re-registration on ownership transfer in the same way NYS does, it’s important to keep the registration info current to receive compliance notices and avoid violations.)
NYC and NYS both require annual Nov 1 certification, 90-day inspections/reporting, regular testing, and documented cleaning/maintenance. Stay current with deadlines and recordkeeping to avoid violations and protect public health (Inspectors conduct annual audits and will ask to see documentation).
New York State Compliance Deadlines and Tasks
Annual Certification by November 1: New York State regulations also require that each cooling tower be certified as compliant by Nov 1 each year. Unlike NYC, the state does not require you to upload a certificate document instead, you must enter the date of the most recent annual certification into the NYS online registry and keep the actual certification letter on file for at least 3 years.
Quarterly Reporting (Every 90 Days): NYS’s electronic system requires a routine update at intervals not exceeding 90 days.
The date of the latest compliance inspection (which must be within the last 90 days).
The date and result of the latest bacteriological test (within last 30 days; however, state only requires reporting it in the 90-day update).
The date and result of the latest Legionella culture test (within last 90 days).
Any corrective actions taken for deficiencies or positive Legionella results.
Each day beyond the 90-day window is technically a violation, so mark your calendar and stay on top of these reports.
Seasonal Start-up/Shutdown Notifications: If your cooling tower is operated seasonally (e.g. only in summer), NYS requires you to disinfect and safely shut it down at end of season, then clean and disinfect before start-up next season. You must record the “seasonal start-up date” and “shutdown date” in the state registry each year. This should be done at the time of those events (and is part of your 90-day reporting cycle).
Maintenance Program and Plan: Similar to NYC, the state requires every cooling tower owner to develop and implement a maintenance program and plan that meets the NYSDOH regulations. While the plan itself isn’t submitted to the state for approval, you must keep it on-site and produce it if inspectors ask. Also, any significant modifications or new systems should prompt an update to the plan.
Legionella Results and Notifications: Under state rules, if a Legionella culture sample exceeds certain thresholds (≥1000 CFU/mL for cooling towers), you not only have to take remedial action immediately, but also notify your Local Health Department within 24 hours. Be aware that certain clusters of Legionnaires’ disease cases can also prompt the health department to demand additional testing or immediate disinfection of your tower.
Register before operation, update the registry every 90 days (with inspection/test data), annual certify by Nov 1, and handle seasonal notifications as applicable. Always follow up immediately on any Legionella issues. County or state health inspectors may inspect your tower records or even take their own water samples to verify compliance.
Penalties for Non-Compliance in NYC and NYS
Failure to comply with cooling tower laws can result in significant penalties – both financial and legal. It’s far cheaper to stay compliant than to pay fines or risk legal action. Here’s what’s at stake:
NYC Penalties for Non-Compliance
In NYC, enforcement is carried out by both the Department of Health (which checks maintenance compliance) and the Department of Buildings (which oversees registration and certain certifications). If you violate the cooling tower requirements, you can receive OATH/Health Department summonses with fines attached. Key points include:
Registration & Certification: Failure to register or certify annually by Nov 1 can result in fines up to $2,000 for a first violation and $5,000 for repeat offenses. Serious lapses tied to outbreaks may reach $10,000 per violation, and criminal charges are possible.
Maintenance & Testing: Not having a maintenance plan ($1,000), missing quarterly inspections ($500), or failing to test/report Legionella ($1,000–$2,000) all carry fines. Multiple violations add up quickly, and towers can be shut down if they pose a health risk.
Enforcement Process: Typically, non-compliance discovered during an inspection will result in a Commissioner’s Order or notice of violation. You may be required to correct the issue by a deadline and attend a hearing. Many violations allow you to admit and pay a fine, but serious ones require a hearing at OATH (NYC’s administrative tribunal). Unresolved fines can become liens on the property.
Example: In 2022, Verizon was fined $118,000 for 225 violations across (missed tests, cleanings, etc.) 45 towers.
NYS Penalties for Non-Compliance
New York State’s regulations are enforced by the NYSDOH and, more directly, by local health departments (for areas outside NYC, this means your county health department). Penalties at the state level include:
Civil Fines: Up to $2,000 per day, per violation, with each day considered a separate offense.
Criminal Penalties: Willful negligence can lead to misdemeanor charges. Neglected towers are treated as a public nuisance, allowing authorities to order or perform cleanings at the owner’s expense.
Local Enforcement Examples: County health departments issue violations for missed reporting, late certifications, or failure to register. The penalties might not always be published in a schedule like NYC’s, but they will cite state law. The Verizon case mentioned earlier spanned statewide; part of those 225 violations were for state reporting failures, reinforcing that the state is watching even large corporate owners.
Non-compliance is expensive and risky. Authorities take cooling tower laws seriously to prevent outbreaks and protect public health.
NYC vs NYS: Differences and Overlap in Requirements
You might be wondering how NYC’s rules and NYS’s rules intersect, especially if you own a building in New York City. Here’s a clarification:
Double Registration for NYC Towers: If your building is in NYC, your cooling tower must be registered in both the NYC and NYS systems. The two databases are separate, and it’s the owner’s job to complete both. This is perhaps the biggest “overlap” – it’s an extra step for NYC owners, whereas owners outside NYC only register with NYS.
Similar Maintenance Requirements: Inspections, cleanings, testing, and recordkeeping are nearly identical. Both require 90-day inspections, annual Nov 1 certifications, Legionella remediation, and 3-year record retention. If you comply fully with NYC’s regimen, you are likely in compliance with NYS’s, and vice versa. One difference is NYC towers must be tested weekly whereas NYS towers require monthly testing.
Reporting Differences: NYC requires the Legionella sample date to be reported within 5 days of sample collection, whereas NYS says “report at intervals not to exceed 90 days” (which effectively means by the end of the quarter).
Enforcement Agencies: NYC enforcement is split between DOHMH (water treatment) and DOB (building compliance). Outside NYC, county health departments or NYSDOH enforce all rules.
Scope of Public Data: NYS maintains a public registry online of all cooling towers (minus NYC) so the public can see locations of registered towers. NYC also publishes some data via NYC Open Data, but owners only need to register and report. Just be aware that some of your compliance info (like tower location, inspection dates) may end up in these public datasets.
Additional City Requirements: NYC has a few extra administrative touches, for example, requiring that the Cooling Tower Registration certificate/number be posted at the tower, and explicitly requiring notification to DOB when a tower is decommissioned. Following NYC’s rules will inherently mean you’ve covered state requirements; just remember to double-report things (one to city, one to state).
NYC rules mirror NYS rules with added oversight. Building owners in NYC must navigate comply with both systems. Owners outside NYC can focus on the state requirements.
Stay Proactive and Informed
For building owners, facility managers, and consultants, the key to managing cooling tower compliance is to be proactive and stay organized.
Register promptly: Before a new cooling tower is turned on, and update registrations if ownership changes. NYC owners must register with both DOHMH and NYSDOH systems.
Mark your calendar for recurring tasks: Annual certification every year by Nov 1 (both NYC and NYS), and quarterly inspections/updates at least every 90 days. Don’t forget monthly water testing and biannual cleanings, build these into your maintenance schedule.
Maintain a robust maintenance plan: Keep logs of everything (inspections, cleanings, chemicals added, repairs). These records are your evidence of compliance if an inspector comes calling.
Respond quickly to problems: Act fast on issues: Disinfect immediately for high bacteria or Legionella, and notify health officials within 24 hours. Quick action can literally save lives and will also mitigate your liability.
Educate and assign responsibility: Designate someone onsite for daily checks and use a qualified person for quarterly inspections. Use software or calendars to stay on schedule. Ensure they know the reporting requirements. Many violations (like Verizon’s case) occurred simply due to poor tracking of deadlines.
Rely on official resources: NYC DOHMH and NYSDOH both publish guidelines and FAQs. When in doubt, consult the NYC Cooling Towers FAQ/Help (contact ctcompliance@health.nyc.gov) or the NYS Cooling Tower Guide for clarifications. These agencies often host information sessions and provide checklists, take advantage of those.
By following the registration processes and meeting ongoing deadlines outlined above, you will keep your cooling towers in compliance with both city and state laws. More importantly, you’ll be doing your part to prevent Legionnaires’ disease and protect public health. Compliance might seem complex at first, but with a systematic approach it becomes part of your building’s routine operations. The cost of proper maintenance is far less than the cost of an outbreak or hefty fines. Stay vigilant, stay informed, and your cooling tower will stay safe and legal.
At NuChem Corp, we offer full service support. From tower registration and annual certification to water testing, cleaning, and reporting, our team ensures your towers meet all NYC and NYS requirements. NuChem Corp is your partner in cooling tower compliance. Get in touch with us to safeguard your facility, stay ahead of regulations, and protect public health with confidence.
Content on the NuChem Corp Blog is for informational purposes only and does not replace professional advice. External sites linked are provided for convenience; NuChem Corp is not responsible for their accuracy or content.
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