0 results available.

    LGOIMA Request Details: LG2409

    Date received: 27/11/2025

    Requested information: Information about Cooling Towers Subject to Testing

    Status: Complete

    Response:

    I refer to your Local Government Official Information Request dated 26 November 2025, in which you requested various information regarding cooling towers. 

     

    Unfortunately, we do not hold the information you requested, and we cannot think of any other agency that would hold it, or whose functions would be more closely connected to it. 

    To confirm this, I made enquiries with the Regulatory team and undertook a search of our document management system. These checks did not identify any records relating to the information requested. For this reason, we must advise that the information is not held by Council. 

    I am therefore refusing your request under section 17(g) of the LGOIMA because the information is not held. 

    I refer to your response under the Local Government Official Information and Meetings Act (LGOIMA) dated Friday 12 december, in which you advised that the Council does not hold any records relating to cooling towers in the Manawatū District.

    We would like to clarify that most large-scale meat processing facilities, such as AFFCO Manawatu (Feilding) and ANZCO Foods Manawatu (Bulls), as well as major dairy factories, typically operate cooling towers as part of their industrial refrigeration and heat rejection systems. These towers are essential for managing process heat loads and maintaining compliance with food safety and operational standards.

    Under AS/NZS 3666, local councils have a responsibility to maintain accurate records of cooling towers within their jurisdiction to ensure proper microbial control and Legionella risk management. This is a critical public health requirement, and accurate documentation helps prevent compliance gaps and health risks

    Thank you for your inquiry regarding cooling tower records within the Manawatū District, and for your follow-up comments regarding industrial facilities such as AFFCO Manawatu (Feilding) and ANZCO Foods Manawatu. I appreciate the opportunity to clarify Council’s responsibilities in this area.

    Cooling tower locations:

    You are correct that facilities such as AFFCO Manawatu, and other major food-processing sites, typically operate cooling towers as part of their industrial refrigeration and heat-rejection systems. However, for clarity, ANZCO Foods Manawatu (Bulls) is not located within the Manawatū District and therefore falls outside the jurisdiction of the Manawatū District Council.

     

    Council is not legally required to maintain a cooling-tower register.

    While AS/NZS 3666 establishes requirements for the maintenance, cleaning, microbial control, and record-keeping of cooling towers, these obligations apply to building owners, occupiers, or PCBUs, not territorial authorities.

    AS/NZS 3666 does not require councils to:

    • maintain a district-wide register of cooling towers
    • proactively collect cooling-tower information from industrial operators
    • hold or manage detailed microbial control documentation

    What Council is responsible for:

    Under the Building Act 2004, Manawatū District Council is responsible for administering and enforcing the Building Warrant of Fitness (BWOF) and compliance schedule system. Where a cooling tower forms part of a building’s specified systems, Council ensures that:

    • the system is included in the compliance schedule, and
    • the building owner maintains it in accordance with AS/NZS 3666.

    Refer to the current Compliance Schedule Handbook for MBIE guidance on what systems are required to be listed on the compliance schedule

    Compliance Schedule Handbook | First edition | Amendment 3 - Page 40    

    The Draft CS Handbook being prepared (dated November 2025) has the same note but with HSE Act 1992 replaced with H&S at Work Act 2015.

    However, the Health NZ Prevention of Legionellosis guidelines confirm that:

    • councils are not required to maintain a central register of cooling towers, and
    • there is no legislative requirement for councils to record this information in an accessible database.

    Cooling towers associated with industrial plants such as meat works or dairy factories are generally governed by WorkSafe under PCBU obligations, rather than by the Building Act’s specified-systems regime.

    Public health guidance vs legal requirement:

    Health NZ notes that maintaining a register can assist in outbreak investigations, but this is a voluntary good-practice recommendation, not a legal duty.

    To summarise:

    • Some facilities in the district (e.g., AFFCO Manawatu) operate cooling towers.
    • ANZCO Foods Manawatu (Bulls) is outside Manawatū District Council’s jurisdiction.
    • Owners/operators are responsible for compliance with AS/NZS 3666.
    • Council’s responsibility applies only if a cooling tower is part of a building’s specified systems.
    • Councils are not legally required to maintain a cooling-tower register.
    • Maintaining a register is recommended by Health NZ, but not mandatory.