// Commercial water treatment · Cooling tower files
Cooling tower compliance files, assembled site by site for the qualified person to review.
Where a city, state or accreditor requires a cooling tower file, the pieces live in different hands: a registry, a binder, lab reports, your technicians' feed logs. A free AI proof of concept drafts that file for 20 to 30 sites you already support and lists what is missing. Your reviewer, the qualified person who knows these files best, checks each draft against the file that was kept.
- Site files
- 20 to 30
- Culture results judged
- None
- Systems certified
- None
// The one job
Scattered records gathered into one file a reviewer can read
New York City's Health Department inspects unannounced, and its page says records have to be produced while the inspector is there and aren't accepted afterward. Under the city's Chapter 8, failing to produce a required record on request counts as prima facie evidence that it doesn't exist. So someone at your company gathers registration details, the maintenance program, lab reports, disinfection paperwork and inspection checklists, and sets them against the rule that site answers to.
For the test, AI reads copies of those records for sites you already support and drafts each site's compliance file: registration and certification fields, the maintenance program and its sections, culture results exactly as the lab reported them, disinfection records, and a list of everything missing. It never decides whether a site complies. A qualified person reviews each draft beside the file that was actually kept.
the site's rule
// What makes it hard
One tower can answer to three rulebooks
New York City and New York State ask differently. Chapter 8 wants a maintenance program and plan, prepared by a qualified person, naming the team down to every consultant, service company and qualified person who cleans, disinfects, delivers chemicals or services the system. It records each tower's Department of Buildings number and tonnage, carries a flow diagram, a risk management assessment and a valve schedule for each operating configuration, and must reflect the most stringent of the city chapter, State Sanitary Code Part 4, the Administrative Code and the manufacturer's instructions. The city points to the latest edition of ANSI/ASHRAE 188, Legionellosis: Risk Management for Building Water Systems; the state's page names the 2018 edition. The state registry under 10 NYCRR 4-1.3 asks for system volume counting all piping, basins and sump, whether disinfection is manual, timed or continuous, who maintains the tower and the year it entered service, updated every 90 days in operation, with a certification by November 1. Each line of the draft names the rule it answers.
Who may sign depends on the line. The city accepts a New York licensed and registered professional engineer, a certified industrial hygienist, a certified water technologist with plan and inspection experience, or an environmental consultant with at least two years in water management planning and operation. The state's inspection section also names a water treatment professional with training and experience. Biocide work needs another credential: the Department of Environmental Conservation names Category 7G, Cooling Towers, Pulp and Paper Process, and a business offering that service must register and employ a 7G applicator. The draft lists each name and credential as the file shows them and says nothing about whether one is valid.
Culture results carry their own paper. In the city, Legionella culture runs at least monthly, with no more than 31 days between samples, at a laboratory accredited through New York's Environmental Laboratory Approval Program. Its final report has to include a copy of the signed chain of custody and the laboratory's ELAP certification number, and since May 8, 2026 the qualified person enters each sample date in the portal within five days. The state's Part 4 sets its own schedule: bacteriological culture at intervals up to 30 days, Legionella within 14 days of seasonal start-up and at intervals up to 90 days. Chapter 8's Table 8-1 sorts results into levels. The draft copies result, laboratory, sample date and report number as written and leaves the level for the qualified person.
Disinfection lines up against a calendar. Summertime hyperhalogenation falls between July 1 and August 31, with a declaration due within 30 days and a Legionella sample 3 to 31 days after. Form CT-SH-DF01 asks for the feed date, pump start and end times, biocide name and supplier, its NYSDEC registration number, and pH and chlorine residual at two sampling points. Every chemical or biocide addition needs its purpose, manufacturer, brand name, safety data sheet, date and time, and amount. A seasonal tower counts as in operation whenever water is present, cooling or not, so a quiet month can still owe paperwork. The draft dates each record and flags the months it can't account for.
Hospitals answer to a different reader, and other places have their own forms. The Joint Commission's R3 Report 32, updated November 18, 2025, holds hospitals and critical access hospitals to PE.04.01.05 and nursing care centers to EC.02.05.02: a basic diagram of the water system, a water risk management plan, monitoring protocols with acceptable ranges, documented results and corrective actions, and an annual review. It notes that neither it nor CMS requires culturing unless law or regulation does. Québec's Régie du bâtiment wants facility information within 30 days of first commissioning and every March 1, from the installation's owner, who may not be the building's. Your qualified person decides what applies, and nothing on this page is legal, medical or engineering advice.
// What you send
Site files your team or your customer already kept
20 to 30 finished site files
Registration and certification records, the maintenance program and inspection checklists as they stood. Include a site that answers to more than one rule, and one with a gap somebody later closed.
Lab reports as issued
Culture reports with their chains of custody, exactly as the laboratory sent them, for the period the sample covers.
Feed and disinfection records
Chemical and biocide logs, cleaning and disinfection records, startup and shutdown dates, and any declaration already filed.
NDA signed, then copies or stand-ins
Files name buildings, owners and credentials, so the NDA is signed before anything moves. We never sign in to a state registry, a city portal or a customer's building system. Files that can't leave a customer's site are rebuilt as look-alikes with your reviewer.
// Before it starts
Settled before the first record moves
The owner writes down who reviews, which rule each site is read against, and what a pass means.
- Your reviewer
- A qualified person named by the owner, yours or the customer's
- Success criteria
- In writing, including how a missed gap counts
- Rule for each site
- Set by your reviewer before any draft is read
- Culture results
- Copied as reported and never rated
- Certification
- None; the draft certifies nothing
- Price
- A range for the live job, settled first
- NDA
- Signed before the first record
// How it's judged
Each draft beside the file that was kept
| On the same 20 to 30 sites | The file your team kept | The AI draft |
|---|---|---|
| Rule or accreditor named for each requirement | Filled from your sites | Filled from your sites |
| Registration and certification fields matched to their record | Filled from your sites | Filled from your sites |
| Maintenance program sections found, with version and date | Filled from your sites | Filled from your sites |
| Culture results copied exactly as the lab reported them | Filled from your sites | Filled from your sites |
| Disinfection and feed records tied to their dates | Filled from your sites | Filled from your sites |
| People and credentials listed as the file shows them | Filled from your sites | Filled from your sites |
| Missing or expired items, all listed | Filled from your sites | Filled from your sites |
| Nothing judged, certified or concluded by the draft | Filled from your sites | Filled from your sites |
// After a yes
About 30 days on newly gathered files
With your reviewer's yes, the same job runs for about 30 days on sites coming up for a filing or an inspection date, at a fixed price you see before signing.
A qualified person reviews every file before anyone relies on it, and every registry update, declaration and certification is still made by your people or the customer's, in the usual place.
Anything further is its own decision, with its own price, and monthly support begins once a job is live.
// Next, if you choose
What could follow the compliance file
- 01Next
Site compliance calendars
Inspection, sampling, certification and filing dates laid out for each site, for your coordinator to schedule.
- 02Then
Service report summaries
Technicians' field sheets drafted into the customer's monthly report, with readings out of range or missing listed.
- 03After that
Hospital water management binders
Diagrams, monitoring protocols and corrective action logs collected by facility, for whoever prepares the annual review.
// One hard limit
It assembles. It never certifies.
This test stays away from controllers, state portals, live reports and live files. It never judges a culture result, sets a chemical dose or certifies a system, and it makes no entry in any registry. It reads copies and gathers what they say. A qualified person reviews every file, and nothing on this page is legal, medical or engineering advice.
Priced per job. You get a range before the proof of concept and a fixed price before you sign.
Rob gives the range on the call, once he knows how many sites keep a compliance file, how many rulebooks they answer to, and whether records are on paper or in portal exports.
// Questions
What qualified persons ask
Does it rate Legionella culture results?
Will it sign in to the New York State registry or the city's cooling tower portal?
Can it certify a tower or a maintenance program?
Our sites aren't in New York. Is this still useful?
Can it handle a hospital's water management program file?
What if the customer keeps the binder and we hold only part of it?

Rob Eason, founder
// Book a proof of concept call
Start with three sites under one rulebook.
Thirty minutes with Rob about your company and role, the sites that keep a compliance file and the rules they answer to. Hold registry records, lab reports and feed logs until the NDA is signed.
- Co-owned a 60-employee financial services firm and sold his share to his partner.
- Ran GOSO Technologies, a Boston solar company rated 5/5 across 24 Google reviews.
- 5/5 across 83 reviews in HighLevel's Certified Admin Directory.
- 4.3/5 from 6 Google reviews of Massmarket AI.
- Every directory and Google review, critical ones included, is shown word for word at massmarket.ai/reviews.
- Takes every proof-of-concept call himself.
