30-min call with RobBook a proof-of-concept call
Job 02 · Compliance file

// 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.

Book a proof-of-concept call30 minutes with Rob
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.

Site recordsAs they sit today
Registry entry
Maintenance program
Lab reports
Feed and disinfection logs
RecordDateHeld by
Made-up records, for illustration
Gathered against
the site's rule
Compliance fileDraft for a qualified person
Rule or accreditor
Registration fields
Program sections found
Gaps listed
RequirementFound inStatus
Made-up file, for illustration

// 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

Copies only
Named rule for each site
01

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.

02

Lab reports as issued

Culture reports with their chains of custody, exactly as the laboratory sent them, for the period the sample covers.

03

Feed and disinfection records

Chemical and biocide logs, cleaning and disinfection records, startup and shutdown dates, and any declaration already filed.

04

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.

Compliance file test termsOwner decides
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

Site by site
Line by line
On the same 20 to 30 sitesThe file your team keptThe AI draft
Rule or accreditor named for each requirementFilled from your sitesFilled from your sites
Registration and certification fields matched to their recordFilled from your sitesFilled from your sites
Maintenance program sections found, with version and dateFilled from your sitesFilled from your sites
Culture results copied exactly as the lab reported themFilled from your sitesFilled from your sites
Disinfection and feed records tied to their datesFilled from your sitesFilled from your sites
People and credentials listed as the file shows themFilled from your sitesFilled from your sites
Missing or expired items, all listedFilled from your sitesFilled from your sites
Nothing judged, certified or concluded by the draftFilled from your sitesFilled from your sites
Nothing scored yet. Cells wait for your own site files to go through.Your qualified person marks each row.

// 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

Possibilities
One at a time
  1. 01

    Site compliance calendars

    Inspection, sampling, certification and filing dates laid out for each site, for your coordinator to schedule.

    Next
  2. 02

    Service report summaries

    Technicians' field sheets drafted into the customer's monthly report, with readings out of range or missing listed.

    Then
  3. 03

    Hospital water management binders

    Diagrams, monitoring protocols and corrective action logs collected by facility, for whoever prepares the annual review.

    After that

// 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?
No. It copies the result, the laboratory and the dates as reported, and leaves any level, action or meaning for the qualified person and the site's team.
Will it sign in to the New York State registry or the city's cooling tower portal?
No. It never signs in to a state or city system and files nothing. Exports and screenshots your staff provide are enough for the test, and registry entries stay with the owner's team or yours.
Can it certify a tower or a maintenance program?
No. Certification belongs to a qualified person under these rules, and the draft only shows what the records do and don't contain. It gives no legal, medical or engineering advice.
Our sites aren't in New York. Is this still useful?
It depends on what your customer has to keep. Send the rule or accreditor checklist your qualified person works from, and each draft will follow it and name it.
Can it handle a hospital's water management program file?
As a draft, yes. It can gather the diagram, protocols, results and corrective actions a hospital keeps and list what is absent. Whether those satisfy an accreditor is for the hospital and its qualified person to decide.
What if the customer keeps the binder and we hold only part of it?
Send what you hold. The draft treats records it never received as not found rather than as failures, and your reviewer sees the difference.
Rob Eason

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.

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