We've Learned Nothing

Alex: I where this is never going to improve. Never going to improve. So, how are we going to tell people that are living in these zip codes that may be fearful, that may have hypersensitivity from a risk communication problem what to do? The solution? Well, if you start to feel sick, go to the doctor. What are we doing? What are we doing? We've learned nothing. It's like the if it's like from COVID. During COVID, you sneeze into your shoulder, you sneeze into your arm. Now in twenty twenty six, sneeze in your hand, go touch everything. We learn nothing. We have a horrible, horrible memory from how to actually protect ourselves. And the job that we are doing from a public health standpoint and Protecting yourself is not great. I'm not gonna lie. there needs to be a serious discussion of this stuff from all all levels. Risk communication, exposure, science, root cause analysis. It's not happening. But it needs to. Before more rules are implemented, before more outbreaks occur, we gotta do something. Hello and welcome to today's episode of the Exposure Scientist Podcast. One thing you've probably noticed in the news is the I'll say the increase in the number of reported legionnaires disease outbreaks. For some context, there is a few going on currently at the moment. I got a news story this morning about one actually occurring in Chicago and in Evanston, Illinois, which is a north side of Chicago, at a local hotel there. You there's a very small number of individuals associated with that, but you're probably also familiar with the ones that occurred in New York City, in the South Bronx and in the Upper East Side. those outbreaks. The Upper East Side was earlier this summer, and the Bronx is currently ongoing. and I wanted to talk about at least some from some of the New York City stuff. getting the information, seeing the information, it's it's very I'll I'll say unique. And I kind of wanted to report on some of the stuff, especially because follow up somewhat follow up to a podcast I had earlier about the new New York rules. Are these rules beneficial or are they detrimental? Well, that's an interesting thought. the number of cases I think are up to, and here's another issue is is up to let's see, 24. maybe it's 20. Around there from cases. Part of the problem is getting information out of the city of New York. If you go to their website, they actually have I'll say news releases that are there. and you can go look up the news releases. And the last one from this this most recent one was let's see, I had it here just a second ago. September thirteenth, last press release. they have had more recent, I'll I'll say d town halls where people can talk. They even put one on YouTube yesterday, and the on the 22nd. And what's interesting about the one on the 22nd is not a lot of more information was released, except this is part of the problem, the information is so fragmented. Where are you supposed to go and get the data from? Figure out what's actually kind of going on. So this YouTube story, and along with the news article that I participated in. a news story I participated in on on Sunday is that you know they originally started out with two zip codes. And then they I was told that they expanded the four zip codes. And this this YouTube video does indicate that they expanded the four zip codes. But that information is super hard to find. It it's like information kind of slowly trickles out to hey, this is kind of just what's going on. Just kind of letting you know kind of I'll say apathetic almost. and so for the YouTube video, and this is where I got the twenty two, it says twenty-two confirmed cases in four zip codes there. and they said that they sample and here's here's an another this is a lot of weird stuff here. but they indicated from the original cooling towers that they looked at, they got 10 that were PCR positive. Okay. PCR positive for what? If you're familiar with the New York rules, there's lots of things that are you have to do for cooling towers in the city of New York. A recent thing that they started was something called a summertime hyperhalogenation. That they are requiring, it says one time per year dosing of higher than normal levels of chlorine or bromine based biocide. Conducted between July 1st and August 31st to ensure the maintenance of minimum five parts per million, I'm reading from it, free halogen residual in the cooling tower for at least six hours. Where do they get this information from? How do they justify this? Well, it's I I I actually found it in Cooling Tower Institute's appendices for their reducing legionella. It says this is in their periodic in the appendix. Let's see, it's appendix E. It says periodic hyper use of halogens oxidizing biasides. And it discusses 5 ppm for six hours, but it's also kind of predicated on other things. So there's lots of things going on here. at least from this cooling tower, summertime hyperchlorination. There's a sheet that you have to fill out. A form you have to submit the city of New York. It talks about it. I see, I'm looking at the sheet right now. It talks about summertime hyperchlorination. Did they do the minimum fight? five parts per million. check the box to describe what kind of protocol did you use? A cooling tower institute or something else. So a bio side did you use, registration numbers, et cetera, et cetera. The problem with and I'll say this, let me take a step back. Also earlier in May, they instituted that you have to test cooling towers every thirty one days for Legionella. We they are instituting more and more rules on what has to be done. I don't know if there's a discussion of the rationale of these rules, why they're being followed, what what what what scientific data they have to establish that this is what they should be doing. Because example, within the Cooling Tower Institute, they say periodic online hyperhalogenation may be necessary for systems, and they give examples that have leaks, they have high heavy biofouling. That use reclaimed wastewater's makeup that have stagnant for extended periods of time, or where the total aerobio aerobiotic bacteria count is regularly exceeding one hundred thousand CFU per mil. So I don't see anywhere in the New York rules that say, hey. We have to establish what the current culture level in the cooling tower is before we do our hyperhalogenation and then afterwards three, five, seven days, or whatever later to show that it was effective. It's almost like they say, do this, and we'll catch you on the next next 31 days. I don't know if that's an effect of policy. The problem is that they are just throwing policies. And rules and chasing a problem instead of potentially getting down to the root cause of the problem. Interestingly, and then we find this article because this is a a press release. The mayor up there said that they are going to s have sweeping, this is September 1st, sweeping new measures to strengthen New York City's response to Legionnaires' disease. So the solution to rules that are already not controlling the problem is to create more rules. Instead of taking a step back and saying, What's going on? Why are we still seeing more problems? What are the problems actually? Are they actually from the cooling towers? Are they actually other sources, other water sources? Fountains or within a a building's water system, it's immediately going towards the cooling tower. And I see this in other places where, and you've probably f familiar with this. If there is a spa, say down in the south or where where there are a lot of hotels, a tourist trap area, if there is a spa, the health department will immediately run to the spa because it is a path of least resistance when they get a report of lesionnaires disease. They say, They put blinders on and say, forget everything else. It's the spa. Even if they sample the spa and don't get anything, they will say, Well, it had to be the spa, it's not there now. Ignoring piping, ignoring water heaters, ignoring decorative fountains, ignoring irrigation systems. They just immediately go to the path of least resistance. And I honestly think that this is kind of what's going on in New York, that they're going to the cooling towers, the path of least resistance. They're saying, listen, it's got to be these cooling towers. We have all these rules. The rules aren't working. We need more rules. Well, maybe the rules aren't working because we're not doing the right thing. For example, a hype a a remediation, quote unquote remediation. And let me get to it. I apologize because it's all over the place. A remediation is necessary or disinfection within 24 hours when they when a the corrective action level for this is over 1000 CFU per mil. I have to perform a full remediation of the tower. Now If it's between one hundred and one thousand CFUs, you have to initiate disinfection by increasing BIOSI concentration using a different BIOSI within twenty four hours, review the treatment program and visual inspection, and maybe retest the water in three to seven days. If it's 10 to 100, it's initiate disinfection by increasing biocide concentration using different biocide. It doesn't say what concentration. It doesn't say listen. And I believe this is for total Legionella. Not only Legionelle Nemofla Legionella and Nemofla CR group. One, it's just total Legionella. If you look at the AIHA guidelines, they're a little more stringent. You know, they let let me get to I had them open earlier. It's always fun doing this on the fly. But I think it's important. So CDC, and just for context, CDC says, hey, if if you're if you're over a hundred, you need to do something. You know, let's let's take let's take some let's take some some action. See AIJ says if it's ten or sorry, a hundred to a thousand, you need emergency disinfection. New York says if it's one hundred to a thousand says, Nah, just initiate some disinfection using something different. Okay. I I think there's a big disconnect on the concentration that we're looking at here. And I I think there rules are such that and and I'm I'm I'm I'm trying to be very nice here. There are some, it's it's almost if you think of this like a bell curve, there are some businesses that are gonna do a lot of work and be very proactive. There's gonna be a lot in the middle. And there are going to be some on the end that say we're going to do the bare minimum. And I honestly think, and I haven't seen the data on this, but I honestly think that's that bell curve is more skewed to be on the lower end where most of the businesses or a lot of the businesses doing this are going to be like, we're going to do the bare minimum. And that makes it hard. Because if they're gonna say, you know what, if they're not gonna say, you know, we're gonna bo go above and beyond New York and say our our number is a hundred. If it's a hundred, we're gonna do emergency disinfection. But if New York City's saying you gotta do a a thousand is is for the is for the emergency disinfection, they're gonna be like, Yeah, you know, well we're we're just gonna do a thousand. That makes it difficult. It really does. And I wish that we could get past that doing the bare minimum thing. A hard thing to do. but there's lots of little things that add up. So you've got that. You've got the 1000 CFU per mil, you've got the emergency, sorry, you have the summertime disinfectant. And what I want to bring up here, and I don't know the processes. Is this is the is the emergency disinfection now written in their water management plan? Do some water management plans now we know that they're not all made the same. There's bare minimums, again, that you have to fit in there, but Do these plans have something in there? And we know the new we know that Legionella doesn't come from just nowhere, seeded by water utilities. The water in New York probably has a good concentration, a low-level concentration of Legionella bacteria in it. I think we've seen some data on it. Are some of these cooling towers during their summertime disinfectant? Maybe they did it this year, just as a hey, while we're doing this, why don't we take the the the the step of emptying the tower and refilling it? Maybe they are. Maybe they're just filling it with water from the city. And instead of treating it as like a new fill where they want to super hyperchlorinate it, maybe they're just refilling it and saying, well, we're just gonna do five ppm for minimum six hours. We're gonna do the minimum and we're just gonna do it as the periodic. We're not gonna treat it like as a new water fill. Well, that's interesting. I don't know if any of them are doing that or not, but I don't think anyone's asking those questions. What is going on that is creating additional legionella and growth in cooling towers? And again, I come back to this. What are they going to do up there? in New York City, and this press release from the mayor says they already have some of the most rigorous cooling tower law and regulations in the country. I will agree. But rigorous standards only matter if we are constantly working to make them stronger. Probably disagree there. It's not about making them stronger, it's making them more scientifically rigid. Just because a role is stronger doesn't mean it's scientifically verifiably stronger. And I think that's the bigger question that a lot of people are missing. What's the science that is showing that what they're bringing in these rules are effective? They're also looking for, interestingly, here, unregistered cooling towers. Now, again, they've had to register cooling towers, and I'll get into that second for a long time. Enhance public visibility and transparency of cooling tower regulations by adding mapping features, exploring faster culture test methods. That's an interesting one. Accelerating enforcement and convening a scientific advisory panel. this is great. A scientific advisory panel. Then you read the rest of the sentence to evaluate emerging cooling tower technology and alternate cooling systems. So it doesn't seem like they want to apply scientific rigor to legionella prevention. They want to look at new cooling tower technologies and how those can be implemented. I don't know. You know, I I I want them. I I I want this to be a healthy scenario. I want this to be a good scenario. And you know, listen, I love it. They said online address-based cooling tower lookup. And they do. You can go download a database of cooling towers in New York. And I I have that database. And you can see. And now it's interesting. Again, I said that they have to test every thirty-one days now. And that's great. When you go look at the information, it says sampling dates. that's great. There's no data. There's no sampling results in there. There's no way that someone could look at this and do any kind of outside of the of I'll I'll say walled gardens and do any independent evaluation of data from cooling towers, even if it's randomized that I've seen. Happy that somebody point that to me, but allow us to see the cooling tower data. See results, culture results, see disinfectant concentrations, see when they've had to do a hyperchlorination. You know, I can almost guess. Well, I I say this, I can almost guess when they've had to do some kind of hyperchlorination or some kind of treatment when there's dates that are not 31 days apart. It may be like two weeks apart. It's a guess. I don't know. They say they want open transparency and everything else, but. If the data are not available for the public to evaluate, then then the how am I supposed to evaluate and then and figure out what's going on or mo myself or anyone doing Legionella investigations, figure out what's going on up there. It's we're not. We can't. Listen, i if it's hidden somewhere, point it point to me where it is, so I can go look at it. I'd love to look at this. Honey again. I I go back to this This scientific advisory panel and it talks about Legional bacteria growth, blah blah blah blah blah, and then you know, and explore alternatives to cooling tower technologies that could reduce New York City's reliance on cooling towers. Well, cooling towers are pretty, pretty damn effective. They they dissipate a lot of heat from operations. I don't know how sure localized technologies are going to be at that. Unless we're getting down to the root cause. Now, all right. So going back to the cooling towers that are up there, and I'll I'll come over here. They say, and I'll I'm gonna share my screen here in a minute. For those who are on the video, I highly suggest you go check out the video. and look for it in the transcript of where we're talking about cooling tower locations. And let me get this correct. I mentioned the four zip codes up there. It was originally two. They expanded it to four. Within those four zip codes, I want and this is important context also, and I'll bring up something that I've seen before. well, I'll bring it up. So they said that we sampled 24 cooling towers in the area. Now, I think this was only when they had the two zip codes. They did. PCR tests on them. and ten popped positive on PCR. I don't know what PCR they're using. They're not very clear on PCR. They just say PCR tests. And those that were PCR positive had to start, had to had to be drained, clean, and disinfected, remediation pretty much. It had to be completed by September 15th. Whatever that's for. I don't know if that's PCR that was done in-house. This is in New York, or the people there sent it out to external laboratories, third-party laboratories. I don't know. Again, information flow is not that great. Within the cooling towers or the number of cooling towers that are up there. Let me get to that table. Just for information within the four zip codes that and and again I I some addresses here on this on this chart are listed twice because they have more than one cooling tower. They tested 24 cooling towers. Within the zip codes, including the two updated ones, there are 56 cooling towers. Are they? Testing the additional ones? Are they under investigation? Are they keeping their close eye on them? No, I don't know. I have no idea what they're doing. They don't say what they're doing. How is this helpful to anybody? I see some things that they're doing and again I don't know and I I don't I don't wanna speculate here. I'm gonna speculate a little bit. Some of the cooling towers here are owned by the city in New York. are those cooling towers were those tested for PCR? Were all of them or they only ones that were owned by third parties? I don't know. Twenty four cooling towers. Let me let me do this on the fly because doing things on the fly is fun while I'm on a podcast. Cause why not? Cut out the two other zip codes. That were listed. See if that's close to twenty four. Hold on. Don't go anywhere, folks. This is riveting stuff, I know. I'm looking at the original cooling tower numbers. Four five six. Now I'm looking at the zip codes. If you look at the zip codes from the original two zip codes that were listed. By the city of New York, there were thirty eight cooling towers, but they only did PCR and twenty four of them. Well, that's a discrepancy. How did they pick those twenty-four? I don't know. Again, it's you know, they talk about information flow, they talk about hey, this is good information, or we're trying to figure out what the source is. One of the recommendations I had in the news story that I participated in is we need to do a root cause analysis. We need to stop making regulations and take this a step back and go, why aren't the regulations working? What could we be doing to help mitigate the Appearance of Legionella in these cooling towers. Are the cooling towers the even the sources of these exposures? Where are the people? You know, again, there are a number. I said there as of yesterday, unfortunately, there are 22 deaths. I think there are John. I'm sorry, I let me take that back. I don't want to say 22 deaths. If I did, I want to I want to verify because I don't want to go, I I don't want to say anything that is untrue. I'm sorry, 22 confirmed cases. I don't think that there have been any two peop no, twenty two confirmed days, two people, two fatalities. Where do those people live? Did they do any tracing? Did or what what where's the center? Are they expanding out half a mile? You know, from an epidemiological investigation the unit typically they start out with a center point and say we're gonna expand half a mile in either direction or a mile in either direction. What's the distance? What are they doing? Who how are they determining whether or not these may be associated with a f actual facility? You know, wha what what what are they doing to say, hey, you know, we're we're doing a root cause investigation to say whether or not our the implementation of our rules contributed to this? I don't know. Have they done that? is there a way to do that? Again, we don't have the cooling tower data. I don't have the culture data. I don't know the what cultures they're doing, what methods are they doing is all give different kind of laboratories? Is this all Legionelli bacteria? Is it LP1? Is it any other and is it LP in general? Are they are they different alternative culture technologies? I don't know. It it's not clear. And the fact that they're sitting there talking about being transparent is I don't see any transparency. I see more information and it's like I hate the if you've seen that I think it's a state farm commercial where the where the guy has a a a fishing pole and he's dangling a dollar in front of somebody, you can save a dollar. It's like you're you're stringing us along, you're giving us some of the information, but you're not giving us all the information, so you know, we we can't figure out exactly what's going on here. I I all know what we're doing. this is this is like a dog chasing his own tail here. Until we figure out what is and is not working, what people actually are and are not doing, we're we're this is this is gonna be a continuing problem. You're gonna throw more regulations after it. Whenever you make one change, there's always downstream impacts. What are those downstream impacts? So if we have so many regulations, what are the downstream impacts? What if we and hypothetically here, what if we come up with an amazing new cooling technology that has some other kind of waterborne path engine problem or some kind of other, you know, problem exposure problem? I don't know, is that gonna be thought about or is that gonna be a won't worry about that down the road kind of scenario? Cause that's what we've done for forty, fifty years. One interesting thing here. Now I say the information for those who us who are in the profession, but what about people in the public? They hear all this stuff. People want to know what to do. How do you protect yourself? How do you you know how do you figure out, okay, let's just say you're a New Yorker that's let me you have all the risk factors. You're over fifty, you're a male, you're a former smoker, and you have some kind of immunom compromised system. Do you not leave your house? Do you stay inside until the outbreak's over? What if the outbreak is inside is the source of the outbreak? That's a whole nother discussion, that last point. But there's nothing in here. Let me give tell you some of the information they said this this YouTube video for for protecting yourself. you're just a New Yorker. How do you want to protect yourself knowing this outbreak is occurring? They say, we do this is from the YouTube video. We do not recommend masks. The risk from rooftop cooling tower is not indoor air. The roof is from rooftop cooling towers, not indoor air or person to person. People who live and work to the effective hip coach, zip coach said, watch for symptoms. And say to their doctor promptly if they've developed them and get to a doctor quickly. So there's no way to prevent it. According to them, you just if you have the symptoms, you show up. And again, their questions are where is another one? Do I need to wear a mask? No, this is a drinking water, this is not a drinking water indoor air problem, which is an interesting thought as well, from the usual sense. Home masks are not recommended because The disease has not spread from person to person. In the year of our Lord 2026, our risk communication still stinks from a profession standpoint, from a public health profession standpoint. I where this is never going to improve. Never going to improve. So, how are we going to tell people that are living in these zip codes that may be fearful, that may have hypersensitivity from a risk communication problem what to do? The solution? Well, if you start to feel sick, go to the doctor. What are we doing? What are we doing? We've learned nothing. It's like the if it's like from COVID. During COVID, you sneeze into your shoulder, you sneeze into your arm. Now in twenty twenty six, sneeze in your hand, go touch everything. We learn nothing. We have a horrible, horrible memory from how to actually protect ourselves. And the job that we are doing from a public health standpoint and Protecting yourself is not great. I'm not gonna lie. there needs to be a serious discussion of this stuff from all all levels. Risk communication, exposure, science, root cause analysis. It's not happening. But it needs to. Before more rules are implemented, before more outbreaks occur, we gotta do something. From industrial hygienists, we talk about this stuff often. We have reference material, what you should be doing. We have courses we're working in developing on on how to be competent professionals, competent outbreak responders, competent technicians in this area that do understand why this is important. But if we're just gonna throw more regulations until the regulations choke everything so cooling towers don't operate, then I hope then you know what? Then then critical infrastructure may not. be feasible in New York. I don't know. You may not be able to cool a building using a cooling tower and everyone has window AC units like it's the seventies again. I don't know. Actually not many people had them back then, but that's a whole nother point. Hope you got something out of today's episode. If you want to have a conversation, reach out. I I'd love to because this is a problem that is going to continue. it's chasing regulations with other regulations until we're blinded by regulations and nothing nothing can happen from a scientific standpoint. Again. What you got something? My name is Alex Leboe. I'm happy to chat. Reach out. if you got questions, appreciate you joining today and look forward to speaking with you in the next one. Thanks.