Developing Standards For Public Pools
Have you ever felt a degree of panic in wondering whether a pool was in compliance with the requirements of the public health code? Or how about conducting repairs or a renovation only to find the job does not comply with the governing health code?
This has been the case for many pool operators in trying to comply with a myriad of issues, including the drain-entrapment requirements in the Virginia Graeme Baker Pool and Spa Safety Act.
Currently, all public swimming pool codes are developed and approved by state and/or local public-health officials or building departments. Conditions that are allowed in one county may be outlawed in an adjoining county. There are some areas in the United States where there are no codes or standards for public swimming pools at all.
As a result, there are no uniform or national code standards for the construction, renovation, or operation of a public swimming pool or spa.
The Centers for Disease Control and Prevention (CDC) has conducted several studies regarding the safety and reliability in maintaining and operating public pools. According to the CDC’s Morbidity and Mortality Weekly Report on May 21, 2010, the agency reviewed 121,020 health department public pool inspection reports from 15 state and local agencies in 2008. Of those inspections, 73,953 (61.1 percent) identified one or more code violations, with 13,532 of the inspections (12.1 percent) resulting in immediate closures of the pool(s).
Based on those studies, the CDC concluded that a comprehensive, uniform national standard for public swimming pools could help prevent disease and injuries, and promote healthy recreational experiences. Thus, the concept of the Model Aquatic Health Code (MAHC) was created.
Defining The Code
The MAHC is intended to be a user-friendly, knowledge-based, and scientifically supported uniform standard for recreational water venues that can be adopted and ratified for any facility. The code can transform various regulations used by health and building departments across the U.S. into a uniform set of state and local codes.
The MAHC has set up 12 technical subcommittees covering all facets of recreational water systems as they pertain to health and safety. Once the code has been completed, the hope is that it will be updated every two years to allow it to respond to new science and engineering, industry developments, or new standards of practice.
To make it easy to use, the code is configured using two or three keywords in the left margins. The right margins contain a grading system divided into three levels:
• Grade A--A practice supported by science/research/data
• Grade B--A widely accepted practice not supported by science/research/data
• Grade C--Neither an industry standard yet nor one supported by science/research/ data.
This grading is intended to explain to pool operators and inspectors the basis for each section. The MAHC also has an annex to support each section that provides details, studies, and data used to compile the information. Once a section has been drafted, it is posted on a CDC website for public review and comment for 60 days. All comments are considered in the final draft version of each module.
Start To Finish
Let’s consider the first section to be drafted and posted--the Operator Training Section.
Completed in the third quarter of 2010, the MAHC Module 6.1 Operator Training was presented at the World Aquatic Health Conference in Colorado Springs in October 2010 for public review and comment. The Operator Training technical subcommittee (OT) consists of 12 members representing the major operator-training programs in the U.S., as well as health department inspectors and public pool operators.
At the onset, the OT identified five goals for this module, including:
• Collect any research currently available on the efficacy of formal pool-operator training and public pool operation.
• Utilize the experience of the members to understand pool-operator training best practices.
• Identify key drivers of public pool-operator training.
• Identify and research other industries with parallel systems.
• Review existing public pool health codes and the requirements for formal operator training.
While the research was conducted, two studies concluded that public swimming pools that are operated with formally trained operators have overall better water quality than pools without them. A study in Nebraska found that both free chlorine and pH violations were twice as likely to occur in public swimming pools not requiring a certified operator.
Research also found parallels between public swimming pool operation and public restaurant operations as they pertain to public health. The OT committee then researched the public restaurant training and certification requirements.
Based upon this research, the committee concluded there is sufficient documentation that a public swimming pool is statistically safer when it is operated by--or reviewed by--a trained and certified operator. Therefore, it was a logical conclusion that it is in the best interest of both the public and the aquatic industry to require a qualified operator for every public swimming pool.
In some pools, such as those in water parks and large venues, it may be determined that a certified operator should be on-site anytime the pool is open for use. In other venues, such as apartment complexes and motels, it may be decided that a certified operator should periodically review the operation and be available on call anytime a public pool is open for use. In the latter case, the certified operator may be an independent contractor, such as a pool service.
Section 6.1.1 of the MAHC identifies the requirement for a certified operator. The annex for this section reviewed various areas of discussion, such as cognitive versus core skill-training requirements, electronic web-based training versus on-site training, and acceptable means for assessing an operator’s competency. Section 6.1.2 of the code identifies the minimum essential topics a certified-operator training course must include.
The Operator Training module in sections 6.1.3 to 6.1.13 identifies other general course requirements and certification requirements.
Other sections that have been posted for public comments are Module 4.6.2, ventilation and air quality, the Preface and Definitions section, and the Fecal/Vomit/Blood/Contamination Response section. The details and actual language of drafts of each completed module and those open for comment can be found at the CDC’s website at www.cdc.gov/healthywater/swimming/pools/mahc .
Once all modules have been posted for the first 60-day review, a complete draft will again be posted for public comment.
Dennis Berkshire is a Senior Associate of Aquatic Design Group. He can be reached via email at firstname.lastname@example.org.
How Do I Submit Public Comments?
Download and fill out the CDC’s comment form and return it via mail or email to the agency. This is the only acceptable form for public comments. It is available at www.cdc.gov/healthywater/swimming/pools/mahc/structure-content/