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CMAHC CR-TRC PresentationsWednesday Morning 10-18-2017

Sections 8-11

Remember for CR Presentations and Comments

Times to be strictly adhered to!

Speakers come to stage table as presentations approach

Sign on and use the chat room to make yourself heard https://thewahc.org/cmahc-live-stream

Stick to the CRs being presented in that hour Section

Summary of chatroom comments each hour to be presented

Slide presentations will be on 2017 conference page Submitter slide submission and changes going on too late to be

able to post so they will be posted in next several weeks

You can still (and should if you feel strongly) submit member comments for 1 month after the conference (until November 19) Submit and influence final CRs in the vote

WEDNESDAY AM

CR PRESENTATIONS

SECTION 8

Lifeguard Chairs, LG Positions and Visibility, Sun Protection, Resuscitation Mask Access, Training and

Certification

CR#: 4.8.5.3.2-0002Lifeguard Chair Height

Presenter Name: John Kelly

Submitter Name: John Kelly

Iowa Department of Public HealthSwimming Pool and Spa Program

4.8.5.3.2-0002: Proposed Change

Summary: Clarifies that lifeguard chairs/stands must be designed for lifeguards and have a minimum seat height of 30”

Suggested changes:

4.8.5.3.2-0002: Rationale Behind/Benefit of CR Rationale for CR

The Redwoods Group notes guards should never sit on standard height chairs or benches

http://www.redwoodsgroup.com/static/media/resources/documents/pdf/lifeguarding-an-inviolate-primer-ymcas-1.pdf


http://www.pentaircommercial.com/products/deck-equipment-lifeguard-stations-and-chairs-lookout-lifeguard-chairs-331.htm

Technical Review Committee ReportCR# 4.8.5.3.2-0002

Summary of internal TRC & TSC discussion

The Lifeguarding and Bather Supervision TSC found this CR to not be technically defensible and picking a seat height arbitrary. The MAHC covers visibility issues already.

TRC: There is an existing concern of facilities utilizing inappropriate chairs as lifeguard stations. It cannot be determined how widespread this issue may be. Regardless, the emphasis should be focused on the actual performance of the lifeguard and not a specific seat height. It should also be noted that the manufacturers of lifeguard stands generally design their stands so that the eyes of the lifeguard when sitting are generally at standing eye height.



TRC: There are multiple variables that exist for determining the appropriate positioning of lifeguards. With the MAHC having the performance based requirement that lifeguards be positioned such as to the eyes of the lifeguard are at a standing height over the water line, the prescriptive requirement of a fixed seat height is made irrelevant. The varying stations and supervision strategies of the lifeguard, when properly utilized by the facility, will negate a need for a fixed seat height. In addition, based on the pool design, requiring a fixed seat height may create a situation that is dangerous for the lifeguard to enact a rescue out of, or at the very least delay the response time of the lifeguard in making a water rescue.


Summary of CMAHC member comments

One member comment stated that a deck chair is not a lifeguard chair (referring to example in the CR of a guard pulling up a deck chair), and that the use of deck chairs by lifeguards should be addressed elsewhere, and that this section is only applicable to lifeguard chairs, not deck chairs.


Summary of pros and cons and/or benefits or deficits

Pros: Looks to ensure guard visibility and stature.

Cons: Adds a subjective and prescriptive seat height.

CR# 5.6.1.2.1.1Reducing Glare and Increasing Visibility for

Lifeguards

Presenter Name: CMAHC Technical Review Committee

Submitter Name: Steve Miller

5.6.1.2.1.1 Proposed Change

Summary

Ensure all lifeguard positions including roving positions or those without a fixed station provide for clear visibility of zone.

Suggested changes

5.6.1.2.1.1 Lifeguard StationsIf the AQUATIC VENUE requires lifeguards, the AQUATIC FACILITY owner shall ensure that glare conditions are assessed from each lifeguard station to determine if the AQUATIC VENUE bottom and objects in the POOL are clearly visible throughout operating hours position as identified in the Zone of Patron Surveillance to determine if the AQUATIC VENUE bottom and objects in the Pool are clearly visible to lifeguard staff throughout operating hours per 6.3.3.1.1.

5.6.1.2.1.1 Rationale Behind/Benefit of CR

Rationale for CR

Changing lifeguard station to “each lifeguard position as identified in the Zone of Patron Surveillance is clearly visible to lifeguard staff throughout operating hours per 6.3.3.1.1” ensures that each lifeguard position is evaluated appropriately and is not only limited to those positions which have a fixed stand or 'station'.

Technical Review Committee ReportCR# 5.6.1.2.1.1

Summary of internal TRC & TSC discussionThe Injury Prevention, Risk Management, & Safety TSC discussion included practical, operational and scientific based information regarding the CR. We found no objections to the CR. We feel that the CR is both practical and scientifically sound.

TRC agreed with the change request and there were a few minor changes added the submitter agreed to these changes. The changes were to add wording to clarify if the Aquatic Venue bottom and objects in the pool were clearly visible.


Summary of CMAHC member commentsOne member comment as received; the commenter agreed with the CR and stated “The proposed Change Request addresses the need to ensure lifeguards can see clearly, without glare, from all positions that they work instead of just fixed lifeguard stations as listed in the existing code and should be approved.”



Pros:

Clarifies how lifeguard’s positions, rather than just fixed stations are to be evaluated

Cons: none

CR# 5.8.5.3.1Sun Protection for Lifeguards



5.8.5.3.1 Proposed Change

Summary

Provide an objective driven solution to UV protection that applies to all lifeguard positions, not just installed chairs or stations.

Suggested changes

5.8.5.3.1 UV Protection for Chairs and Stands

When a chair or stand is provided and QUALIFIED LIFEGUARDS can be exposed to UV radiation, the chair or stand shall be equipped with or in a location with protection from such UV radiation exposure. Lifeguards and lifeguard positions must be provided protection from UV radiation exposure.

5.8.5.3.1 Rationale Behind/Benefit of CR

Rationale for CR

This entry is misdirected. It reads that the chair needs to be protected as opposed to the lifeguard. This can be accomplished by providing the lifeguard with hat/visor, t-shirt, umbrella at position or any combination that meets the objective.

Technical Review Committee ReportCR# 5.8.5.3.1

Summary of internal TRC & TSC discussionLifeguard & Bather Supervision TSC: One member comment that this change gets to the intention of the code with would be protection of the lifeguard from UV. Hats, glasses, and upper body wear will accomplish this when a permanent shading device is not practical for that lifeguard’s position.

TRC: Recommendation to remove of “face, eyes and upper torso” from the proposed language (accepted by submitter)

The Injury Prevention, Risk Management, & Safety TSC agreed with the CR and felt that it provided clarification on how a lifeguard should be protected in non-seated positions or in positions where an umbrella or chair are not feasible



no comments



Pros:

Provides clarification and addresses protection of roving lifeguards.

Cons:

None.

CR# 5.8.5.3.9-0002 PPE on Lifeguard



5.8.5.3.9-0002 Proposed Change

Summary

Ensure lifeguard has needed equipment for in-water unconscious rescue when entering the water to prevent delay in appropriate care.

Suggested changes

5.8.5.3.9 Personal Protective Equipment

Personal protective devices including a resuscitation mask with one-way valve and non-latex one-use disposable gloves shall be immediately available to all QUALIFIED LIFEGUARDS worn in the form of a hip pack or attached to the rescue tube of all QUALIFIED LIFEGUARDS on-duty.

5.8.5.3.9-0002 Rationale Behind/Benefit of CR

Rationale for CR

If it is not worn on person or attached to the rescue tube, the lifeguard will enter the water without necessary equipment to provide appropriate in-water care...this is just a fact of emergency reaction. This concept is also why it is a best practice to have multiple wave stops on a wave pool because the rescue guard reacts immediately and almost never hits the e-stop...reaction to enter water takes priority. Lifeguards reacting to in-water needs the proper equipment with them in the water to effect a rapid and appropriate unconscious rescue and give the guest in distress the best opportunity for a successful outcome.


Summary of internal TRC & TSC discussionThe Lifeguarding and Bather Supervision TSC: "Immediately available" in the current code is open to interpretation. A location near the lifeguard position does not provide immediate availability to a rescuer in the water. While various lifeguard training agencies may have different protocols for when in-water treatment is appropriate, most if not all teach in-water ventilations with a mask for special situations. The TSC agreed that the mask and gloves should be carried by lifeguards on duty.

The TRC concurred with the TSC with minimal discussion.



No comments



Pros:

Places resuscitation equipment on the person of the lifeguard for faster deployment and use. Brings an accepted industry practice into the MAHC.

Cons:

None.

CR# 6.2.1.2.6.3/6.2.1.2.6.4Lifeguard Instructor Physical Testing



6.2.1.2.6.3/6.2.1.2.6.4 Proposed Change

SummaryLifeguard instructors must be able to perform the same physical skill set as lifeguards to ensure quality control of lifeguard training.

Suggested changes6.2.1.2.6.3 Lifeguard Instructor Renewal/Recertification Process

Lifeguard training agencies shall have a lifeguard instructor renewal/recertification process that ensures instructor can physically perform and demonstrate the same skill set as a lifeguard.

6.2.1.2.6.4 Quality Control

Training agencies shall have a quality control system in place for evaluating a lifeguard instructor’s ability to conduct courses and ensures instructor can physically perform and demonstrate the same skill set as a Lifeguard.

6.2.1.2.6.3/6.2.1.2.6.4 Rationale Behind/Benefit of CR

Rationale for CR6.2.1.2.6.3

Instructors must be held accountable to be able to perform the same skill set of a Lifeguard. If instructors are permitted to renew without meeting the full lifeguard course requirements then by definition they are unable to confirm quality control as called upon in 6.2.1.2.6.4.

6.2.1.2.6.4.

Quality control for a lifeguard instructor hinges on the instructor's ability to impart technical skills and knowledge, part of sound education by the instructor is being able to perform, model, and demonstrate those skills to students. This ensures the instructor's ability to properly evaluate and remediate a lifeguard candidate's skill proficiency, and provide the necessary quality control for a lifeguard course.

Technical Review Committee ReportCR# 6.2.1.2.6.3/6.2.1.2.6.4

Summary of internal TRC & TSC discussion6.2.1.2.6.3

Lifeguard & Bather Supervision TSC: comment that does not support the CR. Enforcement of this for some training agencies would be difficult.

Internal TRC: TRC discussion included concerns about ADA, lack of ability to enforce; first time certified, the lifeguard instructor demonstrates lifeguard skill, but not for renewal/recertification (see Annex 6.2.1.2.6.2); have to distinguish instructor from lifeguard.

6.2.1.2.6.4

The TRC believes that individual policies regarding the physical performance and abilities of lifeguarding instructors should be left with the individual training agencies. Could violate ADA.



No comments



6.2.1.2.6.3

Pros: None.

Cons: Not enforceable, there are ADA concerns, no supporting data.

6.2.1.2.6.4

Pros: Helps ensure that lifeguard instructors understand the skills they are teaching.

Cons: (per TSC) not technically defensible or achievable and (TRC) may possibly violate federal law (ADA).

WEDNESDAY AM

CHAT ROOM COMMENTS

DISCUSSION

SECTION 8

Lifeguard Chairs, LG Positions and Visibility, Sun Protection, Resuscitation Mask Access, Training and

Certification

WEDNESDAY AM

CR PRESENTATIONS

SECTION 9

Training and Certification, Number of Lifeguards, Supervision and Pools Requiring Lifeguards

CR# 6.2.2.4.3Lifeguard Supervisor Certification Validity




Summary

Require a re-certification period of 2 years for lifeguard supervisor training to ensure staff are up to date on best practices and skills for supervision of lifeguards.

Suggested changes (new section)

6.2.2.4.3 Number of Years

Length of valid certification shall be a maximum of two years.


Rationale for CR

To ensure leadership staff are up to date on best practices for the requirements of 6.2.2.2 (lifeguard supervisor training), it makes sense to have staff re-certify on a regular basis. We apply the same logic for Lifeguard Training, Lifeguard Instructor Training, Operator Training, etc. Why would we not apply the same strategy for leadership staff?



The Lifeguard & Bather Supervision TSC: agrees that a limited validity period is appropriate, which is already in place for most providers, and that two years is a reasonable term.

6.2.2.3.4.4 requires agencies to have a LIFEGUARD SUPERVISOR recertification process and a validity period could be addressed there. The TRC discussed the appropriate place for this CR and decided that the addition of a new section was best approach. This follows the same formatting as the existing Lifeguard section for the same type of entry.



There were no Member Comments.



Pros:

Provides guidance/definition to 6.2.2.3.4.4, which already requires agencies to have a LIFEGUARD SUPERVISOR renewal/recertification process. This establishes the maximum validity period. Lends consistency between Code sections with similar requirements (lifeguard).

Cons:

Minimal added training cost/time to operators who must now renew Lifeguard Supervisors every 2 years

CR# 6.3.4.4.1Lifeguard Supervisor Staffing




Summary

Clarify the minimum ratio requirements for lifeguards/Supervisor to be 3 lifeguard and 1 supervisor.

Suggested changes6.3.4.4.1 Lifeguard Supervisor Provided

AQUATIC FACILITIES that are required to have two three or more QUALIFIED LIFEGUARDS to satisfy Zone responsibilities per the Zone Plan of Bather Surveillance responsibility in MAHC section 6.3.3.1.1,shall have at least one an additional person at the AQUATIC FACILITY during all hours of operation, designated as the LIFEGUARD SUPERVISOR who meets the requirements of MAHC section 6.2.2.


Rationale for CR

There is some simplification and clarification needed as the current Code language suggests that you would have a minimum of 2 lifeguards and 1 supervisor based on this entry. Revise the language to clarify minimum staffing, such that if the 'Zone of Patron Surveillance' identifies 3 lifeguards, it clarifies whether that indicates 3 lifeguards and a separate supervisor as opposed to 2 lifeguard and 1 supervisor.


Summary of internal TRC & TSC discussionThe Lifeguard & Bather Supervision TSC assessment was “Acceptable Only with Modification” – they felt there was positive health impact and only moderate cost impact with this CR.

The TRC did not agree to a need to change the current intent of the Code and Annex, but does support the desire of the CR author for clarification. The TSC recommendation is that the author revise the CR with additional attention paid to potential changes to the Annex and item 6.3.4.4.2.



No Member comments were submitted


Summary of pros and cons and/or benefits or deficitsPros: The CR will provide clarity needed to communicate the intent of the original language. The CR will reinforce that a qualified lifeguard cannot fulfill lifeguard supervisor duties while on scanning duty at facilities requiring 3 or more Lifeguards with scanning responsibilities.

Cons: Smaller facilities may feel a financial impact if they must adjust their staffing to comply with the Code. More Lifeguards may need to be hired/trained to satisfy the requirements.

The TRC was sensitive to the smaller facility impacts and suggested increasing the number of Lifeguards from 2 to 3 before requiring an additional person to serve as the LIFEGUARD SUPERVISOR.

CR#: 6.3.2.1-0001Requiring a Lifeguard if Alcohol is Served

Within an Aquatic Venue Enclosure

Presenter Name: John Kelly

Submitter Name: John Kelly

Iowa Department of Public HealthSwimming Pool and Spa Program

6.3.2.1: Proposed Change

Summary: Requires lifeguards at aquatic facilities that sell or serve alcohol within the venue enclosure during the periods of which alcohol is sold or served.

Suggested changes: Adds new item to list of items for which facilities are required to have a lifeguard

6.3.2.1: Rationale Behind/Benefit of CR Rationale for CR

The World Health Organization notes:

Alcohol is one of the most frequent contributing factors associated with drowning among adults and that

Alcohol consumption may also play a role in the lapse of supervision in drownings involving children.

Guidelines for safe recreational water environments Volume 2 Swimming Pools and Similar EnvironmentsWorld Health Organization


The CDC notes:

Among adolescents and adults, alcohol use is involved in up to 70% of deaths associated with water recreation.

Alcohol influences balance, coordination, and judgement, and its effects are heightened by sun exposure and heat.

Content source: Centers for Disease Control and Prevention, National Center for Injury Prevention and Control, Division of Unintentional Injury Preventionhttps://www.cdc.gov/homeandrecreationalsafety/water-safety/waterinjuries-factsheet.html


The American Red Cross Swimming and Water Safety manual has many warnings regarding alcohol including:

“Do not serve alcoholic beverages to guests who are or will be supervising or participating in water activities”

American Red CrossSwimming and Water Safety, 2009


Example:

In the drowning incident involving Vincent Owusuat the Clevelander hotel swimming pool, the news article notes that there was a pool party at the hotel and the drowning victim had been drinking prior to the drowning incident.

http://www.nbcmiami.com/news/local/Tourist-Drowns-at-Clevelander-Pool-Party-118782039.html


Example:

In the drowning incident involving Michael Ward in a hot tub on a Carnival Cruise ship, the new article notes the death was ruled drowning due to extreme intoxication. The medical examiner found a blood alcohol of 0.156.

http://www.newsworks.org/index.php/local/off-mic/69027-autopsy-shows-birdie-africa-highly-intoxicated-when-he-drowned-in-hot-tub


Example:

In the drowning incident involving Hailey Stanley at the Grand Seas Resort, the news article notes that the caretakers left her at the kiddie pool while they went to the bar for drinks.

http://www.washingtontimes.com/news/2016/jun/3/georgia-girl-drowns-in-pool-at-daytona-beach-resor/

Technical Review Committee ReportCR# 6.3.2.1-0001

Summary of internal TRC & TSC discussionLifeguarding and Bather Supervision TSC: Agreed that the cited risk assessments and abatements are generally valid. As a rule, patrons are better protected when lifeguards are on duty, and alcohol is a contributing factor in some drowning. However, the degree of risk depends on the situation. A clothed guest having a drink in a lounge chair near a hotel pool does not pose the same risk as an intoxicated group in the water. Given such variations, there was concern that the application, implementation, and enforcement of the proposed addition would be difficult.

TRC: Suggested revision to the CR to remove aquatic facility as being the envelope where alcohol sales would require a lifeguard. Author agreed to remove “Aquatic Facility or” from paragraph #9. CR was updated on CMAHC website to reflect agreed change.



No CMAHC member comments



Pro: adds another level of specificity as to when a lifeguard should be required.

Con: Added cost to facility to provide a lifeguard if they may have otherwise not been required under 6.3.2.1.

It is recommended that annex language is added to clarify “venue enclosure” to help clarify the intent of this proposed language.

CR# 6.3.2.1-0002/ 6.3.2.1-0002/ 6.3.2.1-0003/ 6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Increasing Venues Required to Have Lifeguards

Presenter Name: Carvin DiGiovanni

Submitter Name: Jennifer Hatfield

APSP

CR#: 6.3.2.1-0002/ 6.3.2.1-0002/ 6.3.2.1-0003/ 6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Expands conditions in which lifeguards are required by expanding 3 categories and adding 2 additional categories.

Would require lifeguards: when any portion of pool is more that 4 feet (1.22m) deep;

in all pools that do not ACTIVELY prevent access by unsupervised children under 14 when pool is in use;

at any AQUATIC VENUE with a configuration in which any point on the AQUATIC VENUE surface exceeds 15 feet from the nearest DECK;

CR#: 6.3.2.1-0002/ 6.3.2.1-0002/ 6.3.2.1-0003/ 6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

CONTWould require lifeguards (CONT):

at any AQUATIC VENUE where a person licensed in CPR and AED is not present at all times the venue is open; and

At Any AQUATIC VENUE that does not have a QUALIFIED OPERATOR on side or immediately available within two hours during all hours of operation.

CR#: Rationale Behind/Benefit of CR 6.3.2.1-0002

Data Compiled by Redwoods Group confirms that over 75% of all drowning incidents (and 100% of those involving Children 5 or under) occurred in less than 5 feet of water. Therefore the current language which exempts pools that are 5 feet or less exposes all bathers to unreasonable risk of drowning, especially children 5 and under and other non swimmers.

Lifeguards are trained in rapid recognition (10 seconds to recognize and 10 seconds to react)

Lifeguards also deter and warn against dangerous behavior, preventing incidents from occurring.

CR#: Rationale Behind/Benefit of CR 6.3.2.1-0002 CONT

Lifeguards reduce the risk of drowning, as well as potential unsafe behavior such as diving into shallow water, underwater breath holding and horseplay.

Code relies on height of 50th percentile female adult and therefore ignores risk to children. According to CDC 50th

percentile 13 year old boy is 5’4” and thus not able to stand in 5’ of water

Code incorrectly places reliance on untrained adult to perform rescue of child in distress


Proposal worded incorrectly

Should require lifeguard in all venues that do not ACTIVELY prevent access by children < 14

Prohibition is not adequate without some means of prevention, by onsite or video monitoring. Children will climb fences and access prohibited areas.


Lifeguards should be required where there is any location on the surface more than 15’ from the deck Shepherd's crook and other rescue equipment don’t extend 30

feet

Unsafe to expect a non trained adult to perform a rescue and carry victim across 30 feet of pool surface to deck


Lifeguard should be present at any pool where there is no other person present trained in CPR and AED. This ensures that someone trained in CPR and AED is present at

every public pool

CPR saves numerous lives

Common sense: someone on hand needs to know CPR

CMAHC comments misconstrue proposal. Lifeguards should all have current CPR and AED certification. If no lifeguard is present someone else with these certifications should be.

Rationale Behind/Benefit of CR 6.3.2.1-0006

All aquatic venues require monitoring by qualified personnel to maintain water quality and clarity and address any health or contamination incidents. Lifeguards can and often do perform these functions.

Venues has option of hiring lifeguard or ensuring that a qualified operator is available within two hours notice.

Technical Review Committee ReportCR# 6.3.2.1-0002/ 6.3.2.1-0002/ 6.3.2.1-0003/

6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Summary of internal TRC & TSC discussion: all submissions

LBS TSC: Confusion also arose since some of the changes appear as exemptions rather than inclusions.

Supporting documentation promotes an assertion that lifeguards lower the risk of injury at swimming venues. The TSC agrees with that but does not support any of the changes as currently proposed.

IPRMS TSC: The author’s statement that the original code is a list of exemptions is incorrect. It’s a list of qualifications of pools that require LGs.


6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Summary of internal TRC & TSC discussion6.3.2.1-0002 (LG if no CPO on site): Would require lifeguards whenever a CPO is not available within two hours. The TSC did not address the difference in functions between lifeguards and pool operators to the extent it would have had the CR dealt only with this item, but there was agreement these tasks did not overlap 100%.

LGBS TSC: Operator and LG are very different, which is not dealt with in this.


6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Summary of internal TRC & TSC discussion6.3.2.1-0003: LG required for pool >4ft (current 5 ft). LGBS TSC: Slides list the median depth for an unspecified number of incidents as 4 ft. However, a figure for a different range of dates indicates a significant cluster of incidents in water depths at 4 ft or less (31 of 53 incidents). Most or all the incidents investigated likely were guarded pools. Without additional details/analysis, the data do not support a firm conclusion that 4 ft is a better cutoff than 5 ft, other than promoting a general policy that all venues are safer with lifeguards than without.

IPRMS TSC: The depths and measurements seem somewhat arbitrary. The four feet in depth refers back to the attached report, however there is nothing that states that lowering the standard from 5 to 4 feet would significantly help. According to the presentation, it should be lowered to 2 feet or 3 feet.


6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Summary of internal TRC & TSC discussion6.3.2.1-0004 (LG if actively prevents use by children):

LGBS TSC: Confusion since some of the changes appear as exemptions rather than inclusions. Change substitutes "actively prevents use by" in place of "allows for" unsupervised children. That is, the current code requires lifeguards at venues that allow unsupervised use by children, whereas the change would require lifeguards at venues that actively exclude children. That is probably not what the author intended.”


6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Summary of internal TRC & TSC discussion6.3.2.1-0005 (cuts reach into pool from 30 to 15 ft):

FMO TSC: This is not practical for HOA or other subgroups (country clubs /health clubs – where they have a Jr. Olympic. They are usually 75 feet (25 yard pools) by 40-50 Feet (making then exempt under the 30 foot rule and non-exempt under the 15 foot rule) #9 and #10 are not practical for many facilities that do not have lifeguards including around 100,000 commercial pools in California alone.

LGBS TSC: Would reduce the current cut off of 30 feet or less to the nearest deck to 15 feet or less. The author apparently disagrees with the reasoning in the Annex for the 30 ft range and provides a letter from a third party to that effect.


6.3.2.1-0004/ 6.3.2.1-0005/ 6.3.2.1-0006

Summary of internal TRC & TSC discussion6.3.2.1-0006 (require LG whenever there is not a person present trained in CPR/AED:

LGBS TSC: Although the ability to perform first aid is an important function of a lifeguard, someone with only CPR training is not a valid substitute for a lifeguard. Also, this provision might be difficult to enforce, particularly since it does not define "present", e.g., does someone at the front desk of a hotel suffice.


6.3.2.1-0005/ 6.3.2.1-0006

Summary of CMAHC member comments: 1 comment

Disagreed: Don't add the last 2 underlined (LG if no CPR trained person, no operator on site) There is no excuse for not having trained personnel on site. IF an exception is to be made it might be based on the size of the facility - the lifeguard/instructor/etc. can test the water but at smaller facilities (not waterparks, etc.) may have to close until the trained operator is available.


6.3.2.1-0005/ 6.3.2.1-0006


6.3.2.1-0002 (LG if no CPO on site)Pros: Could lead to the presence of Lifeguards at more Aquatic Facilities.

Cons: If anything this weakens/clouds the Code requirement of always having a Qualified Operator or Responsible Supervisor readily available or on-site. It also indirectly asks the Lifeguards to do tasks that should fall under the duties of the QO/RS. Could impact operations and budgets of many smaller facilities.


6.3.2.1-0005/ 6.3.2.1-0006 Summary of pros and cons and/or benefits or deficits6.3.2.1-0003 (LG required for pool >4ft (currently 5 ft)).

Pros: Could lead to the presence of Lifeguards at more Aquatic Facilities. Could potentially lead to a lower number of drowning incidents.

Cons: More evidence is needed to support the change since the drownings statistics cited were likely in guarded pools. Could impact operations and budgets of many facilities.

6.3.2.1-0004 (LG if actively prevents use by children):

Pros: Needs re-writing to show actual intent

Cons: Provides an exemption in a section that looks to provide requirements. As written it would seem like those facilities that do not actively prevent unsupervised children from using the venue would also not be required to provide Lifeguards.


6.3.2.1-0005/ 6.3.2.1-0006

Summary of pros and cons and/or benefits or deficits6.3.2.1-0005 (cuts reach into pool from 30 to 15 ft):

Pros: Could make the use of the ring buoy more effective by shortening the distance for throwing at unguarded facilities. Would increase dramatically the number of facilities that would be required to have lifeguards; in fact almost every AQUATIC FACILITY covered under the Code would now be required to provide Lifeguards.

Cons: May ultimately lead to facility closures and reduce water exercise and access to swim lessons. Almost every AQUATIC FACILITY covered under the Code would now be required to provide Lifeguards.

Would significantly impact operations and budgets of many smaller facilities.


6.3.2.1-0005/ 6.3.2.1-0006


6.3.2.1-0006 (requires LG when no person trained in CPR/AED):

Pros: Could lead to the presence of Lifeguards at more Aquatic Facilities. Would ensure someone with CPR/FA/AED training is on-site at all time of operation.

Cons: Could impact operations and budgets of many smaller facilities.

Create CR to put training in safety plan vs. requiring a lifeguard


6.3.2.1-0005/ 6.3.2.1-0006

Summary of pros and cons and/or benefits or deficits6.3.2.1-0006 (require LG when no person trained in CPR/AED:

The TRC discussed that requiring Lifeguards based on the lack of anyone else on-site who is trained would be a hardship on many facilities. It was discussed that CPR/FA/AED training is really what is at issue here and so much that it needs to be Lifeguards who have the training. It was suggested that future CRs be looked at that can address the need for CPR trained staff being present during operating hours as a better means by which to handle this than the current CR. It was also discussed that section 6.3.4 (Safety Plan) addresses this need to a degree already and any additional requirements should be added here as opposed to 6.3.2.1. Further it was suggested that in the interim more language could be added to the Annex to help stress the importance of having trained staff on-site.


6.3.2.1-0005/ 6.3.2.1-0006

Summary of pros and cons and/or benefits or deficitsAs a reminder to members:

The MAHC is a tool, a model code, with a foundation built on public health data and practice. The MAHC is now being used to assist public health jurisdictions as they review and revise their codes. However, all guidance has to balance the public health needs with what we know is practicable. We know we could design and operate a pool to do what we need but this group and CDC must balance that with the impact the requirements that could result in the unintended public health consequences of closed pools, fewer people learning to swim, and fewer people sharing in the benefits of aquatic exercise.

WEDNESDAY AM

CHAT ROOM COMMENTS

DISCUSSION

SECTION 9

Training and Certification, Number of Lifeguards, Supervision and Pools Requiring Lifeguards

WEDNESDAY AM

CR PRESENTATIONS

SECTION 10

Communication Systems, Spinal Boards, and Chlorinator Sizing

CR# 5.8.5.2.1.3/ 5.8.5.2.3.2/ 5.8.5.2.3.3Alternate Facility Emergency Communication

Systems



5.8.5.2.1.3/ 5.8.5.2.3.2/ 5.8.5.2.3.3 Proposed Change

Summary

Provide for exceptions to requirements for signage, and emergency communication systems for those facilities with internal first aid response and emergency communication plan.

Suggested changes5.8.5.2.1.3 Conspicuous and Easily Accessible

The telephone or communication system or device shall be conspicuously provided and accessible to AQUATIC VENUE users such that it can be reached immediately or meets requirements for 5.8.5.2.1.4 and facility has internal first aid response.

.

5.8.5.2.1.3/ 5.8.5.2.3.2/ 5.8.5.2.3.3 Proposed Change

Suggested changes5.8.5.2.3.2 Emergency Dialing Instructions

A permanent sign providing emergency dialing directions and the AQUATIC FACILITY address shall be posted and maintained at the emergency telephone, system, or device. Facilities that meet the requirements for 5.8.5.2.1.4 and have internal first aid response are exempt from this requirement.

5.8.5.2.3.3 Management Contact Information

A permanent sign shall be conspicuously posted and maintained displaying contact information for emergency personal and AQUATIC FACILITY management. Where an internal communication or phone system is used, the AQUATIC FACILITY is exempt from posting this information.

5.8.5.2.1.3/ 5.8.5.2.3.2/ 5.8.5.2.3.3 Rationale Behind/Benefit of CR

Rationale for CR

5.8.5.2.1.3

Clarify exception for larger facilities with internal communication and first aid response.

5.8.5.2.3.2 & 5.8.5.2.3.3

This entry is impractical for larger aquatic facilities and waterparks as response to an emergency is immediate and directly on-site.

Technical Review Committee ReportCR# 5.8.5.2.1.3/ 5.8.5.2.3.2/ 5.8.5.2.3.3


5.8.5.2.1.3: Lifeguarding and Bather Supervision TSC determined that there is merit to allowing for an objective driven exception to provide telephone or equipment to Patrons to contacting 9-1-1.

The TRC felt that “internal first aid response” was too vague of a term. The TRC wished to modify the language to specify the use of internal EMS or EMTs. This modification was not approved by the author. Section 5.8.5.2.1.4 provides for the AHJ to allow alternate functional systems, therefore meeting the intent of the author. This is justified by the MAHC annex on page 263 where the annex states: “…..For larger facilities, this could include internal communication processes such as two-way radio use to a central phone to facilitate emergency communications to outside EMS in place of hard wired publicly accessible phones.”



5.8.5.2.3.2: Injury TSC does not support allowing this exemption due to the liability that may result by not having this essential information posted if an emergency occurs when the ACS is not available (after hours/unstaffed) or fails.

LG and Bather Supervision TSC: questioned whether this signage entry was solely for public phone/communication systems. TSC members felt the original code language was appropriate regardless of whether the signage was a public/unguarded situation or within a facility that has an internal communication/response system where a facility employee will be contacting outside emergency services at a non-public telephone/communication system.

The TRC discussion centered around the signage being required as backup to internal response and requirement of the EMS or first aid responders. Also, liability issues if internal system fails or something happens after hours for backup to internal system.



5.8.5.2.3.3: Injury TSC interprets intent to be that facility users should have the ability to report concerns, issues, problems related to the facility management and provide contact information for emergency personnel. The emergency system exemption should not apply to signage. Signage is intended to allow users to report legitimate concerns about facility safety, mechanical issues, needed repairs, or other concerns regardless of on-site presence. Dealing with the illegitimate or unnecessary concerns of the users is the drawback of management choosing to have on-site response.

LG and Bather Supervision In situations where the facility has an internal communication and response plan in place to address safety concerns, as well as on-site Qualified Operator, there is not a need for a public sign with owner or management contact information. CR was acceptable only with modification, and that in situations where there are no staff members to contact.



5.8.5.2.3.2 & 5.8.5.2.3.3:

Agreement: enhanced internal emergency response capabilities of many large aquatic facilities and provides appropriate amendments based on these additional capabilities and should be approved.”

Disagreement: If Internal response is available signs must be posted indicating this and how to reach them. We found that this was only an issue at large, privately owned, open-to-the-general-public water parks.

5.8.5.2.1.3:

One member commented in support of this CR

One member comment was disagreeing with this CR, stating that this is only an issue at large, privately owned waterparks.



5.8.5.2.1.3

Cons: major deficit of the CR was how to define internal first aid response. While some facilities may utilize individuals with advanced medical training (Nurses, Physician Assistants, etc…), this does not mean that the individual with advanced medical training is adequately prepared to respond in an emergency. Emergency Medical Technicians (EMT-B, EMT-P) are specifically trained in pre-hospital emergency medical care.

5.8.5.2.3.2

PROS -911 dialing instructions and facility address are available at any point in time and able to be used by anyone in the event of an emergency.

CONS - Multiple reports of a single incident may occur. "False alarms" may occur by individuals playing a "prank“.



5.8.5.2.3.3

Cons: The TRC disagreed with the CR and recommends a no vote.

Management should be able to be contacted for other issues besides emergencies.

TRC suggests revised wording be tried again next tie. Two re-writes are suggested

CR# 5.8.5.3.2Sufficient Spinal Boards On Site




Summary

Provides guidance on appropriate number of spinal injury board(s) for reasonable response time.

Suggested changes5.8.5.3.2 Spinal Injury Board

At least one spinal injury board constructed of material easily SANITIZED/disinfected shall be provided. Number and location of spine boards should be sufficient to effect a 2-minute response time to location of incident.


Rationale for CR

Adding language to require sufficient number of backboards to ensure a timely response, based on size and configuration of facility increases safety. Based upon language in the annex, adding a 2-minute response time is reasonable and in-line with annex's guidance.



The Lifeguard & Bather Supervision TSC: In agreement with aquatic venues having sufficient backboards available. Discussion centered on having a backboard available in the area of each zone within a certain timeframe - whether it was 1 minute or 2 minutes. There was an assumption that the intent is to ensure there are enough boards located such that the extrication – spinal or passive is not delayed waiting for a board (to reach the scene of an incident). Based on this assumption, the TSC recommends a 1 minute metric.

TSC and TRC recommend that the use of the term "spinal board" in 5.8.5.3.2 be changed to "backboard" since this piece of equipment has multiple uses in the event of an emergency situation.



The Injury TSC: Allows clarification as to where the boards will be provided within the facility and how many boards you will need to operate effectively.

TRC decided to leave this at a 2-minute response time



No Member Comments



Pros: Provides guidance as to how many boards Operators will need to manage emergency response effectively. Helps to ensure that care of Bathers in need of spinal or passive victim response is not delayed waiting for a board. Makes facilitation of the Facility’s EAP more efficient.

Cons: Slight financial cost to operators who may need to purchase additional equipment.

The term "spinal board" be changed to "backboard" since this piece of equipment has multiple uses in the event of an emergency situation.

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002,CR#: 4.7.3.2.2.2-0001, CR#: 4.7.3.2.2.2-0002

Chlorinator Sizing

Presenter Name: Laura M. Suppes, PhD, MPH, REHS

Assistant Professor

Environmental Public Health Program

University of Wisconsin - Eau Claire

CMAHC Technical Review Committee member

Submitter Name: Lars Hagen

on behalf of the

CMAHC Chlorinator Sizing Committee

CMAHC Chlorinator Sizing Committee:

Chlorking, Inc. – Manufacturer(OEM) of Electrolytic Salt Chlorine

Generators and other related equipment

De Nora Tech, LLC. – Leading anode supplier to Chlorine

Chemical Manufacturers and to OEMs producing Electrolytic Salt Chlorine Generators

Hayward Industries

Pentair Water Quality Systems – Both are

manufacturers(OEMs) of Chlorine Chemical Feeders, Electrolytic Salt Chlorine Generators and other Pool/Spa Equipment

SeaWorld Parks and Entertainment – Waterparks

Owner/Operator

Team Horner Group, Inc. – Pool/Spa Equipment Master

Distributor and OEM- including Chlorine Chemicals, Feeders, Manufacturer of AutoPilot Electrolytic Salt Chlorine Generators

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002

These 2 CRs are actually one CR.

It is only necessary to review 4.7.3.2.2.2-0003 to see all of the changes, reasons and benefits, supporting info, etc. for both of these.

CR 4.7.3.2.2.2-0003 also includes additions to:

5.7.3.5.1.5 - which addresses Insufficient Size Capacity

4.1.2.3.6 4 - which is a new documentation requirement

This slide to be skipped during the presentation

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002Summary of Change

1. AQUATIC VENUES shall be required to maintain the minimum Free Available Chlorine (FAC) per section 5.7.3.1.1.2 at all times but have no specific dosing rate requirement based on volume alone. *1

2. Sizing of chlorine dosing equipment shall be based on chlorine demand factors: surface area, volume, type of use/space (flat water, agitated water, hot water), venue type (pool, spa, wading pool, etc.), indoor/outdoor sunlight/UV exposure, max water temp, bathers, CYA usage, water loss, vegetation and airborne debris. *2

3. Registered/Licensed Design Professional will document

adequate dosing size and capacity for the AQUATIC VENUE.*3

4. If upon operation the feed system is incapable of maintaining minimum FAC at all times additional capacity

shall be provided.*4

Code Change Color Legend

Code sections – white is existing MAHC code

green underline are proposed MAHC additions

red strike thru are proposed MAHC deletions

orange indicates an informational cross reference from a presentation summary point to a code section i.e. *1 or [*1]

This slide to be skipped during the presentation

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002 Code Change

4.7.3.2.2.2 Chlorine Dosing

All CHLORINE dosing and generating equipment including erosion feeders, or in line electrolytic and brine/batch generators, shall be designed with a capacity to meet the demand necessary to maintain the minimum required Free Available Chlorine (FAC)concentrations specified in MAHC Section 5.7.3.1.1.2 during all times of operation. provide the following:

1) Outdoor AQUATIC VENUES (unstabilized): 4.0 lbs of FAC/day/10,000 gal (1.8 kg FAC/day/37,854 L) of POOL water;

2) Indoor AQUATIC VENUES (unstabilized): 2.5 lbs FAC/day/10,000 gal (1.1 kg FAC/day/37,854 L) of POOL water.

*1

[*1]

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002Code Change

4.7.3.2.2.2.1 Chlorine Demand Factors[*2]

Sizing of chlorine dosing and generating equipment shall be based on the following chlorine demand factors:

1) AQUATIC VENUE surface area;

2) AQUATIC VENUE volume;

3) AQUATIC VENUE type of use/space:

a) FLAT WATER;

b) AGITATED WATER (vigorous aeration, spray features);

c) HOT WATER;

*2

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002Code Change

4) AQUATIC VENUE type, for example: POOL, SPA, WADING POOL, WAVE POOL (wave time), WATERSLIDE, INTERACTIVE WATER PLAY VENUE, THERAPY POOL;

5) indoor or outdoor including maximum hours of sunlight/UV exposure;

6) anticipated maximum water temperature;

7) anticipated maximum number of bathers per day;

8) cyanuric acid/stabilizer used;

9) anticipated atypical water loss; and

10) anticipated exposure to vegetation and airborne debris.

*2

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002Code Change

(CR#: 4.7.3.2.2.3-0002)4.7.3.2.2.3 The rates above are suggested minimums and in all cases the engineer shall validate the feed and production equipment specified.4.7.3.2.2.3 Documentation [*3]The Design Professional, who is registered or licensed to practice their respective design profession as defined by the state or local laws governing professional practice within the jurisdiction where the project is to be constructed, shall provide adequate documentation to demonstrate the selected feeders/equipment are of sufficient size and capacity per MAHC 4.7.3.2.2.1 and4.7.3.2.2.2. This documentation shall include:

*3, *4

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002Code Change

(CR#: 4.7.3.2.2.3-0002 - continued)1) an evaluation of the disinfection feeder/equipment based on the Design Professional’s related professional experience, the disinfection feeder/equipment manufacturer’s recommendations, or other industry accepted guidelines in sizing the feeders/equipment, and2) a discussion of the analysis and use of the chlorine demand factors listed in MAHC 4.7.3.2.2.2.1 in sizing the feeders/equipment.

4.7.3.2.2.4 Upon Operation[*4]If upon operation it is determined that feeders/equipment are not capable of meeting the demand necessary to maintain minimum required DISINFECTION levels at all times, additional capacity shall be provided.

*3, *4

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002Code Change

4.1.2.3.6 Equipment Characteristics and Rating

The technical specifications and supplemental engineering data for each AQUATIC FACILITY and each AQUATIC VENUE shall include:

……..

4) Documentation per MAHC 4.7.3.2.2.3 to demonstrate that the selected disinfectant feeders/equipment are of sufficient size and capacity, including evaluation of the chlorine demand factors in MAHC 4.7.3.2.2.2.1.

*3

[*3]

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002Code Change

5.7.3.5A Feed Equipment

5.7.3.5.1 Acceptable Chemical Delivery

Acceptable disinfectant and pH control chemicals shall be delivered through an automatic chemical feed system upon adoption of this CODE.

……

5.7.3.5.1.5 Insufficient Size/Capacity[*4]

If it is determined that the chemical feed system is incapable of maintaining the minimum required DISINFECTION level at all times in accordance with the MAHC, additional capacity shall be designed and installed per MAHC 4.7.3.2.2.

*4

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002 Ad Hoc Committee Findings and Rationale Behind/Benefit of CR

Existing prescriptive dosing rates in the MAHC were/are not based on empirical or scientific data Proposed changes based on data from 6,000+ Aquatic Venues

Existing rates typically excessively high when applied to pools and in some cases not high enough. For spas, the data presented show the MAHC dosage rates are likely never high enough

MAHC dosage rates if actually used on spas would provide inadequate sanitization and create a public hazard for the majority of spas based on analyzed data

There is still a prescription for each venue but the prescription is calculated for each venue by the Design Professional

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002 Ad Hoc Committee Findings and Rationale Behind/Benefit of CR

A key precept of the MAHC is that it be performance based

Maintaining a minimum FAC as required by this CR is safe and performance based

This CR does not restrict the ability of the facility to install a unit optimized to the chlorine demand/use pattern of that facility, potentially reducing capital equipment investment

Economic discrimination between alternative sanitation methodologies is eliminated by removing code that requires unnecessarily excessive prescriptive dosing

CR#: 4.7.3.2.2.2-0003 / 4.7.3.2.2.3-0002 Ad Hoc Committee Findings and Rationale

Behind/Benefit of CR

Sizing, which must include a safety margin, to a realistic demand expectation will not create any negative impact to public health

CMAHC Technical Support and Technical Review committee revisions reflected in this CR

CR was recommended for adoption by both committees

CR#: 4.7.3.2.2.2-0001, -0002

Passage of the preceding CR#: 4.7.3.2.2.2-0003 would supersede both of the following CRs.

There is only a minor difference between the following CRs.

CR#: 4.7.3.2.2.2-0001, -0002Summary of Change

4.7.3.2.2.2-0001 – Clarification/minor edit to make it clear that the existing code does not address chlorine dosing rates for indoor or outdoor stabilized Aquatic Venues*5

4.7.3.2.2.2-0002 – Same as above & also reminds that Free Available Chlorine(FAC) residuals must be maintained per existing MAHC 5.7.3.1.1.2*6

CR#: 4.7.3.2.2.2-0001, -0002Suggested additions

4.7.3.2.2.2.

All CHLORINE dosing and generating equipment including erosion feeders, or in line electrolytic and brine/batch generators, shall be designed with a capacity to provide the following:

1) Outdoor AQUATIC VENUES (unstabilized): 4.0 lbs of FAC/day/10,000 gal (1.8 kg FAC/day/37,854 L) of POOL water;

2) Indoor AQUATIC VENUES (unstabilized): 2.5 lbs FAC/day/10,000 gal (1.1 kg FAC/day/37,854 L) of POOL water.

CR#: 4.7.3.2.2.2-0001

3) Indoor or Outdoor AQUATIC VENUES (stabilized) do not have a specific dosing requirement. [*5]

CR#: 4.7.3.2.2.2-0002

3) Indoor or Outdoor AQUATIC VENUES (stabilized) do not have a specific dosing requirement but shall maintain residuals as specified in section 5.7.3.1.1.2. [*6]

*5, *6

CR#: 4.7.3.2.2.2-0001, -0002 Rationale Behind/Benefit of CR

The existing MAHC is specific to unstabilizedAquatic Venues. There is no guidance for health regulators specific to stabilized Aquatic Venues.

Clarify the code so there is no ambiguity on evaluating chlorine dosage equipment for stabilized Aquatic Venues

If 4.7.3.2.2.2-0003 is passed, 4.7.3.2.2.2-0001 and 0002 do not need to pass

TRC is recommending to adopt 4.7.3.2.2.2-0003 and deny 4.7.3.2.2.2-0001 and 0002

Technical Review Committee ReportCR# 4.7.3.2.2.2-0001/4.7.3.2.2.2-

0002/4.7.3.2.2.2-0003/4.7.3.2.2.3-0002

Summary of internal TRC & TSC discussionThe committee would like to remove current chlorine dosing rates for sizing chlorinators from the MAHC because the current rates are not science-based vs. common practice in state/local codes; move to performance-based criteria.

The TRC recommends part 3, which means not recommending part 0001 and 0002. The addition of the Documentation section here is also unnecessary. In part the verbiage itself of documenting based on “related personal experience” is not performance related.

4.7.3.2.2.2-0003 was accepted so this CR needs to also be accepted. The text needs to be deleted for consistency purposes. The text is "The rates above are suggested minimums and in all cases the engineer shall validate the feed and production equipment specified


0002/4.7.3.2.2.2-0003/4.7.3.2.2.3-0002

Summary of internal TRC & TSC discussionDWQ TSC: All CHLORINE dosing and generating equipment including erosion feeders, or in line electrolytic and brine/batch generators, shall be designed with a capacity to meet the demand necessary to maintain the minimum required Free Available Chlorine (FAC) concentrations specified in MAHC Section 5.7.3.1.1.2 during all times of operation.

The removal of the specific dosage requirements in conjunction with this change remains appropriate as previously discussed. The addition of 4.7.3.2.2.2.1 Chlorine Demand Factors is inappropriate. It is a random and incomplete list which provides no specific guidance(scientific or otherwise) as to how to account for their effect in sizing systems. Maybe a good solution here if the authors or others feel compelled to describe factors that may impact chlorine usage is to send it to the ANNEX SECTION 4.7.3.2.2.


0002/4.7.3.2.2.2-0003/4.7.3.2.2.3-0002


Many members have commented on the original CR 4.7.3.2.2.2-0003. 11/15 members who commented are in favor of the CR.

“This change request fits the CMAHC goal of using performance-based guidance. Importantly, the supporting data demonstrates that chlorine demand is unique to the usage and environmental factors of each aquatic venue“

Technical Review Committee ReportCR# 4.7.3.2.2.2-0001/4.7.3.2.2.2-0002/4.7.3.2.2.2-

0003/4.7.3.2.2.3-002


4.7.3.2.2.2-0001

The TRC reached a unanimous consensus to recommend not approving the CR since 4.7.3.2.2.2-0003 is recommended to be adopted.

4.7.3.2.2.2-0002

The TRC reached a unanimous consensus to recommend not approving the CR since 4.7.3.2.2.2-0003 is recommended to be adopted.


0002/4.7.3.2.2.2-0003/4.7.3.2.2.3-0002 Summary of pros and cons and/or benefits or deficits

4.7.3.2.2.2-0003

Pros: This CR is performance based. The chlorination system can be approved as long as it is capable of complying with MAHC 5.7.3.1.1.2 This CR eliminates severe economic discrimination between alternative sanitation methodologies.

Cons: Chlorine dosing under this CR may not be appropriate for rare events that overload the ability of the chlorinator to function appropriately.

4.7.3.2.2.3-0002

4.7.3.2.2.2-0003 was accepted so this CR needs to also be accepted. The text needs to be deleted for consistency purposes. The text is "The rates above are suggested minimums and in all cases the engineer shall validate the feed and production equipment specified."

WEDNESDAY AM

CHAT ROOM COMMENTS

DISCUSSION

SECTION 10

Communication Systems, Spinal Boards, and Chlorinator Sizing

WEDNESDAY AM

CR PRESENTATIONS

SECTION 11

New Filter Media, UV on Splashpads, Draining Pools

CR# 4.7.3Enhanced Filtration Systems


Submitter Name: Steven Ashworth,

Pinnacle Aquatic Group, Inc.

4.7.3 Proposed Change

Summary

This change permits technology new to the US that shifts the removal of organic matter from chlorine to an enhanced filtration system.

Suggested changes

Adds sections to code to create operational and installation guidelines for enhanced filtration systems.

Add text to the annex section to further explain the design and science of using enhanced filtration systems.

4.7.3 Proposed Change

Suggested changes: Introduce enhanced filtration units in a new section UL approved, allows new parameters

Clarity of <0.2 NTU pre-filter and <0.05 NTU post-filter during all hours of operation

ORP value of >725 mV with 0.5 ppm free chlorine at pH 6.8.

Free chlorine shall be maintained between 0.5 and 4.0 ppm (mg/L).

Combined chlorine shall be maintained <0.2 ppm (mg/L)

pH of the water shall be maintained between 6.8 and 7.6.

4.7.3 Rationale Behind/Benefit of CR

Rationale for CRPhysical removal of dissolved organic carbon (DOC) and total organic carbon (TOC) reduces the potential for disinfection byproduct (DBP) formation. This CR establishes a new category of operational parameters of combined chlorine of <0.15 ppm and clarity of <0.2 NTU pre-filter and <0.05 NTU post-filter during periods of maximum bather load and as aspirational goals. A variety of systems meeting German DIN 19643 achieve these goals while maintaining free chlorine in the 0.4 to 2.0 ppm range with an ORP >725 mV. Enhanced filtration systems using continuous coagulant feed with an optimized pH in 6.8 to 7.6 achieve these goals. This CR establishes separate operational parameters for venues using these systems without specifying equipment design.

Technical Review Committee ReportCR# 4.7.3

Summary of internal TRC & TSC discussionThe TRC was of the opinion that this product, in order to be reviewed for acceptance, needs to first be NSF/ANSI 50 certified as is the requirement for all other products in the MAHC. In addition, there were concerns over pH levels below 7.2 (as discussed in the separate CR proposed by the pH ad hoc committee) that would negatively impact product warranties and installations for pool equipment (e.g. heaters, etc.). The TRC also had concerns that there would be a very heavy burden on the operational needs for these facilities.

Residuals less than 1.0 ppm will likely cause issues with current federal EPA requirements.


Summary of CMAHC member commentsOne member comment was opposed to the proposed change request:– I am very much in favor of maximizing filtration to remove contaminants that cause sanitizer demand and that react with sanitizer to form disinfection byproducts. We just need to make sure that the provisions in the CR are sufficient to protect public health. I am concerned about referencing the DIN standard, and saying that pools operating to the performance requirements in the CR will show similar water quality as pools that conform to the DIN standard. The DIN standard has more requirements than those stated in CR 4.7.3-0001 and the MAHC.



The TRC liked the concept, but the referenced sections of the DIN code had the potential impact of leaving vital parts that could impact public health out.

CR#: 4.7.3.3.3.3U.V. Design on Splashpads

Presenter Name: Ron George

Submitter Name: Ron George

Neptune Benson

CR#: 4.7.3.3.3.3: Summary

Currently all venues: pools, spas and interactive water play aquatic venues (spray parks/pads/fountains) that are considered increased risk require secondary disinfection on the filtration loop, after filtration and before chemical treatment. This proposal requires 100% of water to be UV-treated.

CR#: 4.7.3.3.3.3: Proposed Change

4.7.3.3.3.3 Installation

The UV equipment shall be installed after the filtration and before addition of primary disinfectant except on INTERACTIVE WATER PLAY AQUATIC VENUES. For INTERACTIVE WATER PLAY AQUATIC VENUES the UV system shall be located after the feature pump to treat 100% of the water prior to reaching the patrons. On systems designed with a separate filter loop, when the features are off, the UV treatment system shall continue to provide disinfection according to 4.7.3.3.2.

CR#: Rationale Behind/Benefit of CR

This change requests suggests that Interactive WaterplayAquatics Venues are not pools where it is impossible to filter and treat 100% of the water. However, an Interactive Waterplay Aquatic Venue is designed so that you can filter and treat 100% of the water. Further, the current design of these venues with an underground tank, with a relatively small amount of water in relation to a higher bather load, cannot assure that all water is even filtered before it returns to the play area of the patrons

CR#: Rationale Behind/Benefit of CR

This change insures that all the water flowing out to the play area is in fact treated with secondary disinfection. This is our only opportunity to truly optimize prevention of illness to patrons using our public aquatic facilities.


Summary of internal TRC & TSC discussionDWQ and RF TSC’s both recommended yes. There were concerns about the original wording in that it did not provide for continuing UV treatment when the feature pump was off. TRC: The changes made by the TRC were to address this issue and to make the text consistent with MAHC terminology. There were concerns about costs and general operational questions.

DC TSC: Concern over high cost impact item being submitted by the equipment manufacturer. CR is incomplete. No supporting documentation was provided. The proposed requirement may be better placed in 4.7.3.3.1.2. which should also include altered Annex language. TRC altered wording after these comments (response from submitter was that costs for validated units were not that much higher).


Summary of CMAHC member comments; One comment received

The member disagreed with the original proposed change request.

“If I understand it correctly, the current code language requires that UV system be installed before the disinfectant feeder because UV can inactivate the free chlorine. If UV system is installed just prior to spray features, then we might lose the free chlorine responsible for killing germs other than Crypto. Maybe a better solution is to require 100% of recirculation flow to go through the UV system before the disinfectant feeder.”


Summary of pros and cons and/or benefits or deficitsPros: Increased protection for interactive water play aquatic venue patrons. And you only operate the UV system when the venue is being used which translates into energy savings.

Cons: Increased cost

CR# 4.7.3.3.3.4.1

Presenter Name: Technical Review Committee

Submitter Name: Ellen Meyer

Lonza

4.7.3.3.3.4.1 Proposed Change

SummaryRequire shutdown if UVT is less than the minimum validated transmissivity.

Code:

4.7.3.3.3.4.1A Alarm/Interlock Setpoint

The UV alarm/interlock setpoint shall be such that it ensures that the minimum required dose is delivered under all possible conditions of water UV transmittance and lamp output at the actual flow rate.

4.7.3.3.3.4.1 Proposed ChangeAnnex:

4.7.3.3.3.4.1 Alarm/Interlock Setpoint

This requirement is intended to ensure that UV sensor placement is taken into account when determining the minimum setpoint to alarm/interlock. UV equipment validated through the UV Intensity Setpoint Approach relies on UV intensity readings by UV sensors to account for changes in UV transmittance (UVT), and therefore UVT is not monitored separately during operations to confirm dose delivery. However, proper positioning of sensors is necessary to accurately relate a given UV intensity to a specific level of dose delivery, irrespective of changes in UVT or lamp output. Refer to EPA 815-R-06-007 Chapter 3 Section 3.5.2.1 and Appendix D Section D.2 for a discussion of the importance of ideal placement of sensors and the impact of sensor positioning on UV dose monitoring.

This requirement is not intended to specify sensor placement, which is addressed in the validation process. However, if a UV sensor is not placed as close as possible to the “ideal” location (i.e. positioned so that the UV intensity reading is proportional to the UV dose, irrespective of changes in UVT and lamp output), it is necessary to adjust the alarm/interlock setpoint accordingly. This adjustment should account for the disproportionate impact of changes in UVT or lamp output on the measured intensity as a result of sensor positioning to ensure that the minimum dose is delivered at the specified flow rate. EPA 815-R-06-007 Appendix D. Section D.2.1 items 1-3 and their respective examples (D.2, D.3, and D.4) and figures (D.5 (a), (b) and (c)) provide a detailed discussion of the impact of UV sensor positioning on the relationship between UV dose and intensity readings.

4.7.3.3.3.4.1 Rationale Behind/Benefit of CR

Rationale for CR

Many components in aquatic venue water can absorb UV and prevent it from obtaining 3-log inactivation of crypto. Public health could be impacted by having a UV system on a pool where the UV transmittance is not sufficient to ensure that 3-log reduction in crypto oocysts is occurring.

Technical Review Committee ReportCR# 4.7.3.3.3.4.1

Summary of internal TRC & TSC discussionThe Disinfection & Water Quality TSC felt that the original CR was unnecessary as it would require UVT monitoring.

The TRC agreed and worked with the submitter on modified language.



No CMAHC Member Comments



Benefit: Provides an additional measure of protection by requiring that the alarm/interlock set-point be adjusted if necessary to account for any disproportionate relationship between actual dose and measured intensity due to non-optimal sensor placement, which will better ensure that the UV system will shut down of there is insufficient dose due to a decrease in UVT.

Deficit: Does not address the need to consider validation of UV systems for spray features for a UVT that is more reflective of real-world conditions, so that systems are not inadvertently operated outside their validated range.

CR# 4.7.3.3.1.2-0001Draining Venues Instead of Hyperchlorinating


Submitter Name: Ellen Meyer

Lonza

4.7.3.3.1.2-0001 Proposed Change

Summary

Inserts alternatives to secondary disinfection for small pools

Suggested changes

4.7.3.3.1.2.1 Exceptions

For small bodies of water that are less than 500 gallons, the following operational requirements may be used in place of secondary disinfection:

1. Drain the venue daily, or

2. Hyperchlorinate the venue daily according to the diarrheal-stool contamination procedure in section 6.5.3.

4.7.3.3.1.2-0001 Rationale Behind/Benefit of CR

Rationale for CRThe objective of secondary disinfection is to limit a crypto outbreak to one day (see MAHC annex 4.7.3.3.2.5). For very small bodies of water, it should be left up to the operator to decide which treatment is the most practical for their facility.

Technical Review Committee ReportCR# 4.7.3.3.1.2-0001

Summary of internal TRC & TSC discussionDisinfection & Water Quality Committee: these are the increased-risk areas we are trying to make sure best practices are carried out. It is not practical that the alternative, which cannot effectively be monitored to be carried out, makes sense. Options are good but in this case the risk far out ways the benefit.

TRC draining procedure has a greater chance of limiting an outbreak to one day, but the people present during the day of the fecal accident would have a greater chance of becoming infected. From this analysis, I think either approach is valid, but neither is perfect. Intent of annex was treat and decrease over a day, not allow transmission through the day and then remediate.


Summary of internal TRC & TSC discussionTheoretically it would be well-operated facilities that are willing to do the extra work to drain or hyperchlorinate daily, but I can see this being an appealing option at the design stage where the cost of installing a secondary disinfection system could be avoided but then there being a lack of follow-through on the operational end (or subsequent water quality issues due to DBPs and/or inadequate ventilation). Granted UV or ozone systems must be operated properly too, but we may find ourselves in a situation where we are not engineering in a safeguard from the start and instead relying on proper operation and maintenance to achieve public health protection.

There is ongoing reduction of crypto by the UV system throughout the operating day. By changing to just the once per end of day dump or hyperchlorination, the concentration of crypto in the water will remain essentially the same throughout the day.


Summary of CMAHC member commentsOne comment:

“Spas should be included in those requiring UV or Ozone. Swim schools should also be in this category.”

This comment did not appear to be directly relevant to the proposed CR.


Summary of pros and cons and/or benefits or deficitsPros:

This would be an alternative to have secondary disinfection on small bodies of water with cost savings.

Cons:

Secondary disinfection is constant contaminate removal.

Waiting to end of day for contaminate removal could expose patron to higher contaminates levels throughout the day.

WEDNESDAY AM

CHAT ROOM COMMENTS

DISCUSSION

SECTION 11

New Filter Media, UV on Splashpads, Draining Pools

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E-mail: [email protected]

Phone: 678-221-7218

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thanks to cmahc sponsors...2017/10/18 · the lifeguarding and bather supervision tsc found this cr...

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