Aquatic facility operators are likely aware of the new Model Aquatic Health Code (MAHC), which was designed to provide a template, with scientifically supported backup, for states to update their aquatic health codes. There are 14 modules that have been written, opened for public content, and are now being “interwoven” into a complete first-draft document. This is expected to be completed in the first few months of 2014. It will then be reopened for public comment for the second, and final, round. The complete first edition of the MAHC is expected by summer 2014.
A Little Historical Review
The Center for Disease Control (CDC) secured a grant from the National Swimming Pool Foundation to act in concert with public health and aquatic industry representatives to prevent drowning and aquatic-related injuries while also reducing the numbers of recreational water illnesses (RWIs) at public pools and spas. In 2005, the CDC sponsored a workshop that addressed these issues. The result was the realization that the country did not have consistent standards and that the states often had widely differing levels of recreational water and facility regulation. So, it became a priority to create a model code that states could used to update their policies.
Why is the MAHC Important to Pool Operators?
The MAHC will be used by the states to update, augment or even rewrite their aquatic health codes. This has a direct effect on aquatic facility operators since they will need to comply with their new state codes. It may take several years for the states to study and adopt new codes based on the MAHC. In the meantime, pool operators should familiarize themselves with the portions of the model code that would require changes to their facility construction, operation and staffing. While the MAHC will be overwhelmingly positive for the health and safety of pool operations, it does have a downside in the amount of money, time and effort required for operators to meet the new standards.
The Modules and Their Effects on Facility Operators
The modules listed below are arranged in order of how they are listed on the CDC website. Each module will be named and its possible effect discussed.
- Facility Design and Construction Module. Impact: This module only applies to new construction or renovations of older facilities. Depending on the age and condition of a current facility, the increased costs to meet the module’s requirements may be 10 or more years in the future.
- Risk Management/Safety Module. Impact: Pools that have fallen behind industry standards of chemical storage, staff training, use of safety monitoring systems and general employee/patron health will need to update. Operators should not expect their state codes to allow safety aspects of a facility to be delayed or grandfathered in.
- Facility Maintenance and Operation Module. Impact: Just like in risk management, facilities that are not professionally managed will need to dramatically improve their procedures and documentation of the healthfulness of the facility.
- Monitoring and Testing Module. Impact: It will be very difficult to meet the module’s requirements without a large outlay of funds for chemical controllers and comprehensive chemical test kits. Operators need to assess the costs for the changes and work now to get the funding for when they will need it.
- Contamination Burden Module. This module is found only in the MAHC Annex. It includes definitions of terms and contaminants that are noted in the rest of the modules.
- Hygiene Facilities Module. Impact: This module outlines some recommended updates of older facilities with diaper-changing stations and improves suggested procedures to encourage patrons to take cleansing showers. This should prove to be a low-cost impact to facilities since most currently have changing stations in place.
- Fecal/Vomit/Blood Contamination Response Module. Impact: None if a facility has already changed their contamination Standard Operating Procedures.
- Operator Training Module. Impact: Summer-only pools used to having a seasonal pool manager will need to increase their training through a nationally recognized operator training program. This will cost approximately $200 and the manager will need to pass the exam. Trained operators must to be present or on call, so many pools will need at least two trained operators each.
- Preface, User Guide, Definitions Module. Impact: None. This is a housekeeping module that lists all of the definitions and how to use the modules.
- Recirculation Systems and Filtration Module. Impact: Once a pool is built, it would take major renovations to change the filtration and recirculation system. So, unless the pool is up for remodeling or renovation, this module should not affect a pool’s operation.
- Lifeguarding and Bather Supervision Module. Impact: This module may increase the cost to staff a pool since it requires a comprehensive, professional approach to staffing, equipping and training lifeguards. After initial equipment costs, there are long-term costs to certify and provide ongoing in-service training. An aquatic safety plan is required to be on file, and documentation of testing lifeguard competency must be a part of the facility records.
- Disinfection and Water Quality Module. Impact: While it is mostly addressing new facilities, this is a module that the states may apply to older facilities because of the additional sanitation benefits given by adding secondary disinfection. The cost for secondary disinfection can be significant. For example, a medium-pressure ultraviolet light system can cost $20,000 for a 100,000-gallon pool, even without factoring in the ongoing additional electrical costs.
- Regulatory Program Administration Module. Impact: The most likely result will be more time spent year round by organizational leadership to forge and maintain effective relationships with regulatory, EMS and the community, even if the facility is summer-only.
- Ventilation and Air Quality Module. Impact: Many facilities’ ventilation systems are built to code but are still not suitable to an aquatic environment. This may require upgrades to an indoor pool building’s air handling system if the building or pool has other major renovations.
Pool operators should visit the CDC website and download the modules. Carefully read the modules to look for areas where your facilities or practices may not be up to the same standard. Then, create a plan to upgrade policies, practices, procedures and facilities to meet the new standard of care.
John Whitmore, CPRE, AFOI, AFO, is the Organizational Development Manager for the City of Denton, Texas.