At the World Aquatic Health Conference in October, the Council for the Model Aquatic Health Code (CMAHC) held its bi-annual meeting to review and present many of the changes proposed for the upcoming edition.
A room full of professionals from all disciplines -- including aquatics operators, designers, manufacturers, service technicians, waterpark operators and public officials – gathered for a final exchange before voting. This year, nearly 200 change proposals were filed. Many of them were reviewed by a committee within CMAHC and either recommended or not.
Several of the proposed changes surfaced as hot topics:
· Certification requirement for chemicals: One proposal seeks to require all pool and spa chemicals to be third-party tested for certification to NSF 50, a relatively new standard aimed specifically at pool and spa chemicals. The proposal was met by resistance from some manufacturers, who believe it is enough for the products to meet NSF 60, a standard meant for drinking water. Others said the cost of third-party testing could jeopardize smaller manufacturers, or at least remove lower-selling skus from the market if profits can’t justify testing costs. Others believe that some specialty chemicals should not require regulation, if they are not traced to any harmful side effects. On the other side of the argument, professionals found it appropriate to have a standard specifically for pool and spa water and said the issue is too important to skimp. Some public officials said adherence to a set standard makes it easier for them to inspect facilities.
· Interlocks on chemical feeders: To prevent the kind of chemical spilling or flooding incidents that have made headlines, a proposal suggests requiring a chemical feeder interlock on all feeders. While the general concept wasn’t questioned, some believed the language is not specific enough and should require that the interlocks turn off the feeders when water flow is detected to be too low, and not shut down the power. Others thought a backup should be required, stating that certain types of interlocks have been known to fail.
· CYA levels: A proposal to reduce the maximum allowable cyanuric acid levels from 90 parts per million to 25 ppm, met something of a standstill, when the technical committee that reviewed it could not gain a consensus. As a special subcommittee has been exploring the issue of CYA levels, some would rather hold off on any changes.
· Change to pH levels: One proposal suggested reducing the minimum allowable pH level to 6.8 ppm, from 7.2. While some didn’t have a problem with it, stating that it was discretionary and operators could stick with the 7.2 ppm ceiling if they wanted, others said potential damage to surfaces and equipment were too risky. Others cited the fact that many methods for testing pH don’t have a reading that low, while some said lower pH can cause air quality issues.
· Calcium hardness levels: The Technical Review Committee recommended a yes vote on a proposal that would raise allowable calcium hardness levels from 1,000 to 2,500 ppm.
· Lifeguard instructor abilities: One proposal suggested that lifeguard instructors should be physically able to perform the job of a lifeguard. The technical review committee recommended against it, citing concerns about the Americans with Disabilities Act.
· Lifeguard supervision: Currently the MAHC requires one supervisor for every two lifeguard. If this change proposal passes, one supervisor would be needed for every three. While some said this showed progress, they also believed the ratio should be higher to allow for individual conditions, such as slow periods.
· Chlorine feeder sizing: One proposal would change the practice of sizing chlorine dosing and generating equipment. It would remove current dosing requirements and, instead, saying the equipment must be sized to “meet the demand necessary to maintain the minimum required free available chlorine concentrations specified in MAHC Section 184.108.40.206.1.2 during all times of operation. This would put the onus on designers to determine the best method of delivery, rather than on operators to monitor the dosing. While the Technical Review Committee endorsed the proposal, others believed dosing should be specified, since designers can’t plan in advance for factors that can affect free available chlorine, such as leaks and changes in bather load. Some believed the proposal doesn’t provide enough guidance for designers, while others said it doesn’t take into account the use of alternative sanitizers.
· Backboards: A change request would require that backboards be placed so that one can be reached within 2 minutes from any spot in a facility. While the technical review committee recommended the change, there was some disagreement: Some believed backboards should be within 1 minute’s reach, while others said even 2 minutes is impracticable for waterparks and larger spaces.
· Ultraviolet light on splashpads: While there seemed to be agreement that UV should be used on water play venues, others wanted specific information about where the UV injectors should be placed. They advocated placing the UV on the waterfeature pump, rather than the filtration pump, to guarantee that every drop of water released onto the pad will have been treated with UV. While some worried that the UV would destroy the chlorine that would have been injected before it, others said that newer UV systems do not destroy the chlorine.
Only CMAHC members are allowed to vote. Voting ends November 19. Once the ballots close, the results will be tabulated and presented to the Centers for Disease Control and Prevention, which implements the code and has the authority to accept or reject the advice of the CMAHC.
The Model Aquatic Health Code takes effect in those jurisdictions that adopt it.
The CDC and CMAHC have changed the procedure for updating the model code. Now, instead of releasing a new edition every other year, it will do so every third year, to give the committees more time to review change requests and to explore issues on its own.