California lifeguard agencies are grappling with the ramifications of a new law that’s prompting uneasy questions about the role of lifeguards in public safety.

Title 22 mandates that all public safety personnel, including lifeguards, undergo no less than 21 hours of advanced first-aid training. This goes beyond the instruction that certifying agencies provide to better prepare lifeguards for the pre-hospital emergency medical services they sometimes must perform.

The required training equips them with skills such as administering CPR and AED – things lifeguards typically learn on the job. But it also covers new ground. Approved training curricula also must address hemorrhage control, administration of oral glucose and how to render aid in drug and alcohol emergencies, dental emergencies, amputations and impalements, among others.

Responsibility falls on public recreation programs to provide the training.

Though the law went into effect in April 2015, it allowed a two-year grace period for agencies to implement a training plan. That time has passed, and some aquatics programs are still scrambling to comply.

The hang-up appears to be a change in the approval process. Before, the state would approve training curricula. Title 22 now places that responsibility on local emergency medical services authorities (LEMSA). Some of these agencies were caught off guard when local recreation departments requested that they rubber stamp their training plans.

“Some were like, ‘I have no idea what you’re talking about. I need to look into this,’” said Tom Hellmann, recreation supervisor at the Cosumnes Community Services District in Elk Grove, Calif.

Aquatics programs also were blindsided by the cost to have the trainings approved. LEMSA departments have been charging anywhere from $100 to $1,300, Hellmann said.

But lifeguard instructors do not have to create training curricula from scratch. Both the Red Cross and the American Safety & Health Institute currently have programs that meet California’s requirement. For its part, the Red Cross said it’s currently working with LEMSA to approve its Title 22 course.

Beyond the deadline and budgetary concerns, California’s code poses another challenge for the lifeguarding profession. The law essentially blurs the lines between lifeguards and advanced medical support professionals. Lifeguards wonder: Where do their responsibilities end and those of the EMTs begin?

“We’re taking them further away from their primary responsibility, which is the prevention of drowning,” said Hellman, who chairs the California Park & Recreation Society’s aquatics section. The organization recently assembled a task force of 12 lifeguarding professionals who are researching the law's potential ripple effects to see if it should be amended.

Some wonder if the additional training might prove too demanding for younger professionals who simply want a part-time job by the pool doing the occasional water rescue.

“What level of responsibility is appropriate for a 15-, 16- or 17-year-old?” asked Kevin Post, a principal at aquatics consulting firm Counsilman-Hunsaker. “Should a 15-year-old be delivering a baby on a pool deck?”

Yes, under Title 22, agencies can train guards to assist in childbirth. And therein lies the quandary.

Hellmann asks: “How far away from their primary responsibility are we willing to go to see that we’re meeting the requirements of the code?”