O a k l a n d C o u n t y H e a l t h D i v i s i o n Wavelength Spring 2014 Welcome to the 2014 issue of the Wavelength. Along with this newsletter, the Oakland County Health Division (OCHD) provides a free pool seminar as part of our educational outreach to public swimming pool operators. This year the pool seminar will take place on Friday, April 25, 2014; see page 2 for more information. As a reminder, a State of Michigan Public Swimming Pool license must be renewed each calendar year and posted at the facility. An application and submittal instructions can be obtained by calling Teresa Fry, Michigan Department of Environmental Quality (DEQ), (517) 284-6529 or by e-mail at [email protected]. In addition, OCHD charges a $66.00 annual inspection fee per pool. The fee is required for both new and renewal applications for the 2014 season and is separate from any fees that are paid to DEQ for licensure. Click here for the link to Oakland County Health Division’s Environmental Health Services Application for Inspection/ Review. Failure to submit the appropriate fee and complete the inspection process will result in forfeiture of your State of Michigan license for the following year. Call the OCHD Environmental Health Services office in Pontiac with questions regarding the license and/or inspection fees. An inspection cannot be done on your pool until all fees have been paid. OCHD looks forward to building a strong working relationship with you and your staff. We recommend keeping a copy of the State of Michigan Public Swimming Pool Rules (Click here for link) available for reference as you prepare your pool for opening this spring. As always, feel free to contact us with questions. We wish you a safe and healthy swimming season. Save the Date APril 25, 2014 Spring 2014 POOL SEMINAR “Crack the Code: Michigan Public Swimming Pool Rules” In This Issue “Crack the Code: MI Public Swimming Pool Rules” Seminar 2 Americans With Disabilities Act Update 2 Model Aquatic Health Code Update3 What are Therapy Pools? 3 Chlorine vs. Bromine in Spas 4 Enclosures 4 Swimming Pool Modifications5 Before Your Pool Inspection, Check the Plumbing! 6 Pool Attendant and Lifeguard Roles and Responsibilities 6 Article Quick Links 7 CDC Healthy Swimming App7 Swimming Pool Monthly Operational Report 7 Oakland County Health Division 1200 N. Telegraph Rd., Pontiac, MI 48341 L. Brooks Patterson Oakland County Executive Page 1 Spring 2014 Wavelength For More Information Contact: Pontiac - EHS 1200 North Telegraph 34E Pontiac, MI 48341-0432 248.858.1312 FAX 248.452.9758 Southfield - EHS 27725 Greenfield Rd Southfield, MI 48076-3625 248.424.7191 FAX 248.424.7115 Click here to view the EHS Pool Program website. The Oakland County Health Division will not deny participation in its programs based on race, sex, religion, national origin, age or disability. State and federal eligibility requirements apply for certain programs. Spring 2014 POOL SEMINAR: “Crack the Code: Michigan Public Swimming Pool Rules” Join us for a review of the DEQ Pool Rules and gain insight into what to expect from your annual OCHD public swimming pool inspection. Save the following date: Date: Friday, April 25, 2014 Cost: Free Location: Oakland County Executive Office Building East and West Oakland Conference Rooms 2100 Pontiac Lake Rd, 41W Waterford MI 48328 Schedule: 8:30 am to 9:00 am - Registration 9:00 am to 1:00 pm - “Crack the Code: Michigan Public Swimming Pool Rules” Note: No lunch break will be provided Pre-Enrollment required. Click here to register on-line or contact Richard C. Peresky at 248-858-1007 or by email at [email protected]. Americans with Disabilities Act Update In the 2013 Wavelength, a review of the revised Americans with Disabilities Act law discussed required pool modifications, entry access point types, and legal aspects. The implementation date was January 31, 2013. Paul Sisson, Michigan Department of Environmental Quality (DEQ), was asked about notable changes after the new implementation date. He expressed concern regarding pools that have a chair lift with no attendant present as the lifts must be capable of unassisted operation. The DEQ updated the “2010 ADA Standards and Public Swimming Pools Frequently Asked Questions” (Click here for link). The updates include a discussion on how the 2004 American with Disabilities Accessibility Act Guidelines (ADAAG) differ from the Michigan Public Swimming Pool Rules. Click here for the link to the ADAAG Chapter 10 section specific to public pools located under ‘Recreation Facilities’. The DEQ document also reiterates that construction permits are only required by the DEQ for proposed modifications that change the structure of the pool such as sloped entries and transfer walls. Having a construction permit for such modifications will verify the required pool rules are being followed. Enforcement of the ADA is by the United States Department of Justice (DOJ) and through local building officials. The primary mode of enforcement is through private lawsuits, many of which were filed within weeks after the January 31, 2013 deadline. When an ADA violation complaint is filed, there may be mediation, or an investigation may take place. Mediation involves the complainant and facility working to find a mutually acceptable resolution to the concern. A DOJ investigation is another option where a complaint is kept open for an extended period to find out if the complaint is an individual case or has impacted the general population. Oakland County Health Division can provide contact information for local building departments or the DOJ. Both public and private lawsuits can take place under the ADA. A person may pursue civil trial, often in district court. The DOJ may also pursue legal action against a facility when many ADA violations occur against the public. For more information, call the DEQ at (517) 284-6541. DOJ offices can be reached at (800) 514-0301. 2 Page Spring 2014 Wavelength Model Aquatic Health Code Update What are Therapy Pools? The 2013 issue of the Wavelength described, in detail, the Model Aquatic Health Code (MAHC). To date, all 14 draft modules of the MAHC have been through the public comment period at least once. Water therapy can be a great way to exercise. It reduces joint stress, supports a longer work out, and may even help improve mood. Public swimming pools were defined by the Michigan Department of Environmental Quality (DEQ) Public Swimming Pool Rules in January 2005 as “…an artificial body of water used collectively by a number of individuals primarily for the purpose of swimming, wading, recreation, or instruction ...” They may be located at: The revised modules, with topic examples covered after the first public comment period include: • Disinfection and Water Quality: Chemical levels, cyanuric acid prohibitions, and secondary disinfection • Regulatory Module: Aquatic Health Advisory Committee, plans, and permits • Risk Management/Safety: Depth markers, employee training, glare reduction, and water temperature • Facility Maintenance and Operation: Closure, planning, and daily records • Monitoring and Testing: Water quality testing devices, automatic controllers, and dye testing • Contamination Burden: Particle contamination burden and disinfectant demand/byproducts • Hygiene Facilities: Hygiene facility location, diaper changing, and shower type • Fecal/Vomit/Blood Contamination Response: Vomit/ stool planning, blood response, and training • Operator Training: Course elements, instructor qualifications, and certificate validity • Preface, User Guide, Definitions: Recommendation and scientific decision support The other modules, including topic examples, that are closed for public comment include: • Recirculation Systems and Filtration: Water supply requirements and improved flow meter use • Facility Design and Construction: Pool shape, lighting, waste water, electrical, and specialty items • Lifeguarding and Bather Supervision: Aquatic Facilities Safety Plan and patron watch zones • Ventilation and Air Quality: Make-up air quantity/ sources and combined chlorine concerns As each module is revised it is being merged with other revised modules to create a final draft version. This should be available in early 2014. The first edition of the MAHC after the second round of public comment review should be ready in the summer of 2014. Comments can still be submitted to the MAHC coordinator by e-mail or mail. For contact information click here. For more information on the MAHC click here to visit the Centers for Disease Control and Prevention’s website. Questions can be directed via email to [email protected]. • • • • • • • • • • • • Parks Schools Motels Camps Resorts Apartments Clubs Hotels Mobile home parks Subdivisions Waterparks The like The rules define what is not a public swimming pool as “…pool or portable pool located on the same premises with a 1-, 2-, 3-, or 4-family dwelling and for the benefit of the occupants and their guests…” and “…an exhibitor’s swimming pool built as a model at the site of the seller and in which swimming by the public is not permitted, or a pool serving not more than four hotel, motel, apartment, condominium, or similar units...” Thus, based on definition alone, therapy pools should be licensed and regulated. Therapy pools can vary in size and use. Some may be for one person while others may be used by groups. They may have the same features as spas and some have a tread mill or water jets. Therapy pools are often located at skilled nursing sites, retirement homes, medical offices, and hospitals, and are used there under the care of a health aide or by appointment only. Therapy pools may even be used as part of a physical therapy program. These pools require approval to construct, a license, and an inspection each year. Contact Paul Sisson at the DEQ at (517) 284-6541 or [email protected] when making small changes, large changes, or to build. Contact the Oakland County Health Division for inspection information and daily concerns. Page 3 Spring 2014 Wavelength CHLORINE VS. BROMINE IN SPAS The general nature of the spa environment changes the water balance more readily, often making it very challenging to maintain. Elevated water temperature, aeration, and high bather loads are the main culprits to the issues commonly associated with spas such as higher bacterial levels. The National Swimming Pool Foundation recommends that a spa operator consider checking the disinfectant and pH levels in a spa on an hourly basis vs. three times a day for a swimming pool. Whether using chlorine or bromine as your sanitizer, it is often recommended that residual levels be kept higher in spas. Free chlorine levels between 3.0 ppm and 5.0 ppm (mg/L) (with a maximum combined chlorine level of 0.5 ppm) and bromine levels of 4.0 ppm to 6.0 ppm (mg/L) are generally suggested. Bromine is usually preferred over chlorine in a spa environment due to its greater performance at higher pH levels and because spa clients usually do not have as many skin and eye irritation complaints. Higher levels of contaminants, commonly found in spas, cause the formation of chloramines or bromamines. These compounds are the irritants that will often result in user complaints. The use of bromine, and subsequently the bromamines that are formed, are less irritating to the eyes and mucous membranes, contributing to bromine’s higher rate of use. Enclosures When preparing your outdoor pool for opening this spring, do not forget to check the fence and gates. Refer to Rule 28 of the Michigan Public Swimming Pool Rules. A minimum four foot tall fence, as measured from the outside, is required to surround and enclose the entire pool. More than one pool may be contained by the same enclosure; however, wade pools must be enclosed separately. Also, it is important to remember that the fence is designed to keep people out of the pool when it is not open to the public. Thus, the enclosure must be designed to prevent passage through or under, and cannot provide any footings for climbing. Take a look at the landscaping, walls, structures, and bike racks that may be located near the outside of the fence. Do any of them provide easy access for climbing over the fence to gain entry into the pool? If so, these items may need to be removed or modified. In addition, remember gates must be self-closing, latching, and lockable. These should be checked on a regular basis. Please contact Oakland County Health Division, Environmental Health Services if you have any questions. 1-800-784-8669 Contact 248-858-8745 for further information on tobacco dependence. The Oakland County Health Division will not deny participation in its programs based on race, sex, religion, national origin, age or disability. State and Federal eligibility requirements apply for certain programs. The Michigan Department of Community Health offers many solutions to those who want to quit Tobacco. Finding the right one is up to each individual and we encourage people to visit the MDCH Quit Tobacco tools and resources website. RoxanneCondit/MyBookGraphics/SubstanceAbuse/YouCanQuit/02.14.2012 Page 4 Spring 2014 Wavelength Swimming Pool Modifications Public swimming pools require periodic care or upgrades. This may include equipment changes that are not the same as the make and model originally installed. At these times it is important to obtain approval from the Michigan Department of Environmental Quality (DEQ) prior to changing equipment. Click here for helpful forms available to assist you with reporting pool modification information to DEQ. The ‘Public Swimming Pool Equipment Change Form’ is used when a change is made to the pump, filter, chemical feeder, chemical controller, or flow meter. The DEQ is required to review plans for all new public swimming pools and for new equipment installation that is not a simple replacement for the same make and model. Changes may have occurred that were not properly noted. Equipment that is not being changed should have a mark in the box labeled ‘Existing’ and the rest of the information completed. If a chemical controller is not being changed, place an ‘X’ in the box next to ‘Existing’ and write down the make, model, and feeder capacity. Prior to salt generation system installation, a ‘Salt Feeder Installation Form’ must be completed and submitted for review. Salt generation systems are becoming more popular as many pool operators are finding the ease of handling and storing salt preferable to chlorine or bromine. It is important to list the type of backup system that will be installed. The chlorine or bromine reserve system is used if the salt feeder is not working. There are times when both forms need submission. This could happen when a pool is remodeled with changes to the filter and chemical feeder. It is a must to fill out the forms completely. Not providing complete data may leave out information necessary to make an informed decision. Making a bad choice can lead to problems. For example, if a pump is too large for a sand filter, sand could enter the swimming pool when the pump is started. Or if a spa is required to run at 37.5 gpm and the lowest reading on the flow meter is 40 gpm, it would be impossible to gain an accurate flow meter reading. If you need help with finding some of the information for existing equipment, most models contain a data plate that has at least the make, model, and serial number. The manufacturer company’s web site may also provide some data. The pool operator or manager can also contact the DEQ or Oakland County Health Division to see if files contain other needed data. Paul Sisson, with the DEQ, can be reached by phone at (517) 284-6541, or by e-mail at sissonp@ michigan.gov or contact OCHD Environmental Health Services at (248) 858-1312. Page 5 Spring 2014 Wavelength Before Your Pool Inspection, Check The Plumbing! As you prepare to open your pool for the season, and complete your seasonal opening checklist, it is important to confirm that all plumbing backflow prevention devices are in place and working. A simple review of the pool plumbing will help avoid unnecessary pool violations. Below is a list of common pool plumbing violations and solutions: (1)No backflow prevention device on the indoor or outdoor spigot. Solution: When a hose may be attached to a spigot it is required that the spigot be equipped with a hose bib vacuum breaker (ASSE 1011). (2)A hose bib vacuum breaker is attached to an outdoor spigot, however, the outdoor spigot features a hose with a spray handle on the end of it. A shut off device, in this case the spray handle, cannot be used if the only backflow prevention device is a hose bib vacuum breaker. Solution: Install a pressure vacuum breaker (ASSE 1020) on the waterline that feeds the outdoor spigot, or remove the spray handle after each use. (3)The backwash discharge line is directly connected to the waste water line or is hanging inside of the sump pump drain basin. Solution: Provide an air gap between the wastewater discharge line and the waste water drain (sewer) or sump pump drain basin. Please note the size of the air gap must be at least 2 pipe diameters of the wastewater discharge line. (4)Backwash water is being discharged to a storm drain. Solution: Reroute the pool waste water so that all waste water is being discharged, through permanent piping, into a sewer line. (5)There is no backflow prevention device on the main water supply line that feeds the pool. Solution: Install a reduced pressure zone (RPZ) backflow prevention device on the water supply line. The RPZ (ASSE 1013) should be installed before any pool treatment equipment, or provide an air gap between the main water supply line and the receiving pipe, vessel or tank. Please note: the size of the air gap must be at least 2 pipe diameters of the water supply pipe. Ensuring that all backflow prevention devices are in place and working will help to avoid unnecessary pool violations and ensure water supplies are protected and safe. Pool Attendant and Lifeguard Roles and Responsibilities It is important to distinguish between a pool attendant and a lifeguard. A pool attendant may track patrons as they enter and exit the pool, spend time taking water readings, and tend to the water filtration system that is usually located somewhere indoors. A lifeguard is trained for water rescues and submersions and has obtained required certifications. A lifeguard must also keep their eyes on the water at all times to prevent drownings. Therefore, the two positions require vastly different skills. The most important duty of a pool attendant is to maintain the water’s chemistry, clarity and color. If the attendant fails in any of these, it can result in terrible health concerns for swimmers. In addition, poor water maintenance can cause the health division to close the facility. Besides water maintenance, a pool attendant is often required to enforce pool facility rules and attendance policies, as well as clean and maintain the deck and any bathrooms or changing rooms in the pool area. A lifeguard is responsible for the health and safety of the patrons in the pool and is required to hold special certifications that include passing both an approved lifeguarding course and a cardiopulmonary resuscitation course. A lifeguard must be clearly identifiable as such and is required to wear swimming attire while on duty. A lifeguard must be aware of their surroundings at all times and must be in a strategic poolside location to ensure a view of the entire pool. In many instances, more than one lifeguard may be required based on the number of swimmers in the enclosure as well as the shape of the pool. In addition to watching swimmers, a lifeguard monitors for conditions that may lead to dangerous situations. If injuries occur, a lifeguard is trained to provide basic first aid. For more serious injuries, a lifeguard has access to emergency phone numbers and trained personnel. See Rule 98 of the Pool Rules for specific requirements for lifeguards. Page 6 Spring 2014 Wavelength Article Quick links Environmental Health Services Application for Inspection/Review: http://www.oakgov.com/health/Documents/EH/eh_app_insp_ review.pdf State of Michigan Public Swimming Pool Rules: http://www.michigan.gov/documents/deq/deq-dwrpd-eh-swmplSR_Rules_PRINT_COPY_2-8-01_ 270447_7.pdf “Crack the Code: Michigan Public Swimming Pool Rules” Registration: http://www01.oakgov.com/servicesreg/ “2010 ADA Standards and Public Swimming Pools Frequently Asked Questions” http://www.michigan.gov/documents/deq/deq-rmd-dwehs-spadafaq_368038_7.pdf CDC Healthy Swimming App Download the Center for Disease Control and Prevention’s free Healthy Swimming App for iPhones and iPads before heading to the pool. It provides pool operators with the latest information on pools and spas, including helpful tips on how to answer patron questions. All of this material can be at your fingertips, conveniently loaded on your mobile device. http://www.cdc.gov/healthywater/swimming/ resources/apps.html Americans with Disabilities Act Accessibility Guidelines (ADAAG) Chapter 10 http://www.access-board.gov/guidelines-and-standards/ recreation-facilities Model Aquatic Health Code Contact Information: http://www.cdc.gov/healthywater/swimming/pools/mahc/ comments.html Model Aquatic Health Code: http://www.cdc.gov/healthywater/swimming/pools/mahc/ structure-content/index.html Swimming Pool Modifications Forms: www.michigan.gov/deq/0,4561,7-135-3313_51087_ 3732----,00.html CDC Healthy Swimming APP http://www.cdc.gov/healthywater/swimming/resources/apps. html MI Dept. of Environmental Quality MOR template: http://www.michigan.gov/documents/deq/deq-wb-dwehs-spmor_254923_7.pdf Swimming Pool Monthly Operational Report The Swimming Pool Rules require that the operator of a public swimming pool fill out a monthly operational report (MOR) daily. The completed report must then be submitted to Oakland County Health Division (OCHD) within 10 days of the end of each month that the swimming pool is in operation. One report form must be submitted for each swimming pool. The report must include daily sanitizer residual and pH test results, flow rate, chemical addition quantities and maintenance issues. OCHD strongly recommends recording the pH and sanitizer results three times per day. Additionally, any safety or contamination events must also be noted. You may use the template found on the Michigan Department of Environmental Quality website click here for template or submit your own design to OCHD for approval. If creating your own report, be sure to include all information found on the template. Page 7
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