Wavelength - Swimming Pool Newsletter

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
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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].
•
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•
•
•
•
•
•
•
•
•
•
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.
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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.
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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.
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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.
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