Thanks to CMAHC Sponsors

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1 Founding Sponsors Thanks to CMAHC Sponsors Gold Silver Bronze Conference Sponsors

2 CMAHC CR-TRC Presentations Tuesday Afternoon Sections 4-7

3 Remember for CR Presentations and Comments Times to be strictly adhered to! Speakers come to stage table as presentations approach Sign on and use the chat room to make yourself heard Stick to the CRs being presented in that hour Section Summary of chatroom comments each hour to be presented Slide presentations will be on 2017 conference page Submitter slide submission and changes going on too late to be able to post so they will be posted in next several weeks You can still (and should if you feel strongly) submit member comments for 1 month after the conference (until November 19) Submit and influence final CRs in the vote

4 Pool Chemical Certification, Listing, and Labeling and Chlorine Out-gassing Events TUESDAY PM CR PRESENTATIONS SECTION 4

5 CR # s: / / / / / and Presenter Names: Harold Evans/Blake Stark Submitter Names: Harold Evans/Theresa Bellish Disclosure Statements: Harold Evans is a member of the NSF/ANSI 50 Recreational Water Facilities Joint Committee. Blake Stark is a member of the CMAHC Recreational Water Facilities Joint Committee.

6 CR Proposed Change: Summary: Include certification to NSF/ANSI Standard 50 as a specification/requirement for pool chemicals. Suggested changes: Add requirement: Chemicals used in recreational water facilities shall be certified to NSF/ANSI 50 by an ANSI accredited certification organization.

7 Rationale Behind/Benefit of the CRs: The chemical safety evaluations under NSF/ANSI 50 provide verification that recreational water treatment products do not impart undesirable levels of chemical constituents or contaminants to the water. The evaluations include the oral, dermal, and inhalation exposure of chemicals.

8 Technical Review Committee Report 5.7.3/ / / / / / Summary of internal TRC & TSC discussion DWQ TSC indicated general approval for all the CRs requiring NSF-50 listing of pool chemicals TRC had unanimous consensus for a NO vote recommendation, as no requirements exist for oxygen feedstock in NSF 50, so the addition is inappropriate.

9 Technical Review Committee Report 5.7.3/ / / / / / Summary of internal TRC & TSC discussion The TRC approved of the CR on stabilizers with the modification to certified, listed, and labeled. TRC Comments NSF/ANSI 60 certification is required by most drinking water regulatory authorities in the U.S. and Canada, and is also used as a benchmark criteria for acceptance of pool chemicals by some regulatory authorities. The limitation of NSF/ANSI 60 as a standard for pool chemicals is that the dermal and inhalation routes of exposure are not part of the Standard 60 evaluation criteria. There is a larger number of certified chemicals available under NSF/ANSI 60, with a smaller but growing number of chemical products being certified under Standard 50."

10 Technical Review Committee Report 5.7.3/ / / / / / Summary of internal TRC & TSC discussion TRC approved of the CR on pool grade salt with the modification to certified, listed, and labeled :- No requirements exist for oxygen feedstock in NSF 50 so the addition is inappropriate The TRC approved of the CR on clarifiers, flocs, and defoamers with the modification to certified, listed, and labeled and noted that the submitter of CR agreed to alter their CR, deferring to the language of this CR.

11 Technical Review Committee Report CR 5.7.3/ / / / / / Summary of internal TRC & TSC discussion DWQ TSC indicated general approval for all the CRs requiring NSF listing of ph adjustment chemicals.

12 Technical Review Committee Report CR 5.7.3/ / / / / / Summary of CMAHC member comments & & We agree with the addition of NSF 50 here, but the following change to the text: certified listed and labeled to NSF/ANSI Standard 50 by an ANSI accredited certification organization. TRC used certified, listed, and labeled & There are no requirements for oxygen feedstock in NSF 50, so we do not understand how or addition is appropriate. NSF 50 states that the required quality and feed gas flow rate is determined by the manufacturer".

13 Technical Review Committee Report CR 5.7.3/ / / / / / Summary of pros and cons and/or benefits or deficits & & & & Pros: Chemical safety evaluations verify the recreational water treatment products do not impart undesirable levels of either chemical constituents or contaminants to the water. Provides operators and regulators a means to determine if chemicals are appropriate for use in aquatic venues. Cons: Certification, listing and labeling of chemicals to NSF-50 Annex R will increase the cost of pool chemicals. Requiring certifications of chemicals may limit competition and product choices.

14 Technical Review Committee Report CR 5.7.3/ / / / / / Summary of pros and cons and/or benefits or deficits & Cons: No requirements exist for oxygen feedstock in NSF 50 so the addition is inappropriate.

15 CR#: / / / / / / Reducing the Risk of Chlorine Outgassing Events Presenter Name: Jason Wilken, PhD, MPH; Michael Beach Submitter Name: Jason Wilken, PhD, MPH Submitter Conflict of Interest to Report? None

16 CR#: / / / / / / Summary: Multiple CRs covering engineering, maintenance, training, and policy to reduce the risk of the recirculation system shutting off while the chemical feed continues. This can lead to dangerous outgassing in the piping and exposure of patrons to a chlorine gas plume when the recirculation is turned back on.

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18 Contra Costa Waterpark Chemical Controller Regulates feed of concentrated muriatic acid and sodium hypochlorite into recirculation line (maintains ph and free chlorine) Equipped with rotary flow sensor Interlocked with an overfeed alarm to prevent chemical feed in the absence of recirculation flow.

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20 Muriatic acid Sodium hypochlorite Chlorine gas

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25 CR : Proposed Change Protocols to prevent chlorine gas exposures among bathers resulting from equipment failure or human error Suggested changes: to follow

26 Interlock Controls and No or Low Flow Deactivation All chemical control and feed systems feeders in new or existing aquatic facilities shall be provided upon adoption of this CODE with an automatic means to be disabled through an electrical interlock with at least two of the following: 1) Recirculation pump power, 2) Flow meter/flow switch in the return line, 3) Chemical control power and paddle wheel or flow cell on the chemical controller if SAFETY test confirms feed systems are disabled through the controller when the pump is turned off, loses prime, or filters are backwashed.

27 Interlock Controls and No or Low Flow Deactivation (continued) The electrical interlock system shall be installed per manufacturer s instructions and shall never be altered.

28 Installation The chemical control and feed systems feeders shall be installed according to the manufacturer s instructions Installed and Interlocked Chemical feed system components shall be installed and interlocked so the chemical feeder it cannot operate when the RECIRCULATION SYSTEM is in low or no flow circumstances as per MAHC

29 For new installations and replacement equipment, if the feeder is disabled through the electrical interlock, a visual alarm or other indication shall be initiated that will alert staff on-site for bather evacuation.

30 When the interlock is activated stopping flow of chemical feeders per MAHC and , or the water recirculation pump is stopped manually or unexpectedly for any reason and duration (including power outages), all BATHERS shall be evacuated from the AQUATIC VENUE until manual evaluation of the cause for interlock activation or recirculation pump interruption is completed by the RESPONSIBLE SUPERVISOR or QUALIFIED OPERATOR.

31 (continued) BATHERS shall not be permitted to reenter the AQUATIC VENUE until the RESPONSIBLE SUPERVISOR or QUALIFIED OPERATOR has successfully understood the cause of the interlock activation and/or recirculation pump interruption and has manually overridden the interlock for restart of the recirculation pump and chemical feeder [and UV or ozone system, if applicable] for 5 minutes following the restart of these systems in order to prevent BATHER exposure to dangerous chlorine gas that potentially formed during the pause in recirculation pump flow.

32 Ultraviolet Light Operate with Recirculation System UV systems shall only operate while the RECIRCULATION SYSTEM is operating Any interruptions in UV system operations that are triggered by an interlock per MAHC shall be evaluated as possible evidence for low flow state of the AQUATIC VENUE pumps, prompting bather evacuation according to

33 Ozone Any interruptions in ozone system operations that are triggered by an interlock per MAHC shall be evaluated as possible evidence for low flow state of the AQUATIC VENUE pumps, prompting bather evacuation according to

34 CR : Proposed Change Protocols to prevent chlorine gas exposures among bathers resulting from equipment failure or human error Suggested change: Prior to permitting BATHER entry in to AQUATIC VENUE each day, the RESPONSIBLE SUPERVISOR or lifeguard shall inspect that the recirculation pump is running at full design capacity

35 CR : Proposed Change Protocols to prevent chlorine gas exposures among bathers resulting from equipment failure or human error Suggested change: Backwashing without Bathers Present: BATHERS shall not be permitted to reenter AQUATIC VENUE until the RESPONSIBLE SUPERVISOR or QUALIFIED OPERATOR ensures that the recirculation pump and chemical feeders have restarted and run for a minimum of 5 minutes following completion of backwashing.

36 CR : Proposed Change Recognizing symptoms of chlorine gas exposure and appropriate first aid, and ensuring that only those properly trained perform water quality and equipment monitoring Suggested change: As follows

37 The training shall include at a minimum: 1) How to recognize and avoid chemical hazards; 2) The physical and health hazards of chemicals used at the facility; 3) How to detect the presence or release of a hazardous chemical; 4) Required PPE necessary to avoid the hazards; 5) Use of PPE; 6) Chemical spill response; and 7) How to read and understand the chemical labels or other forms of warning including SDS sheets; and 8) initial first-aid for a chemical release including basic physical decontamination (i.e. irrigation), and respiratory decontamination (i.e moved exposed bathers away from chemical release, upwind, circulate air if possible). Monitoring and management of water quality and equipment shall be undertaken only by those trained per MAHC

38 CR : Proposed Change Reporting of chemical exposures Suggested change: As follows

39 The POOL owner/operator should immediately report to the permit issuing official any injuries or exposures resulting in death or that require emergency medical response, resuscitation or transport to medical facility, chemical decontamination, or any illness suspected of being associated with bathing water quality or use of the AQUATIC FACILITY. The POOL owner/operator will have posted and available for use the routine phone numbers and after hours phone numbers necessary for reporting to the permit issuing official. This will facilitate a rapid investigation of the incident and could result in limiting further spread of infectious pathogens that cause disease and additional injuries.

40 CR : Proposed Change Protocols to prevent chlorine gas exposures among bathers resulting from equipment failure or human error Suggested changes: As follows

41 Maintained All chemical feed equipment shall be maintained in good working condition The system and its components shall be tested on a regular basis to confirm that all safety features are functioning correctly. Unless specified otherwise by the device manufacturer, once monthly challenge testing of the chemical feeder interlock system shall be conducted by turning off recirculation pump flow to the chemical feeder and ensuring triggered shutoff of chemical feeder occurs via electrical interlock with flow meter/flow switch, paddle wheel, or other device being used to assess flow to chemical feeder. Following confirmation of triggered shutoff, recirculation flow shall immediately be restarted.

42 Daily Water Monitoring and Testing Records Daily, or as often as required, MONITORING and testing records shall include, but are not limited to the following: 1) ph level, 2) Disinfectant residuals, 3) Combined CHLORINE concentrations, 4) Operating pressures of water recirculation pumps and filters or the corresponding flow rate from flow meter readings, 5) CYA levels, if used, 6) Maintenance and malfunctioning of equipment, including dates and time of all equipment calibration including WQTDs, and dates of challenge testing of the chemical feeder interlock system as outlined in MAHC

43 CR : Proposed Change Protocols to prevent chlorine gas exposures among bathers resulting from equipment failure or human error Suggested changes: As follows

44 Any of the following violations are IMMINENT HEALTH HAZARDS which shall require immediate correction or immediate POOL closure: 1) Failure to provide adequate supervision and staffing of the AQUATIC FACILITY as prescribed in this CODE; 2) Failure to provide the minimum DISINFECTANT residual levels listed in various sections of this CODE; 3) ph level below 6.5; 4) ph level above 8.0; 5) Failure to continuously operate the AQUATIC VENUE filtration and DISINFECTION equipment; 6) Use of an unapproved or contaminated water supply source for potable water use; 7) Unprotected overhead electrical wires within 20 feet horizontally of the AQUATIC VENUE; 20) any unplanned deactivation of recirculation pump and/or interlock deactivation of chemical feeders, UV system, or ozone system.

45 CR# Setting the Level of Recirculation for Chemical System Interlock Activation Presenter Name: CMAHC Technical Review Committee Submitter Name: James Amburgey

46 Proposed Change Summary Clarifying wording involving chemical feeder interlocks. Sets 70% of turnover rate as level below which the interlock kicks in. Suggested changes Interlock Controls and No or Low Flow Deactivation All chemical feeders in new or existing aquatic facilities shall be provided upon adoption of this CODE with an automatic means to be disabled through an electrical interlock with at least two of the following: 1) Recirculation pump power less than 70% of the level required to achieve the maximum turnover time for the pool, 2) Flow meter signal less than 70% of the level required to achieve the maximum turnover time for the venue or a flow switch located in the return line for water to the venue, 3) Chemical control power paddle wheel or flow cell on the chemical controller if SAFETY test confirms feed systems are disabled through the controller when any of the following three conditions occur: the pump is turned off, pump loses prime, or one or more filters are backwashed.

47 Rationale Behind/Benefit of CR Rationale for CR : Chemical feeder interlocks will help prevent chemical exposure injuries to bathers and staff.

48 Technical Review Committee Report CR# / / / / / / Summary of internal TRC & TSC discussion : D&C TSC vote Yes with modification. O&M TSC vote No to original CR, issues addressed in revision. IPRM&S felt that the CR was too extreme and that the wording should be re-evaluated. The committee agreed with the intent but the wording demanded evacuation and could be interpreted as an emergency situation. Based on the current code, the CR calls for alarms anytime the interlock is activated including backwashes. This could create panic situations and also does not consider automatic backwash systems.

49 Technical Review Committee Report CR# / / / / / / Summary of internal TRC & TSC discussion FMO TSC It is not possible for a Supervisor or Lifeguard to be able to confirm the pump is running at maximum designed capacity. Suggest changing that the flow is within permitted guidelines. RF TSC agreed with submission The TRC took the TSC/Member Comments and Recommendations into consideration, and after some discussion the TRC felt like the changes proposed were already sufficiently addressed in the existing Code language MAHC section (Daily inspection list)

50 Technical Review Committee Report CR# / / / / / / Summary of internal TRC & TSC discussion The IPRMS, OM and RF TSC committees were opposed to the original wording of the CR. The TRC thought that the existing text in the section Backwashing with Bathers Present was sufficient to protect bathers from chlorine gas exposure and that the additional text was not needed in this section. A new section was created to cover re-entry of bathers to a venue after backwashing without bathers present.

51 Technical Review Committee Report CR# / / / / / / Summary of internal TRC & TSC discussion IPRMS and FMO TSC thought it was acceptable. The TRC felt like the changes proposed were already sufficiently addressed in the existing Code language. The addition of #8 was already covered under #7, as precautions, what to do if there is a chemical released, and basic first aid is listed in the SDS information/label. Further, it was not clear what the training requirements would be as written O&M vote No, not feasible for AHJ to respond to this type of incident at all times, the list currently in the MAHC is too broad. TSC believes that this is a good recommendation to add to the annex.

52 Technical Review Committee Report CR# / / / / / / Summary of internal TRC & TSC discussion No formal TSC comments received. TRC comments included A mix of data was provided. The peer reviewed journal reference described the effect of chlorine on lungs, but provided minimal incident information. The two California cases provided more incident information, but no peer reviewed journal references were provided. Now published and provided on handout table TSCs felt it was acceptable. The TRC felt changes proposed were already addressed in the existing Code language. The addition of #20 was already covered under #5 (recirculation off), and it was decided that the catch-all of #19 (any other public health hazard) was sufficient to capture anything not covered.

53 Technical Review Committee Report CR# / / / / / / Summary of CMAHC member comments : Disagree: CR should be broken down into individual units for separate voting. Agree: The feeder should turn off if the pump is off. What about automatic filter backwash? Seems too broad for small facilities Disagree : stating that electrical interlocks should not be required on feeders

54 Technical Review Committee Report CR# / / / / / / Summary of CMAHC member comments There was one Member Comment Submitted that agreed with this CR: I think the last addition goes too far. At non-lifeguard facilities we do not want to limit the persons doing water tests. We want to limit the people APPLYING the chemicals. We also need to include language that management will not value engineer the chemical purchase. If I remember correctly the NSF listed feeders have the product information on the label. I don't think it says these products can cause fire, explosion and chlorine gas releases if mishandled.

55 Technical Review Committee Report CR# / / / / / / Summary of pros and cons and/or benefits or deficits Pros: Change should help prevent chlorine gas incidents Cons: Increased costs in equipment (alarm system) and time (extra steps and responsibilities for operator).

56 Technical Review Committee Report CR# / / / / / / Summary of pros and cons and/or benefits or deficits Pros: The built-up chemical release is a concern. There is growing concern over reducing recirculation rates with VFD s or throttling valves to save energy costs and this would help to ensure a dangerous condition is not created in doing so. Cons: Hard for certain staff to do what is being proposed here (measure full design capacity). This is covered in section (daily operator check list) and would be needlessly redundant. This would create additional responsibilities for Lifeguards that are beyond the scope of current training requirements.

57 Technical Review Committee Report CR# / / / / / / Summary of pros and cons and/or benefits or deficits Pros: Change should help prevent chlorine gas incidents Cons: None

58 Technical Review Committee Report CR# / / / / / / Summary of pros and cons and/or benefits or deficits Pros: Would be beneficial to provide additional training to lifeguards and management. Would put management of water quality in the hands of those trained per meaning, only those that were trained on handling chemicals would be managing the water quality. Cons: Could be burdensome to some operations. This training is not readily available as part of a standard course and would require additional cost/time to complete.

59 Technical Review Committee Report CR# / / / / / / Summary of pros and cons and/or benefits or deficits Pros: Should help public health authorities work with chemical exposure incidents Cons: None Pros: Change should help prevent chlorine gas incidents Cons: Slight increase in cost due to increased time to perform test

60 Technical Review Committee Report CR# / / / / / / Summary of pros and cons and/or benefits or deficits Pros: Provides additional language intended to address a specific issue that could result in injury/illness. Cons: The existing language adequately addresses the items found in the CR, and there was no benefit to the redundancy.

61 Technical Review Committee Report CR# Summary of internal TRC & TSC discussion DC, IPRMS and RF TSCs voted No. In general, the TSCs were concerned about facilities having flow meters capable of functioning according to the CR, the use of flow switches instead of flow meters for interlocks, and whether 70% is the optimal value to choose.

62 Technical Review Committee Report CR# Summary of CMAHC member comments : An electronic shutoff may be unnecessary if the feeder runs off pump flow. The procedure should be that NO bathers are in the pool without power. When circulation is restored bathers should not be allowed in until flow has been restored for (X? time). This would not deal with auto-backwash but that could be limited to multiple tanks. We did not have good results with auto-backwash systems.

63 Technical Review Committee Report CR# Summary of pros and cons and/or benefits or deficits Pros: The CR was meant to help prevent chlorine gas incidents. Cons: Existing provisions in the MAHC (i.e. NSF certification of controllers) make this change unnecessary.

64 Pool Chemical Certification, Listing, and Labeling and Chlorine Out-gassing Events TUESDAY PM CHAT ROOM COMMENTS DISCUSSION SECTION 4

65 Legionella Remediation, Water Quality and TOC, Air Induction, Gate Latches, and Safety Covers TUESDAY PM CR PRESENTATIONS SECTION 5

66 CR#: Adding Legionella Remediation Protocol Presenter Name: Eugene R Knight Submitter Name: Eugene R Knight Member TRC, Aquatics Program Manager State of New Mexico

67 : Proposed Change Summary: To give regulatory guidance to AHJ and Aquatic Facilities on how to deal with a suspected Legionella outbreaks. Suggested changes: Adding the CDC recommendation for Legionella remediation to the MAHC to give the recommendations regulatory authority similar to fecal remediation already in the code.

68 : Rationale Behind/Benefit of CR Rationale for CR: Current data for recent outbreaks are still being compiled but there is a trend upward in cases of Legionella. My experience in New Mexico is we have gone from having a case about every 3 to 5 years to multiple cases per year in recent years.

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70 Technical Review Committee Report CR# Summary of internal TRC & TSC discussion IPRM&S vote No, at the time, the IPRM&S committee did not know that the proposed remediation was originally written by CDC, they recommended that CDC be consulted O&M vote Yes No formal comments from D&WQ Since this protocol has already been published by CDC ( the TRC was in favor of incorporating it into the MAHC with minor revisions.

71 Technical Review Committee Report CR# Summary of CMAHC member comments 1 comment received: agree, but alternate remediation procedures should be allowed

72 Technical Review Committee Report CR# Summary of pros and cons and/or benefits or deficits Pros: Cons: Incorporates CDC guidance for Legionella decontamination. Remediation requirements (e.g. replacing filter media) may be cost prohibitive.

73 CR# / Alternate Water Replenishment Systems Should Remove More than Total Organics Presenter Name: CMAHC Technical Review Committee Submitter Name: Ellen Meyer

74 Summary / Proposed Change Alternate systems for water replenishment should remove more than just dissolved organic compounds (current MAHC) to reduce water quality problems and water dumping Suggested changes Alternate System An alternate system capable of removing an equivalent amount of turbidity, total dissolved organic carbon (TOC) and total nitrogen (TN) containing compounds shall also be acceptable in lieu of discharging AQUATIC VENUE water Product Water When an alternate system is used, the return water from the alternate system shall maintain turbidity, total organic carbon and total nitrogen concentrations that are less than or equal to tap water.

75 / Proposed Change Suggested changes Discharge This system shall be designed to discharge (or treat and reuse via a separate treatment system capable of removing compounds specified in section ) AQUATIC VENUE water at a rate of up to at least four gallons (15 L) per BATHER per day per AQUATIC VENUE.

76 Rationale Behind/Benefit of CR / Rationale for CR The current code language only includes the removal of dissolved organic compounds (and at an undefined equivalent amount ). A water replenishment system is there to remove (by discharge) all of the things we cannot remove by existing treatment. There are potential health impacts associated with chloramines (dissolved Nitrogen), disinfection by-products, and pathogens. Furthermore, elevated TDS levels could lead to corrosion of equipment while increased UVTs and/or particle levels could lead to problems with UV disinfection systems The current code language of treat and reuse is ambiguous since ALL of the water in a swimming pool is treated and reused on continuing basis.

77 Technical Review Committee Report CR# / Summary of internal TRC & TSC discussion Disinfection & Water Quality TSC: TSC supports CR. Filtration Ad Hoc Committee: CR is acceptable as submitted Internal TRC: The TRC reached unanimous consensus for approval of the CR D&C TSC: Agrees that this section should have the same water replenishment requirements as Sec Also, agree that there needs to be a distinction about treating the removed water to an acceptable level that is separate from the normal pool filtration system. TRC: Agreed that the CR clarifies the language in the MAHC and makes the requirement of treating the water to acceptable standards before reuse.

78 Technical Review Committee Report CR# / Summary of CMAHC member comments Agrees but asks if this would mean that all RWVs have to have carbon or nanofiltration. Concerned about expense for semi-public pools. Would only apply if a facility elected not to traditionally dilute to waste There were no comments on this CR from CMAHC members.

79 Technical Review Committee Report CR# / Summary of pros and cons and/or benefits or deficits Pros: Provides clarification on what alternate systems should remove Cons: None Pros: Provides clarification on treat and reuse wording since all pools treat and reuse water Cons: None.

80 CR#: Jets and Air Induction Presenter Name: TRC Submitter Name: John Kelly

81 CR#: : Proposed Change Summary: Airflow shall be permitted through the jet system only (not recirculation system). Suggested changes Jet System Inlets Air Flow Air flow shall be permitted through the jet system and/or when injected post-filtration.

82 CR#: : Rationale Behind/Benefit of CR Rationale for CR Air flow shall be limited to the hydrotherapy jet system. The clarity of the spa is determined when the agitation system is off, but the recirculation system should remain in operation. Allowing air flow into the recirculation system post filtration supplying the return inlets will impair visibility into the spa at all times.

83 Technical Review Committee Report CR# Summary of internal TRC & TSC discussion The TRC felt that the CR was initially looking to strike from the code any air induction to the recirculation system. The author s concern was addressing spas but the D&C and IMRMS TSCs were in disagreement and felt that recirculation wall inlets could be used as jets and an external air blower, for example, could be tied to the system and set to a timer or even emergency stop as would be required by NEC for conventionally designed jet pumps under suction.

84 Technical Review Committee Report CR# Summary of internal TRC & TSC discussion TRC noted that hydrotherapy jet pumps are often a decent bit larger, in terms of GPM flow, than recirculation pumps in most instances. If a designer would use just the recirculation wall inlets for jets, the typical jet flow would not be reached. Otherwise the filter, piping, and other systems would need to be increased in size and it wouldn t make likely economic sense. This CR could also have consequences on filtration designs that may look to conserve water and utilize an air scour system.

85 Technical Review Committee Report CR# Summary of CMAHC member comments Two comments in agreement with submitted CR. The filter system and the air/water jet systems should be COMPLETELY separate.

86 Technical Review Committee Report CR# Summary of pros and cons and/or benefits or deficits Pros: Without a timer on an air induction system, there can be no moments of periodic quiescence in the water surface when water clarity can be best assessed. Cons: Rationale for patron safety not justified; would have consequences on filtration design as air scouring could be prohibited.

87 CR# / / Gate Latches Presenter Name: CMAHC Technical Review Committee Submitter Name: Richard Fuller ( ), John Kelly ( ), Douglas Sackett ( )

88 / / Proposed Change Summary Adds exception to self-closing/latching gates if gate is staffed or venue is guarded at all times. Clarifies that latches are same height on all gates Suggested changes (new annex language as well) Staffed Entry Exception 1: When the gate or door of an AQUATIC FACILITY OR VENUE ENCLOSURE is part of a staffed entrance and locked at all times the AQUATIC FACILITY or AQUATIC VENUE is not open to the public Lifeguard(s) Provided Exception 2: When the gate or door serves as part of an AQUATIC FACILITY OR VENUE ENCLOSURE and the AQUATIC VENUE(s) therein has a QUALIFIED LIFEGUARD(s) conducting PATRON surveillance at all times the AQUATIC VENUE(s) is open and the gate or door is locked at all times the AQUATIC FACILITY or AQUATIC VENUE is not open to the public.

89 / / Proposed Change Suggested changes (plus Annex language) A Self-Latching Device Height Operable parts of the release of latch on self-latching devices must be located 4 ½ feet (1.37 m) above finished grade Operable by Children Self-latching devices shall not be operable by small children on the outside of the ENCLOSURE around the AQUATIC VENUE Unauthorized Entry EXIT GATES or doors shall be constructed so as to prevent unauthorized entry from outside of the ENCLOSURE around the AQUATIC VENUE. Removes language from other areas to clarify intent

90 / / Rationale Behind/Benefit of CR Often the primary public access gates or doors are large and remain open to accommodate large number of bathers entering and exiting the aquatic facility. These gates and doors need to remain open when the facility is open to the public for safety and convenience reasons. The use of an interior staffed entry provides the same if not better safety component Allows flexibility in design if a lifeguard is present at all times facility or venue is open Increasing the latch height to 4.5 ft for all pools (just unguarded currently) to be consistent with the requirements for unguarded pools will further reduce the potential risk for unauthorized entry by small children.

91 Technical Review Committee Report CR# / / Summary of internal TRC & TSC discussion : The Design & Construction TSC supported the CR. The Injury Prevention, Risk Management, & Safety TSC agreed with the intent of the CR. The TSC stressed that the gate must be locked when staff are not present and that an entry monitored by a video camera should not be considered a staffed entry : The Injury Prevention, Risk Management, & Safety TSC felt that the CR would be acceptable with modification. Facility Design & Construction TSC felt that the CR was not technically defensible and favored approving CR instead. They questioned whether this would add to the duties of a lifeguard and interfere with supervision of bathers in the water.

92 Technical Review Committee Report CR# / / Summary of internal TRC & TSC discussion : The Injury Prevention, Risk Management, & Safety TSC felt that the CR was acceptable only with modification as well as relocating MAHC to within MAHC The Design & Construction TSC They supported the CR but recommended the minimum latch height be changed to 52 inches from 54 inches (4.5 feet) as the ADA maximum in is 54 inches, and lowering the minimum to 52 inches would help avoid conflict and provide tolerance that would allow for future variations such as new hinge sets or changing deck finishes. The TRC agreed that relocation of the section to was appropriate, and proposed modifications. The TRC also proposed adding Annex language regarding the related ADA requirement vs. reducing from 54 inches.

93 Technical Review Committee Report CR# / / Summary of CMAHC member comments Three CR comments agree. Many large and small aquatic facilities use perimeter fences and a common, staffed entry area to control access to aquatic venues during operating hours. The existing code does not adequately address this common industry practice and places many facilities in non-compliance with the code Two CR comments received, both disagree with CR was a better means to allow for exception of the self-closing self-latching gate requirement. This change request does not require that the stated entries be staffed, only that lifeguard supervision is provided in the aquatic facility. The lack of a requirement for staffed entries creates an unnecessary safety hazard : Disagree. Defeats purpose of guarding pool

94 Technical Review Committee Report CR# / / Summary of pros and cons and/or benefits or deficits Pros: CR would provide a safe alternative and allow for more flexibility at gates. Cons: Some TRC members had reservations about modifying a design requirement (self-closing and self-latching gate) that attempts to engineer out a hazard to allow an option to omit the requirement if specific operational measures (staffing) were in place. The TRC felt that modifying the CR to present the staffed entry as a separate exception, add Annex language which highlights the need to consider the operational aspects during the design phase if the exception were to be used, and modifying the existing operational requirement to reference the required staffing would provide additional security, especially in the event of operational or ownership changes at a facility

95 Technical Review Committee Report CR# / / Summary of pros and cons and/or benefits or deficits Pros: TRC agreed with the CR submitter that an exception could be made to the self-closing self-latching gate requirement if an aquatic venue was guarded. The TRC also feels that pairing this CR with CR would provide two distinct alternatives for a self-closing self-latching gate (it guarded aquatic venues, or at guarded or unguarded aquatic venues where the gate is staffed), and that both should be considered. Cons: reservations about modifying a design requirement that attempts to engineer out a hazard to allow an option to omit the requirement if specific operational measures were in place.

96 Technical Review Committee Report CR# / / Summary of pros and cons and/or benefits or deficits Pros: Requiring a minimum latch height of 4.5 feet at guarded aquatic venues in addition to unguarded will help prevent unauthorized entry by children during times outside the hours of operation. Cons: Latch heights of greater than 4.5 feet may be in violation of ADA requirements; however, anthropometric data, which indicates that a 54- inch latch height would put the latch just out of the reach of a 5-year-old of average height, supports use of the greatest latch height that would not exceed the ADA maximum in the MAHC.

97 CR# / / Safety Covers Presenter Name: CMAHC Technical Review Committee Submitter Name: Richard Fuller

98 / / Proposed Change Summary Adds language for when safety covers are not used or are not practical. Three parts: closed venues when they have a barrier, or venues w/o barrier when facility is open or closed adds option to drain an Aquatic Venue where pool covers are not practicable. Suggested changes Aquatic Venues With a Barrier Where the AQUATIC VENUE has a BARRIER enclosing it per MAHC 4.8.6: 1) The water shall be recirculated and treated to meet the criteria of the CODE; or 2) The water shall be drained; or 3) An approved SAFETY cover that is certified, listed and labeled to ASTM F by an ANSIaccredited certification organization shall be installed. Where a SAFETY cover is not used or not practical, access to the AQUATIC VENUE shall be restricted and routine check of the integrity of the AQUATIC VENUE ENCLOSURE shall be made.

99 / / : Proposed Changes Suggested changes: Aquatic Venues Without a Barrier but Open to the Public Where the AQUATIC VENUE does not have a BARRIER enclosing it per MAHC 4.8.6, and other parts of the AQUATIC FACILITY are open to the public : 1) The water shall be recirculated and treated to meet the criteria of the CODE, and the AQUATIC VENUE shall be staffed or a temporary BARRIER installed to keep bathers out; or 2) The water shall be drained, and the AQUATIC VENUE shall be staffed or a temporary BARRIER installed to keep bathers out; or 3) An approved SAFETY cover that is certified, listed and labeled to ASTM F by an ANSIaccredited certification organization shall be installed. Where a SAFETY cover is not used or not practical, access to the AQUATIC VENUE shall be restricted and routine check of the integrity of the temporary AQUATIC VENUE BARRIER shall be made.

100 / / : Proposed Changes Suggested changes Aquatic Venues Without a Barrier and Closed to the Public Where a SAFETY cover is not used or not practical, access to the AQUATIC VENUE shall be restricted and routine check of the integrity of the AQUATIC VENUE ENCLOSURE shall be made.

101 Rationale Behind/Benefit of CR / / (venue with barrier in closed facility) This change incorporates language already found in the Annex concerning those AQUATIC FACILITIES where the use of covers on individual AQUATIC VENUES is not used or not practicable (venue w/o barrier in open facility) The option of installing temporary barriers in venues w/o them or draining an aquatic venue (especially where there is long term maintenance or repairs) needs to be provided as well as address situations where pool covers are not used or are not practicable to use. This mirrors language that is already found in the Annex (venue w/o barrier in closed facility) This change incorporates language already found in the Annex where it is not practicable to use a pool cover because of the particular shape or size of the aquatic venue.

102 Technical Review Committee Report CR# / / Summary of internal TRC & TSC discussion / / Operation & Maintenance TSC: Agrees Injury Prevention, Risk Management, & Safety TSC: CR was acceptable as submitted but they recommended defining routine. TRC: The TRC recommended a change to the CR that the ASTM reference for the safety cover NOT be deleted. There remains concern about what routine check means Is it daily? Is daily practical? Is the intent public safety and/or mosquito prevention?

103 Technical Review Committee Report CR# / / Summary of internal TRC & TSC discussion One member asked about what a temporary BARRIER would be based on the definition of BARRIER. Maybe there needs to be more work on a description of what a temporary BARRIER is. There is a lower level of risk if the venue is not already required to have a separate barrier, and there needs to be some distinction that patrons cannot enter the venue.

104 Technical Review Committee Report CR# / / Summary of CMAHC member comments (similar for all) Comment #1: Disagrees and requests MAHC reference current version of ASTM F (2010). Comment #2: Agrees with intent of CR. Comment #3: Agrees with CR pulling over Annex information that properly addresses situations where safety covers are impractical for aquatic venues that have MAHC-compliant barriers. Comment #4: Posted by O&M TSC and agrees with CR.

105 Technical Review Committee Report CR# / / Summary of pros and cons and/or benefits or deficits & Pros: Adds an option when safety covers are not used or practical. Cons: None Pros: Adds options for compliance with code requirement. Cons: None.

106 Legionella Remediation, Water Quality and TOC, Air Induction, Gate Latches, and Safety Covers TUESDAY PM CHAT ROOM COMMENTS DISCUSSION SECTION 5

107 Waterslides, Lazy Rivers, Lighting, SVRS Systems TUESDAY PM CR PRESENTATIONS SECTION 6

108 CR#: 4.8.4/ / / Waterslide Safety Presenter Name: John Kelly Submitter Name: John Kelly Iowa Department of Public Health Swimming Pool and Spa Program

109 4.8.4/ / / : Proposed Change Summary: Moves pool slides out from waterslides and adds requirements for access by stairs Adds requirement for flow meter to confirm the water flow rate at each connection is within the limits established by the manufacturer Adds requirement for a scale to confirm group of riders are within weight limit established by the manufacturer Requires flume designed to prevent users from becoming airborne, minimize collisions with side and ensure they cannot be thrown out of the flume.

110 : Rationale Behind/Benefit of CR Rationale for CR Water flow rate is a critical variable in the proper performance of waterslides With a heavier raft if it starts to travel too fast, the water will start to pile up in front of the raft slowing it down. With a light raft if it begins to travel too slow, the water will start to pile up behind the raft pushing the raft to speed up.

111 : Rationale Behind/Benefit of CR

112 : Rationale Behind/Benefit of CR The ARC Lifeguard Training Manual notes that lifeguards are responsible for assessing riders to ensure they meet all of the requirements established by the manufacturer.

113 : Rationale Behind/Benefit of CR Weight is a critical variable in the proper performance and changes in weight directly effect the performance of a waterslide. Project Number: 0548 Ilian Zinoviev, May 17,2013

114 : Rationale Behind/Benefit of CR Rationale for CR The ASTM standard for waterslides is missing many important design requirements.

115 : Rationale Behind/Benefit of CR Rationale for CR Iowa Swimming Pool and Spa rules 641 IAC 15.5(17) a (6) & 641 IAC 15.5(17) a (7) require that the waterslide flume shall be designed to prevent users from becoming airborne, to minimize user collisions with the sides of the flume and to ensure they cannot be thrown out of the flume to prevent injuries.

116 : Rationale Behind/Benefit of CR Rationale for CR

117 Technical Review Committee Report CR# 4.8.4/ / / Summary of internal TRC & TSC discussion First half of wording is already in MAHC at Should it be moved to blank area under ? Moved out from under waterslides? New language is about slide access. TSCs felt that much more work was required on to be recommended for approval. TRC concerns over conflicting with the CPSC which govern the new language on access proposed in the CR. CPSC currently calls for a maximum angle, relative to the deck, for ladders, minimum lengths and width of the ladders, and dimensional allowances for ladder risers. ASTM recommends referencing F2376 for classification, design, manufacture, and operation of waterslide systems. They define pool slides and slides and are concerned about inconsistency and misapplication of the requirements.

118 Technical Review Committee Report CR# 4.8.4/ / / Summary of internal TRC & TSC discussion (flow meter on slide) Design & Construction TSC believes that equipping the waterslide system with an appropriate flow meter is acceptable. TRC discussed that a posted pump curve near the slide pumps can be used as an alternative to the flow meter (scale at waterslide) TRC felt that the weight limit and riding criteria may vary from slide to slide and manufacturer to manufacturer, but it should be incumbent upon the manufacturer and ASTM to set the appropriate operating parameters and limits for each ride. The cost of a potential scale can be $6,000 to $8,000 as determined in the review of this CR during the 2015 cycle. Operators / lifeguards are often unaware of the designed limitations stipulated by the manufacturer and ASTM. And even if the weight limits are posted, there is no way to enforce without the use of a scale. So, while the scales used in these applications can be fairly expensive, they will have a positive health and safety impact as demonstrated by the CR.

119 Technical Review Committee Report CR# 4.8.4/ / / Summary of internal TRC & TSC discussion: (Flume design) Design & Construction TSC believes that the proposed addition here is appropriate. They felt that the wording helps to clarify the safety requirements of a waterslide. But they recommended some additional changes: TRC disagreed with the proposed CR. This area has historically been regulated by ASTM. The AHJ has no way of governing this during plan review. The proposed CR language will put the liability on the aquatic design engineer of record and the AHJ, not the manufacturer. ASTM is revising standard and ASTM wrote back: ASTM F24.70 Subcommittee strongly agrees that slide design requirements are covered and should remain in ASTM F2376. The MAHC should only reference this standard and should not create alternate design standards. The F24.70 subcommittee which manages ASTM F2376 is open to comments and will review all suggestions and comments presented by the CMAHC.

120 Technical Review Committee Report CR# 4.8.4/ / / Summary of CMAHC member comments: (Pool slide access) 1. Agrees with the CR author s intent of separating the waterslide and pool slide requirements, but felt that it didn t far enough or wasn t clear enough. Also suggested breaking down the CR for individual voting purposes. 2. ASTM recommends referencing F2376 for classification, design, manufacture, and operation of waterslide systems. They define pool slides and slides and are concerned about inconsistency and misapplication of the requirements. The proposed language is requiring stairs and handrails be provided to access slides per Section 14 of F2291. However, that standard states that this practice shall NOT apply to..amusement rides that involve the purposeful immersion of the patron s body in water (including pools, waterslides, lazy rivers, etc.). 3. ASTM F24.70 strongly agrees that slide design requirements are covered and should remain in ASTM F2376. The MAHC should only reference this standard and should not create alternate design standards. The subcommittee which manages ASTM F2376 is open to CMAHC comments.

121 Technical Review Committee Report CR# 4.8.4/ / / Summary of CMAHC member comments (flow meters on slides) : Suggested breaking up the CR into multiple components which was done by TRC. Another commenter thought this was unnecessary economic burden (slides should have weigh scales): Commenter thought this was unnecessary economic burden (flume design): Split up CR, which TRC did.

122 Technical Review Committee Report CR# 4.8.4/ / / Summary of pros and cons and/or benefits or deficits Pros: Would improve access safety for younger patrons and works to delineate differences between waterslides and pool slides. Cons: Increase in construction cost and would not be consistent with the CPSC s published standards Pros: Help to ensure that waterslides will operate within their designed parameters. Cons: Cost increase Pros: Scales will have a positive health and safety impact. Cons: Increase in cost Pros: Tries to clarify the design safety requirements of waterslides. Cons: A radical shift to put the onus of the design and safety of the waterslide flume path on design engineer and the AHJ.

123 CR# / Lazy River Handhold Exception Presenter Name: CMAHC Technical Review Committee Submitter Name: Richard Fuller ( ) Lee Hovis ( )

124 Summary / Proposed Change Exempts handhold requirement for Lazy Rivers where bathers are required to be in or on a tube at all times. Suggested changes : A handhold in compliance with MAHC Section shall be required on at least one side of the LAZY RIVER except where bathers are required to be in or on a tube while in the LAZY RIVER : A handhold in compliance with MAHC shall be required on at least one side of the LAZY RIVER but shall not include horizontal bars and/or recessed handholds.

125 / Rationale Behind/Benefit of CR Rationale for CR The current MAHC could create tube and raft congestion at entry/exit locations that will impact lifeguarding, sight lines and/or rescue operations. It can potentially impede entry points to a Lazy River that can create crowd management and egress issues. It could in essence create obstructions cited in Handholds in a Lazy River will also create the potential for injuries for bathers holding on from the opposing force of the water flow.

126 Technical Review Committee Report CR# / Summary of internal TRC & TSC discussion LG TSC: Found this section confusing. Having handhold could be a safety factor for someone in trouble if they are not handrail or recessed handholds. IPRM&S TSC: We agreed that handholds create multiple significant hazards that outweigh the benefit of providing users a handhold to steady themselves and assist them in access or egress. Due to accepting , CR is not necessary. TRC: There was confusion on the citation of Handrail being required on lazy rivers Handholds is the citation that should be in the MAHC for The CR was changed to include the new citation and a couple of exclusions added.

127 Technical Review Committee Report CR# / Summary of CMAHC member comments Two Comments from members agreeing with the proposed CR 1.Handholds could be a safety risk. Handholds similar to a ladder, handrail or door handle have an opening that is large enough to get extremities through it. This might result in an injury depending on the flow rate and other riders behind them. 2.There are two conflicting proposed change requests for section regarding relief for LAZY RIVER handholds due to well established industry safety concerns. Change Request is the preferred code revision due to its clarity. Change Request is a reasonable amendment which addresses specific criteria for relief that is an improvement to the existing code. Either is preferred to the hazards created by the existing code.

128 Technical Review Committee Report CR# / Summary of pros and cons and/or benefits or deficits for both and Pros: A place for someone to hold on to if they fall from a tube or gets into trouble until a lifeguard can reach them. Cons: Could be a safety hazard if people hang on and cause a backup. If CR passes it would need to be combined at the end of CR

129 CR#: / Lighting Presenter Name: John Kelly Submitter Name: John Kelly Iowa Department of Public Health Swimming Pool and Spa Program

130 Summary: / : Proposed Change Prohibiting colored underwater lighting and requiring lights to be used in accordance with design intent. Suggested changes: Dimmable Lighting Dimmable lighting shall not be used for underwater lighting Colored Lighting Colored lighting shall not be used for underwater lighting.

131 / : Proposed Change Suggested changes: A Night Swimming with No Underwater Lighting; Minimum Requirements Where outdoor POOLS are open for use from 30 minutes before sunset to 30 minutes after sunrise, or during periods of low illumination, all installed lighting must remain on and be fully operational in accordance with the original design intent. Designs may exclude underwater lighting may be excluded where: 1) Maintained POOL surface lighting levels are a minimum of horizontal footcandles ( lux), and 2) All portions of the POOL, including the bottom and drain(s), are readily visible as required in MAHC

132 / : Rationale Behind/Benefit of CR Rationale for CR Decorative lighting is not designed to meet functional lighting requirements. It does not appear that any of the colored lighting has cataloged values of lamp lumens throughout the available colors. Similar to dimmable lighting, for colored LED lighting the light output is variable as color is blended from RGB. Water filters different wavelengths of light at different rates introducing another variable, so applying the minimum lamp lumen requirements to significantly different wavelength/colors will not ensure similar lighting levels.

133 / : Rationale Behind/Benefit of CR Rationale for CR

134 / : Rationale Behind/Benefit of CR Rationale for CR

135 / : Rationale Behind/Benefit of CR Rationale for CR

136 Technical Review Committee Report CR# / Summary of internal TRC & TSC discussion (ban colored lights) The IPRM&S TSC note that as long as the required foot candles are met, having colored lights should not impose a hazard. In the TRC s opinion, there are already performance requirements in the Code.

137 Technical Review Committee Report CR# / Summary of internal TRC & TSC discussion (expands night use lighting levels to all pools and increases levels) IPRMS TSC: The guidelines regarding the required lighting levels are already spelled out in Additionally, a facility may be designed to provide lighting greater than the minimum required. As written this CR would require any underwater lighting to be immediately repaired even though the minimum lighting levels may still be me according to Additionally, the CR text is placed in a portion of the code that addresses conditions for underwater lighting can be excluded which is not the appropriate place to insert this text. If it is accepted it should be placed in

138 Technical Review Committee Report CR# / Summary of internal TRC & TSC discussion (expands night use lighting levels to all pools and increases levels) TRC: TRC sees that strikeout of outdoor means this would apply to all pools. Why double the surface lighting? The change to strike outdoor is what appears to increase/double the surface lighting level to 30 horizontal footcandles (323 lux). One member stated that indoor pools already have lighting requirements.

139 Technical Review Committee Report CR# / Summary of CMAHC member comments: No comments on (no colored lighting) The proposed change request should be disapproved or amended to define the appropriate criteria for colored lighting that allows for a full and unobstructed view of the aquatic venue bottom at all times. Submitter As LED lighting replaces incandescent lighting there is significant variability. Restricting the LED lighting to White reduces the variability to match that of the incandescent lighting. The MAHC notes that lighting shall be located to provide illumination so that all portions of the AQUATIC VENUE, including the AQUATIC VENUE bottom and drain(s), may be readily seen. Unfortunately, this a subjective rather than an objective standard. Most swimming pool inspections occur during daylight hours so an inspector rarely sees an outdoor pool in operation under the lights.

140 Technical Review Committee Report CR# / Summary of pros and cons and/or benefits or deficits Pros: Colored lights do not provide the same level of visibility as traditional white lighting which is best for illuminating underwater surfaces. Cons: There are already performance-based requirements in the Code Pros: Perceived intent to improve bather safety for night swimming. Cons: Seeks to apply night swimming lighting level requirements to both outdoor and indoor pools. Doubles the minimum lighting level requirement without substantiation.

141 CR#: / Safety Vacuum Release Systems Presenter Name: Paul Sisson Submitter Name: Paul Sisson Conflict of Interest: none

142 / Proposed Change Summary: Adds Annex information on Safety Vacuum Release Systems (SVRS) and adds a code section allowing them to be installed. Suggested changes Add section to annex section, explaining the two types of SVRS (mechanical and electrical), hybrids and variations of the two types, and potential problems.

143 / Proposed Change Suggested changes SVRS Mechanical SVRS A mechanical SVRS listed to ASTM F or ASME A may be installed on the exposed filter main drain pipe or feature drain pipe according to the manufacturer s recommendations Electrical SVRS An electrical SVRS listed to ASTM F or ASME A may be installed on the filtration or feature pump control system or be integral with a filtration or feature pump or pump motor according to the manufacturer s recommendations.

144 / Rationale Behind/Benefit of CR Rationale for CR This adds an Annex section to describe the function, operation, maintenance of SVRS devices This is a proposed new section to add permissive requirements for mechanical SVRS devices.

145 Technical Review Committee Report CR# / Summary of internal TRC & TSC discussion : The IPRM&S TSC was in favor of the CR as submitted but noted that revisions were likely warranted to better organize the content. TRC feels that SVRS does not need a specific call out in the annex and that concerns detailed in this proposal are covered in (32) of the Code The IPRM&S TSC was in favor of the CR revisions The wording "may be" installed according to manufacturers recommendations is confusing language. According to the manufacturers recommendations, SVRS should be installed. The submitter has explained the background and should include the supporting information into the Annex. TRC feels that mentioning the two types of SVRS systems in the Annex is ok and that it would be useful.

146 Technical Review Committee Report CR# / Summary of CMAHC member comments MAHC already requires compliance with VGB. This section is about Submerged Suction Outlets not Entrapment "Prevention" An SVRS is not necessary. Single drain systems should be converted to multi-drain systems that meet VGB.

147 Technical Review Committee Report CR# / Summary of pros and cons and/or benefits or deficits The TRC unanimously recommends a no vote on this CR since SVRS systems don t need a specific call out. Annex material only TRC feels that mentioning the two types of SVRS systems in the Annex is ok and that it would be useful to help meet other requirements in the code. Listing them separately though is not necessary and they should be part of one section as altered

148 Waterslides, Lazy Rivers, Lighting, SVRS Systems TUESDAY PM CHAT ROOM COMMENTS DISCUSSION SECTION 6

149 Stabilizers, ph, UVT Monitoring; Ca Hardness, Use of ORP TUESDAY PM CR PRESENTATIONS SECTION 7

150 CR#: Presenter Name: Ellen Meyer Submitter Name: Ellen Meyer Submitter Conflict of Interest: Submitter works for Lonza, a company that manufactures calcium hypochlorite and sells stabilized sanitizers

151 Summary CR#: Current MAHC disinfection (2 ppm FC, 90 ppm CYA) is 3.4 times slower than 1 ppm monochloramine* Lower the cyanuric acid stabilizer limit to 25 ppm so chlorine is at least as effective as monochloramine Suggested changes Cl 3 Cy The CYA level at all AQUATIC VENUES shall remain at or below ppm (mg/l). HCl 2 Cy Cl 2 Cy - HOCl H + + OCl - H 2 ClCy HClCy - ClCy 2- *Based on Giardia CT values H 3 Cy H 2 Cy - HCy 2- Cy 3-

152 %HOCl CR#: HOCl is the primary sanitizer Giardia 50% 40% 30% 20% 10% 0% 1 ppm FC 2 ppm FC 3 ppm FC 4 ppm FC 10 ppm FC CYA, ppm CT chloramine = 17 x CT free chlorine 750 ppm min = 17 x 45 ppm min Disinfection time (T) T 1 ppm chloramine = 17 x T 1 ppm free chlorine T 1 ppm chloramine = T 2 ppm free chlorine with 25 ppm CYA

153 CR#: This is not the consensus recommendation of the CMAHC Ad Hoc Committee on CYA. TRC vote = No, wait for Ad Hoc Committee consensus. So why vote Yes now? Current MAHC (2 ppm FC, 90 ppm CYA) is 3.4 times slower than 1 ppm monochloramine. Improvement in public health can be made now. Proceed with best guidance to date and adapt as further guidance is available for MAHC Some state and local codes are being revised now. Maintain chlorine efficacy chloramine.

154 Technical Review Committee Report CR# Summary of internal TRC & TSC discussion No formal CR evaluation was received from the Disinfection & Water Quality TSC. This CR was proposed anticipating that the CYA ad hoc committee would have final recommendations by June. Recent findings of the committee suggest the most appropriate way to control the impact CYA has on chlorine efficacy is by maintaining a CYA/FC ratio, much like time/temperature in the FDA Food Code. The proposal to lower the maximum allowable CYA level from 90 ppm to 25 ppm was based on Giardia data from EPA. Some TRC members felt that the data presented in support of the CR by the CR submitter provided sufficient rationale to recommend approval of this CR. Other TRC members felt that there was incomplete science and that they would recommend a no vote and would instead wait for the cyanuric acid ad hoc committee s recommendations.

155 Technical Review Committee Report CR# Summary of CMAHC member comments No member comments received.

156 Technical Review Committee Report CR# Summary of pros and cons and/or benefits or deficits Pros: Some TRC members felt that a lower maximum allowable CYA level was supported by existing data and that this change would have a positive public health impact. Cons: Other TRC members felt that the additional support from scientific literature was needed and that this CR should be reconsidered in a future change request cycle after the cyanuric acid Ad Hoc committee s recommendations are finalized. TRC could not reach consensus 2/3 vote so abstained

157 CR# Reduce Minimum ph Requirement Presenter Name: TRC Submitter Name: Stan Pickens, Ellen Meyer

158 CR# : Proposed Change(s) Summary: Reduce ph minimum to 6.8 Suggested changes The ph of the water shall be maintained between and 7.8.

159 CR# : Rationale Behind, or Benefit of, CR Increased efficacy of HOCl (27% increase from ph 7.2) Clarifies the ambiguity between section (ph levels) and section (immediate closure if ph below 6.5). By clarifying that facilities may operate at lower ph the number of immediate closures for slightly low ph will be reduced. While facilities may operate in the 6.8 to 7.2 ph range they are not mandated to do so under this provision. German DIN and increased knowledge of pool operations in European countries such as Austria now have produced a substantial body of science and field experience with lower ph

160 TRC Report: Summary of TRC & TSC discussion CR# There could be operational and health concerns. When cyanuric acid is present the relationship between ph and HOCl is different.

161 TRC Report: Summary of Member Comments CR# Received comments from 3 individuals: 1 agree/ 2 disagree. Have to ensure water balance and that air quality is maintained; electronic ph meters must be used. Issues with traditional colorimetric tests at lower ph. Manufacturers pointing out that most warranties will be voided outside of operational norm of Corrosive actions that will limit product lifetime.

162 Pros: TRC Report: Summary of Pros and Cons CR# HOCl: Chlorine is more effective at lower ph. Closure- ph values down to 6.8 are not an imminent health hazard, so pools should not be shut down if the ph is between 6.8 and 7.2. Test kits- Test kit companies can produce kits that measure ph to 6.8. European practice- Some Europeans have been operating at a ph of 6.8 for at least 30 years. Equipment- We need an aspirational goal on where new pool construction and equipment might go in the future Operation and Training- If ph values down to 6.8 are allowed, facilities can still choose to operate within the old range of Operation and Training- This will be a major change in the way pools in the US are operated, but it is possible to change industry standards, literature and training.

163 TRC Report: Summary of Pros and Cons CR# Cons: HOCl- Chlorine may be overdosed with typical levels of 1-4 ppm A Violations Requiring Immediate Correction or Closure Test kits- Currently, common test kits do not measure ph values to 6.8. European pool codes vary, not all of them allow ph values as low as 6.8. WHO recommends Equipment- Equipment and pool finish damage may occur at ph values below 7.2. Many equipment warranties will be void at ph values below 7.2. Different metals (e.g. Cupro-nickel or titanium) may need to be used to avoid heat exchanger damage. Operation and Training- If the ph drops below 6.9, automation probes can lose calibration Operation and Training- An operator may be in violation of EPA pesticide laws if their sanitizer label specifies a minimum ph of 7.2 and they are running at ph 6.8.

164 TRC Report: Summary of Pros and Cons CR# Cons: Operation and Training- It will take years for training courses (CPO, AFO, CMS/CST), published standards and guidelines from trade organizations (APSP, NPC, IPSSA, NSPF, etc), EPA pesticide labels, equipment manufacturer manuals, and other industry literature to change and accommodate the larger ph range. Some organizations may not change, leading to inconsistent standards in the industry. Health effects of low ph- Sensitive individuals may experience eye and skin irritation Health effects of low ph- The production of some disinfection byproducts (haloacetonitriles (HAN) and nitrogen trichloride) is increased at lower ph, and decreased for others (trihalomethanes (THM) and haloacetic acids (HAA)).

165 CR# Changes UV System Parameter Monitoring Presenter Name: CMAHC Technical Review Committee Submitter Name: Ellen Meyer

166 Summary Proposed Change Modifications to clarify expected monitoring/calibration frequency and recording of parameters and to eliminate conflict with MAHC Suggested changes Added text to table to clarify expected monitoring/calibration and recording of parameters and to eliminate conflict

167 Rationale Behind/Benefit of CR Rationale for CR As modified, the table will better qualify whether the parameter listed is being monitoring or calibrated, and the change of frequency of calibration of UVT and intensity to per manufacturer s requirements will eliminate the conflict with MAHC (measure based on manufacturer recommendations)

168 Technical Review Committee Report CR# Summary of internal TRC & TSC discussion The Disinfection & Water Quality TSC felt that the CR was not technically defensible; stating that requiring UVT monitoring is not necessary if a unit is validated for a maximum UVT (which is required in the MAHC), and that UVT is incorporated into the calculations for maximum flow rate and minimum intensity, and the required monitoring for these parameters will ensure system performance. The Operation & Maintenance TSC felt that monitoring for intensity with shut-off if dose goes below 40mj/cm 2 was sufficient. Both TSCs felt cost of UVT meters and data recording was prohibitive. The TRC agreed that UVT monitoring was not necessary for units validated using the set point approach but suggested improvements to provide clarification

169 Technical Review Committee Report CR# Summary of CMAHC member comments One comment was received, the commenter agreed with the CR and suggested that UV systems be tested and certified with cyanuric acid stabilizer at various ppm, but that is not related to the CR.

170 Technical Review Committee Report CR# Summary of pros and cons and/or benefits or deficits Pros: As modified, the CR will better qualify whether the parameter listed is being monitoring or calibrated, and the change of frequency of calibration of UVT and intensity to per manufacturer s requirements will eliminate the conflict with MAHC The removal of the originally proposed requirement for UVT monitoring is defensible from both a cost standpoint and the fact that it is unnecessary for units validated through the process typically used for UV systems designed for recreational water. Cons: None.

171 CR# / / Changing Calcium Hardness Levels Presenter Name: CMAHC Technical Review Committee Submitter Name: Ellen Meyer

172 Summary / / Proposed Change : Change the maximum calcium hardness limit, in case a new lower limit of ph 6.8 is adopted : Remove text indicating calcium hardness may be a health concern : Extend LSI chart to 2500 ppm hardness Suggested changes : Calcium hardness shall not exceed ppm (mg/l) : Remove text indicating calcium hardness may be a health concern in the Annex Section. Add Text indicating deviations up to 300,000 do not pose as imminent health threats to bathers : Add text to extend LSI chart to 2500 ppm hardness in MAHC Annex table

173 / / Rationale Behind/Benefit of CR & : If the ph lower limit is changed from 7.2 to 6.8, the current calcium hardness limit of 1000 ppm restricts options for balancing water, especially in areas with hard water. In areas that have high calcium hardness in the source water, lowering the calcium hardness can be difficult and add costs to maintaining the aquatic venue (costs of reverse osmosis or shipping in water.) : Public health is not improved by providing faulty information in the annex to the code.

174 Technical Review Committee Report CR# / / Summary of internal TRC & TSC discussion TRC-This CR was originally proposed in conjunction with a CR to lower the acceptable range of ph to 6.8. While the CR to lower ph was not supported, the TRC sees value in evaluating independently. The TRC agrees that any technically incorrect information found in the annex should be corrected. In drought-stricken parts of the United States municipalities are enacting water saving restrictions. These restrictions affect the ability of the aquatic venue to drain and refill the venue to maintain a lower calcium hardness level. Allowing a higher calcium hardness, and adjusting the Calcium Saturation Index accordingly allows aquatic venues working under restrictions intended to conserve water to continue operations without excessive water use or AHJ closure.

175 Technical Review Committee Report CR# / / Summary of CMAHC member comments No comments received from CMAHC members

176 Technical Review Committee Report CR# / / Summary of pros and cons and/or benefits or deficits TRC recommends passing all three CRs. The modification of the Calcium Saturation Index provides the ability to the aquatic venue to remain in operation while maintaining water that is not detrimental to the aquatic venue hard surfaces or mechanical systems. Removes information in the annex that is not scientifically supported and is considered faulty information will be linked to and will vote together.

177 CR# Allowing ORP Measurement to Substitute for FAC Presenter Name: CMAHC Technical Review Committee Submitter Name: Fred Ross

178 Summary Proposed Change Change will allow ORP/HRR (as measured by calibrated ORP controller) to be an accepted substitute for FAC measurement. Suggested changes A Chemical Levels FAC or ORP/HRR (as measured by calibrated ORP controller), combined available chlorine (CA) or total bromine (TB) and ph shall be tested at all Aquatic Venues prior to opening each day.

179 Rationale Behind/Benefit of CR Rationale for CR These related sections including do not provide clear direction on the use of ORP/HRR controllers for UNMANNED facilities. The MAHC needs to set a range of acceptable ORP/HRR readings.

180 Technical Review Committee Report CR# Summary of internal TRC & TSC discussion Operation & Maintenance TSC: The TSC members feel that ORP/HRR value range is dependent on too many other factors to have a set range. FAC is much more critical on a daily basis than combined chlorine. Disinfection & Water Quality TSC: ORP values are not absolute and vary by sensor and manufacturer even when measuring the same water. Internal TRC: Members expressed concern that the submitter references unmanned facilities in the CR under Rationale indicating there is a glaring omission to not include acceptable ORP/HRR readings. All pools have to measure combined chlorine; ORP may be a tool for controlling but not an absolute level. Need to have a minimum acceptable ORP/HRR.

181 Technical Review Committee Report CR# Summary of CMAHC member comments One Comment Received. Agrees but says the CR does not address the issue of not providing clear direction on the use and acceptable levels, as the CR does not include a range of acceptable ORP/HRR readings. Suggest that the CR be revised to include at least an Annex discussion of acceptable ORP/HRR readings, although it would be more appropriate to include under the noted section

182 Technical Review Committee Report CR# Summary of pros and cons and/or benefits or deficits Pros: None. Cons: No supporting documentation, such as a range of acceptable ORP/HRR readings that is science-based.

183 Stabilizers, ph, UVT Monitoring; Ca Hardness, Use of ORP TUESDAY PM CHAT ROOM COMMENTS DISCUSSION SECTION 7

184 Tonight s caucus is scheduled for 7-9 pm. Does group want to work directly through caucus and then go to dinner or come back after dinner? CAUCUS TIME: TUESDAY 7-9 PM CR SECTIONS 4-7

185 Caucus Guidance Split into your sector Facilitators provided Go straight to caucus room from lunch Public Health: Pine Designers: Private Dining Room Management/Staff: Fir Supplier: Spruce Discuss CRs covered, get pulse of your community, plan comments to be submitted post-conference, or what you want to discuss Federal, State, Local Public Health/Regulators Designers/Builders Management/Staff/ Consumer Supplier/Manufacturer/ Consumer Protection/ Academia

186 Founding Sponsors Thanks to CMAHC Sponsors Gold Silver Bronze Conference Sponsors

187 Contact Information Doug Sackett Executive Director, CMAHC Phone:

188 MAHC More Information: Search on CDC MAHC or visit the Healthy Swimming MAHC Website: CMAHC More Information: Search on CMAHC or visit the CMAHC Website: