Heads up!  In case you haven’t zoned in on this before now, one of the most important modules in the Model Aquatic Health Code is now open for comment.  This Regulatory module is where compliance requirements and enforcement authority are discussed.  You need to read this one!

We are now almost half way through the comment period on the Regulatory Program Administration module.  Given the happy distractions of the holidays, maybe you should put this into your tickle file for early January 2012.  The deadline for public comments on this module is February 5, 2012, and you will need some time to think about how it affects your operations.

About the Regulatory Module

The Regulatory module is really a set of guidelines for how to set up an aquatics regulatory program, and in broad terms, what should be included in it (the other modules provide detailed guidelines on specific issues).  The MAHC describes the module as “the framework around which an effective model aquatic health code is built.”

In other words, and this is the important point, this module is where local and state jurisdictions can get guidance on how to build an effective regulatory program.

We think this is pretty important for aquatics professionals to know about and review.  The topics it covers include staffing, training, permitting, and recordkeeping requirements, as well as critical factors like enforcement and fees. One important item recommended in these guidelines is the establishment of an Aquatic Health Advisory Committee that would advise and support the Authority Having Jurisdiction (AHJ) in the implementation of the code.   These will have direct impacts on your operation.

You can see more about this module in the abstract about it, and in more detail in the PDF you can download from the module review schedule page (both of these pages cover all of the modules).

What Would This Module Do In Practice?

You can get a flavor of how this module might be implemented in this proposed standard for “Plan Submittal”:

Section 4.1.1.2: No person shall begin to construct a new AQUATIC FACILITY or shall alter or renovate an existing AQUATIC FACILITY without first having the construction plans detailing the construction or renovation submitted to and approved by the AHJ.

And later, in Section 4.1.2.3.9:

The technical specifications for each AQUATIC VENUE shall include information on each piece of equipment associated with that venue.

This kind of review already exists in many (perhaps most) jurisdictions, but in the context of MAHC, it will include a much wider standard range of factors.  And as you can see, the requirements are highly detailed.

The recommended language goes on to define compliance and enforcement requirements, and potential fees that might be charged for various elements of the process.  It also defines the composition of the Aquatic Health Advisory Committee, which is where the industry would be represented in the process.

This is Mission Critical

This module is where the rubber hits the road.  It is one thing to discuss best practices for sanitation, life safety, and risk management.  It is entirely another to talk about how all these guidelines might become requirements.

As always, we are interested in your comments!