Act Now: Comment Period on MAHC Risk Module Ends Soon

October 25th, 2011

Most of our readers already know that there’s another module of the Model Aquatic Health Code (MAHC), the Risk Management / Safety Module, in the public comment phase.  You have until November 18th to submit your comments, so please take a look at this module.

Go to the Centers for Disease Control site for links to PDFs on this module within the summary table.  The table provides information on the status of all the modules of the emerging code.  We posted before on the MAHC review process.

There’s More to Risk Management

We think the technical committee for this module did a good job.  Our only real comment is that ‘risk management’ is actually a core theme throughout the code development effort. The reason the process was started in the first place was to find better ways to minimize the risk of RWIs, especially Crypto.  In that regard, we can think of the MAHC as a whole as a risk management tool, and it is a little misleading to label one component of the code this way.

In our own area of expertise, with our VP Beth Hamil serving on the Water Quality Technical Committee, risk management is a central concern.  We’ve talked before about how properly designed, sized and installed secondary disinfection systems help to minimize bathers’ risks AND help to control risk exposure of aquatics operators.  In fact, once the code is finalized, operators will face growing social and possible legal expectations of acting in compliance with it (as states begin to adopt portions of it).

A Summary of the Risk Management Module

The CDC provides this summary of the new module, if that’s all you need to know about it:

Increased vigilance is needed at aquatic venues to reduce injuries in the water, chemical storage room, and around the pool and facility. The Risk Management/Safety Module outlines steps to be taken to manage and reduce these risks and associated health problems. The Risk Management/Safety Module contains new guidelines covering:

  1. Controlled access aquatic venues (e.g., lazy rivers) not requiring depth markers throughout.
  2. Expanded employee training to cover fecal- and vomit-related pathogen response and clean-up.
  3. Potential sources of glare and ways to prevent glare in aquatic venue design.
  4. Consideration of water temperature and patron use.
  5. Expanded chemical storage and handling.
  6. Use of remote monitoring systems.
  7. Employee illness policies.
  8. Inspection items for daily opening and closing of aquatic features or venues.

Next Up: More Modules Coming Soon

The CDC says that the modules on Facility Maintenance and Operation, and the Hygiene Module, are in final clearance.  They will be available for public comment soon, and we’ll be following it with you.

Posted by DELOzone on October 25, 2011 | Comments (0) | Trackbacks

Stump the Expert: Hamil at Intl Pool Spa Patio Expo

October 20th, 2011

Beth Hamil is DEL’s roving ambassador for clean, safe public pool water, and she’s going to be talking about it at the International Pool Spa Patio Expo in Las Vegas on November 3rd.

Start early at 8:00 a.m. at the meeting room Islander E to learn about ozone system components for a public pool,  sizing an ozone system, and matching public health requirements for an ozone pool.

Get Technical Credit Hours!

This Level 300 presentation is accredited for 1.25 hours, certified for IACET, CBP, and CSP.

Sign Up Now

It’s not too late.  Attend the Expo at the Mandalay in Las Vegas.  Register for the Super Pass and get into all venues everyday, including this really important talk by Beth.

Posted by DELOzone on October 20, 2011 | Comments (0) | Trackbacks

Design Water Quality into Your Waterpark

August 4th, 2011

We just ran across an old article in Aquatics International by Bob Feller and Patrick Eagan, but its point bears repeating.  The success of your new waterpark will be determined by the character of your design process.  If you plan “holistically” to incorporate all the critical components, including water quality, you have a much better chance to succeed financially.

What’s in a “Holistic: Design Process?

Feller and Eagan refer to the holistic design process as a new paradigm, which “maximizes efficiency, flexibility and return on investment.  It also can produce a more efficient design with fewer headaches during construction and faster completion.” The authors identified 5 components in a holistic design process for waterparks:

  • Site Design
  • Water Quality
  • Water Consumption
  • Operational Performance
  • Indoor Air Quality

Part of the holistic process is to build around a team.  There has to be explicit recognition that these critical components interact, so communication and exchange are important for the final design.

Water Quality:  The Sweet Spot for Ozone

The authors say this about water quality:

When each team member understands the intended operation of the entire resort, opportunities such as centralized water heating and distribution systems can allow for a more sustainable property, and offer operational savings. Current technologies can combine hotel and waterpark heating and distribution systems, thereby reducing equipment, maintenance and utility usage. Additionally, alternative water treatment methods can improve water quality and lower chemical usage, providing a better waterpark experience for patrons.

Clearly, a superior “alternative water treatment” method is ozone. That’s why the CDC recommends it as a secondary disinfection treatment for aquatics venues (see our slideshow on pool ozone disinfection as suggested by the Model Aquatic Health Code).

Water Quality Supports Air Quality – and Other Factors

We know our audience is aware of how chlorine-based disinfection can produce that “swimming pool smell” that is actually a whiff of chloramines.  We’ve talked in this space before about the health threats from chlorine disinfection in indoor pools, but it is important to emphasize that ozone disinfection minimizes these risks.

It’s also useful to know that ozone systems can help to simplify aquatics management.  Properly sized and installed ozone systems require less hands-on management and maintenance than similar capabilities in UV or chemicals.

Ozone should be part of the design process of your waterpark.  Your customers’ satisfaction – and your bottom line – will benefit from it.

Posted by DELOzone on August 4, 2011 | Comments (0) | Trackbacks

3 Aquatic Codes: Can You Say ‘Compliance’?

July 13th, 2011

We have been following the Model Aquatic Health Code closely since it’s very important to aquatic professionals, and to DEL with respect to ozone being a recommended secondary disinfection system.

But there are several efforts on-going right now that impose requirements and/or guidelines on commercial aquatics.  (And we are not even going into the 2008 Virginia Graeme Baker Pool & Spa Safety Act, which has already imposed technical requirements on drain and circulation system designs.)

The 3 codes we are referring to here are the Model Aquatic Health Code, the Association of Pool & Spa Professionals (APSP) Pool & Spa Code, and the Americans with Disabilities Act (ADA) binding pool accessibility requirements.  These codes are intended to make commercial pool and aquatic environments safer and more accessible.  The APSP guidelines extend to residential facilities, as well. We are not saying all these guidelines are necessarily worthy, but canny operators and owners need to be aware of them.  Safety is an ethical and liability issue.

MAHC – The Model Aquatic Health Code

Our audience is well aware of the MAHC. As of today, there has been no new module issued for public comment since the closure of comments on the Ventilation & Air Quality module on June 12.

The MAHC is the broadest effort to set public pool and spa best practice guidelines for a full range of management and design issues that affect the quality and safety of aquatic venues.  Every aquatic operator in the United States should bookmark this CDC page and visit it often.  We will continue to review and interpret this on-going effort.

APSP – The 2012 Pool & Spa Code

The first public version of this code was released early this year.  In cooperation with the International Code Council (ICC) the APSP has been working to create a national code for swimming pools and spas to form the basis for enforcement language that can be adopted by states.

The lengthy draft document (PDF opens in new window) includes a template for an ordinance and a timeline for code development.  It is scheduled to be published in March 2012.

The code is an exhaustive set of guidelines for the design, mechanical, siting, sanitizing, accessories, and occupancy of private and public pools. In fact, the code is so broad that even in 100 pages it does not include great depth on many of its topics.

Watch the development of this code with respect to its adoption by your state or states where you are commercially active.  Its real impact will happen in the legislative arena.

ADA – It’s Time to Comply

Note March 15, 2012 in your calendar.  That is the deadline for compliance with the ADA guidelines for aquatic facilities, swimming pools, wading pools and spas.  Both public and private facilities that are open to the general public are affected. We outlined the ADA requirements for pools in an earlier post.

Sanitation is Part of Every Best Practice

Whether a code component applies to sanitation directly or not, water quality is the crucial feature of any aquatic venue.  In the MAHC and APSP codes, sanitation is explicitly addressed, and in the MAHC it is at the very heart of the purpose of the code.

Ozone disinfection systems by DEL are available for every swimming pool and aquatic facility.  They provide operators and owners with safe, reliable pool sanitation while reducing or eliminating the chemical by-products that threaten health.  Compliance with safety standards has to include protecting bathers’ quality of enjoyment of facilities.

Posted by DELOzone on July 13, 2011 | Comments (1) | Trackbacks

When Disinfection is a Liability Issue

July 8th, 2011

The recent chemical spill at a waterpark in Manassas, VA prompted us to take a closer look.  We confirmed a couple things commercial aquatic operators already know.  First, when something bad happens, events spin out of control.  Second, something bad for the aquatics operator is a golden opportunity for a lawyer.

The amazing thing is how fast this all happens! We did a little Internet search on “chemical spill at waterpark” to see what happened in response to the Manassas spill and found 3 important facts:

  1. Chemical spills happened surprisingly often.  We found 3 within the past 3 months, and all of them hit the news immediately. The causes of the spills were varied.
  2. The instant action, always on Internet magnified the event in at least one case, and a negative message came to dominate the search results.
  3. Right there in the online information, near the top of the search results, were personal injury lawyers promoting their services specifically for the chemical spill event.

We are reminded of the discussion of operator liability in the context of the Model Aquatic Health Code.  As Gareth Hedges urged people regarding liability and MAHC (PDF opens in new window), there is no time to wait to put a risk management plan into action.

We believe that minimizing chemical use should be part of that plan.  Using an ozone system for secondary disinfection allows a dramatic reduction in chemical use, and therefore a reduction in exposure to accidents.  But whether you wean yourself away from chlorine or not, systematic risk assessment and response planning is essential.

Chemical Spills Made Good News Stories

Within the top 10 results for our little Internet search project, we found 3 chemical spills in commercial aquatics venues:

April 28:  There was a small spill of muriatic acid at a rec center in Vandalia, Ohio. Apparently it was an accidental spill, but it sent at least two persons into health treatment for observation.  And, of course, it made the news.

June 7:  A TV news report said that “during routine maintenance by a worker” there was “an excess amount of chlorine and sulfuric acid” put into a pool in southern Wisconsin.  Eleven people were taken to the hospital with respiratory complaints.

June 11:  Stories broke about the chemical spill at a waterpark in Manassas, VA. Initial reports indicated that 7 people were treated for exposure, but that quickly blew up into “dozens”.  This story was in the news for a week.

The Internet Magnified the Buzz

Within hours of initial reports about the Manassas spill, the news had spread to other blogs and news outlets online.  Given the copycat habits of a lot of “news” publishers, the most dramatic (and possibly misleading) version of the story got a lot of coverage.

June 11:  A second online news outlet published a story about the Manassas spill with a grabby headline starting with “Dozens Sickened in Chemical Spill…”.  The detail in the story says that “seven people were taken to the hospital and 30 were assessed…”, leaving the reader to assume that assessment is evidence of sickness. If you only skimmed the headline, no qualification was even possible.

June 11:  A headline blogger picked up the sensational news item and flashed a quick post with the title starting “Dozens Sickened…”. This post was nothing more than a title and a link to the original article, but it made the first page of the Google search results.

June 12:  A second me-too blogger titled a post “Dozens Sickened…” with a link to the original article.  It also performed well in Google’s results.

First Thing We Do … Is Alert the Lawyers?

Within days of the spill, personal injury lawyers were posting online invitations to possible victims to get representation.

June 14:  This post by a “Prince William Injury Attorney” is aimed specifically at people affected by the Manassas spill.  “If you have a loved one that has been injured…” is the invitation to contact the firm.  The post includes the original article with the title “Dozens Sickened…” in the list of sources.

No date:  A general solicitation for help recovering damages due to a chemical spill was pulled up in search results. This one probably was not posted due to the Manassas spill, but the “chemical spill” in our search query snagged it. The net result is the same:  anyone viewing news about the event would see it.

Liability is Manageable

The story about the Manassas chemical spill was in the news as late as June 16h, when a follow up was posted in at least one news outlet.  It said the facility still hoped to re-open by June 19th, but that was not certain.  A full week’s operational loss was due to a mechanical failure in the chemical feed system, it seems.  The damage from the news cannot yet be assessed.

We fully understand how difficult it is to control events like these. But that’s why anticipation is your best response.  As the Scouts say, Be Prepared.

Posted by DELOzone on July 8, 2011 | Comments (0) | Trackbacks

Can You Trust the Source?

June 28th, 2011

We at DEL are highly aware that when we argue for ozone as a disinfectant for commercial aquatic facilities, we are making claims about something that matters very deeply to the users and operators of those facilities. We try hard to know and incorporate the objective science into our designs and machines and what we say about them.

That makes us go to high alert when we find strong claims made without the factual or experimental backup they need, especially in places where the publisher has a monetary stake.

Here’s an example:

Chlorine resistant microorganisms such as Cryptosporidium crypto [sic] may come in the municipal piped water supply mainly in countries with bad sanitation conditions, and are not easily killed by chemical disinfectants in the pool. Alternative pool sanitation technologies such as electronic oxidation [sic] combined with copper ionisation provides a 100 protection against Cryptosporidium.

We’ve studied crypto, run our own tests on it, had 3rd party validation tests run on our pool disinfection equipment to make sure we kill crypto. We know our ozonators, properly sized and installed, destroy Cryptosporidium parvum. But in none of our tests or in any other tests we’ve seen, can anyone claim to kill 100% of crypto oocytes. No scientist worth his or her salt would ever claim it.

The problem here is that the adsense website where the exaggerated claim is made is really all about selling you stuff. In fact, embedded in the long article about pool disinfection (probably lifted from another source), you will find invitations to buy knockoff wholesale leather handbags. The part of the article that is about pools, however, sounds like it’s written by someone who knows what they are talking about. It uses professional-sounding jargon and even some technical terminology.

We know that our readers are too sophisticated to be fooled by an outlandish website like the one we’re using here to illustrate a point. But there are more subtle misleading claims showing up promoting disinfection solutions without really putting the science on display. The problem is that these websites are often found in search results where uninformed people may take them at face value. That can hurt all of us.

Posted by DELOzone on June 28, 2011 | Comments (1) | Trackbacks

All About Secondary Disinfection by Ozone

June 27th, 2011

We posted this slideshow last fall, but it’s chock-full of good information about ozone as a secondary disinfectant for commercial swimming pools. As you know, ozone has been recommended by the Model Aquatic Health Code as one of the preferred alternatives for secondary disinfection.

We are posting this again because we been hearing some questions about how well ozone works in the commercial pool venue. As you will see from this information, it works very well indeed.  Please note:  this slideshow is for people who want thorough fact-based information — it can be a little dense, and it reports data from research and validation studies.  We think it repays the attention you give it.

We would love to hear your feedback about this slideshow!

Ozone for MAHC Secondary Disinfection
View more presentations from DEL Ozone

Posted by DELOzone on June 27, 2011 | Comments (0) | Trackbacks

Model Aquatic Health Code Modules Status

June 23rd, 2011

The Model Aquatic Health Code is being written in ‘modules’ by a dozen technical committees under the guidance of a steering committee. These modules will be submitted to an extensive process of public comment and revision, and eventually will be published as a single code (see our companion post on the Model Aquatic Health Code process for the steps and how to participate in it).

Summary of the Modules

Since each technical committee corresponds to a module (excepting process or administrative modules), the summary table below lists the committee / module as one item.  We will update and publish this table as information becomes available. To find draft documents see the CDC webpage.

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Operator Training Module

The Operator Training module is the example for how the process works.  It has been through the technical committee draft; reviewed and edited by the steering committee; submitted for public comment; revised; and published in draft form.  This module has been receiving publicity by interested parties, like the important National Swimming Pool Foundation, which endorsed the module.  NSPF was instrumental in starting the MAHC process, and is the kind of influential organization whose comments go far to shape the final document.

DEL on Disinfection & Water Quality

Full disclosure:  DEL Ozone VP Beth Hamil is a member of the Disinfection & Water Quality Technical Committee.  In this role, she has supplied technical information about best practices for aquatic ozone disinfection systems, based on DEL experience. However, the MAHC process, not DEL, is responsible for the final draft of the module.

Posted by DELOzone on June 23, 2011 | Comments (3) | Trackbacks

In Brief: MAHC Review and Approval Process

June 23rd, 2011

The seeds planted in 2005 are beginning to bear fruit.  The Model Aquatic Health Code is well on the way to being a single public document containing best practice health and safety standards for public aquatic facilities.  However, as you will see in the outline of the process below, the final completed code is probably quite a long way off (think in terms of a couple years rather than months).

Technical Committees and Modules

Each of the 12 Technical Committees is responsible for drafting the best practice standards for their area.  Thus, each committee will produce one ‘module’ in draft form to insert into the review, revision and approval process set up by the CDC (for more on these areas of expertise, see the companion post on Model Aquatic Health Code  modules).

The final code will be a compilation of modules that have been drafted by a technical committee, approved by the steering committee, opened to review and comments by the public, revised, and finally published.

A Summary of the Process

There is ample opportunity for public comment on the MAHC.  Here’s the steps:

  1. A technical committee drafts a module and submits it to the steering committee for review (this is a fluid process to allow the steering committee to integrate the work of multiple technical committees on the fly).
  2. The steering committee review of the module may call for further work by the technical committee.  A module will not receive steering committee approval until its concerns have been addressed (there may be iterations).
  3. Upon approval by the steering committee and a final edit to ensure cross-module compatibility, a module is released for a 60-day public comment period.
  4. The steering committee and technical committee consider the public responses and revise the module as appropriate.
  5. The module may then be submitted again to public comment for another 60-day period.  (There is no stated, fixed limit on how many times a module can be submitted for public comment prior to being incorporated in the complete document, but time and successive improvements will cut them off at some point.)
  6. Once all the modules are revised following public comment, they will be compiled into the full Model Aquatic Health Code document and submitted for comment yet again.
  7. After a final revision, the complete document will be published.  However it is clear that this process will be on-going with continuous revisions to the code.

How You Can Comment

Comments will be accepted only for specific modules that are in a public comment period.  And, you MUST submit comments on a specific form (this is a Word document that will download in a new window) sent to either:

  • By email as an email attachment to MAHC@cdc.gov or
  • By mail (postmarked by the submission deadline) to:
 MAHC Coordinator
, Waterborne Disease Prevention Branch, 
Division of Foodborne, Waterborne, and Environmental Diseases, 
Centers for Disease Control and Prevention, Mailstop F-22, 
4770 Buford Highway, NE
, Atlanta, GA 30341

Which Modules Are Open for Comment?

At this moment, no modules are open for comment.  Please see our companion post on the Model Aquatic Health Code modules.  The authoritative calendar will be kept and publicized by the CDC, and unfortunately there is little visibility on when subsequent modules will be released. Stay tuned.

Posted by DELOzone on | Comments (3) | Trackbacks

Some Chloramines not Shocked by Chlorine

June 4th, 2011

This post by Aqua Magazine is drawing a lot of punny attention, but it does make clear that ‘shock and awe’ does not apply to superchlorination of pool water.  The magazine reports on some research by DuPont that shows that shocking a pool with chlorine does NOT eliminate all chloramines.  Organic chloramine continues to accumulate in the pool, and the disinfection byproducts that may result continue to threaten human health.  By contrast, ozone is both more effective than chlorine shock and leaves none of the disinfection byproducts chlorine produces.

The Sweat Test

Traditional practice suggests that superchlorination will destroy chloramines in a pool. Pools and aquatic venues throughout the country – both commercial and residential – have been managed according to this accepted method.

The new evidence shows that the assumptions behind tradition are false.

Dr. Tom Tufano, a senior R&D chemist at DuPont, and researchers Professor E.R. Blatchley and Dr. Jing Li at Purdue University, designed and carried out research to test the effectiveness of chlorine. The test involved dosing the water with creatinine, an organic compound in human sweat, and then shocking the water with chlorine.

As the following chart from Aqua Magazine indicates, superchlorination is effective in destroying inorganic chloramines, but the organic chloramines introduced by the creatinine persisted, and even increased slightly over time.  As Trufano says, “We see the buildup of persistent organic chloramines that remain no matter how much chlorine is added.  The added chlorine did nothing but produce a persistent chloramine where there was none.”

Chlorine shock does not destroy organic chloramines like ozone does

Chlorine Shock Does Not Destroy Organic Chloramines

The conclusion of the research is that “Breakpoint chlorination techniques are really only effective against inorganic, ammonia-based chloramines.  They do not impact the organic chloramines present in all pool water.”

Superchlorination is a Problem, not a Solution

The buildup of organic chloramines over time presents a health hazard.  Further, the high levels of free chlorine introduced by shocking a pool interact with organics in the pool to stimulate the development of disinfection byproducts – like trichloramine (NCl3) – that are known to be dangerous to humans.

This is a perverse result:  the traditional practice of superchlorination contributes to the very outcomes it is designed to prevent.  Trufano puts it bluntly:  “We should stop the practice of superchlorination.”

Ozone is the Alternative

DuPont (a sponsor of the research reported here) is a major manufacturer of potassium monopersulfate (MPS) shock, and the company recommends it as an alternative to chlorine shock treatment.  However, MSP is also only effective against inorganic chloramines.

Jeff Smith, the product manager of sanitizers and water chemistry for Pentair Water points out that ozone is an alternative, and is a much more effective oxidizer than chlorine. This belief is becoming more and more common among aquatic professionals, and it is embedded in the draft form of the MAHC recommendations, which recommend ozone for secondary disinfection of human aquatic venues.

One more piece of evidence:  it is time to move away from over-dependence on chlorine.

Posted by DELOzone on June 4, 2011 | Comments (1) | Trackbacks
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