How to meet water management guidelines for pools in hotels, resorts and aged care facilities

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Now is the perfect time for facilities managers to assess whether the commercial pool under their charge meets the latest regulations on water quality. Stacey Edwards dives in.

As the cooler weather begins to set in, it’s a timely reminder that some states across Australia have recently upgraded their rules around pool standards, regulations and maintenance requirements.

So why the concern about aquatic facilities?

Microbiological hazards present the greatest risk for recreational water use due to exposure to humans and surrounding environments. 

The most common illnesses resulting from public aquatic facilities are gastroenteritis and skin, wound and ear infections. These can be caused by a range of bacteria, viruses, protozoa and fungi. Many of these can be managed by chlorine disinfection. In order for chlorine to be effective, turbidity must be appropriately managed, thus the requirement for filtration. Clarity of water also assists with visibility within the body of water, which is important for both safety and swimmer enjoyment.

One key hazard that is not managed by chlorine is Cryptosporidium. Cryptosporidium are parasites carried by humans and cattle that are spread via faecal matter. The cryptosporidiosis is the most common illness outbreak associated with public facilities and can lead to diarrhoea lasting up to 30 days. The risk profile of a facility is determined based on the number and demographic of users, and the category of use.

To avoid these devastating consequences the development of a risk management plan is essential.

What you need to know

Requirements for commercial pools currently vary between states, though the guidelines often reflect similar principles. Facility managers should consider both location-based requirements and best practice recommendations.

When creating or reviewing a risk management plan, it is important to assess the risk profile of a facility and how this is handled by practices such as turnover period, chemical dosing and filtration. The risk assessment process should have the ability to identify the value provided by existing practices to be able to consider further optimisation suggestions.

Plans guide aquatic facilities by providing clear management strategies for ongoing operations and measures required in the case of an incident. By implementing a risk management plan, public aquatic facilities can ensure their customers’ safe enjoyment of their facility.

Breakdown by state

The Queensland Government has a requirement under the Public Health Act 2005 that public aquatic facilities do not pose a public health risk. The Queensland Health ‘Water Quality Guidelines for Public Aquatic Facilities 2019’ provides advice for operators on managing risks and incidents, prior to this there were the ‘Queensland Health Swimming and Spa Pool Water Quality and Operational Guidelines’ (October 2004). One means of managing risks related to public aquatic facilities is to develop a site-specific risk management plan – Queensland Health provides a template of what should be included in this.

In Victoria the Public Health and Wellbeing Regulations 2019 have replaced the Public Health and Wellbeing Regulations 2009 and require that all category 1 aquatic facilities must have been registered with local council from 14 December last year. Registration includes a statement explaining whether each facility has a site-specific water quality risk management plan. To support this requirement there are the ‘Water quality guidelines for public aquatic facilities’ (December 2020) which require public facilities to have a water quality risk management plan in place. Victoria Health have a guide and template for Water Quality Risk Management Plans.

The guidelines for both states make similar recommendations regarding pool management, treatment and monitoring requirements and are largely informed by the Pool Water Treatment Advisory Group, ‘Swimming pool water – treatment and quality standards for pools and spas’ (2017) and the NSW Department of Health – ‘Public swimming pool and spa pool advisory document’ (2013)

Other states have no specific requirements for a risk management plan but have specific technical recommendations for maintaining public health. The development of a plan can assist facilities to ensure these standards are met and any potential hazards are identified. With regards to legislation in New South Wales, the Public Health Act and Public Health Regulation outline specific water quality requirements (relating to disinfection) that must be met with records of testing kept.

In South Australia there is the SA Department of Health and Ageing – ‘Standard for the Operation of Swimming Pools and Spa Pools’ (2013) for guidance and the Public Health Act and Public Health Regulation with specific requirements for treatment.

The Western Australia Department of Health – Code of Practice for the Design, Construction, Operation, Management and Maintenance of Aquatic Facilities outlines the requirements for an Aquatic facility, focusing on technical aspects. And the WA Health – Health (Aquatic Facilities) Regulations (2007), which has requirements for microbiological sampling.

Northern Territory has the Department of Health – Public Health Guidelines for Aquatic Facilities.

In Tasmania, the Recreational Water Quality Guidelines (2007) require councils to monitor water quality at some public facilities.

How to manage your risk

The development of a Risk Management Plan includes undertaking a risk assessment. The risk assessment process is essential for facilities to identify gaps within their process. This process should involve identifying hazards, determining the consequence of this hazard, identifying barriers and assigning a residual risk after controls. This allows facilities to consider which barriers are most critical in preventing a threat to public health. 

Typically, the major risks to public health will be due to waterborne microbiological hazards due to their ability to cause widespread illness. Recommended risk assessment methodologies are available including risk matrices. Risks are categorised by their consequence and the likelihood of the hazardous event occurring. Barriers such as disinfection will reduce the likelihood of an outbreak and as such reduce the residual risk. How effectively a barrier is implemented should be considered during this process. Unacceptably high residual risks will require additional risk treatments which should be outlined in the Plan. 

Once hazards and controls are identified, a risk management plan can be developed. The risk management plan should include a description of the facility and treatment process, results of the risk assessment, monitoring to be undertaken, incident response protocols, operator skills and training and how the plan will be reviewed and audited. 

The specific needs of the facility will dictate the treatment applied but, at a minimum, all facilities must employ filtration and primary disinfection. These are essential barriers against microorganisms and without these a facility is not safe for public use. The filters should be pre-validated by the manufacturer and operated within recommended ranges. Filters should be able to treat water to <0.5 NTU immediately post-filter and backwashing employed regularly. Primary disinfection must provide a residual – meaning that a concentration of the disinfection is maintained within the body of water to protect against re-infection between circulations. Chlorine or bromine-based disinfectants are recommended by the states’ guidelines. 

The need for secondary disinfection is based on the potential Cryptosporidium risk. To effectively remove Cryptosporidium a filter must be able to remove particles as small as four microns, which is outside the capabilities of conventional media filters. 

Monitor, measure and repeat

Monitoring can be split into operational and verification monitoring. Operational monitoring is performed on site and guides routine corrective actions to ensure water quality targets are met. Recommended monitoring frequency is determined based on the risk category of the facility and whether automated monitoring is available. Verification monitoring is performed externally by a lab and confirms the effectiveness of operational practices. Facilities should perform monthly or quarterly (based on category) monitoring of E. coliPseudomonas aeruginosa, Heterotrophic colony count (HCC) and Chloramines (and ozone if used).

There are recommended limits for operational monitoring outlined in the state guidelines for key parameters such as pH, turbidity and free and total chlorine. The Victorian Guidelines recommend that facilities develop Critical Control Points (CCP) with a target range, action range and critical action range. The action range triggers corrective actions before the process leaves a safe range to prevent non-compliances and possible down time. Critical control points are used in a range of industries, the most relevant being drinking water and should provide clear guidance to operators regarding trigger limits and corrective actions. Ensuring that this information is clearly recorded will improve knowledge retention and operator engagement with the Risk Management Plan. It is recommended that facilities use their operational monitoring data to calculate the pool’s Langelier Saturation Index. This is calculated using the pH, total alkalinity, calcium hardness, water temperature and total dissolved solids. LSI is an indicator of how well a pool is balanced which impacts treatment effectiveness and equipment longevity.

If the risk management plan is implemented and reviewed properly then facility managers should be able to avoid a case of ‘H2-Uh-Oh!’ when customers start enjoying the pool again.

Stacey Edwards is technical officer of Viridis Consultants, which specialises in the management of municipal water quality risks.

Photo by Serena Repice Lentini on Unsplash

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