Welcome to Vote on the Code 2015 The Process Begins!

CMAHC CR-TRC Presentations Wednesday Morning

Thanks to CMAHC Sponsors Founding Sponsors Gold Bronze

Change Request #77  Submitter presentation: TRC  Summary: Sets water quality parameters that, if met, would allow operator to reduce halogen levels to 0.5ppm and 0.3ppm

CR 77

WEDNESDAY AM USE OF MEMBER COMMENT INFORMATION POST-CONFERENCE

Using Member Comment Post Conference  I said yesterday we could use member comment post- conference to modify CRs for the final vote (as if a virtual floor modification was being done)  Lots of response to that negative and positive so really need to discuss with membership now so we can have some agreement while you are here

Using Member Comment Post Conference  Scenarios: Three thoughts  CRs cannot be changed after they are published for conference  CRs can be modified with new data, wording to improve them  CRs can be extensively modified with new ideas

Using Member Comment Post Conference  Scenarios: Three thoughts  CRs cannot be changed after they are published for conference  CRs can be modified with new data, wording to improve them As Jennifer Hatfield said yesterday, the NEC wording used in GFCI requirement required to be inspected is old (15v) and NEC uses new wording now. In this scenario we could put in new wording  CRs can be extensively modified with new ideas In discussion of pool shelves we never discussed other solutions such as use some stairs to step them down into main pool, we could do that or is it too big a change after presentation to conference

Using Member Comment Post Conference  Scenarios: Three thoughts  CRs cannot be changed after they are published for conference  CRs can be modified with new data, wording to improve them  CRs can be extensively modified with new ideas  What do we do this year?  What do we do next time when we will improve process and amount of input at front end so the CRs coming to conference have had more vetting and member input

THOUGHTS???

WEDNESDAY AM CR PRESENTATIONS SECTION 8 CR’S 80/81/82A/82B/152, 94/95/96, 101

Change Request #80/81/82A/82B/152  Submitter presentation: Michael Beach, CDC  Mea Culpa  Summary: CRs seek to change  Alter the fecal incident response to include guidance for stabilized pools---new data shows little inactivation of Crypto above 16 ppm cyanurate (CR152)  Ban cyanurates in indoor settings (unless they have UV exposure warranting stabilizer use) (CR80)  Reduce allowable cyanurate levels to 20ppm unless secondary disinfection available (CR81)  Reduce allowable cyanurate levels to 90ppm in all venues since test kits can’t differentiate between 100 and >100ppm (CR82A)  Reduce allowable cyanurate levels to 90ppm in venues without secondary disinfection since test kits can’t differentiate between 100 and >100ppm (CR82B)

Change Request #80/81/82A/82B/152  Submitter presentation: Michael Beach, CDC  Summary: CRs seek to change  Alter the fecal incident response to include guidance for stabilized pools---new data shows little inactivation of Crypto above 16 ppm cyanurate (CR152)  Ban cyanurates in indoor settings (unless they have UV exposure warranting stabilizer use) (CR80)  Reduce allowable cyanurate levels to 20ppm unless secondary disinfection available (CR81)  Reduce allowable cyanurate levels to 90ppm in all venues since test kits can’t differentiate between 100 and >100ppm (CR82A)  Reduce allowable cyanurate levels to 90ppm in venues without secondary disinfection since test kits can’t differentiate between 100 and >100ppm (CR82B)

Recent CDC Crypto Inactivation Data Publication  Reason for collecting Crypto data was to make science- based recommendations for how to alter the fecal response protocol in the presence of stabilizer  Previous data had to be extrapolated to 3 log inactivation levels, which is not good practice Did it because no other data existed  Pertains to an extremely chlorine-tolerant pathogen where “normal” halogen disinfection is ineffective  Data not intended to influence normal operating disinfection guidance designed to inactivate chlorine-sensitive and moderately-sensitive pathogens

 A = 20ppm FAC  B = 40ppm FAC  C = ppm cyanurate  Bad news for Crypto inactivation  Full presentation at WAHC What Data are Being Used?

Change Request #152  Data warrants changing fecal incident response to treat stabilized venues after diarrheal events

Change Request #80  Ban cyanurates in indoor settings (unless they have UV exposure warranting stabilizer use) (CR80)  Uses Crypto inactivation data to rationalize ban although Crypto cannot be solved through a halogen solution under operating conditions  MAHC requires showing a potential public health impact or deficit to change Rationale is not showing this vs. using a non-public health impact argument for change o Operational rationale: If cyanurates use is rationalized only for UV protection then it is not needed indoors  This same change was rejected during MAHC development

Change Request #81  Reduce allowable cyanurate levels to 20ppm in all venues unless secondary disinfection available (CR81)  Uses Crypto inactivation data to rationalize change although Crypto cannot be solved through a halogen solution  Data for common chlorine-sensitive pathogens like bacteria do demonstrate reduced inactivation times with cyanurates If it takes a second to inactivate a pathogen and stabilizer changes that to seconds----is that really going to have a public health impact? Based on existing data, doubling the amount required as the MAHC does should be sufficient to cover issue unless newer data shows differently

Change Request #81  Reduce allowable cyanurate levels to 20ppm in all venues unless secondary disinfection available (CR81)  Wait for data that applies to operating conditions before making changes, not use halogen tolerant pathogen data to change operating conditions—not applicable  Including secondary disinfection wording says rationale is mixing chlorine inactivation with Crypto inactivation The secondary disinfection is there for Crypto

Change Request #82A  Reduces allowable cyanurate levels to 90ppm in all venues since test kits can’t differentiate between 100 and >100ppm (CR82A)  Rationale that current level of 100ppm is maximum of test so you can’t tell if you are at 100ppm or way above---all looks the same  Argument that one should just do dilutions Clear evidence from investigations that operators and public health staff do not do dilutions and many are unclear on methods

Change Request #82B  Reduce allowable cyanurate levels to 90ppm in venues without secondary disinfection since test kits can’t differentiate between 100 and >100ppm (CR82B)  Rationale that current level of 100ppm is maximum of test so you can’t tell if you are at 100ppm or way above---all looks the same  Amends to remove venues without secondary disinfection Alters operating conditions for FAC based on UV/ozone sensitivity of Crypto---not appropriate use of data, could impact chlorine sensitive pathogens  Including secondary disinfection wording says rationale is mixing chlorine inactivation with Crypto inactivation The secondary disinfection is there for Crypto

Change Request #82B  Reduce allowable cyanurate levels to 90ppm in venues without secondary disinfection since test kits can’t differentiate between 100 and >100ppm (CR82B)  Unintended consequence is there is now no cyanurate limit in venues with secondary treatment Cyanurate levels could go out the roof and may result in reported “chlorine lock” so you essentially have no residual disinfection and are totally dependent on a circulation- dependent technology Bacteria more resistant to UV than Crypto since they have UV repair mechanisms so may take longer to inactivate (crypto ’s weakness is that it does not have a UV repair system)  Potential negative public health impact likely to occur during extended time to inactivate chlorine-sensitive pathogens via circulation-dependent technology alone

CR152

CR 80

CR 81

Change Request #94/95/96  Submitter presentation: RAC Carroll, Jeff Ellis and Associates  Summary: All deal with emergency communication equipment (hard-wired telephone) needs if on-site personnel present or signs needed to alert users  Exempts facility when personnel on-site for phone and signs

TRC Review CR94 Phone CR95/96 Signage

Change Request #101  Submitter presentation: TRC  Summary: Deletes requirements for pool chemical training for aquatics personnel who handle chemicals because pool programs would not have capability to know if training meets these requirements

WEDNESDAY AM CR SUBMITTED COMMENTS (0) CHAT ROOM COMMENTS SECTION 8 CR’S 80/81/82A/82B/152, 94/95/96, 101

WEDNESDAY AM CR PRESENTATIONS SECTION 9 CR’S 107, 117, 118/122, 119

Change Request #107  Submitter presentation: TRC  Summary: Deletes caveat (if AHJ requires) for purveyors of pool operator training courses to submit course information to AHJ whether required or not

Change Request #117  Submitter presentation: TRC  Summary: Adds wording requiring lifeguard training agencies to have methods in place to revoke certifications in the case of a lifeguard creating safety and health hazards  Parallels what is required for operator training agencies

CR 117, cont.

Change Request #118/122  Submitter presentation: TRC  Summary: Clarifying requirements for Lifeguard Supervisor eligibility  CR118: requires current lifeguard certification to be supervisor  CR122: Deletes words “in the past” from requirement for completion of lifeguard training to be supervisor but does not require current certification

CR 118, cont.

CR 122, cont.

Change Request #119  Submitter presentation: TRC  Summary: Reduces requirements for becoming a Lifeguard supervisor. Waives need for at least 3 months lifeguarding experience under certain circumstances

WEDNESDAY AM CR SUBMITTED COMMENTS (1-117) CHAT ROOM COMMENTS SECTION 9 CR’S 107, 117, 118/122, 119

WEDNESDAY AM CR PRESENTATIONS SECTION 10 CR’S 124, 127, 128, 134/135

Change Request #124  Submitter presentation: TRC  Summary: Requires any facility serving alcohol to have a lifeguard

CR 124, cont.

Change Request #127  Submitter presentation: Joe Stefanyak, Jeff Ellis and Associates  Summary: Requires that Lifeguard in-service training be done only by a Qualified Lifeguard

CR 127, cont.

Change Request #128  Submitter presentation: RAC Carroll, Jeff Ellis and Associates  Summary: Removes wording about competency testing of lifeguards from in-service training section

Change Request #134/135  Submitter presentation: Joe Stefanyak, Jeff Ellis and Associates  Summary: Both seek to alter the wording concerning use of lifeguard remote monitoring systems so they can not substitute for “line of sight” positions since line of sight is required.

CR 135  Make screenshots

CR 135, cont.

WEDNESDAY AM CR SUBMITTED COMMENTS: (3-CR128) CHAT ROOM COMMENTS SECTION 10 CR’S 124, 127, 128, 134/135

WEDNESDAY AM CR PRESENTATIONS SECTION 11 CR’S 137/137A, 138/138A/139

Change Request #137/137A  Submitter presentation: TRC  Summary: Concerns inspections for bonding conductors  CR137: removes requirement for 6 month inspection and replaces with 5 years  CR137A: keeps 6 month inspection and adds sentence about also having inspections when bonding conductors potentially impacted by site disruption

Change Request #138/138A/139  Submitter presentation: TRC  Summary: All concern facility record keeping  CR138: removes 24 hour time for reporting injury and illness to AHJ from operations manual since it could apply to non-aquatic facilities  CR138A: Clarifies that this is for aquatic facility only requirement and keeps 24-hour time  CR139: Clarifies this reporting is only for aquatic facilities

WEDNESDAY AM CR SUBMITTED COMMENTS: (0) CHAT ROOM COMMENTS SECTION 11 CR’S 137/137A, 138/138A/139

Wednesday Lunch noon – 1pm: Thanks to CMAHC Sponsors Founding Sponsors Gold Bronze

Contact Information Doug Sackett Executive Director, CMAHC Phone:

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: