Welcome to
Vote on the Code 2015
The Process Begins!
CMAHC CR-TRC Presentations
Tuesday Afternoon 10-06-2015
Tuesday Lunch: Noon-1pm
Thanks to CMAHC Sponsors
Founding Sponsors
Gold
Bronze
CAUCUS TIME: TUESDAY 1-2 PM
CR SECTIONS 1-3
Caucus Guidance
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Federal, State, State
Designee, Local Health Depts.
Split into your sector
 Facilitator provided

Public Health/Regulators:
Public Health: Las Palmas 1
Manufacturer: Las Palmas 2
Designers: Las Palmas 3
Management/Staff: Garden Terrace
Manufacturers/Suppliers:
Aquatic Manufacturer,
Aquatic Supplier
Designers/Builders:
Aquatic Design, Aquatic
Builder, Academia
Management/Staff:
Consumer, Consumer
Protection, Aquatic Staff,
Aquatic Management
Remember for CR Presentations and Comments
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Times to be strictly adhered to!
Sign on and use the chat room to make yourself heard
 Best if you stick to the CRs being presented in that hour Section
 Summary each hour to be presented

All submitter slide presentations are available on the
website (if they came by the weekend)
 Posted in the CR/TRC data listing (Column labeled “Present.
Documents” at end of listing)

You can still (and should if you feel strongly) submit
member comments for 2 weeks after the conference
(until October 23)
 Submit and influence final CRs in the vote (info@cmahc.org)
TUESDAY PM
CR PRESENTATIONS
SECTION 4
CR’S 39, 44, 48, 50
Change Request #39

Submitter presentation: Lars Hagen, AquaCal AutoPilot,
Inc.

Summary: Transition chlorinator sizing away from one
number for all to performance based criteria
* 4.7.3.2.2.2 Chlorine Dosing
* All chlorine dosing and generating equipment…. shall be
designed with a capacity to provide and maintain Free
Available Chlorine (FAC) levels as specified in Section
5.7.3.1.1.2. (which are minimum FAC concentrations of 1,2 or
3 ppm based on Aquatic Venue)
* 4.7.3.2.2.3 Rates
* The engineer shall address the following factors when
sizing the feeders/equipment:
* Pool surface area
* Pool volume
* Pool type: Pool, Spa, Kiddie/Wading Pool,…
* Indoor/Outdoor…..
* And other chlorine demand factors….
* MAHC Research Agenda – Tier 1
(needed to make short term improvements in MAHC)
* Develop guidance and supporting data to enable
appropriate sizing of feeders.
* Collect data on chlorine usage in real world pool situations
under different environmental and operational conditions to
inform development of an effective rate law from which the
sizing of chemical feed pumps could then be calculated.
* Once actual chlorine usage is obtained, a surplus safety factor
could be introduced to slightly oversize the feed pump to
ensure that the disinfectant dosing amount can be increased
to meet increases in demand.
* Any such sizing requirements need to specify the timeframe
within which the pump must be able to satisfy the chlorine
dosing required.
* Due to time constraints, the workgroup was not able to
gather and/or analyze data from enough pools in sufficient
detail to address different environmental and operational
conditions as specified in the research agenda.
* Based on the available data, the CMAHC Chlorinator Sizing
Workgroup sub-committee's preliminary analysis indicates
that there is not a direct correlation between actual
chlorine consumption vs. aquatic venue volume, and that
other factors should be included in the engineering design
dosing capacity of chlorine per day.
* The preliminary analysis indicates that currently there is not
an ideal dosage rate formula.
* The analysis also indicates that the current MAHC/code
requires a higher feeder capacity than necessary to meet
demand.
* One of the key precepts of the MAHC is that it be
performance-based where possible. Below is the proposed
performance-based revision to the MAHC, included in the
submitted Change Request (CR39). Prescriptive dosing levels
(# lbs of FAC/day/10,000 gal) were considered, but revised
dosing levels based on the available data could not be
defended nor did the data support the existing rates.
* To better design chlorine dosing capacity for aquatic venues
and revise the MAHC accordingly, a formal scientifically
gathered data collection and analysis effort is
recommended. The CMAHC intends to pursue this additional
data collection and analysis recommendation.
* The sub-committee is preparing an interim progress report
which will be passed on to the CMAHC. It will then be
posted on the CMAHC website.
MAHC, NSF/ANSI 50 Chlorine Recommendation, and Reported Usage Normalized
(Indoor Pools/Spas & Outdoor Stabilized/Unstabilized Pools/Spas)
2,500%
2,000%
1,500%
Reported usage
NSF % of typical
MAHC % of typical
1,000%
n=102 Aquatic Venues: including
Regular Pools/Spas, Kiddie/Wading,
Water feature, Water slide
500%
0%
1
4
7
10
13
16
19
22
25
28
31
34
37
40
43
46
49
52
55
58
61
64
67
70
73
76
79
82
85
88
91
94
97
100
Ratio - Chlorine Recommendation versus Typical
3,000%
Chart Details:
- The MAHC & NSF/ANSI 50 recommendations and the Reported Usage are
divided by the Reported Usage to provide a normalized value for plotting.
- The current MAHC does not have dosage recommendations for outdoor
stabilized pools/spas. A plotted value of 0% indicates the Aquatic Venue falls
into this category.
- Samples are sorted in ascending order by the NSF/ANSI 50 normalized value.
Code Dosage Rates: Currently both MAHC and NSF code recommend chlorine
dosage strictly by the volume of the Aquatic Venue. NSF has one rate. The
MAHC has two rates, which is why values are above and below the NSF line.
Chart Analysis Summary:
- The NSF/MAHC code does not provide adequate sanitation or safety margin
on some Aquatic Venues. (i.e. Only 84% of the typical daily usage is
recommended by NSF on the first pool.)
- The MAHC and NSF codes recommend an excessive amount of sanitation
dosing capacity on many venues. (i.e. 2,824% and 2,353% respectively, on the
last pool)
- Pool volume does not correlate to chlorine demand. Other factors are
involved. A better method for determining dosage rates is warranted.
Pool/Spa Sample
CR39: Annex Language

The CMAHC established a Chlorinator Sizing Workgroup to address chlorinator
sizing by collecting and analyzing actual chlorine consumption at operating pools.
Based on the available data collected, the CMAHC Chlorinator Sizing Workgroup
sub-committee's preliminary analysis indicates that there is not a direct correlation
between actual chlorine consumption vs. aquatic venue volume, and that other
factors should be included in the engineering design dosing capacity of chlorine
per day. The preliminary analysis indicates that currently there is not an ideal
dosage rate formula. The analysis also indicates that the current MAHC/code
requires a higher feeder capacity than necessary to meet demand. One of the key
precepts of the MAHC is that it be performance-based where possible.
Performance-based revision to the MAHC have replaced prescriptive dosing
levels(# lbs of FAC/day/10,000 gal.). Revised prescriptive dosing levels were
considered, but dosing levels based on the available data could not be defended,
nor did the data support the existing rates. To better design chlorine dosing
capacity for aquatic venues and revise the MAHC accordingly, a formal scientifically
gathered data collection and analysis effort is recommended. The CMAHC intends
to pursue this additional data collection and analysis recommendation.

An interim progress report by the CMAHC Chlorinator Sizing Workgroup will be
posted on the CMAHC website.
Change Request #44

Submitter presentation: TRC

Summary: Annex wording change to change minimum
flow rate calculation for secondary disinfection systems
CR 44, cont.
Change Request #48
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Submitter presentation: TRC

Summary: Deletion of water replenishment
requirements in design section, which may be needed
in arid states with water restrictions. No policy changes
in Operation and Maintenance Section
CR 48, cont.
Change Request #50

Submitter presentation: Richard Cacioppo, Water Tech
Corp.

Summary: Requirements for pool vacuum cleaning and
use, and installation in Design and Construction
Section
CR 50, cont.
TUESDAY PM
CR SUBMITTED COMMENTS(1-CR50)
CHAT ROOM COMMENTS
SECTION 4
CR’S 39, 44, 48, 50
TUESDAY PM
CR PRESENTATIONS
SECTION 5
CR’S 51, 52, 56/58/99/156
Change Request #51

Submitter presentation: John Kelly, IA Dept. of Health

Summary: Places limits on use of wing walls: not on
zero entry, not next to 5 feet of water, or in areas where
depths differ by more 6 inches
CR51-Issue: Drowning Prevention

4.8.1.6.7 Wing wall uses
Wing walls shall not be used immediately adjacent to a zero
depth entry, immediately adjacent to water depths greater than
5 feet in depth, or to separate sections of pools with water
depths varying by more than 6 inches in water depth.

Wing walls create large physical obstructions limiting
visibility into a swimming pool and abrupt depth changes
across wing wall can allow young non-swimmers to quickly
and quietly access water that is too deep. Generally these
young non-swimmers are separated by non climbable
barriers or distance from deeper water
CR51-Issue: Drowning Prevention

Data from CDC
Wonder, appears to
indicate the rate of
drowning and
submersion deaths
associated with
swimming pools for
young children has
been trending higher
since 1999.
CR51-Issue: Drowning Prevention

Wing walls used immediately adjacent to a zero depth
entry places young children only a step away from a
serious drowning hazard
CR51-Issue: Drowning Prevention

Wing walls used
immediately adjacent to
deep water limit the
lifeguard access and
visibility into the deep
water
CR51-Issue: Drowning Prevention

In this pool a wing wall is used
to separate an 18” deep
toddler play area from a
current channel. In the drowning
incident that occurred the child
was with his sibling in the zero
depth entry before he was
recovered from the current
channel. It appeared likely he
entered the channel over the
wing wall or through the
underwater stairs.
Change Request #52
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Submitter presentation: John Kelly, IA Dept. of Health
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Summary: Diving board change requiring railings and
stairs for all boards 1 meter or higher
CR52-Issue: Injury Prevention


4.8.2.2.4 Tall Platforms
Diving stands or platforms that are 1 meter or higher two meters (6.6
ft) or higher must have guard rails with the top rail at least 36 inches
(0.9 m) above the board and a second rail approximately half the
distance from the platform to the upper rail. Diving boards or
platforms greater than 1 meter (3.3 ft) in height shall be accessed by
a stairway. The stair railing and diving board or platform guard rails
shall be designed to prevent falls and extend past the pool edge.
There have been many injuries and multiple deaths associated with
falls from the ladder or board at 3 meter stands. Many of these
injuries and deaths could be eliminated through design changes that
can make these diving boards safer by removing the vertical ladder
replacing it with a stairway and improving the guardrails at the diving
board.
CR52-Issue: Injury Prevention

There have been many injuries from falls and multiple
deaths associated with falls from 3 meter boards and I
found reference to at least one large award in a lawsuit.
CR52-Issue: Injury Prevention

Many 3 meter boards are being removed due to the
injuries that are being experienced many associated
with falls from the ladder or diving board onto the
concrete below.
CR52-Issue: Injury Prevention

Paddock Industries has gone as far as to recommend on
their info center that both one and three meter boards
should never be used for recreation and that diving
equipment should only be used under direct supervision of
a diving instructor.
CR52-Issue: Injury Prevention

USA Diving recognizes the need to train their athletes to
climb up and down the ladder to the springboards
CR52-Issue: Injury Prevention

Facility operators who do not remove the 3 meter boards
have no clear direction in how to make them safe for
recreational use. Some impose age or height limits. Others
have resorted to waivers.
CR52-Issue: Injury Prevention

One manufacturer that I checked with does not provide an
owners manual. They indicated no age or height
restrictions are recommended.
CR52-Issue: Injury Prevention

The photo is from an inspection this summer. On the
inspection I almost fell due to the inconsistent spacing of
the rungs. While every other rung is slightly offset, the top
rung leaves a hole of over 8”.
Change Request #56/58/99/156

Submitter presentation: TRC

Summary: All related to complete deletion of sections
that are perceived as administrative guidance
(regulating the regulator) including



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Operating permits (CR56)
Inspections (CR58)
Waiver language speaking to AHJ (CR99)
AHJ Inspections (CR156)
Sections contain parts that speak to operators
 Cut all or surgically remove specific AHJ wording?
Change Request #56/58/99/156

Submitter presentation: TRC

TRC Review: Sections contain parts that speak to
operators
 Cut all or surgically remove specific AHJ wording?
TRC Review #56/58/99/156

TRC Review: While it is understood that AHJ’s want to adopt the
MAHC by reference, the need for the basic terminology appears
valid to be displayed in the MAHC. The consensus was that these
items need to remain in the rule and have specific changes to meet
AHJ needs met by them for their compliance. Specific to this
section, the owner is typically responsible for operating permits
and annual inspections required by local departments of health.
Inclusion of the details in the code informs the owner/operator of
their responsibilities

Sections contain parts that speak to operators
 All except 99 cut entire sections vs. surgically removing
inappropriate AHJ language
TUESDAY PM
CR SUBMITTED COMMENTS (0)
CHAT ROOM COMMENTS
SECTION 5
CR’S 51, 52, 56/58/99/156
TUESDAY PM
CR PRESENTATIONS
SECTION 6
CR’S 63, 74, 75/75A, 77
Change Request #63

Submitter presentation: Doug Sackett, CMAHC

Summary: Requires ground fault interrupter branch
circuits on lights operating at over 15volts. Retroactive
since it is Section 5 Operation and Maintenance
Change Request #74

Submitter presentation: TRC

Summary: Deletes section on standing water saying
“decks should be free of standing water” as overly
broad
Change Request #75/75A

Submitter presentation: TRC

Summary:
 CR75: Deleting requirement for continuous water
treatment using the recirculation system to operate
24 hours per day
 CR75A: TRC keeps continuous operation but
modifies wording on what is required to meet
standard
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
CR 77, cont.
TUESDAY PM
CR SUBMITTED COMMENTS (0)
CHAT ROOM COMMENTS
SECTION 6
CR’S 63, 74, 75/75A, 77
TUESDAY PM
CR PRESENTATIONS
SECTION 7
CR’S 78, 79, 88, 89
Change Request #78

Submitter presentation: TRC

Summary: On maximum free available chlorine levels
(currently 10ppm) adds wording about levels in
manufacturers’ label and must use lowest level
 EPA limit is 4ppm for pools and 5 ppm for spas
Change Request #79

Submitter presentation: Doug Sackett, CMAHC

Summary: Sets maximum level for bromine (8ppm),
which was missing in MAHC
Change Request #88

Submitter presentation: TRC

Summary: Deletes need for water quality sampling
locations to be rotated around the pool
Change Request #89

Submitter presentation: TRC

Summary: Changes “action” level for combined chlorine
to 1.0ppm from 0.4ppm
TUESDAY PM
CR SUBMITTED COMMENTS (0)
CHAT ROOM COMMENTS
SECTION 7
CR’S 78, 79, 88, 89
Tuesday Dinner 6-7pm:
Thanks to CMAHC Sponsors
Founding Sponsors
Gold
Bronze
Contact Information
Doug Sackett
Executive Director, CMAHC
E-mail: info@cmahc.org
Phone: 678-221-7218
MAHC
More Information: Search on
“CDC MAHC” or visit the
Healthy Swimming MAHC
Website: www.cdc.gov/mahc
Email: mahc@cdc.gov
CMAHC
More Information: Search on
“CMAHC” or visit the CMAHC
Website: www.cmahc.org
Email: info@cmahc.org