FOISA / EIRS Information Request
ELIR 00035
1.
Policy of the use of snorkels and diving masks
Your Policy on the use of Snorkels and diving masks with in your pool facilities
Although we have provided the information that was asked for regarding our
Policy on the use of Snorkels and diving masks with in our pool facilities, we
redacted the names of individual staff within Edinburgh Leisure in all of the
documentation provided.
Under the terms of the Act, a request for information can be refused where one
or more exemptions listed in the legislation apply. In this instance, Edinburgh
Leisure is applying the following exemption to the information that you have
requested:
S38 (1) (b) (2) (a) (i) Personal Information.
It is Edinburgh Leisure’s Policy to disclose names of individuals at Head of Service
Level and above only as this constitutes personal data and to disclose it would
breach the data protection principles. The individuals named in the Risks section
are below Head of Service therefore we have redacted their names.
“Section 1(1) of the DPA defines personal data as data which relate to a living
individual who can be identified –
(a) from those data, or
(b) from those data and other information which is in the possession of, or is
likely to come into the possession of, the data controller, and includes any
expression of opinion about the individual and any indication of the
intentions of the data controller or any other person in respect of the
individual.”
The names of individuals within Edinburgh Leisure is “personal data”. This meets
the above definition of "personal data" for the purposes of the Data Protection
Act 1998 (“DPA”).
We have provided you with the information requested however we have redacted
the names of individual members of staff in each document supplied.
Please note that this letter constitutes a formal refusal notice under section 16 of
the Freedom of Information (Scotland) Act 2002.
Edinburgh Leisure does not have a corporate policy on the use of snorkels and
diving masks in Edinburgh leisure facilities. Managers of the pools assess the risk
for each individual pool and following the risk assessment incorporate the required
actions into their Normal Operating Procedure (NOP).
FOISA / EIRS Information Request
In conducting their Risk Assessment the Managers use the best practice guidelines
issued by the Institute of Sport & Recreation Management (ISRM) on the use of
facemasks, snorkels and fins in swimming pools.
ISRM is the national professional body for sport and recreation facility
management. Its aim is to improve the management and operation of recreation
centres, sports facilities and swimming pools through the provision of training,
advice and consultancy services.
As each of our pools are different, each Manager conducts their own Risk
Assessment based on the specific risks within their pool. They then ensure that
their Normal Operating Procedure includes information on this and the action to
be taken.
The table below outlines each sites specific policy on use of face masks, flippers
or snorkels:
Site
Policy
APLC
NOP – Section 5.2
5.2 (c) No face masks, flippers or snorkels to be used
during casual swimming sessions.
5.3 (d) Soft flippers may be used by adults to swim train in
the fast lane only with consideration to the following there are few swimmers in it and they are swimming at
an equal pace. This should be monitored individually
by the Ops Supervisor to assess if they are competent
in using the equipment safely.
DLC
NOP – Section F page 27
-
DSC
GLC
Airbeds, goggles (except those allowed by the Duty
Manager i.e. anti-chlorine goggles), masks, snorkels,
fins, hand paddles etc. are not allowed at all during
public bathing. Apart from the risks involved there is
not enough room in a crowded pool.
Page 33 - Snorkelling masks are not allowed, unless in
supervised sessions.
NOP – Section 3 (c) Page 2
No face masks, flippers or snorkels to be used during open
sessions
NOP 3.4.6 (c) Page 9
No face masks, flippers or snorkels to be used during casual
sessions
Risk Assessment Page 19
FOISA / EIRS Information Request
Specialist Training Equipment - Use of fins and hand
paddles is not permitted in public sessions due to the risk
of injury to other bathers in the event of collision.
Masks and snorkels are not permitted during public sessions
as they are deemed to require specialist skill for safe use.
They could also impede the lifeguard in their duties in the
event of a rescue, to the detriment of the casualty.
GSC
NOP 3.4.3 Page 7
Restricted use of facemasks and snorkels during casual
sessions, limited to 1 bather in the pool at any time.
LVSC
NOP Section 8 Page 9
No face masks, flippers or snorkels to be used during casual
sessions
NOP Section 16 Page 11




In line with ISRM guidance the use of face masks,
snorkels and fins should be discouraged during unprogrammed public swimming therefore their use is
prohibited during un-programmed public swimming.
The reason for this is that their use poses too many
hazards to the user and other public swimmers.
These hazards include possible glass entering the
pool if plastic face cannot be confirmed. The
possibility of panic being caused if water enters the
mouth and the user cannot breathe out of their nose,
impact to other bathers with full snorkels or fins can
cause excessive harm. By using a full snorkel also
the user may not look where they are going as much
therefore the likelihood of impact or collisions is
higher.
Face masks also restrict the level of vision to the user
therefore there use must also be discouraged.
If someone wishes to use a facemask with snorkel or
fins they may wish to book out a lane for their use if
the pool programme permits.
There may be instances however where face masks
or snorkels may be used if there is a specific medical
condition however if they are regular users they must
provide proof that a snorkel and face mask is to be
used by their GP. If they are using this equipment
they must be confident in its use and come at times
FOISA / EIRS Information Request
when the pool is quiet and be made aware of
consideration for other pool users.
 If there are issues with collisions and impact due to
the user not considering other bathers needs they
must be asked to not use the Facemask and Snorkel
as it is becoming too dangerous and they can book a
lane instead.
Risk assessment page 21 - 22
Use of masks, snorkels and fins - No the swim sessions are
not suitable for the use of this specialist equipment as there
is always casual bather swimming during public swim times.
Customers using the pool during public swim times could be
hit or caught by fins and snorkels and customers may be hit
by fins. No fins or snorkels are allowed during public swim
times.
The use of fins, and snorkels is prohibited during public swim
times in line with ISRM guidance as there are few control
measures that would negate the hazard.
PSC
No face masks, flippers or snorkels to be used during casual
sessions
QHRC
Admissions Policy
No face masks, flippers or snorkels to be used during casual
sessions
RCP
NOP 3.7.6 Page 3
No face masks, flippers or snorkels to be used during casual
sessions
Public Lanes Swimming Equipment
Short end soft fins allowed
Hand & Finger paddles allowed
Swim Snorkel – swim training allowed, scuba snorkel not
allowed
Documents provided:
ISRM Use of facemasks, snorkels and fins in swimming pools
APLC Normal Operating Procedure (NOP)
DLC NOP
DSC NOP
FOISA / EIRS Information Request
GLC NOP (Redacted)
GLC Risk Assessment (Redacted)
GSC NOP (Redacted)
LVSC NOP (Redacted)
LVSC Risk Assessment (Redacted)
PSC Rules for Pool Use
QHRC Admissions Policy and Rules for Customers
RCP NOP (Redacted)
Public Lanes swimming equipment