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