Welcome to
Vote on the Code 2015
The Process Begins!
CMAHC CR-TRC Presentations
Wednesday Morning 10-07-2015
Thanks to CMAHC Sponsors
Founding Sponsors
Gold
Bronze
Change Request #77
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Submitter presentation: TRC
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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

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I said yesterday we could use member comment postconference 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
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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
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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 sciencebased 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
What Data are
Being Used?
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A = 20ppm FAC
B = 40ppm FAC
C = 90-100ppm
cyanurate
Bad news for
Crypto
inactivation
Full presentation
at WAHC
Change Request #152

Data warrants changing fecal incident response to treat
stabilized venues after diarrheal events
Change Request #80
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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 10-20 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 circulationdependent 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
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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
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Submitter presentation: TRC
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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
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Submitter presentation: TRC
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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
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Submitter presentation: TRC
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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
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Submitter presentation: TRC
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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
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Submitter presentation: TRC
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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
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Submitter presentation: TRC
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Summary: Requires any facility serving alcohol to have a
lifeguard
CR 124, cont.
Change Request #127
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Submitter presentation: Joe Stefanyak, Jeff Ellis and
Associates
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Summary: Requires that Lifeguard in-service training be
done only by a Qualified Lifeguard
CR 127, cont.
Change Request #128
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Submitter presentation: RAC Carroll, Jeff Ellis and
Associates
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Summary: Removes wording about competency testing
of lifeguards from in-service training section
Change Request #134/135
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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.
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
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Submitter presentation: TRC
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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
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Submitter presentation: TRC
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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
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