A Swimming Pool & Hot Tub Safety Manual provides written safety programs, procedures, responsibilities, and safe work practices for employees who operate, maintain, clean, inspect, or work around swimming pools, hot tubs, spas, splash pads, and other treated aquatic facilities.
Aquatic facilities may be operated by public swimming pools, recreation centers, hotels and resorts, apartment communities, homeowners’ associations, fitness clubs, schools, universities, healthcare facilities, municipal recreation departments, waterparks, and other organizations.
Employees working around aquatic facilities can be exposed to hazards involving wet and slippery walking surfaces, pool chemicals, chlorine products, acids, chemical-feed systems, pump and equipment rooms, electrical equipment near water, mechanical equipment, hot water, drowning, biological contamination, manual material handling, indoor-air contaminants, and members of the public.
An effective Swimming Pool & Hot Tub Safety Manual should therefore address both ordinary workplace hazards and hazards unique to aquatic operations.
Federal OSHA does not maintain a single comprehensive occupational safety standard specifically for swimming-pool or hot-tub operations.
Instead, OSHA requirements apply according to the work performed and hazards present.
Depending on operations, applicable requirements may address:
State and local health departments also regulate many aspects of public swimming-pool and spa operation.
Facility management should determine which occupational safety, public-health, building, fire, electrical, and aquatic-facility requirements apply to the particular operation.
The Centers for Disease Control and Prevention developed the Model Aquatic Health Code (MAHC) to provide science-based guidance for public aquatic venues.
The MAHC addresses swimming pools, hot tubs, spas, splash pads, and other treated aquatic facilities.
Its subjects include:
The MAHC is guidance rather than a federal OSHA regulation. State or local jurisdictions may adopt or modify portions of it.
Aquatic facilities should follow applicable state and local requirements while using appropriate industry guidance to strengthen their safety programs.
Depending on operations, the manual may address:
Programs should be included according to the facility’s actual equipment, chemicals, services, and employee duties.
An effective Aquatic Facility Safety Program establishes responsibilities and procedures for maintaining a safe environment for employees while supporting safe operation of pools, spas, and related equipment.
Management should provide:
Managers and supervisors should:
Employees should follow established procedures, use required PPE, report unsafe conditions, and perform only tasks for which they have been trained and authorized.
Hazard assessments should consider:
Potential hazards may include:
Hazard assessments should be reviewed when equipment, chemicals, operations, or facility conditions change.
A JSA/JHA may be used for higher-risk aquatic-facility tasks.
Potential JSAs/JHAs may address:
The analysis should identify job steps, hazards, controls, PPE, and employee responsibilities.
Wet pool decks are one of the most persistent hazards at aquatic facilities.
Employees should maintain walking surfaces to reduce:
Deck surfaces should be maintained in good condition.
Employees should anticipate wet surfaces around:
Appropriate drainage and housekeeping should be maintained.
Employees should wear footwear appropriate to the work environment.
Standing water should be corrected where practical.
Potential causes may include:
Persistent water accumulation should be investigated rather than treated solely as a housekeeping issue.
Walking surfaces should provide appropriate traction for the environment.
Damaged or excessively smooth surfaces should be evaluated and corrected.
Temporary mats should not create additional trip hazards.
Potential trip hazards include:
Walkways should remain clear.
Pool decks should be routinely inspected.
Employees should promptly address:
Maintenance activities may require temporary restriction of public access.
Barriers, signs, cones, or other controls should be used where necessary to prevent patrons from entering hazardous work areas.
Pool chemicals can cause serious injury when improperly stored, mixed, handled, or added to treatment systems.
Potential hazards include:
Only appropriately trained employees should handle pool-treatment chemicals.
Employees who handle pool chemicals should receive training appropriate to their duties.
Training may address:
Employees should understand the specific chemicals used at their facility.
Aquatic facilities using hazardous chemicals should maintain an appropriate Hazard Communication Program.
The program should address:
Employees should have access to SDSs during their work shifts.
Chemical containers should remain properly labeled.
Employees should not transfer pool chemicals into:
Labels should remain legible.
Safety Data Sheets should be available for pool and maintenance chemicals.
Employees should understand how to locate information concerning:
Pool chemicals should be stored in areas designed and maintained for their hazards.
Storage areas should be:
Chemicals should not be stored where leaking containers can cause incompatible products to mix.
Pool chemicals can react violently when incompatible materials are mixed.
Particular care should be taken to prevent unintended contact between:
Employees should follow manufacturer instructions and SDS information.
Employees should never intentionally mix different pool chemicals unless the process and equipment are specifically designed for that purpose and the procedure is authorized.
Employees should not combine:
Even chemicals used for the same general purpose may be incompatible.
Incompatible chemicals should be separated.
Storage arrangements should consider:
Chemical containers should be kept closed when not in use.
Secondary containment may be appropriate to prevent leaking chemicals from spreading or mixing with incompatible materials.
Containment materials should be compatible with the chemical stored.
Many pool chemicals can react when exposed to water or moisture.
Chemical-storage areas should protect products from:
Wet chemical packaging should be treated as a potential hazard.
Chemical-storage areas should remain clean and orderly.
Employees should not store:
Spilled chemical residue should be addressed using procedures appropriate to the product.
Pool chemicals should be protected from unauthorized access.
Access should generally be limited to trained and authorized personnel.
Chemical-storage rooms should not be used as general storage areas.
Chemical deliveries should be planned so products are:
Damaged or leaking containers should be handled according to established procedures.
Employees should use appropriate material-handling methods when moving heavy chemical containers.
Controls may include:
Containers should be protected from dropping or puncture.
Swimming pools and spas may use different chlorine-containing disinfectants.
Potential products include:
Employees should be trained on the actual product used.
Different chlorine products should not be assumed to have identical hazards.
Liquid sodium hypochlorite can cause:
Employees should use appropriate PPE and handling procedures.
Calcium hypochlorite is a strong oxidizer.
Contamination with incompatible substances can contribute to:
The material should be stored and handled according to manufacturer instructions.
Some facilities may use chlorine gas systems.
Chlorine gas presents severe inhalation hazards and requires specialized controls.
Where chlorine gas is used, the safety program should address applicable:
Chlorine-gas procedures should not automatically be assigned to facilities using only liquid or solid chlorinating products.
Aquatic facilities may use acids or other chemicals to control water pH.
These products can cause:
Employees should follow chemical-specific handling procedures.
Acids should be kept separate from chlorine products.
Accidental mixing can generate toxic chlorine gas.
Storage and chemical-feed systems should be designed and operated to minimize this possibility.
Automated chemical-feed systems can reduce manual chemical handling but introduce equipment and process hazards.
Employees should understand:
Only trained personnel should adjust or service chemical-feed equipment.
Chemical-feed systems should be configured and maintained to prevent incompatible chemicals from mixing under abnormal flow conditions.
Chemical feeders should not continue feeding into systems when loss of circulation creates the potential for dangerous chemical reactions.
Required interlocks and safety devices should be maintained.
Where chemical-feed safety depends on water circulation, interlocks or other appropriate controls should prevent continued chemical feed when circulation is lost.
Safety devices should not be bypassed.
Chemical-feed lines should be:
Leaks should be addressed promptly.
Before servicing chemical-feed equipment:
Employees should follow manufacturer procedures.
Pump rooms can contain:
Access should be limited as appropriate.
Rooms should remain adequately illuminated, ventilated, and orderly.
Pump-room floors and access routes should remain clear.
Employees should control:
Electrical equipment should not be obstructed.
Pool pumps can expose employees to:
Employees should not service pumps until applicable hazardous-energy controls have been implemented.
Pool filtration systems may contain stored pressure.
Before opening or servicing a filter:
Employees should not loosen filter components while equipment remains pressurized.
Pool systems may contain pressurized:
Stored pressure should be released before equipment is opened.
Pool-maintenance employees may perform servicing on:
Where unexpected startup or hazardous-energy release could injure employees, applicable Lockout/Tagout procedures should be followed.
Energy sources may include:
Employees should identify all applicable energy sources before servicing begins.
Pumps, motors, belts, couplings, and other equipment should have required guards.
Employees should not operate equipment with required guards removed.
Preventive maintenance should address:
Defects affecting safe operation should be corrected promptly.
Indoor swimming pools require appropriate ventilation to control humidity and airborne contaminants.
Air quality concerns may include:
Employees should report persistent eye, nose, throat, or respiratory irritation.
Chloramines can form when chlorine reacts with substances introduced into pool water by swimmers.
Chloramines can move from the water into the air.
At indoor facilities, inadequate ventilation can allow airborne chloramines to accumulate near the water surface and in occupied areas.
Potential symptoms may include:
Indoor aquatic-facility ventilation should be maintained to:
Ventilation problems should be investigated when employees or patrons repeatedly report irritation.
Chemical-storage and pump-room ventilation should reflect the chemicals and equipment present.
Air from chemical-storage areas should not be intentionally distributed into occupied facility areas.
Ventilation systems should be inspected and maintained.
Respirators should not be treated as a substitute for proper chemical storage, ventilation, or process controls.
Where respirator use is required, an appropriate Respiratory Protection Program should address:
Employees should not enter dangerous chemical atmospheres with ordinary dust masks or inappropriate respirators.
PPE should be selected through an appropriate hazard assessment.
Potential PPE for aquatic-facility employees may include:
The required PPE depends on the chemical and task.
Chemical handling may require splash goggles and additional face protection.
A face shield should not automatically be considered a substitute for required primary eye protection.
Gloves should be selected for the specific chemical.
Employees should inspect gloves and replace damaged or contaminated gloves as appropriate.
Aprons or other protective clothing may be necessary when employees handle corrosive or oxidizing pool chemicals.
Contaminated clothing should be removed and handled appropriately.
Where employees may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body should be provided within the work area for immediate emergency use as required.
Emergency equipment should be:
Employees should know its location.
Chemical-spill procedures should be based on the specific material involved.
Employees should:
Employees should not attempt cleanup beyond their training and equipment.
A chemical incident may require emergency response when it involves:
Employees should understand when to evacuate and summon emergency assistance.
Accidental mixing of chlorine products and acid can produce toxic chlorine gas.
If a suspected chlorine-gas release occurs:
Employees should not attempt an uncontrolled rescue or cleanup.
The facility’s Emergency Action Plan should address foreseeable aquatic-facility emergencies.
Potential emergencies include:
Employees should understand alarm, communication, evacuation, and emergency-reporting procedures.
Employees who work around pools, spas, tanks, or other water features may be exposed to drowning hazards.
Facility procedures should address:
Employees should not enter the water to perform a rescue unless they are trained and capable of doing so safely.
Where appropriate, rescue equipment may include:
Equipment should be readily accessible and maintained.
Where lifeguards are provided or required, they should:
Lifeguard requirements may be established by state or local aquatic-facility regulations.
Hotels, apartment complexes, fitness facilities, and other operations may operate pools without lifeguards where permitted.
The absence of a lifeguard does not eliminate the need for:
Applicable state and local requirements should be followed.
First-aid resources should reflect facility hazards and emergency-response availability.
Potential emergencies may involve:
Employees should know how to obtain emergency medical assistance.
Where employees are assigned aquatic-rescue responsibilities, appropriate CPR and rescue training should be maintained.
Automated External Defibrillators should be maintained and used according to applicable requirements and facility procedures where provided.
Aquatic facilities may experience contamination involving:
Employees should follow established contamination-response procedures.
Procedures for fecal incidents should reflect applicable public-health requirements.
Employees responsible for response should be trained in:
Facility procedures should distinguish between formed stool and diarrheal incidents where required.
Vomiting incidents may require both:
Employees should use appropriate PPE and follow established disinfection procedures.
Blood on surfaces should be handled using appropriate exposure-control procedures.
Employees with occupational exposure to blood or other potentially infectious materials should be covered by applicable Bloodborne Pathogens requirements.
Where employee duties create reasonably anticipated occupational exposure to blood or other potentially infectious materials, an Exposure Control Plan may be required.
Potentially affected employees may include personnel assigned to:
Applicability should be based on employee duties rather than assumed for every aquatic-facility employee.
Employees may perform routine testing for:
Employees should be trained in:
Water-quality limits and testing frequencies should follow applicable state or local requirements.
Facilities should maintain required records for:
Records should meet applicable jurisdictional requirements.
Hot tubs and spas present many of the same hazards as swimming pools but may require additional attention because of:
Hot-tub procedures should reflect applicable state and local requirements.
Employees servicing spas should be aware of elevated water and equipment temperatures.
Maintenance should be performed only after equipment and water conditions are safe for the task.
Water accumulation around hot tubs can create significant slip hazards.
Employees should maintain:
Drain covers and suction-system components should be inspected and maintained according to applicable requirements.
Damaged, loose, or missing drain covers should be treated as serious hazards.
Aquatic venues should not operate with required drain protection missing or defective.
Employees may use:
Cleaning procedures should consider:
Empty pools can create additional hazards involving:
Employees entering drained pools should use safe access and appropriate fall controls where necessary.
Employees installing or removing pool covers may be exposed to:
Mechanical systems should be maintained and operated according to manufacturer instructions.
Water substantially increases electrical hazards.
Aquatic-facility electrical equipment should be installed, maintained, and repaired according to applicable electrical requirements.
Employees should report:
Ground-fault protection should be provided where required.
Protective devices should not be bypassed.
Electrical problems should be evaluated by qualified personnel.
Portable electrical equipment should be suitable for its location and use.
Employees should avoid using damaged electrical equipment in wet areas.
Extension cords should not be used as substitutes for permanent wiring.
Underwater lighting and associated electrical systems should be serviced only by appropriately qualified personnel.
Pools should be taken out of service where an electrical defect could expose patrons or employees to shock.
Employees should not perform electrical work unless they are qualified and authorized for the task.
Applicable electrical energy should be controlled before maintenance.
Pool ladders, handrails, steps, and access equipment should be:
Damaged equipment should be repaired or the area restricted.
Diving equipment should be inspected and maintained.
Employees should report:
Public-use requirements should follow applicable aquatic-facility regulations.
Splash pads may involve:
Employees should follow facility-specific operating and maintenance procedures.
Aquatic facilities may contain:
Maintenance should address equipment-specific hazards and public access.
Water-slide maintenance may expose employees to:
Applicable fall protection and hazardous-energy controls should be used.
Certain aquatic facilities may contain spaces that meet the definition of confined spaces.
Potential examples may include:
Spaces should be evaluated individually rather than automatically classified as permit-required confined spaces.
Where a space meets applicable permit-required criteria, procedures should address:
Employees should not enter permit spaces without required controls.
Aquatic-facility employees may handle:
Mechanical assistance or team lifting should be used where appropriate.
Large chemical containers can create both chemical and ergonomic hazards.
Employees should avoid lifting loads beyond safe capability.
Carts or other handling devices should be used where practical.
Outdoor aquatic-facility employees may work in hot environments despite being near water.
Heat exposure can be increased by:
Heat-illness prevention should address hydration, acclimatization, rest, shade or cooling, and employee monitoring.
Outdoor employees may experience prolonged ultraviolet exposure.
Protective measures may include:
Year-round outdoor pool maintenance may expose employees to cold, wind, or wet conditions.
Appropriate clothing and work practices should be used.
Outdoor aquatic facilities should maintain procedures for severe weather.
Potential conditions include:
Employees and patrons should be moved to appropriate locations when conditions require closure.
Employees should follow facility procedures when lightning threatens.
Outdoor pools should be cleared as required by applicable facility procedures or local requirements.
Employees should not remain exposed simply to continue routine maintenance.
Aquatic facilities may have maintenance areas containing:
Shop areas should be maintained in a safe and orderly condition.
Tools should be:
Damaged tools should be removed from service.
Good housekeeping is particularly important at aquatic facilities.
Employees should control:
Emergency exits and equipment should remain accessible.
Maintenance work may occur while swimmers, hotel guests, residents, students, or other patrons are present.
Employees should establish controlled work areas where activities could expose the public to:
Signs, cones, barriers, or other controls may be necessary for:
Controls should remain in place until the hazard has been corrected.
A pool, hot tub, or other aquatic feature should be closed when conditions present an unacceptable health or safety hazard.
Examples may include:
Reopening should follow applicable regulatory and facility requirements.
Aquatic facilities may use contractors for:
Facility and contractor responsibilities should be coordinated.
Contractors should be informed of relevant hazards.
Where outside contractors provide chemical service, the facility should coordinate:
The presence of a service contractor does not eliminate the need for facility employees to understand relevant emergency hazards.
Employees should promptly report:
Prompt reporting can prevent recurrence.
Significant incidents should be investigated to identify:
Investigations may consider:
Root Cause Analysis may identify underlying issues involving:
Corrective actions should address identified causes rather than simply assigning blame.
Periodic safety inspections should evaluate applicable:
Deficiencies should be corrected according to risk and applicable requirements.
Facilities should conduct appropriate inspections before opening to patrons.
Potential inspection items include:
Inspection requirements should reflect applicable state and local codes.
Chemical areas should be periodically evaluated for:
Unsafe conditions should be corrected promptly.
Employee training should reflect assigned duties.
Depending on responsibilities, training may address:
Employees should not independently perform specialized work until appropriately trained.
New aquatic-facility employees should receive appropriate safety orientation before independently performing assigned work.
Orientation may address:
Employees responsible for pool or spa operation should receive training appropriate to applicable state or local requirements and assigned duties.
Training may address:
Employees handling pool chemicals should receive task-specific training before beginning the work.
Training should address the actual chemicals used at the facility.
Additional training may be appropriate following:
Applicable regulatory requirements should determine mandatory refresher frequencies where established.
Periodic safety meetings may reinforce topics such as:
Aquatic facilities should maintain safety and operational records required for their activities.
Records may include:
Records should be retained according to applicable requirements.
Depending on facility operations and employee exposures, additional programs may be necessary for:
Programs should be included when the facility’s operations and employee exposures make them applicable.
A useful Swimming Pool & Hot Tub Safety Manual should reflect the aquatic facility’s actual equipment, chemicals, staffing, and operations.
A municipal aquatic center may require extensive procedures for pool chemicals, chemical-feed systems, lifeguards, water rescue, indoor-air quality, public access, maintenance, emergency response, water testing, and biological contamination.
A hotel or resort may operate pools and hot tubs without a dedicated aquatic-maintenance department. Its manual may place greater emphasis on maintenance employees, chemical-service contractors, wet walking surfaces, guest safety, emergency equipment, chemical storage, and coordination between engineering and housekeeping personnel.
An apartment community or homeowners’ association may use outside pool-service contractors while its own employees remain responsible for facility inspections, public access, barriers, wet surfaces, emergency procedures, and contractor coordination.
A fitness club or school may operate an indoor pool requiring additional attention to chloramines, ventilation, chemical handling, locker rooms, lifeguarding, water rescue, and employee exposure.
A waterpark or large aquatic facility may require more extensive programs for slides, splash pads, water features, pumps, chemical systems, elevated maintenance, crowd management, lifeguarding, and emergency response.
A facility using chlorine gas may require specialized chemical-release and respiratory-protection procedures that would be unnecessary at a facility using only liquid or solid disinfectants.
The safety manual should therefore be based on actual aquatic operations rather than automatically assigning every possible pool-related program to every facility.
A Swimming Pool & Hot Tub Safety Manual can be developed around the facility’s pools, hot tubs, spas, splash pads, chemicals, pump rooms, treatment systems, electrical equipment, maintenance activities, employees, contractors, and public operations.
The finished manual may incorporate applicable programs for Pool Chemical Safety, Chemical Storage and Compatibility, Chlorine Safety, Hazard Communication, PPE, Pump Room Safety, Lockout/Tagout, Electrical Safety, Indoor Pool Air Quality, Chloramine Control, Slips and Falls, Water Rescue, Bloodborne Pathogens, Emergency Planning, Contractor Safety, Incident Investigation, and other hazards associated with aquatic-facility operations.
This provides public pools, hotels, resorts, apartment communities, homeowners’ associations, fitness clubs, schools, recreation centers, waterparks, and other aquatic facilities with a practical occupational safety manual organized around the work their employees actually perform.