Category Archives: Regulation

MAHC Hygiene: Counsilman – Hunsaker Response

The CDC posted the Hygiene Model Aquatic Health Code Module for public comment on October 31, 2011.  The Counsilman – Hunsaker team posted a group response in support of the public comment requirements.  This response can be viewed at the below link.

Counsilman – Hunsaker Response

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Regulatory Program Administration MAHC

CDC posts Regulatory Program Administration Model Aquatic Health Code Module for public comment with a closing date of February 5, 2012.

The Regulatory Program Administration module for the MAHC was posted on December 7, 2011, for public comment.  The Regulatory Program Administration Program Module follows a best practice and research-based protocol to ensure the AQUATIC FACILITY is operating safely. The guidance reflected in this module promotes all parties working together from the initial building permits to the code enforcement process. The Regulatory Module contains requirements for but not limited to:

  1. Establishment of an independent Aquatic Health Advisory Committee
  2. Delineation of imminent aquatic health hazards and corresponding remediation and enforcement procedures
  3. Establishment of facility staffing requirements based on facility size and type
  • Trained operators required for all facilities
  • Outlines facilities requiring on-site vs. off-site operators
  1. Aquatic facility operator training
  2. Plans and permits guidelines
  3. Recordkeeping requirements
  4. Swimmer empowerment methods

MAHC Background:

The Model Aquatic Health Code (MAHC) effort began in February 2005 and the latest round of modules is being published for public comment. The MAHC will have a significant impact on the aquatic industry and we strongly encourage all industry members to take an active role in providing meaningful feedback to develop the best possible result. To view the latest updates regarding the Model Aquatic Health Code go to www.chh2o.com/MAHC.

The first industry standard was issued in 1958. In the subsequent 50 years, there have been at least 50 different state codes and many independent county codes. What was required in one jurisdiction may be illegal in another. It is clear that this historic approach is not working. Thus, the National Swimming Pool Foundation took a leadership position and provided funding to the Center for Disease Control (CDC) for the creation of the MAHC. The MAHC is intended to transform the patch work of industry codes into a data-driven, knowledge-based, risk reduction effort to prevent disease, injuries and promote healthy water experiences.

 

 

Kentucky Pool Regulations – CH Response

Scot Hunsaker with Counsilman – Hunsaker responded with comments to the Kentucky Department for Public Health regarding changes to the pool regulation.  A copy of these comments is listed below:

November 9, 2011

Ms. Kathy Fowler

Interim Director

Division of Public Health Protection and Safety

Kentucky Department for Public Health

275 E Main St, HS1CB

Frankfort, KY 40621

Re: Proposed Changes to Kentucky Pool Regulations

Ms. Fowler,

We appreciate the invitation to review and provide input on the proposed changes to the existing Kentucky Pool Regulations.

Since aquatics is all Counsilman-Hunsaker does, we have had the good fortune to work on close to 1000 projects over the 40 years our firm has been in business, including dozens of commercial pools in the State of Kentucky.  We have licensed engineers in all 50 states in the U.S. and we have several projects abroad as well.  That affords us the opportunity to work in many different jurisdictions and under many different codes and regulations.  Because of this experience, our expertise is often sought in helping to author new codes.  Counsilman-Hunsaker currently takes a leadership role in industry organizations such as the NSPF and the development of regulatory standards such the Model Aquatic Health Code which is sponsored by the CDC and will be released nationally in the coming months.

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Kentucky Pool Regulations

The Kentucky Department for Public Health is currently working to revise the swimming pool and bathing facility regulation, 902 KAR 10:120. The current regulation has not been updated in many years and is under consideration for revision.  The Division of Public Health Protection and Safety have met several times and drafted proposed changes.  At this time they are inviting comment on the proposed language.  There is a meeting schedule for November 16, 2011 for interested parties to attend.

To receive copies of the proposed language or participate in the comment process it is recommended to contact Kathy Fowler, Interim Director Division of Public Health Protection and Safety, Kentucky Department for Public Health, phone 502-564-7398.

 

MAHC Ventilation – CH Response

The CDC posted the Ventilation Model Aquatic Health Code Module for public comment on April 13, 2011.  The Counsilman – Hunsaker team posted a group response in support of the public comment requirements.  This response can be viewed at the below link.

Counsilman – Hunsaker Response