Input Needed for the Model Aquatic Health Code

Disinfection and Water Quality Module Just Released For Public Comment

The Disinfection and Water Quality module for the Model Aquatic Health Code (MAHC) was posted on February 27, 2012 for public comment.  This module could potentially be more impactful to today’s operators than other modules.  The deadline for public comments is April 27, 2012.  Counsilman – Hunsaker strongly encourages everyone in the aquatic community to review and participate in this process.


MAHC Disinfection & Water Quality Module Abstract

Disinfection and water quality are critical components in maintaining bather health and comfort. Health issues related to inadequate disinfection and poor water quality are increasingly being documented. Outbreak investigations have often determined that disinfectant levels and other water quality parameters were not maintained appropriately thereby allowing disinfectant-sensitive pathogens to be associated with pool use. The emergence of chlorine-tolerant microbes also necessitates changing accepted standards for pool treatment to protect the health of bathers in the future. The Disinfection and Water Quality Module takes the first steps in addressing these recurring and emerging aquatic health issues. The Disinfection and Water Quality Module contains requirements for new or modified construction that include:

  1. Primary disinfectant levels set.
  2. Secondary disinfection required for “increased risk” aquatic venues such as Interactive features, spray pads, wading pools, and other venues designed primarily for diaper-aged children as well as therapy pools
  3. Combined chlorine maximum levels set
  4. Prohibition of cyanuric acid in Indoor facilities and “increased risk” aquatic venues

In addition to each MAHC module, an annex section for Disinfection & Water Quality provided for support information to assist users in understanding the background of the provisions.

The Model Aquatic Health Code Steering Committee and Technical Committees appreciate your willingness to comment on the draft MAHC modules. Click here to download comment form.

Comments are due 60 days after the draft module is posted on the MAHC website. All public comments will filter back to the Technical Committee for review before the module is officially released..

MAHC Background

The Model Aquatic Health Code (MAHC) effort began in February 2005.  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. To view the latest updates regarding the Model Aquatic Health Code go to

1 Comment to Input Needed for the Model Aquatic Health Code

  1. February 29, 2012 at 8:24 pm | Permalink

    There are several issues that concern me in this section. The definition of an “increased risk aquatic venue” seems to make some sense and is consistent with the directions several states of taken. I think the industry needs to be very clear on the definition of an activity pool. Is this just a spray feature or at what level of amenities does this definition apply? The use of UV with a validated approach is appropriate and will catch the swimming pool industry up with other industries that use UV.

    The water quality section will now set a limit of .4ppm for combined chlorine. While I agree that this is a desire, I do not believe we have enough data to make this a requirement. There has been no database of testing to determine what real world combined chlorine levels are. My concern is that we are over-reaching that will result in significant pool closures because we don’t know what we don’t know. The annex talked to this point, but forged ahead with the .4ppm standard. This issue maybe exasperated by the new proposed requirement of 3.0ppm of FAC for increased risk aquatic venues. With these higher FAC levels the potential for increased combined chlorine may increase as well.

    The suggested language also requires water quality requirements for total alkalinity, calcium hardness and TDS. The annex suggests the purpose is to help evaluate that the pool is being well run. My concern is depending on the source water and location in the country these ranges may or may not be appropriate. It also seems over reaching to have a 1,500 limit for TDS which is a new vocabulary in the industry and then provide a work around for salt pools. I question the data on the health impact of these suggested requirements. If the goal is to define a well-run pool, I might suggest using the LSI as the single measure of success.

Leave a Reply

You must be logged in to post a comment.