The latest industry guidance document was recently released by the Health and Safety Executive (HSE) at the CIMSPA conference in February 2018. The guidance is ‘Managing Health and Safety in Swimming Pools’, and it is more commonly referred to as ‘HSG 179’.
HSG 179 applies to all types of ‘public’ pools, as defined in BS EN 15288 (such as communal pools, leisure pools, hotel pools, camping pools, etc.). The guidance does not apply to private pools in domestic premises, stand-alone children’s paddling pools in public parks, or stand-alone spa pools.
This is the fourth edition, having been first published as ‘Safety in Swimming Pools’. In line with other revised HSE materials (such as The control of Legionella and other infectious agents in spa pool systems – HSG 282), HSG 179 is only available as an online resource. It is imperative to refer back to the website http://www.hse.gov.uk/pubns/books/hsg179.htm to check the latest version (which at the time of writing this article is ‘02/18’).
The current guidance is a slimmed down version of the previous publication, and there are numerous hyperlinks to other industry guidance.
In keeping with the advice from HSE, it states that “Following the guidance is not compulsory unless specifically stated, and you are free to take other action. However, if you do follow the guidance, you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance”.
It is crucial to read HSG 179 in full to get a complete understanding of what is required, but this article highlights a number of the key headings.
There is a reference to essential industry standards and guidance, including European standards BS EN 15288 (in 2 parts) and BS EN 13451 (parts 1 – 11). Sport England has very important Design Guidance and some handy appendices, and PWTAG’s Code of Practice and ‘Swimming Pool Water’ publication are also referenced.
It is also useful to be aware of the use of the words ‘must’ and ‘should’ as ‘must’ is used only where there is an explicit legal requirement to take a certain action, while ‘should’ is used to indicate what to do to comply with the law – although dutyholders are free to take other action if that would result in compliance.
The meaning of ‘reasonably practicable’ is also mentioned as referring to “balancing the level of risk against the measures needed to control the real risk regarding money, time or trouble. However, you do not need to take action if it would be grossly disproportionate to the level of risk”.
What the law requires
Mention is made of key legislation such as the Health and Safety at Work Act (HSW Act), the Management of Health and Safety at Work Regulations (MHSWR) the Control of Substances Hazardous to Health (COSHH) and the Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR).
Appendix 1 also covers other legislation that is applicable such as Corporate Manslaughter and Corporate Homicide Act, Workplace (Health, Safety and Welfare) Regulations, Provision and Use of Work Equipment Regulations, Construction (Design and Management) Regulations, Electricity at Work Regulations, Manual Handling Operations Regulations, Diving at Work Regulations, Regulatory Reform (Fire Safety) Order and Fire (Scotland) Act, Confined Spaces Regulations, and The Work at Height Regulations.
Managing for Health and Safety
The importance of undertaking risk assessments is detailed in this section, and having a written risk assessment is a ‘must’ if you have five or more employees.
It is vital that employers assess the competence of their staff to determine what training and supervision (for instance) are required.
Pool safe operating procedures (PSOP’s) are commonly used and are based on the information obtained from undertaking the risk assessment. The PSOP comprises the Normal Operating Plan (NOP) and the Emergency Action Plan (EAP).
This section also covers topics such as ‘pool access for disabled people’ and ‘safety information and signs’.
Ensuring pools users’ safety
The topic of poolside supervision is covered in this chapter, and while it states that constant poolside supervision by lifeguards provides the best assurance of pool users’ safety, where a risk assessment shows this may not be reasonably practicable, then other robust, alternative measures ‘must’ be implemented to ensure the safety of pool users. There is an acknowledgement that using technology to help existing lifeguards may be applicable. This technology can come in various forms, such as drowning detection systems, poolside CCTV, poolside mirrors, motion sensors and user-worn detection systems.
This chapter deals with the requirements of what lifeguards need to be to perform their duties effectively. Training is a vital part of the initial and on-going competence of a lifeguard
Pool equipment and features
A number of items are covered in this chapter, such as diving boards, starting platforms, teaching platforms, water slides, wave machines, inner tube rides, slow and fast rivers, falling rapids, inflatable play structures, movable floors and bulkheads, spa pools and emergency equipment. Advice is given on how to manage these best to ensure the safety of users.
Maintenance of plant and equipment
The key message is to undertake regular and correct maintenance of buildings, plant and equipment, according to manufacturer’s instructions. Cleanliness is essential, while heating, ventilation and air-conditioning systems should be effective and suitable.
Topics such as glazing, electrical installations and equipment, potentially flammable atmospheres, and portable electrical equipment are also covered in this chapter.
Swimming pool design
The role of the designer needs to be considered under the Construction Design and Management Regulations (CDM). In the section on ‘Building materials and specifications’ there is advice on the pool tank profile (e.g. to avoid abrupt changes in depth and steep gradients) and the pool tank edge (e.g. consider using colour-contrasting the edge with the pool water to make it clearly visible to pool users).
The relevance of Sport England’s Design Guidance is also highlighted in this chapter.
The pool water treatment system
This chapter highlights that the “treatment of pool water is essential to ensure that employees and pool users are not exposed to risks of infection from contamination of the pool water by microbiological organisms”. References are made to PWTAG’s Code of Practice and Swimming Pool Water book. With regards showers, HSE’s L8 publication (Legionnaires’ disease. The control of legionella bacteria in water systems) is a valuable resource. The Dangerous Substances and Explosive Atmospheres Regulations (DESAR) are mentioned in this chapter.
HSG 179 states that “You should develop a procedure for dealing with emergencies”. Training is also a vital part of implementing any emergency procedures.
At 60 pages, HSG 179 is a must-read and with various other links to additional resources, this guidance needs to be read by the industry to ensure that everyone involved in the design, project management, construction, maintenance and operation of these public pools is aware of what is required to ensure a safe environment for employees, contractors, visitors and bathers.
* Text above in RED are additions to the SPN Article June 2018 Issue