The Two Latest MAHC Modules Pose Serious Challenges to Waterpark Operators
The WWA's Government Relations and Safety Committees urge all waterpark owners and operators to carefully review the latest modules released by the Steering Committee for the Model Aquatic Health Code (MAHC).
The WWA believes that language and provision in both of these new modules presents significant challenges to waterpark facility operators. In fact, much of what is contained within them does not apply to waterpark attractions and would create unsafe practices and environments rather than improve safety. Owner and operators are urged to read through both the Module text and the Annex text to gain a better understanding before submitting comments by the deadline.
The deadline for public comment on Lifeguarding & Bather Supervision and Facility Design & Construction Modules is October 14, 2012
To give owners and operators a better understanding of why the Lifeguarding and Bather Supervision Module presents such a significant challenge -- from both a safety and financial perspective -- members of WWA's committees have pulled out 11 troubling examples from the module for your review:
Section 188.8.131.52 of the module uses one full page to specifically and minutely detail the type and number of supplies/equipment required to be carried in each first aid kit. There is no reference to carrying supplies suggested or required by local EMS providers.
Sections 184.108.40.206.3 and 220.127.116.11.4 requires that any pool -- including a splashdown pool, spa pool, wading pool and even spray pads - which only has one lifeguard per pool -- must have a rescue throwing device with a 50 foot rope and a 12’ to 16’ reaching pole. There are no minimum/maximum pool size or depth exceptions.
Section 18.104.22.168.5 requires that a “hard-wired” telephone or other communications device with access to 911 must be provided and be accessible to all facility users.
Section 22.214.171.124.1 mandates that lifeguard training/certification agencies must teach CPR/AED protocols consistent with the Emergency Cardiovascular Care Update and/or the International Liaison Committee on Resuscitation without reference to what local EMS providers may recommend or mandate.
Section 126.96.36.199.1 mandates that lifeguard training/certification agencies must teach treatment guidelines as recommended by the National First Aid Science Advisory Board for the treatment of bleeding, shock, sudden illness, and muscular/skeletal injuries without reference to what local EMS providers may recommend or require.
Section 188.8.131.52 requires any lifeguard with “supervisory responsibility” to be at least 18 years of age.
Section 184.108.40.206 – 7 requires an on-duty lifeguard for “Any catch pool, splash pool, run-out or shutdown lane for any waterslide whose elevation at any point is 8 feet (2.4 m) or more as measured from that point to the surface of the water at the terminus of the slide.”
Section 220.127.116.11.8.3 requires that there must be at least two lifeguards present for any extrication without reference to age/size of the guest being extricated or depth of water, etc.
Section 18.104.22.168.9 requires “The aquatic supervisor shall ensure that any lifeguard that requires corrective lenses must wear the corrective lenses while on duty.” There is no discussion regarding who or what determines this requirement exists in the first place or what level of visual acuity differing from 20/20 should bring about a requirement for corrective lenses.
Section 22.214.171.124.12 requires that “The aquatic supervisor shall ensure all Aquatic Facility Safety Team members have been trained in proper Fecal, Vomit and Blood Contamination Incident Response.” The Aquatic Facility Safety Team is defined as “any employee of the aquatic venue that has job responsibilities related to the aquatic venue’s emergency action plan.” This presumably includes maintenance, guest services and other staff whose duties would not put them in any contact with such contamination but still have some small part in an emergency action plan.
Section 126.96.36.199.1 Annex – Requires pools that provide lifeguards should provide chairs or stands. No comment or exception made for pools with roving guards or splash pools where lifeguards are in the water.
While the WWA and the waterpark industry fully support reasonable safety rules and regulations, the industry must take this opportunity to submit comments on a module that does not take into account the best practices already ongoing within the industry or the unique environment presented at a waterpark.
Comments are due October 14, 2012 and must be submitted using the Comment Form found at the bottom of the MAHC web page. All public comments will filter back to the Technical Committee for review before the module is officially released. To review this module and other information relating to MAHC, click here.
In addition, the WWA's Safety Committee will host a session on these modules this week at the WWA Show in Las Vegas. The session will take place at 9:00 a.m. Pacific time at the Paris Convention Center. Anyone in attendance at the show is encouraged to attend.
World Waterpark Association
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