Risk management for public entities: public swimming pools and wading pools

Swimming Pool

Across many public entities, public swimming and wading pools provide a venue for the community to access aquatic facilities and programs. These are indoor and outdoor venues that operate year-round or only during the summer months. Although public swimming and wading pools bring many benefits to the community, they also carry public safety risks and must be operated safely.

The following guidance highlights key areas of consideration when developing and implementing a risk management plan for public swimming and wading pools. It should not be seen as an exhaustive list and should be used in conjunction with your internal policies and procedures, as well as in compliance with local laws and regulations.

Personnel and Supervision

Public entities will need to design their staff structure so that it provides adequate supervision of all pool patrons and thorough management of the pool facility.

  • Create an organization chart can help you determine which roles you will need to fill and help prevent any supervisory gaps. Once you have identified the necessary positions, you can write job descriptions for each of them that outline their responsibilities, specific duties, and minimum qualifications. Depending on the role, operators should address the following items:    Minimum age, skills, and experience required to fulfill roles and responsibilities
    • Minimum certification, such as lifeguard certification or CPR training
    • Minimum training on identifying and addressing heat stroke and exhaustion
    • Minimum vision and hearing standards
    • Minimum seasonal or annual training required to perform all duties
  • Set performance standards and expectations for personnel, as well as a system to evaluate them. Try to be specific, measurable, and realistic. Determine how often performance reviews will be done and the consequences for not meeting expectations.
  • Establish a centralized documentation repository to contain personnel records, including their applications, copies of certifications and licenses, completions of emergency response and first aid training, and performance records
  • Develop supervision standards for all staff, patrons, and activities
    • Review lifeguards on duty requirements necessitated by your jurisdiction. See the below guidance from Ontario as an example:

Only lifeguards on duty

Number of patrons

Minimum number of lifeguards on duty

0–30

1

31–125

2

126–250

3

251–400

4

401+

1 additional lifeguard for every 150 additional patrons

Source: R.R.O. 1990, Reg. 565, s. 17 (2); O. Reg. 270/99, s. 1 (1)

Lifeguards and assistant lifeguards on duty

Number of patrons

Minimum number of lifeguards on duty

0–30

1

31–100

2

101–200

3

201–300

4

301+

1 additional lifeguard for every 100 additional patrons

Source: R.R.O. 1990, Reg. 565, s. 17 (2); O. Reg. 270/99, s. 1 (1)

  • Designate supervision station locations, walking patrols, and schedules
    • Document any issues found during the patrols and any actions taken
    • Establish standardized documentation practices
  • Enforce that all personnel wear clearly marked uniforms
  • Draft a manual for all supervisory staff, subordinate staff, and volunteers that contains pertinent information to successful in their positions, such as:
    • All facility supervision and operational requirements
    • All operating and emergency plans and procedures
    • All relevant policies and procedures required to fulfill their roles and responsibilities
  • Make sure that all personnel review and acknowledge their understanding of the requirements contained in the staff manual. File their acknowledgement accordingly

Operations

Public entities will need to operate their swimming pools or wading pools according to safety standards put forth by their local jurisdictions to lower the risk of safety incidents and disease transmission. To help achieve a robust maintenance program, include the following elements:

  • Establish regular inspection cycle for pool and pool equipment before, during, after operating hours. Your inspections should take into account the following:
    • Removing any debris (for example, leaves) that can pollute water or be hazardous (such as glass) to patrons
    • Disinfecting pool water, testing water chemistry, and maintaining water balance so that it meets or exceed standards
    • Testing and addressing pool water clarity
    • Checking that all drain outlet covers are installed securely and are tamper resistant
    • Confirming there is adequate lighting over the entire water surface and deck
  • Log the results of these inspections and make sure that any identified deficiencies are appropriately documented and corrective actions are taken
  • Institute a system to safely address pool fouling (for example, accidental fecal release, vomit, and blood), which includes removal of contaminated materials and pool disinfection
  • Establish access control, including secured entry points and perimeter fencing, to the swimming pool, wading pool, and pool equipment. Make sure of the following:
    • All patron access doors and gates are both self-closing and self-latching
    • Secured entry point is at least the same height as perimeter fencing
    • Perimeter fencing meets minimum required height, as per requirements by your local jurisdiction
    • Perimeter fencing is difficult to climb
    • There is no structure adjacent to perimeter fencing that could facilitate a person attempting to climb over it
  • Confirm that the following have non-slip surfaces on them to reduce the likelihood of slip, trip, and falls:
    • Pool deck
    • Ladders
    • Diving boards
    • Stairs

Emergency Procedures

Operators need to design a response plan that clearly outlines the steps to take in case of an emergency incident. The emergency plan needs to be clearly documented and readily accessible. The appropriate training must be provided to supervisory staff, subordinate staff, and volunteers who are involved in the supervision of patrons and operation of the public swimming and wading pools.

  • Emergency Plan
    • Establish a plan that delineates response activities for emergencies ranging from minor, such as simple first aid, to major, such as serious injury or drowning. It should contain specific procedures to address the following situations:
      • Drowning
      • Entrapment
      • Medical
      • Fire
      • Weather
      • Evacuation

The emergency response plan should address the following:

  • Roles and responsibilities of supervisory staff, subordinate staff, and volunteers
  • Required emergency and safety equipment
  • Actions to contact emergency services
  • Actions to contact other relevant parties, such as family members and supervisory staff
  • Approach to addressing media inquiries
  • Training
    • Provide all personnel with a copy of the emergency response plan
    • Provide all personnel with training on the emergency response plan, including their specific roles and responsibilities
    • Provide all personnel refresher training on an annual or seasonal (e.g. summer) basis and document completion of training in your repository
  • Availability
    • Make sure the emergency response plan is readily available and accessible to all personnel:
      • Have the emergency response plan available through electronic and print formats
      • Mark the physical copies of the emergency response plan in a distinct color, such as a red binder, so it is instantly recognizable to personnel

First aid and safety

Operators will need to ensure they can provide first aid to staff, volunteers, and participants. This practice involves the regular inspection of the first aid and safety equipment available at the facility, and confirming that the appropriate individuals are trained in first aid response.

  • Locate all first aid kits in easily accessible areas that are in close proximity to the pools
  • Develop a roster of personnel required to hold active first-aid training certification, including knowing how to use an automated external defibrillator (AED)
  • Track the currency of all personnel’s certifications and require them to take recertification training and provide updated documentation in order to maintain employment at the facility
  • Ensure availability of safety equipment at lifeguard station or pool area, which can include:
    • Ring buoy
    • Pool rescue hook
    • Pool rescue tube
    • Life jackets
    • Flutter boards
    • Spine board for transporting a person with a possible spinal injury
    • Emergency telephone that is directly connected to emergency services
  • Install a divider rope that distinguishes the deep end of the pool
  • Make sure that an automatic external defibrillator is available and in close proximity to pool area

Signage

Public entities need to have the appropriate signage throughout the swimming and wading pool area to keep patrons informed of the following:

  • No diving area
  • Deep water area
  • Shallow water area
  • Pool depth
  • Restricted activity
    • No horseplay
    • No running
    • No alcohol consumption
    • No smoking
    • No glassware
    • No food or drinks
  • Pool entrances and exits
  • Emergency exits
  • Capacity limits
  • Concession areas
  • First aid station
  • Garbage and recycling areas

Summary

Addressing public safety risks is paramount when planning and operating public swimming and wading pools. Through the development and implementation of a comprehensive multi-tiered risk management plan, safety measures can be put in place to help prevent injury, severe harm, or death and provide patrons with an enjoyable and safe experience.

If you have questions, please contact your Marsh representative.