Purpose

The purpose of the Indiana University Environmental Health and Safety (IUEHS) Water Venues Program is to ensure that bathing beaches, swimming, spa, and therapy pools owned and/or operated by Indiana University are safe for the users and staff. This Program was developed to prevent waterborne illnesses and injury, protect equipment, and respond to concerns of users and staff associated with these facilities at the University. This is accomplished through education, training, regulatory inspections, consultation, water quality and indoor air quality tests, monitoring bacteriological water reports, enforcement, and keeping informed of current aquatic trends.

This Program utilizes established state, federal and international codes and regulations and standards of best practices for these types of water venues. The applicable regulatory reference, codes, standards, and guidelines are outlined in the References section of this document. The operation of swimming, spa, and therapy pools in the State of Indiana are subject to the Indiana State Department of Health’s (ISDH) 410 IAC 6-2.1 Public and Semi-Public Swimming Pools Rule and Indiana bathing beaches are subject to ISDH’s 410 IAC 6-7.2 Youth Camps rule.

Scope

This Program applies to all treated and untreated water venues including: bathing beaches, swimming pools, therapy/spa pools, and all related facilities that are owned and/or operated by Indiana University and affiliated properties. Users of these facilities include staff, faculty, students, visitors, competitors from other universities and schools, lifeguards, and aquatic staff required to operate these facilities.

Exceptions:

• Water venues are subject to the construction code in effect at the time of installation. If a water venue undergoes a significant renovation, then it should be brought into substantial compliance with the current construction code. Replacing ‘like with like’ would not be considered a significant renovation.

• Some athletic therapy facilities are used as a drain and fill (single use) facility and therefore not regulated by state rules.

• The Marion County Public Health Department (MCPHD), inspects, regulates, and licenses water venues at IUPUI.

• The bathing beach at Camp Brosius on Elkhart Lake in Sheboygan County, Wisconsin is subject to Chapter DHS 254.46 Subchapter IV: Recreational Sanitation. While it is not subject to Wisconsin’s Department of Health Services (DHS) Chapter DHS 175: Recreational and Educational Camps, it is recommended that the camp use Chapter DHS 175.18(5) Water Activities as guidance for operating the bathing beach.

Physical quality of water inspection - bathing beaches

IUEHS staff and maintenance staff shall conduct occasional physical quality of water inspections of the bathing beach area. Inspection elements shall include looking for and documenting:

• Floating debris;
• Water current. Current shall not exceed three (3) feet per second;
• Turbidity/clarity: A six-inch black secchi disk placed on a white background or an 8-inch black and white secchi disk shall be readily visible from the surface of the water to a depth of at least 4 feet;
• Unusual color, odor, taste, oils, and grease;
• Indicators of a possible algal bloom: cloudiness, scum, foam; and
• Harmful Algal Blooms (HABs): Excessive growth of algae (cyanobacteria) in response to extended periods of warm weather without heavy rainfall, such as late summer and/or early fall, and/or pollution (possible nutrients like nitrogen and phosphorus).

Air quality sampling and testing - swimming, spa, and therapy pools

Air samples are collected at the pool deck level at the indoor pools using a modified nitrogen trichloride (trichloramine) detection method. Excessive trichloramine exposures can lead to eye, nasal, and respiratory system irritation. Indiana University has adopted the World Health Organization (WHO) guideline of 0.5mg/m³ trichloroamine or less.

The recommended frequency of IUEHS air quality sampling and tests is 1-2X a year for indoor pools based on risk and past history of trichloramine levels. Testing can also occur in response to a complaint, event, or upon request. Testing is conducted free of charge.

Compliance and enforcement

The MCPHD provides corrective action oversight on the IUPUI campus in a manner consistent with this program and applicable state and local rules.

Violations cited at water venues shall be corrected in a timely manner. Follow up inspections will occur following the closure of a water venue during a routine inspection. Progressive enforcement for repeated non-compliance will continue to escalate, as described below, until compliance has been achieved.

Furthermore, Section 43 of Title 410 IAC 6-2.1: Public and Semi-Public Swimming Pools Rule details reasons for the closure of a swimming pool or spa.

A facility shall close when any of the following occurs: 

1. Failure to meet the following requirements in Title 410 IAC 6-2.1: Public and Semi-Public Swimming Pools Rule:
   • bacteriological requirements of section 31(f), 42.1(b)(15), or 42.1(b)(16);
   • disinfectant concentrations of section 30(b), 42.1(b)(1); or
   • the water clarity requirements of section 31(a) or 42.1(b)(13)
2. The grate on the main drain is missing or broken, or failure to meet the requirements of section 32(e).
3. Failure to meet lifeguard requirements of section 35, where applicable.
4. A pump, filter, or disinfectant chemical feeder is not operational.
5. A fecal accident.
6. The spa water temperature exceeds 104 degrees Fahrenheit.
7. pH values less than 6.8 or equal to or greater than 8.0.
8. If combined chlorine is .5 ppm or above, the pool must be super-chlorinated to breakpoint chlorination. The pool shall be closed and remain closed until the chlorine level drops to the maximum allowable level of 7 ppm.
9. If the concentration of cyanuric acid exceeds 60 ppm the pool must be closed until appropriate measures are taken to lower concentration. Cyanuric acid stabilizers shall not be used in indoor pools.
10. If the department determines a condition, situation, or installation is created, installed or maintained that may:
    • cause or result in a health or safety hazard; or
    • cause or transmit disease.

Additionally, as detailed in section 30(s), a pool or spa shall be closed for at least one hour following the manual additional of a chemical directly to the pool water.

Bathing beaches shall also close if the water quality does not meet the following water quality standards:

1. Escherichia coliform bacteria, using the membrane filter count, exceeds one hundred twenty-five (125) colonies per one hundred (100) milliliters as a geometric mean based on no less than five (5) samples equally spaced over a thirty (30) day period.
2. Escherichia coliform bacteria using the membrane filter count exceeds two hundred thirty-five (235) colonies per one hundred (100) milliliters in any one (1) sample in a thirty (30) day period.
3. The water has aquatic vegetation, deposits, growths, oil, grease, chemicals, or other substances capable of creating toxic reactions, skin or membrane irritations, or a health or safety hazard.

Training

Swimming, Spa, and Therapy Pools:

Lifeguard training is required as detailed in 410 IAC 6-2.1-35:

• Lifeguards shall possess a current nationally recognized certification in each of the following:
  • Lifeguard training,
  • Adult/infant/child cardiopulmonary resuscitation, and
  • First aid

Copies of these certificates shall be kept on site and available for inspection. The operators of all public pools shall provide annual lifeguard orientation and training that includes training in bloodborne pathogens. New guards shall also receive training when they are employed.

It is recommended that water venue operators receive and maintain accreditation as a Certified Pool Operator® (CPO) in order to practice and demonstrate pool and pool safety knowledge.

Bathing Beaches:

Lifeguard training and requirements as detailed in 410 IAC 6-7.2-30:

• An individual currently certified as a lifeguard and having a current cardiopulmonary resuscitation (CPR) certification must direct swimming, boating, canoeing, watercraft, water skiing, and other aquatic activities.
•  At each aquatic site, a minimum of one (1) currently certified lifeguard for each thirty (30) campers must be provided.
•  At least one (1) qualified lifeguard shall be on duty when the bathing beach is open to swimmers.

Recordkeeping

In Indiana, all bathing beach, swimming, spa, and therapy pool records of bacteriological water sample reports are maintained by the regulatory authority and copies are sent to the pool and beach operators and managers for retention.

Per 410 IAC 6-7.2-30(11) the results of each camp bathing beach water sample analysis in must be reported to the department.

Copies of the Swimming Pool Record of Operation logs are given to water venue operators for their recordkeeping as required by the Indiana State Department of Health Public and Semi-Public Swimming Pools Rule 410 IAC 6-2.1, Sec. 38 – which requires that operating records be kept at a minimum of one (1) year and shall include data on:

• Disinfectant residuals and combined chlorine concentrations,
• pH readings,
• Volume of fresh water added,
• Operating periods of pool water recirculation pumps and filters and the corresponding rate of flow meter readings,
• Amounts of chemicals used,
• Maintenance and malfunctioning of equipment, and
• Date and time of any fecal events occurring in the pool, whether it involved formed stool or diarrhea, and the free chlorine of pH levels at the time of observation of the event. Before reopening the pool, the a) free chlorine and pH levels, b) procedures followed in response to the fecal accident, including the process used to increase chlorine levels (if necessary); and c) contact time; must be recorded.

Injury/incident reports: using a form prescribed by the regulatory authority, reports shall be made for each occurrence that: results in death, requires resuscitation, results in transportation to a hospital or other facility for medical treatment, or results in an illness connected to the water quality at the water venue. Accident and illness reports are submitted to IUEHS for the respective campus.

Inspection report: Inspection, water chemistry, water clarity, and air quality reports are kept at IUEHS. Copies are sent to the water venue operators and managers for retention.

Emergency response planning and consultation: providing and maintaining current information and plans for emergencies; fecal accidents, blood and vomit in the pool water, body fluid on deck, recreational water illnesses, contact surface diseases associated with pool and locker rooms, communicable disease prevention, lightning, tornadoes, floods, earthquakes, fires, chemical accidents.

Emergency plan for bathing beaches: 410 IAC 6-7.2 (22)(c):

• Camps offering aquatic activities must have an emergency plan that includes procedures for rescues, accounting for each camper, evacuations, and the method for notification of emergency services. Weekly orientation in using the aquatic emergency plan must be conducted.