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An evaluation of policy for public spas and hot tubs in British Columbia Crandall, Robert A. 1983

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AN EVALUATION  OF POLICY FOR  PUBLIC SPAS  AND HOT TUBS IN BRITISH COLUMBIA by Robert B.A.  A. C r a n d a l l  Stanford University  A THESIS SUBMITTED  1972  IN PARTIAL FULFILMENT OF  THE REQUIREMENTS FOR THE DEGREE OF MASTER OF SCIENCE in THE FACULTY OF GRADUATE STUDIES School  We  o f Community  accept  this  & Regional  t h e s i s as  to the r e q u i r e d  Planning  conforming  standards  THE UNIVERSITY OF BRITISH COLUMBIA April,  © Robert  A.  1983  C r a n d a l l , 1983  In p r e s e n t i n g  this thesis  r e q u i r e m e n t s f o r an of  British  it  freely available  agree that for  Library  s h a l l make  for reference  and  study.  I  f o r extensive copying of  h i s or  be  her  g r a n t e d by  shall  the  not  be  COMKu'fxJ Try  j  of  further this  this  The U n i v e r s i t y o f B r i t i s h 1956 Main Mall V a n c o u v e r , Canada V6T 1Y3  thesis  a l l o w e d w i t h o u t my  Date  DE-6  (3/81)  (Lfu\0  .St.  P^o/UAC ft^WHUfe-  Columbia  my  It is  permission.  Department o f  thesis  head o f  representatives.  copying or p u b l i c a t i o n  f i n a n c i a l gain  University  the  s c h o l a r l y p u r p o s e s may  understood that  the  the  I agree that  permission by  f u l f i l m e n t of  advanced degree a t  Columbia,  department or for  in partial  written  i i  ABSTRACT  Increasing outbreaks created spa  numbers  associated  with  appropriate  policies  public  problem,  safety  order  to  is  based  criteria  issues  i s developed public  established  practices are  existing  by t h e h i g h In  examining  policy for public  s p a s and  f o r the Province  reasonable public  of health  the  deficiencies  s p a use a r e  The  difficulties  spa  framework,  spa  of the U n i t e d  evaluative  spa o p e r a t o r s  e v i d e n c e d by t h e U . S . - C a n a d i a n  r e s u l t s of the study  indicate  that  policies  S t a t e s and from  and o t h e r s  are  i s then proposed which and  Using  obtained  f o r the evaluation.  criteria  A  policies  literature.  L i t e r a t u r e and i n t e r v i e w s  Columbia  illuminate  management  by t h e e v a l u a t i v e jurisdictions  pose  must a d d r e s s .  health  the industry,  examined  and u n c e r t a i n t i e s which  for evaluating  of information  for British  meet  risks  with  p o l i c y and p u b l i c  evaluated.  used as a b a s i s  The  complicated  which p o l i c y e v a l u a t i o n  in selected  government a g e n c i e s ,  policies  the  f o r s p a management.  upon  Canada  w h i c h would p r o v i d e  of  have  The p r o b l e m o f d e v i s i n g  r e l a t e d t o s p a management.  identify  basic  framework  to  policies  disease  protection.  difficulties  and  the e f f e c t i v e n e s s  p o t e n t i a l hazards a s s o c i a t e d  several  and  o f s p a s and h o t t u b s  the t h e s i s evaluates  Columbia  The in  use  t u b s and p r o p o s e s a s e t o f p o l i c i e s  British and  the  injuries,  and p r o c e d u r e s .  spa  degree of u n c e r t a i n t y  hot  deaths,  i n c r e a s i n g concern about  management  this  of  A s e t of spa i s designed  overcome  existing  experience.  potential  hazards  associated  with  regulation  of  public spa  spas  and  management  hot tubs  in  a  justify  manner  different  r e g u l a t i o n o f swimming p o o l a n d o t h e r p u b l i c b a t h i n g Spa  policies  health  (1)  acceptable public,  development,  be  precisely define  level  (3)  should  of  actively (4)  "safe"  developed spa  to  hazards,  conditions  policy  (2)  provide  a  social  implementation  l e a r n i n g process  i m p r o v e s p a management p r a c t i c e s . attaining  these  objectives are  the an  f o r spa users and t h e in  policy  measures which  e f f e c t i v e l y d e a l w i t h the v a r i a b l e c o n d i t i o n s of spas, organize  public  accomplish  i n v o l v e spa u s e r s and o p e r a t o r s  provide  from  activities.  i n B r i t i s h Columbia which provide reasonable  protection  following;  government  and  (5)  t o reduce u n c e r t a i n t i e s and  Specific  suggested.  recommendations  for  TABLE OF  CONTENTS  Abstract i i L i s t Of F i g u r e s And T a b l e s vi Acknowledgements . . v i i I . INTRODUCTION ix 11 . CHAPTER 1 The D e v e l o p m e n t Of The Spa And Hot Tub M a r k e t And I t s I m p l i c a t i o n s F o r The E s t a b l i s h m e n t Of P o l i c y 1 What A r e Spas And Hot Tubs? 1 The Emergence Of Spas And Hot Tubs As A P u b l i c C o n c e r n . 2 The D e v e l o p m e n t Of The Spa And Hot Tub M a r k e t And I t s Economic And S o c i a l Impacts 3 An Explanation F o r The R a p i d Growth Of The Spa And Hot Tub M a r k e t 8 I m p l i c a t i o n s Of The Spa And Hot Tub M a r k e t Development F o r The E s t a b l i s h m e n t Of P o l i c y 11 Summary 12 I I I . CHAPTER 2 The C h a r a c t e r i s t i c s Of R i s k s And U n c e r t a i n t i e s I n R e g u l a t i o n Of P u b l i c H e a l t h H a z a r d s A s s o c i a t e d W i t h Spas And Hot Tubs 16 D e f i n i t i o n s Of " R i s k s " And " U n c e r t a i n t i e s " 16 Spas And Hot T u b s : P u b l i c H e a l t h C o n c e r n s 18 P o t e n t i a l Hazard Areas 22 Pathogenic Hazards 22 M a n a g i n g Spa Water Q u a l i t y To C o n t r o l P a t h o g e n s .. 22 C o n t r o l l i n g S p e c i f i c Pathogens 30 Hyperthermia Hazards 37 V i s u a l H a z a r d s From Poor Water C l a r i t y 40 D r o w n i n g H a z a r d s R e l a t e d T o The Spa A e r a t i o n Systems 41 Identification Of Specific Risks And Uncertainties W i t h i n The P o t e n t i a l H a z a r d A r e a s 43 Major P o l i c y D i f f i c u l t i e s A r i s i n g From Spa Management Uncertainties 50 F. B a s i c I s s u e s I n v o l v e d I n The R e g u l a t i o n Of Spas 59 IV. CHAPTER 3 How S h o u l d P u b l i c Spa And Hot Tub P o l i c y Be D e s i g n e d ? .. 65 Governmental R e s p o n s i b i l i t y F o r P r o t e c t i n g U s e r s Of Spa Facilities 65 Governmental R e s p o n s i b i l i t y For P r o t e c t i n g The Public From E x t e r n a l E f f e c t s Of Spa O p e r a t i o n s 68 Decision Processes F o r D e t e r m i n i n g Spa R e g u l a t i o n And P r o v i s i o n Of I n f o r m a t i o n To The P u b l i c 70 Development Of E f f e c t i v e I m p l e m e n t a t i o n M e a s u r e s 72 E s t a b l i s h m e n t Of A S o c i a l Learning Process To Reduce Uncertainty 75 C r i t e r i a F o r E v a l u a t i n g A l t e r n a t i v e Spa P o l i c i e s 78 V. CHAPTER 4 E x p e r i e n c e I n The U.S. a n d Canada 85 A. B a c k g r o u n d Of The U.S. E x p e r i e n c e 85 Scope Of S t u d y 85 A B r i e f D e s c r i p t i o n Of The U.S. E x p e r i e n c e 88  V  B. The U.S. S t r u c t u r e Of Organizational Involvement W i t h P u b l i c Spas ". 93 C. The A c t o r s And T h e i r R e l a t i o n To The S y s t e m 94 A n a l y s i s Of The U.S. E x p e r i e n c e 96 G o v e r n m e n t a l R o l e s And R e s p o n s i b i l i t i e s 96 Decision-Making Processes For E s t a b l i s h i n g Conditions Of " S a f e " Use 103 Implementation P r a c t i c e s 107 P r o v i s i o n For S o c i a l Learning 112 D e f i c i e n c i e s In U.S. Spa P o l i c i e s And P r a c t i c e s : L e s s o n s F o r D e s i g n Of M o d e l P o l i c y 114 The C a n a d i a n E x p e r i e n c e W i t h S p a s 115 S c o p e Of S t u d y 115 D e s c r i p t i o n Of The B.C. P u b l i c H e a l t h S y s t e m And I t s R e l a t i o n To P u b l i c S p a s 116 The B r i t i s h C o l u m b i a E x p e r i e n c e W i t h Spas 118 The C a s e F o r Spa P o l i c y Change I n B r i t i s h C o l u m b i a ..120 VI CHAPTER 5 Recommendations F o r A Spa P o l i c y Framework F o r B r i t i s h Columbia 124 Development Of Approved S t a n d a r d s And P r o c e d u r e s F o r P u b l i c Spas And Hot Tubs 125 D e t e r m i n a t i o n Of P r o v i n c i a l P u b l i c S p a / H o t Tub S t a n d a r d s And Management P o l i c i e s 127 M e a s u r e s F o r I m p l e m e n t i n g Spa S t a n d a r d s And Management P o l i c i e s I n B.C 1 29 Policies To Reduce Uncertainties And Improve Spa Management And E n f o r c e m e n t P r o c e d u r e s 134 E . N o t e s On P r o v i s i o n s F o r F u n d i n g 137 Summary And E x p e c t e d R e s u l t s : How The M o d e l Policy Can Correct Present D e f i c i e n c i e s 139 APPENDIX A P a t h o g e n i c H a z a r d s And P u b l i c S p a / H o t Tub F a c i l t i e s ....146 APPENDIX B C u r r e n t Knowledge & G u i d e l i n e s F o r Spa Management 167 APPENDIX C B e h a v i o u r a l C o n s i d e r a t i o n s Of Spa A c t o r s 174 APPENDIX D A D e t a i l e d D e s c r i p t i o n Of The U.S. E x p e r i e n c e 190 APPENDIX E The B.C. H e a l t h A c t And I t s P r o v i s i o n s F o r Spas 224 APPENDIX F A Sample Spa O p e r a t o r T r a i n i n g P r o g r a m 235 APPENDIX G A Sample ' P l a n Of O p e r a t i o n ' 241  vi  L I S T OF  FIGURES AND  TABLES  FIGURE 1  PAGE Pool  Sales  v s Spa/Hot  Tub  Sales  1976-1980  7  TABLE I II III IV  PAGE CPSC C a s e s I n v o l v i n g Spa J a n u a r y 1, 1979 - J u n e  Fatalities 14, 1981  The U.S. S t r u c t u r e o f O r g a n i z a t i o n a l W i t h P u b l i c Spas and Hot Tubs  19 Involvement  The C a n a d i a n S t r u c t u r e o f O r g a n i z a t i o n a l I n v o l v e m e n t W i t h P u b l i c Spas and Hot Tubs C u r r e n t Knowledge and G u i d e l i n e s Management  93 .......  115  f o r Spa 170  vii  Acknowledgements I wish t o express whose  encouragement  I appreciate  and a s s i s t a n c e c o n t r i b u t e d t o t h i s  the i n f o r m a t i o n and i n t e r e s t  numerous i n d i v i d u a l s pool  and  my s i n c e r e s t g r a t i t u d e t o t h e many  spa  people  thesis.  w h i c h was p r o v i d e d  by  from p u b l i c h e a l t h and s a f e t y a g e n c i e s , t h e  industry,  and  personnel  associated  with  spa  facilities.  I am i n d e b t e d of  Health  furthering health  Care  my  strengthened  wisdom, m o r a l  about  thanks  His insights the f i n a l debt  of  this  advisor,  I  f o r myself,  excellent  I efforts  why  also  wish  to  o f my t y p i s t s ,  was  considerably  who c o n t r i b u t e d , I I r v i n g Fox whose to  T h r o u g h my a s s o c i a t i o n w i t h an  other  academic  people  and  a  thesis  the opportunity to consider  him  an  man.  acknowledge  the hard  work and d e d i c a t e d  Sharon and M a r g a r e t .  I thank my a source  supervisor)  g u i d a n c e , comments, and  fortunate having  many  a d v i s o r and a great  Finally, support  extremely  both  public  w i t h me was i n s t r u m e n t a l  thesis.  Fox i n h i s r o l e a s  learn,  (thesis  Of a l l t h o s e  and p a t i e n c e  Dept.  h i s help in  h a z a r d s and  of g r a t i t u d e t o Professor  Professor  was  his  for  and a t t e n t i o n t o d e t a i l  product.  support,  development  pathogenic  for  (Professor,  U.B.C.)  P r o f e s s o r Anthony Dorcey  special  the l a r g e s t  Mackenzie  Epidemiology,  my u n d e r s t a n d i n g  suggestions.  the  and  protection.  deserves  owe  t o D r . C.J.G.  family  and  of strength.  friends  To a v e r y  whose special  love  and  friend, I  viii  e x p r e s s a warm and h e a r t f e l t t h a n k y o u .  This IV,  thesis  i s dedicated  i n memory o f D r . James  my f o r m e r mentor a t S t a n f o r d U n i v e r s i t y ,  October  1982.  H i s support,  encouragement,  T. W a t k i n s  who p a s s e d away i n and  spirit  w i t h me a n d I g r a t e f u l l y a c k n o w l e d g e h i s c o n t r i b u t i o n .  remain  ix  INTRODUCTION The  p u r p o s e of  framework use  of  this  thesis  for evaluating  public  s p a s and  recommend a s e t  of  policies  hot  policies  reasonable protection  public  spa  p r o b l e m s and identified  hot  and  To  limitations parts  of  evaluated. existing public  The the  these  provide current  the  United  and  reason  occurrence  hot  in  States  of  in  Columbia  deaths,  s p a * use  safety.  and  in B r i t i s h study  may The  which  and  framework  i s the  and  the  be  inadequate  protection  and  selected  and  analysis  of  that  of p u b l i c  status  in  for be  regulating  recommended.  concern  disease  for  public  and  will  and  possibility  normative  described  increasing  injuries,  be  be  policies  Columbia  will  evaluating  Canada w i l l  of  in  objectives,the  management  for  to  will  safety  these  spa  and  framework  existing policies  a guide, a set  tubs  this  i n s i g h t i n t o the  evaluative  as  operation  r e l a t e d t o a number of  practical  for this  with  and  be  policies,  the  associated  health  a  of  policies  British  will  the  health  achieve  faced  to develop a •  Columbia  t o e s t a b l i s h a framework  Using  spa  of p u b l i c To  (1)  to apply  for B r i t i s h  use.  uncertainties  considerations policy.  tub  governing (2)  tubs;  assure  and  i s twofold:  outbreaks  present  protecting health  about  and  policy public safety  * N o t e : Spas and hot t u b s a r e v i r t u a l l y i d e n t i c a l i n f u n c t i o n and purpose. The only significant d i f f e r e n c e i s t h a t "hot tubs" r e f e r t o u n i t s where t h e m a t e r i a l c o n s t r u c t i o n o f t h e shell is wooden. T h i s d i f f e r e n c e has some p o s s i b l e r a m i f i c a t i o n s f o r spa management. The r e a d e r s h o u l d be aware of t h e d i s t i n c t i o n , but f o r t h e sake o f b r e v i t y , t h e word " s p a s " w i l l f r e q u e n t l y be u s e d t o mean b o t h s p a s and hot tubs.  X  in  the  related activity  traditionally it  has  been  pose a g r e a t e r In  potential benefits safety  suggested,  health  view of  and  of  and  regulations,  and  spa  policy  in  and  some  In  in other  of  d e t e r m i n e how  on 2.  The  first spas  s p a s and  some  3.  By  the  an  policies,  the  and  be  the  costs  and and  Canada  is  Standards,  e x i s t , vary policy  greatly is  non-  existing policies management  evident  this  of  health  U.S.  spa  the  swimming  examination  confused.  of  spas  problems  confusion  thesis  endeavors  designed.  are  The  and to  thesis  follows:  chapter  describes  in order  to provide  the  growing will  and  in order  regulation  drawing  public  jurisdictions,  has  Further,  public  public  where t h e y do  of  that  s p a s , and  the  in light  view  existing  risks  management in  than  j u r i s d i c t i o n s , the  In  second chapter  health  in  e x i s t i n g p o l i c i e s should  o r g a n i z e d as  public  risk  facilities  government.  some e x p e r t s ,  areas,  guidelines,  uncertainties.  The  of  with public  needed.  each c o u n t r y .  limitations  1.  by  t o be  q u e s t i o n a b l e when c o n s i d e r e d  is  concern  these c o n s i d e r a t i o n s ,  public  inconsistent  and  public  a l t e r n a t i v e p o l i c i e s to p r o t e c t  would a p p e a r  existent  in  safety  hazards associated  Current  within  swimming  been a r e g u l a t o r y  also  pools.  of  upon  the the  importance  development  reader with a of  i d e n t i f y the uncertainties  to determine  of  historical  the  the  spa  nature  background  industry. of  the  associated basic  of  issues  public  with  spa  involved  spas.  the  l i t e r a t u r e dealing  w i t h the  design  of  xi  public  policies  and t h e p r o t e c t i o n  third  chapter  develops  policies 4.  governing  and  framework  describes  policies  Canada, b a s e d  public  health,  the  for evaluating public  spa management.  The f o u r t h c h a p t e r management  a  of  and  evaluates  existing  i n s e l e c t e d p a r t s of the U n i t e d  upon t h e framework  developed  in  spa  States chapter  three. 5.  The  final  chapter  developed  i n chapter  Canadian  experience  proposed  t h r e e and  safety.  the draws  evaluative upon  described i n chapter  s e t o f spa management  which w i l l and  utilizes  assure a reasonable  policies  the  framework U.S.  four to specify a  for British  protection  and  of  public  Columbia health  1 CHAPTER 1  The  Development  o f t h e Spa a n d Hot Tub M a r k e t  Implications  f o r the Establishment  and I t s  of P o l i c y  What a r e Spas and Hot T u b s ? Spas  and  Individual sexual  hot  tubs  conjure  p e r c e p t i o n s range  stimulation.  from  some c a l l action term  the  reflecting  questioning  water); negative  their  biases  I n any c a s e ,  sizes,  shapes,  a basis  perceived  attributes.  is  substantial  excellent  for  in  "Suggested  Spas and Hot T u b s " .  (a t e r m  spas  water  as  status);  the s w i r l i n g  a  result  quality);  illustrating  their  i t is. t r u e and  the  to  t o them a s " c e s s p o o l s " (a  uses  diverse  that for  U.S. H e a l t h  but  o f spas  are  many  and h o t t u b s ,  descriptions  and  of  and some  a subtle,  there  spas  f o r m a l and g e n e r a l d e f i n i t i o n  provided  publication,  and  therapy  generic  d e r i v e d from  refer  images.  f o r much m i s u s e and m i s u n d e r s t a n d i n g  providing  An  different  them " J a c u z z i s " (a b r a n d  toward  cleanliness  factor  hot t u b s ) .  varieties,  tubs  others  t a g them "baby p o o l s "  significant and  call  them " w h i r l p o o l s " ( p r i m a r i l y  of  people  many  ideas of a r t h r i t i c  Some p e o p l e  name misnomer w h i c h h a s c a p t u r e d  up  and  o f spas Human  their  and h o t Services  H e a l t h and S a f e t y G u i d e l i n e s f o r P u b l i c  1  Spas a n d h o t t u b s a r e p o o l s d e s i g n e d f o r r e c r e a t i o n a l and therapeutic u s e and f o r p h y s i o l o g i c a l and p s y c h o l o g i c a l relaxation. These pools a r e not d r a i n e d , cleaned and  2  refilled after each use and may include, but a r e not l i m i t e d to these types: hydrojet c i r c u l a t i o n , hot water, cold water, mineral b a t h s , a i r i n d u c t i o n s y s t e m s o r some c o m b i n a t i o n of t h e s e . Spas and h o t t u b s a r e s h a l l o w i n d e p t h and not meant f o r swimming o r d i v i n g . However, t h e s e facilities, like swimming pools, are closed cycle water systems and may be designed with c o m p l e t e water c i r c u l a t i o n , f i l t r a t i o n , h e a t i n g and i n some c a s e s d i s i n f e c t a n t and o v e r f l o w s y s t e m s i n t e g r a t e d w i t h t h e water c i r c u l a t i o n system. In most c a s e s , b o t h spas and h o t t u b s e q u i p p e d w i t h h e a t e r s have a u t o m a t i c w a t e r t e m p e r a t u r e controls. A public spa and hot tub, depending on i t s size, location and support equipment c a p a c i t y , c a n accommodate from one t o many b a t h e r s .  The  Emergence o f Spas and In  t h e mid  hold  on  "the  land  its  hedonistic  was  regrettable  did  not  they  o f n u t s and  suffer  became  the  The  as  North America.  turning  2  and  milieu.  fate a  While  o f many  viable  back t o  e c o n o m i c and  distribution  when spas  took  this  fads,  and  the  first  1970  and  through  phenomenon hot  but  growing early  tubs  instead industry  model  spas  a number of s p a s no  recognized  as  real  in  market  that  1977  began t o have a m a j o r  impact  3  emergence o f t h e  significant  pursuits".  i t i s generally  point  tubbing"  destruction  were i n o p e r a t i o n even e a r l i e r ,  1 973,  social  "hot  image o f C a l i f o r n i a  on m o r a l  Although  date  the  Concern  welcome t o o t h e r s , s p a s and  short-lived  established  until  upon our  small  the  bent  libertine  t o some and  facilities  existed was  and  known as  reinforcing  fruits  consumer p u r c h a s e  public  Tubs a s a P u b l i c  1970's a phenomenon  t h e West C o a s t ,  throughout for  Hot  thus  spa and societal far.  hot  tub  impacts Along  market  has  produced  despite i t s relatively with these  impacts,  the  3  n a t u r e o f t h e p r o d u c t and i t s use health  and s a f e t y c o n c e r n s  s p a s and h o t t u b s faced and  rise  to  but  i t  dealing  h e a l t h hazards  is  also  with  in  problems  water  illustrative  uncertainty  public  The s u b j e c t o f  i s n o t o n l y an example o f t r a d i t i o n a l  management, of  gave  i n a number o f ways.  i n dealing with public  importance  also  in  planning  of the growing public  policy  development.  G r e a t e r c o m p l e x i t y and r a p i d change  i n our s o c i e t y  increasingly  and  health  often well  exposes  b e f o r e our s c i e n t i f i c  sufficient and  abruptly  to  manage  strategy  and d e s i g n which  The  Development  and  Social  this  properly.  case  hazards  knowledge  In c h o o s i n g  is spas  study aims a t d e v e l o p i n g a  i s relevant  to this  o f t h e Spa and Hot Tub Market  general  problem.  and I t s Economic  Impacts  Despite reminded  and i n s t i t u t i o n a l  the s i t u a t i o n  h o t t u b s a s an example,  us t o p u b l i c  o u r modern view  that  their  precedence.  As  one  manual a p t l y  describes  of  cultural spa  spas use  chemical  the h i s t o r i c a l  and and  hot  tubs,  acceptance  manufacturer's  we has  are long  maintenance  role:  Congratulations on b e c o m i n g p a r t o f h i s t o r y . As t h e owner o f a s p a / h o t t u b , y o u a r e now p a r t o f a social phenomenon t h a t i s t r a c e a b l e back t o a n c i e n t E g y p t , t o t h e p r e h i s t o r i c cities o f t h e Indus Valley, t o the e a r l y c i v i l i z a t i o n s a r o u n d t h e Aegean Sea and t h e O r i e n t a s w e l l . The a n c i e n t G r e e k s d e v i s e d l u x u r i o u s b a t h i n g provisions with heated water, plunges, and showers. The Romans developed b a t h i n g as a p u b l i c d i v e r s i o n to a unique and elaborate degree. The J a p a n e s e t r a d i t i o n a l l y use t h e b a t h as a d i s c i p l i n e d , s p i r i t u a l r i t u a l . The cleansing comes first and t h e b a t h i s r e s t r a i n e d , s i m p l e , a n d s u i t a b l e f o r q u i e t c o n t e m p l a t i o n . I t ' s up t o y o u t o u s e y o u r spa/hot tub i n any way or i n many ways f o r your b e n e f i t and pleasure. You have a b e a u t i f u l a d d i t i o n t o your way of  4  life  a n d we want t o h e l p y o u keep i t t h a t way."  Today, in  private  spas  and hot tubs a r e found  residential  u s e and p u b l i c  Spas a n d h o t t u b s a r e h e r e their  presence  means  a myriad  According  t o C r a n f o r d K. G i b b s ,  Ministry  of Health:  us  and  now,  people  degrees  American  private  use  perceived public  of  health  involvement  facilities  public  become  a  100,000 ranging spas/hot  pools,  this  a  are publicly  used.  between  portion  tubs  $2,500  sold  t o $500 m i l l i o n after-market  hundreds  of  accepted varying  depending  into upon  of p o o l s and spas  rationale  for  T h i s study  the their upon  government t r u e where  i s f o c u s e d on t h e  annually.  they  have  estimated  total  With  p e r y e a r a t an a v e r a g e (modest  support  annually. items  of  of the c u r r e n t l y  and $5,000  t u b s and n e c e s s a r y  i s with  o f spas and h o t tubs,  o f $3-$4 b i l l i o n  spas/hot  t u b problem  of t h e p o o l and spa i n d u s t r y .  history  substantial  problems. Ontario  This i sparticularly  6  people  the  intervention  services,  major  some  health  generally  government  industry.  the b r i e f  p o o l / s p a market  $250  been  to  5  has  and  everywhere, facilities.  with  lives  view."  spa and h o t t u b s e c t o r  Despite  spa/hot  The p e r c e i v e d e f f e c t s  has  in  upon  products  effects.  engineer  the  tradition  of l i m i t a t i o n s  and  o f new p u b l i c an  affecting  about  or commercial  stay,  "The w h i r l p o o l  . . . a d v e r s e l y , i n my  North  such  is  to  just  such  figures),  approximately retail  price  new s a l e s o f  equipment a l o n e account  for  On t h e b a s i s o f e x p e r i e n c e  with  as  chemicals,  replacement  5  equipment/parts, Therefore, market  sales  annually. the  it  and s e r v i c e s w o u l d p r o b a b l y d o u b l e is  somewhere  Thus,  total  pool/spa  their  relative  tubs  are  even  The  newness and t h e f a c t 1/3  more  percentage  that  1/4 t o 1/3 o f  spas/hot  o f an a v e r a g e based  market  considering  for  upon  pool. market  only.)  comparison  i s , a s shown  o f p o o l s and s p a s / h o t  As one c a n s e e , i n o n l y f o u r y e a r s , s a l e s  t u b s have a l m o s t  billion  of d o l l a r  prices  approximations  of u n i t s  $1  i s remarkable  t o 1/2 t h e p r i c e  interesting  of  approximately  r e p r e s e n t t h e U.S. market  below, t h e number  per y e a r .  neighbourhood  to the t o t a l  a l l f i g u r e s a r e merely  An  hot  the  market.  by s p a s  generally  s u r v e y and t h e y  graph  in  figure.  t o p l a c e t h e e s t i m a t e d t o t a l spa  i t would c o n s t i t u t e  share c o n t r i b u t e d  (Note:  reasonable  this  equalled pool sales annually.  i n the  tubs  sold  o f s p a s and  6  Pool  S a l e s v s . Spa/Hot  Tub S a l e s  1976-1980  120 Pools 108  1 10 100 90 Number of Units Sold  80 70  (in 60 thousands) 50 40 30 20 1 0  (No a c t u a l s t a t i s t i c  was a v a i l a b l e  for this  year)  0 1976  1977  1978  1979  ( S o u r c e o f s t a t i s t i c s : "Swimming P o o l I n d u s t r y Reports", Hoffman P u b l i c a t i o n s )  1980 Market  7  Although downturn  sales dipped  in  the  general  growth t r e n d s .  Future  spas/hot  except  tubs  conditions. pattern, and  The  and  contractors contractor. targeted  sales  has  also  the  spa  at  had  that  market  reveal  2/3  an  of  pool  optimistic  for  influence  13  and  for extensive  true  economic  astounding  the  the  the  poor g e n e r a l  spas, a v e r a g i n g of  reflects  time, not  are  a substantial Over  sell  this  predictions  still  Manufacturers  7  1980,  under e x c e p t i o n a l l y  behaviour. now  in  economy  figures  this  consumer  slightly  on  growth industry  swimming s a l e s per  spa  pool  year  products  a d v e r t i s i n g and  per have  promotion  ef f o r t s .  Consumers have alternative. However, on and  Actual the  a general  reasonable that  idea  to  the  existence  receive  are  that not  public  generally  officials  about  f o r spa/hot  tub  required;  and  spas  be  installed  without  with,  the  of  the  Illinois  in  are  not  in the  where ( f o r the  recreational available.  swimming p o o l market,  i n the  is  millions  and  facilities.  are  reliable  operation.  Queries  number This  they  of  units  i s due  to  (unlike are  obvious  s p a s we  Health  8  no  easy d e t e c t i o n ) .  Public  use  it  public  installations  numbers of p u b l i c  D e p t . of  a  spa  there  unsure r e p l i e s .  to enforce  idea  the  spas  difficult  an  use  as  public  occurs  are  provide  on  of  provisions can  spa  u s e r s number  public  vague and  permits  spa  spas  unfortunately,  number of  to  size  activity  pools,  directed  fact  the  spa  of  information  assume t h a t  public  f i g u r e s on  of  of  of  adopted  statistics  basis  a good d e a l  Unlike  clearly  may  estimates  in the  pools)  required, reason  that  However, be  to  dealing  that  there  8  are  a minimum o f 2,200 u n i t s i n  comparison,  British  approved  75 p e r m i t s  permits  in  number  and  pools"  hot  information statistics their  material  a large  increase  over the  that  permitted  in  the  92  of a c t u a l p u b l i c Spa market  1 0  future,  yet  the  t o demonstrate the magnitude of  various  magazines  1 1  are  f a r too extensive overall  abound w i t h  behaviours  regard  to the  impacts  generally  related to health,  Explanation  changes  to the various had.  involved with  t o document h e r e .  social  and n e w s p a p e r s  1 2  i n f l u e n c e s p a s and h o t t u b s have  number o f s o c i a l  An  and  1980  and i n d i c a t e some o f t h e s o c i a l  and a r t i c l e s  and  values  in  i n the p r o v i n c e .  improve  by  observation  Stories  contributed  pools"  estimate  will  In  9  permits)  are a conservative i n operation  Illinois. require  conceded  from t h e g r o w t h .  social  does  is  tubs  It  in  growth.  this  resulting  the  represents  so f a r a r e s u f f i c i e n t  Editorial  and  This  likely  sudden  support  (which  "therapeutic  i n 1977 o f 23 p e r m i t s .  "therapeutic spas  Columbia  for  1981.  operation  are  fitness,  variety  s p a s and h o t t u b s  But i t i s e v i d e n t  consistent  increased  The  uses  with  societal  and  that have  emphasis  on  r e c r e a t i o n , and r e l a x a t i o n .  f o r t h e R a p i d Growth o f t h e Spa a n d Hot Tub  Market  What interest  are  the  i n spas as  reasons a  for  this  recreational  r a p i d g r o w t h a n d sudden  amenity?  The  tremendous  9  growth  rate  apparently,  is  a sufficient  Industry/spa consumers  attributable  on  f o r spas and,  supply.  operator  the  t o a s t r o n g demand  demand  interests  on  side perceive  the  supply  side  and  large b e n e f i t s through  growth of t h e spa market. The  industry's motivation  economic, both to  meet  market  in i t s efforts  the response.  f o r promoting  growth  i s obviously  t o s t i m u l a t e consumer  Specifically,  demand  and  f o r the i n d u s t r y , t h e spa  means: 1. A v a s t from  new market pool  opportunity,  sales  and  as s p a s do n o t d i s t r a c t  sometimes  may  promote  pool  purchases. 2.  A potentially reason  3.  g r e a t e r market  i n the long  i n chemicals.  The  and  relative  such  ease  from t r a d i t i o n a l as:  weather  inconvenience, investment, and  cash  simply  f o r the  above and a l s o b e c a u s e o f t h e t r e m e n d o u s  market, p a r t i c u l a r l y  freedom  term,  sell  themselves  pool  labor  problems.  more  (causing  requirements  delays, capital  and p r o b l e m s ,  I n some i n s t a n c e s , spa  retailers  packages,  from p o t e n t i a l  allows  drawbacks  slow-downs), h i g h  "do-it-yourself" even  construction  constraints  and s e a s o n a l  extensive flow  s p e e d of i n s t a l l a t i o n  after-  freeing  profit-draining  problems.  The by  owners o f p u b l i c s p a o p e r a t i o n s  the market's p r o f i t  potential.  similarly  To some, i t  are motivated  offers  a  brand  10 new  area  of business  enhance t h e o v e r a l l  e n d e a v o r , and t o o t h e r s ,  facilities  i s both a t t r a c t i v e  a l s o a c t s as a f o r c e  f o r meeting competition  Operators,  too, both s t i m u l a t e  What a r e t h e r o o t s spa  incentives;  (1) social-recreational  represents  "consumer  a choice  demand  incentive by  activities.  considerable  fluctuations  physicians  to  over  are looking  arthritis  and  patients.  One d o c t o r  1 3  increases  case  a t spas  blood  The dispute,  and  demand  time,  and  demand. may  The  and  i t  large  number  of  is  subject  to  it  be  thus,  may  of t h i s m o t i v a t i o n . the  for  paraplegics  interesting  The one,  and  reasons, not j u s t  many  while  easier.  other  multiple  the b e n e f i t s  circulation  We  I n c r e a s i n g l y , consumers and  but  describes  and  the  health sclerosis  this  way;  water  "the  provides  The h y d r o t h e r a p y  reduces  soreness." " 1  positive health however.  unfounded)  a  for therapeutic  b u o y a n c y , w h i c h makes movement stiffness  apparent,  a  study.  stiffness,  including  operators  b a s e d on two b r o a d  quite  is  The  (2) therapeutic.  amongst  however,  this  sufferers,  heat  is  Such  incentive,  particularly  for  and  to  i n the r e c r e a t i o n a l  being  t o p r e d i c t usage a s a r e s u l t  therapeutic  spa  and meet consumer  as  consumers  alternative  difficult  to  o f t h e consumer demand f o r s p a s ?  categorize  social-recreational  serve  of a r e c r e a t i o n a l o p e r a t i o n .  g r o w t h o f t h e market  field.  s p a s may  1 5  On a s c a l e r a n g i n g  therapeutic  b e n e f i t s and t o  e f f e c t s of spas a r e s t i l l  claims  a l l points  in  to  from e x t r e m e  arbitrary  between,  a  matter  of  (and p e r h a p s  d i s m i s s a l o f any  medical  and  health  11  experts  have no  majority  of  effects;  but  extent U.S.  as  and  exact  benefits,  what c o n d i t i o n s may  device.  entire  c o s t s of  operators  Further,  1 6  and  installing  beneficial  It  health  may  understood, gained either  a  be  predict  of  presents  a troublesome  hazards  in  one  spa  to the  with  The as  a  I n t e r n a l Revenue spas  are  treatment  spa  of  a  personnel,  experience  definitely  their  and  have  very  or as  a proven medical  spas w i l l just  small  conflict  between  direction,  a  " f a d " or a  pool/spa  for  policy-makers,  protecting while  and  total  fact,  Spa  Hot  Tub  for  the  Establishment  of  health  substantial market.  It  involving  seeking  direction.  the  we  t h e p u b l i c from h e a l t h  simultaneously  of  have  planted,  become a v e r y major  simply  fully  t h e r a p e u t i c worth  f o o t h o l d becomes f i r m l y  improve p u b l i c h e a l t h i n a n o t h e r  Implications  spas  t h e r a p e u t i c b e n e f i t s are  of  that  relatively  balancing  for  maintaining  t h a t spas do  reality  longer  their  1 7  that  portion  delicate  the  no  beneficial  purpose,  b a s e d upon t h e i r  perceptions  as a p e r c e p t u a l  —  felt,  If  of the  interviews  before  foothold.  consideration  in  results.  the  the case  and  the  anybody's guess.  is essential  customers,  a while  but  safely  use  managers  comments from t h e i r  If anything,  their  be  Under S e c t i o n 213  d e d u c t i b l e where t h e  disability.  issue.  seem t o b e l i e v e t h a t t h e r e a r e  t o the  under  this  I n t e r n a l Revenue S e r v i c e s u p p o r t s  Code, t h e  can  agreement on  experts  therapeutic  tax  solid  Market Policy  Development  to  12  An  understanding  market may and  policy  and  implications 1.  The  may  be  in  dealing  associated with  reasonably  of  spa  with  spas.  the  spa  policies potential  The  following  drawn:  s t r o n g p e r c e p t i o n of and  development  in establishing  difficulties  uncertainties  operators, from  the h i s t o r i c a l  e x p l a i n government d e l a y  current  hazards  of  spa  benefits  c o n s u m e r s may  by  have d i v e r t e d  industry,  spa  attention  away  c o n s i d e r a t i o n of p o t e n t i a l  hazards  a s s o c i a t e d with  development  market  from  spa  use. 2.  The  swimming  pool  were s i m i l a r  of  the  spa  i n d u s t r y l e d many p e o p l e  t o swimming p o o l s w i t h  c o n s t r u c t i o n , m a i n t e n a n c e , and public  swimming p o o l p o l i c y  f o r many y e a r s ,  the  hazards  initially  was  not  T h u s , t h e manner the  need  for  policy  uncertainties.  Issues  being  of  spa  significant public  to  respect to  engineering  standards.  Since  been a c c e p t a b l e and  stable  examine  potential  spa  spa m a r k e t d e v e l o p e d  considerations relating  of p o t e n t i a l  to the p u b l i c  u s e r s and  the  general public  extent.  As  a  hazards.  spas  use  perceived.  i n which the  h e a l t h should begin  potential  Summary  need  existing  t o assume t h a t  management  has  the  result,  were not  present  with a thorough  health  obscured  hazards and  raised  policy  and  wellto  any  to protect  examination  of  the  13  We  can  emergence of First,  the  firmly even  the  one  previously Second,  there  growth  of  industry,  (but  of the  could  were  i n the  market and  been  future.  Yet,  there  consideration.  and  are  the  this  spa  as  stay. and  i s d i s t r i b u t e d among Consequently,  any  and  Hence,  here to  i f action  imposed on  are  preservation  users.  exists  hand, p r o p e r  has  constructed,  to merit  costs  other  increase  spas  i s taken  of  these  a  which groups  effective policies  and  failure and  to  regulate  safety  strong  spas to  protection  public  provide  result  pressures  for  reasonable  i n major  public  government  action  a public health  concern  develop. the new  find  Information  now  a  problems,  creates  some  the  advantageous to a l l concerned).  health  Fourth,  to  examining  public  i n t e r e s t in  operators,  the  of  public matters,  spa  perceived  should  health  spa  potential conflict  management a r e  public  likely  s p a s , as  public  spa  a l s o , on  Third,  may  i s much v e s t e d  the  deal  and  supply  in operation  stated,  from  market:  more p u b l i c  already  increases  conclusions  g r o w i n g demand and  i f not  good  several  spa  established  enough  the  draw  sudden emergence of  s p a s as  challenges  to  ways  protecting  on  areas,  of  scientific  public health non-existent).  e x i s t , government may  be  But  will  reasonable protection  In  order  to appreciate  for  the  health  spas  despite  required  basis  political  public  e f f e c t s of  scientific assure  develops  and  act  public  difficulties  safety. (and  uncertainties  managing s p a s of  and  i s sketchy  the  to  communities  before  a  i n a manner  health faced  and by  in that solid that  safety. those  who  14  must and  deal with  spas,  uncertainties  public  spas  we  need t o examine t h e n a t u r e  w h i c h may  i n the p u b l i c  be  c o n f r o n t e d by  interest.  efforts  of t h e  risks  to regulate  15  Footnotes  - Chapter  1  U.S. D e p t . of H e a l t h and Human S e r v i c e s , Suggested H e a l t h and S a f e t y G u i d e l i n e s f o r P u b l i c Spas and Hot Tubs, Report of the P u b l i c H e a l t h S e r v i c e , C e n t e r s f o r D i s e a s e C o n t r o l ( A t l a n t a : C e n t e r s f o r D i s e a s e C o n t r o l , 1981), p. 1. 1  D i a n e Newton, " E v o l u t i o n of t h e Spa News, September 21, 1982, pp. 41-42.  Industry",  2  Pool  Hoffman Publications, Inc. Swimming P o o l R e p o r t , ( F t . L a u d e r d a l e , F l a . , 1980), p . 8.  Industry  "Great Lakes Biochemical M a i n t e n a n c e , ( M i l w a u k e e , Wis.,  & Hot  3  Cranford News, F e b r u a r y 5  K. 9,  Robert Janis, News, A p r i l 5, 6  Spa  7  Hoffman  Co., Inc., 1979), p. 3.  Gibbs, "Letters 1 9 8 1 , pp. 6-7.  to  Spa  the  Editor",  Tub Pool  "SPEC M e e t s on G o v e r n m e n t a l A f f a i r s " , 1982, p. 16.  Publications,  op.  c i t . , 1981,  "RAB Instant Background: Swimming s u p p l i e d by WGN R a d i o , C h i c a g o , I l l i n o i s ,  p.  &  Spa  Market Water &  Spa  Pool  &  3.  Pool D e a l e r s " , Survey 1979, pp. 187-188.  8  i n t e r v i e w w i t h Dave Antonacci, Illinois D e p t . of Public Health, E n g i n e e r i n g and S a n i t a t i o n D i v i s i o n , S p r i n g f i e l d , 111., J u l y 7, 1982. I n t e r v i e w with W i l l i a m Withers, B r i t i s h Columbia H e a l t h , P r e v e n t i v e S e r v i c e s , V i c t o r i a , B.C., A u g u s t 1 0  of  Ministry 27, 1982.  " H o t T u b s & Spas — The J o y s o f T u b b i n g " , B e t t e r Homes G a r d e n s , R e m o d e l i n g I d e a s , W i n t e r 1980/81, p. 118. 1 1  1 2  Ideas  " G e t t i n g Y o u r s e l f I n t o Hot Water", S u n s e t M a g a z i n e , f o r Hot T u b s , S p a s , & Home S a u n a s , A u g u s t , 1979, p.  Helen D o n i g a n , "Spas Mean H y d r o t h e r a p y " , September 21, 1981, p. 58. 1 3  1 t t  P o o l & Spa  Sunset 5. News,  Ibid.  C l a r e F l e i g , "Hot W a t e r : I t ' s Time Tested Cure, Claims." P o o l & Spa News, F e b r u a r y 23, 1981, p. 29-30. 1 5  MacKenzie Canter I I I , " U n c l e Sam S p a s " , PS M a g a z i n e , ( W a s h i n g t o n , D . C ) , p. 6. 1 6  interviews June-July 1982. 1  and  with  various  Doctor  May H e l p S e l l P o o l s and October/November 1980,  operators  in Chicagoland  area,  16  CHAPTER 2 The C h a r a c t e r i s t i c s of R i s k s and U n c e r t a i n t i e s i n R e g u l a t i o n of P u b l i c H e a l t h H a z a r d s A s s o c i a t e d w i t h Spas and Hot T u b s  Definitions  of  "Risks"  Potential  health  classified  i n t o four to  water  clarity),  and  drowning  spa  aeration  in dealing spa  with  "Uncertainties"  hazards  temperature),  system).  management, we "uncertainty"  the  p u r p o s e s of  need  and  this  to  visual  Managers To  spa  use  pathogenic,  face  the  be  to  water  body e n t r a p m e n t  from  numerous u n c e r t a i n t i e s  explore  the  uncertainties  t o d i s t i n g u i s h between t h e  clarify  may  hyperthermia  (related  ( r e l a t e d t o h a i r and  these hazards.  and  related  broad c a t e g o r i e s :  (related  the  and  distinction  terms  between  in  "risk"  them.  t h e s i s , a framework p r o v i d e d  by  Quade  risk  in  which  For 1  is  used.  A  s i t u a t i o n of  possible  outcomes a r e  occurring. will  What  occur."  The risky  defined  known, t o g e t h e r  is  not  uncertainty  distinction  s i t u a t i o n the  probability  with  known i s t h e  "one the  odds  of  all each  p a r t i c u l a r outcome  is defined  probability distribution  distribution,  as  that  2  A s i t u a t i o n of underlying  is  between r i s k  as  "one  i s unknown." and  distribution  in is  a  uncertainty  situation unknown  and  of  the  3  random e v e n t comes f r o m a known  whereas  where  i s that  "in a  probability  uncertainty must  be  the  chosen  17  subjectively." meant a  that  4  By use o f t h e terms  e x p e r t s c a n be c a l l e d upon  s i t u a t i o n and make j u d g e m e n t s  Both  "chosen  of these  i n some c a s e s  based  types of u n c e r t a i n t i e s  subjectively",  upon  o c c u r r e n c e have some l o g i c a l  There "real for  an a s s i g n m e n t  risk.  Real  uncertainties  b e h a v i o u r and v a l u e s ) and p r e d i c t i o n s  could  within  be e l i m i n a t e d  where d o i n g practical can  i n i n d i v i d u a l and  by g a t h e r i n g  purposes a l s o  Uncertainties  uncertainties  which  by g a t h e r i n g  i n cost  can  be  additional  which c o u l d  a c t i o n s of (i.e.,  about  future  states  Uncertainties  which  information,  or time, might  real  of  preferences  of a d d i t i o n a l  be c o n s i d e r e d  the various  1. U n c e r t a i n t i e s  2.  category.  so would be e x c e s s i v e  classify  risks  this  social  basis  situation  w h i c h depend on t h e d e l i b e r a t e  human  fall  w h i c h may be c a l l e d  have no l o g i c a l  or changes  the world  possible  basis.  people  of  "stochastic  to their  of p r o b a b i l i t i e s t o a p o t e n t i a l  Uncertainties  knowledge.  are considered  i s another c l a s s of u n c e r t a i n t i e s  uncertainties".  is  to evaluate  their  u n c e r t a i n t i e s " because p r o b a b i l i t i e s a t t a c h e d  i t  but  for a l l  uncertainties.  into these  eliminated  We  areas:  and/or  reduced to  information.  likely  be  reduced  to  risks  by  be e l i m i n a t e d  or  judgement. 3.  Uncertainties reduced  For  which  are  r e a l and c a n n o t  to risks.  facility,  uncertainties uncertainties,  we  will  label  a s : (1) i n f o r m a t i o n a l  and  refer  uncertainties,  and (3) r e a l u n c e r t a i n t i e s .  After  to  these  (2) judgement examining the  18  public  h e a l t h concerns  tubs,  we  accord  w i t h t h e above d e f i n i t i o n s  Spas and In  will  Hot  acknowledging  truly  "yes". direct  specify  Spa  Health  s p a s and  alternative,  a public  potential  we  is  supported  division  of  the  hereafter  referred  and  U.S. t o as  and  spas  and  hot  uncertainties  in  distinctions.  hot  tubs as a v i a b l e  must t h e n  address  The  tub  the Center  Dept. of  Health  "CDC"), w h i c h  and  i s unequivocally  exposed  hot  health  the q u e s t i o n : are  answer  doubt,  spa and  by  of  Concerns  are, without  consequence of p u b l i c  conclusion  risks  h e a l t h concern?  users  hazards  pertinent  Tubs; P u b l i c  recreational they  and  to hazards  operation.  as a This  f o r D i s e a s e C o n t r o l (a and  states  Human  Services,  that:  The spa and hot tub i n d u s t r y i s c u r r e n t l y expanding i n t o s t a t e s w h i c h do not have a d e q u a t e regulations to control the health and safety f e a t u r e s of these facilities. E p i d e m i o l o g i c e v i d e n c e has shown t h a t s p a s and h o t t u b s c a n be o f s i g n i f i c a n t p u b l i c h e a l t h c o n c e r n i f they are not p r o p e r l y d e s i g n e d , o p e r a t e d , and m a i n t a i n e d . 5  Even  the  business  encouraging hazard  t o some  The press  spa use  U.S.  do  industry not  deny  interests the  who  existence  profit of  from  potential  degree. Consumer P r o d u c t  release  drowning  and  i n spas  in  December,  from  exposure  S a f e t y Commission 1979  warning  t o water  of  (CPSC) i s s u e d the hazards  a of  19  exceeding  104°F,  alcohol.  The  6  and  report  also  in  combination  with  use  of  states:  T h e r e were an e s t i m a t e d 200 emergency r o o m - t r e a t e d i n j u r i e s i n 1979, and 1,100 i n 1980 w h i c h were a s s o c i a t e d w i t h s p a s . The CPSC has on file, records of 30 r e s i d e n t i a l s p a a s s o c i a t e d d e a t h s , 22 o c c u r r i n g i n 1979, 6 i n 1980 and 2 i n the f i r s t h a l f of 1981. Heat and alcohol were cited as contributory or causal factors in 12 of these cases; d r o w n i n g w i t h no s p e c i f i c c a u s a l f a c t o r was cited in 13 cases; 2 drownings were said t o have r e s u l t e d from the v i c t i m s b e i n g r e n d e r e d u n c o n s c i o u s as a r e s u l t of a fall and head i n j u r y p r i o r t o d r o w n i n g ; and one d e a t h was c a u s e d by electrocution. T h e r e a r e 2 d e a t h s and 2 c a s e s o f n e a r d r o w n i n g s r e s u l t i n g from h a i r e n t a n g l e m e n t s i n spa d r a i n s . T h e r e a r e 6 d e a t h s and one i n j u r y r e p o r t e d which occurred in a commercial or public location. T h e s e 7 c a s e s have been d e t e r m i n e d t o be o u t o f s c o p e f o r t h i s r e p o r t . 7  CPSC C a s e s I n v o l v i n g Spa J a n u a r y 1, 1979 - June  Fatalities 14, 1981  Hazard P a t t e r n  Number  Drowning - Heat and A l c o h o l C o n t r i b u t i n g F a c t o r s D r o w n i n g - Cause Not S p e c i f i e d Drowning - H a i r E n t a n g l e m e n t Drowning - R e n d e r e d U n c o n s c i o u s from F a l l / H e a d I n j u r y Electrocution Drowning - C o m m e r c i a l / P u b l i c L o c a t i o n  12 13 2 2 1 6  Total  36 (U.S. Consumer P r o d u c t S a f e t y  Since August, made  t h e t i m e of t h i s  1982)  of  d e a t h s have o c c u r r e d .  125,000  drain  m a n u f a c t u r e r , as a r e s u l t drowning.  8  report  Significantly,  Commission/HIEH)  an  additional  In J u n e ,  cover  fittings  of two  drownings  the  CPSC  1982,  sold and  report  41  (as  of  a recall  was  n a t i o n w i d e by  one  a  third  shows  a  nearlarge  20  increase deaths  in  from  Some example, spas) has  emergency 1979  to  states the  led  Pseudomonas  view  to  own  strains  o f Pseudomonas, t h i s  reference to  as a g r o u p the  to  regulations has  potential  In of and  As  stated  ordinance a f t e r  named). land  rashes, i s  deleterious.  there are  "Pseudomonas" any  one  other  other solely  strains  Municipalities, area  have  which  begun  Although particular  member, "We  a drowning  tubs  or  such  compose  to  devise  no  serious  jurisdiction, and  don't  serious  want  see to  disease  9  research, every expressed  hazards.  skin  extremely  use  their  by  (not  organism,  a r e aware o f p r o b l e m s e l s e w h e r e  occurred."  background,  causes  spas.  in  For  tubs*  bacterial  aeruginosa;  public  seriously. hot  aware t h a t  Conference,  occurred  dangers.  field  safety  to  be  study w i l l  i n the Chicago  officials  have t o w r i t e an has  s h o u l d be  Municipal  yet  the  can  specifically  specific  those h e a l t h  problem  be  of v i l l a g e s  Northwest  accident  reader  Pseudomonas  will  continuing  e x p e r i e n c e w i t h hot  primarily  i n t h e s e u n i t s and  a l t h o u g h the  referred  that  which  (Note:  in  banned p u b l i c  r e s e a r c h and  conclude  aeruginosa  uncontrollable  and  the problems q u i t e  of Oregon has  Their  them  injuries  1980.  also  state  outright.  room-treated  individual  interviewed, regardless  some measure o f c o n c e r n There  i s no d i s p u t e a s  over  the  health  t o whether o r  not  *The distinction between spas and hot t u b s i s i m p o r t a n t h e r e b e c a u s e p o r o s i t y o f t h e wood c o n s t r u c t i o n m a t e r i a l s o f h o t tubs was c o n s i d e r e d more of a h a z a r d t h a n o t h e r spa c o n s t r u c t i o n m a t e r i a l s ( e . g . , f i b e r g l a s s and c o n c r e t e ) .  21  hazards the  exist.  degree  of  likelihood  of  hazard  which  being  merely  the cause. that  hazard,  Although task,  the  probability  s h o u l d be  allowed,  associated  There  appears  that  people  of  t o be  questions  virtually and  determine  view p r o p e r  brought  under c o n t r o l  However, technical  spa  and  scientific  uncertainty  appears  uncertainties  and  normative  hazard  r e g a r d i n g spas  i n c o n t r a s t to unanimous  exposure  between  hazards  technical  weaknesses policy.  in  In they  uncertainty  The areas has  which  order  being  and  the  outcomes. a  hopeless hazards  with  complex  significant  to  identify  the  complicate  technical  and  spa water q u a l i t y  scientific  as  agreement  the h e a l t h  dealing  d e v e l o p m e n t , an  i s important.  and  where  how  of  careful operation.  entails  exist.  as the  t h e amount  spa management as  matters  demonstrate  a s p e c t s of p o l i c y  relationship potential  to  occurrence,  o p e r a t i o n a l factors are  through  management  i s s u e s such  the hazard,  with the hazards  management,  elements a few  and  with  t h e v a s t m a j o r i t y of e x p e r t s t h i n k t h a t  be  these  of o p i n i o n b e g i n s  r e d u c i n g or e l i m i n a t i n g  maintenance,  principal  can  Divergence  understanding  characteristics  following and  the  and  the  sections describe  illustrate  frustrated  of  the  establishment  key of  22  Potential The  safety  examined  and h e a l t h h a z a r d s  by c l a s s i f y i n g disinfection  2.  hyperthermia hazards  3.  visual  4.  drowning each  and c o n t r o l  h a z a r d s f r o m poor hazards  area,  there  three areas are l e g i t i m a t e  1.  by p u b l i c  Pathogenic The  hazards. important  Managing  and/or  of  constitute This  public  difficulties  the  be  four a r e a s :  water  clarity system  a r e a number o f s p e c i f i c of  occurrence. have been  hazards of  However,  a l l  documented  as  private sources.  bacteria, one  viruses,  of  the  hazard  and  major area  h e a l t h c o n c e r n s , and  fungi  sources one  of  health  of  the  most  poses  the  most  management f o r spas  (like  it  is  i n t h e spa  also  f o r spa management.  Spa Water Q u a l i t y  of  to Control  i n water  i s t o p r e v e n t growth  spread  can  of p a t h o g e n i c h a z a r d s  concerns that  potential  The main c o n c e r n pools)  into  i n spa usage  Hazards  growth  environment  involved  from t h e spa a e r a t i o n  v a r y i n g d e g r e e s and p r o b a b i l i t y  problems  Areas  the problems  1.  In  Hazard  infectious  quality  Pathogens  of b a c t e r i a , diseases.  viruses, These  and  fungi,  pathogens  can  and be  23  introduced  from the  bathers.  The  the  growth of  water pH,  trace  factors  In  order  spa  to achieve  dissolved  ability  bromine) to a c t  conducive  for disinfectant  total  the  of  levels,  w i t h any  upon t h e  water q u a l i t y  to the  solids,  the  by  and  body  of  disinfectant  pathogens.  The  include:  Factors  pH Total Alkalinity C a l c i u m Hardness Total Solids Langelier Saturation Tendencies Trace Elements  F.  Biological A. B.  Standards but of  requirements  recognized  for these  pools for  have that  C o r r o s i t i v i t y or  r e m o v a l of  factors  Scaling  One  investigated,  residual chlorine p r o p e r pH a properly  c h l o r a m i n e ammonias,  have worked  e v e n p o o l s have p r o b l e m s . 193  to  Index of  Factors  Disinfection Shock T r e a t m e n t f o r organic materials Algae c o n t r o l  C.  failed  or  water a r e  or  Filtration Circulation Temperature  A. B. C. D. E.  that  upon  air,  Factors  Chemical  pools,  spa  the  T h e s e p a r a m e t e r s , as  w h i c h a f f e c t p o o l and  A. B. C.  III.  bearing  Physical  supply,  indicators  hardness,  used.  chlorine  water  these pathogens.  objectives,  are  have  of  t e m p e r a t u r e s of  alkalinity,  (usually  II.  many of  metals  water,  I.  higher  quality  total  source  "105 levels,  ranges." trained  1 0  and  reasonably  study  has  failed and  well  However, i t i s conscientious  for  indicated  t o meet 106  and  of  state these  generally individual  24  can  fairly  easily  maintain  "Pseudomonas b a c t e r i a environments violated,  if  probably  proper  or u n l e s s the  make i t d i f f i c u l t T h i s has  proper  would n o t  inherent  proven  be  maintenance  to maintain  not  water  so  a  in pools.  problem  in  requirements  characteristics  those  for  quality  of  requirements."  pool  are  not  the  pool  1 1  spas.  Due t o t h e h i g h t e m p e r a t u r e s m a i n t a i n e d i n w h i r l p o o l s , and t h e f r e q u e n t h i g h i n t e n s i t y a c t i v a t i o n of t h e w a t e r , p r o p e r free d i s i n f e c t a n t residuals are difficult to maintain. Frequent monitoring of t h e s e p o o l s t h r o u g h o u t t h e day i s necessary to a s s u r e that the proper f r e e disinfectant and pH i s maintained. Since frequent monitoring i s d i f f i c u l t to achieve, the potential for Pseudomonas and other pathogenic contamination i s always present. I t i s our contention that heated whirlpools will continue to be marginal o p e r a t i o n s from t h e s t a n d p o i n t o f swimmer h e a l t h , and p e r h a p s p u b l i c h e a l t h a g e n c i e s should run exhaustive water q u a l i t y t e s t s on t h e s e t y p e s of p o o l s t o d e t e r m i n e i f t h e y can c o n t i n u e t o be a l l o w e d a s s a f e t o u s e . 1 2  It  was  first  thought  management would not "track  record" with  that  spas  could  be  large  would  treated  numbers  be  has  1.  of t h e s e  an  2.  "baby p o o l s " . proved  important  water  The  this variable  results  Loads  a  I t was  There  conditions  quality  had  emergence  false.  of is  of  good  thought  that  they  spas  in  a lack  of  spas  as  a  differences: rapid  t h e c o n c e n t r a t i o n of d i s s o l v e d  Heavy B a t h e r  have  e x t e n s i o n of p o o l s , and  H i g h Water T e m p e r a t u r e s c a u s e  increase  spa water  swimming p o o l w a t e r q u a l i t y .  s i m p l y be as  that  a p r o b l e m , b e c a u s e we  e x p e r i e n c e w i t h the h i g h l y result  by most p e o p l e  (a f u n c t i o n  of  e v a p o r a t i o n of water  and  solids. spas'  s m a l l s i z e ) and  i n h i g h c o n c e n t r a t i o n s of body o i l s ,  skin  hot  flakes,  25  and  other organic  3.  Aeration  Effects,  heat,  rapidly  turn  accelerates  possibility quality the  wastes  resulting  of  chlorine  First,  may  also  velocity  of water,  which  in  on  local  air  i n t r o d u c e more d i r t  into  in  in predicting  the  The p r i n c i p a l  conditions  variations  and o r g a n i c  numbers  and  spa f a c t o r s  present  of  that  quality affect  stem spa  in  spa  o f t h e spa w a t e r , i n t h e spa  individuals  water  from water  a r e f o u n d i n (a) t h e p h y s i c a l  materials  kinds  water  (b) t h e p r e s e n c e water,  using  and  spas.  c o n d i t i o n s c a n v a r y f r o m spa t o s p a o r w i t h one s p a o v e r variability  for  quality?  difficulties  biological  High  and  pH, a n d i n c r e a s e s t h e  Depending  do t h e s e u n i q u e  chemical c h a r a c t e r i s t i c s  the  affects  foaming.  aeration  o f water  t h e wide v a r i a t i o n  of  increased  1 3  the maintenance  and  loss,  excessive  What d i f f i c u l t i e s  quality.  from  change t h e c h e m i c a l c h a r a c t e r  conditions,  water.  which contaminate the water.  quality  (c) These  time.  i s c a u s e d by f o u r  main  i n t h e numbers and k i n d s o f s p a b a t h e r s and  the  factors: 1.  Variations consequent organic  2.  material  in  introduced  t h e amount  of exposure  Variations  from t i m e t o t i m e  organisms  exist  being 3.  differences  carried  Differences  in  into in  the  amount  of b i o l o g i c a l  and  differences  in  t o t h e spa a n d  they b r i n g  a given  to disease  organisms.  i n the e x t e n t t o which local  environment,  disease  apart  from  s p a s by b a t h e r s .  local  water  supplies  and  the  physical  26  4.  environment  (i.e., a i r , sunlight, etc.)  Variations  caused  and of  chemical  factors  water q u a l i t y  factors  because  of  l o a d s , and a e r a t i o n  The  indoor  illustrates varying  the  load",  water o v e r - each the  the  level, etc.)  dramatically  water  and  The  spa of  at  t o each  temperature,  the  bather  pool  UBC  loads  contains  d e f i n e d as t h e number would by c o m p a r i s o n  person  of these  heavy  bather  Aquatic  Center  in creating  highly  approximately  of p e r s o n s be a s  per  800,000 gallons.  volume  of  follows:  i n t h e spa would be e q u i v a l e n t t o 400 p e o p l e i n  pool.  equal  10  people  in  at  one  water  time.  (and  pool users suggested are  rather  i s not a l l o w e d t o But  such  would  be  a  and  have bather  organic  tremendous  F o r h e a l t h and s a f e t y  by o u r i l l u s t r a t i o n .  t h e more  by l o o k i n g important  Yet  that  many  load  were  materials and  r e a s o n s , we  probably c o u l d not d e a l with)  deceived  than  if  of the b i o l o g i c a l  chemistry  maintenance d i f f i c u l t . tolerate  i n the pool!  the pool  the e f f e c t s  the  perceptions  i n t h e s p a (a common o c c u r r e n c e ) w o u l d be  t o 4,000 p e o p l e  regulation,  permitted,  people,  high  operation  i n spas.  effects  time,  - thus,  not  respond  treatment,  (U.S.) o f water and t h e s p a h a s r o u g h l y 2,000  "Bather  upon  may  pool  conditions.  gallons  people  (e.g., chemical  spa f i l t r a t i o n e q u i p m e n t , water  Spa  By  by spa o p e r a t o r m a n i p u l a t i o n o f p h y s i c a l  make would  t h e number o f  with  spas,  our  a t t h e a b s o l u t e number o f proportion  of  users  to  27  the  volume o f  effect of  of  bather  complex  can  or  significance  upon spa  is highly  but  "marginal" user  and  the  not  number of  portion  fluctuate  are  of  greatly.  only  relatively  small  of  might  far  number of  spa  conditions.  lead  to  pools  and  quality  even under  (ranges  fluctuations  occur  immersed  in  spa  of  Casual,  by  to  an  water the  each  user,  water  factors  all  and  by  or  use  limits  imposed  broad,  are  difficult,  i n the  tolerances  lead  the  careless  significant errors  which  pools. between water q u a l i t y readily predictable in order  parameters, s o l i d s , and  such  stable  and  as  disinfectant be  pH  conditions requires  to maintain  and  There  total  levels, and  is  normal s t a n d a r d s ) ,  the  hypochlorous  acid  are also  evidence  chlorine  meet  "safe"  pH,  non-linear  i n water q u a l i t y .  seemingly  which  spa  Calculating  i n the  c h a n g e s , w h i c h may  deterioration  shows,  to develop a r t i f i c i a l  observation  dramatic  rapid  in  i s not  total dissolved  show t h a t  can  ratio  parameters  volume of  combination  water.  use  users  Water  to  bodies  relationship  monitoring  subject  and  important the  becomes e x t r e m e l y  tight  less noticeable the  alkalinity,  the  volume of  factors  Second,  close  by  small  spent  attempts  that  example  parameters.  possible  but  and  above  i n the  time  users'  The  infinite,  division be  users,  the  complicated  and  the  the  i s the  water q u a l i t y  c h e m i c a l water b a l a n c e a l s o  because the  this  variable.  spa  as  have tremendous e f f e c t on  of  water q u a l i t y  amongst  in themselves,  proper  in  load  relationships  additional  to  The  u s e r s t o water q u a l i t y The  is  water.  that  ranges extreme  (i.e.  the  28  bactericide and  a g e n t ) c u r v e and t h a t  pH l e v e l s  quality.  effects  parameters  Further,  of d i f f e r e n t  temperatures  people  bring  deodorants, etc.) into "foreign"  will  maintaining  individuals  c a n s o m e t i m e s be more  Spa  cannot  for  materials  be r e a d i l y cause  many the  differ  parameter  conditions,  which  p r o b l e m was  from  related  Therefore,  quality  involved and  correlations  parameters.  parameters  users,  be  water  It  of  of  respect  to  exceeded  procedures are  and  water is  spas with  an  similar  t o m a i n t a i n and g e n e r a l  water  skin  cannot  revealed  that  the  particles  in  the  often  suntanned.  be s i m p l y  o f spa u s e r s  difficult for  conditions.  to  define  purposes  of  If incorrect  possible  to  In  It  spa,  u s e r s who a l s o  needed  and  users  of t h i s  users.  effects  i t becomes c o n s i d e r a b l y more d i f f i c u l t  management  bodily  one  practices  the  (e.g. d i r t ,  of d i f f e r e n t  investigation  users  oils.  to i n d i v i d u a l .  two s e p a r a t e  number  is  quality  body  of  illustration  between number  t o meet c e r t a i n  made w i t h  to  t o h i g h amounts o f  management  of  amounts  individual  An  An e x t e n s i v e  "average" user or group  are  desired  materials  when t h e e f f e c t s  from a group of f r e q u e n t  theoretical  The  l e v e l s were d i f f i c u l t  was p o o r .  secretion  thresholds  management,  disinfectant  water  chlorine  upon t h e water  "foreign''  spa.  predicted  incident  quality  the  of  s i g n i f i c a n t t h a n t h e number o f  increase  conditions drastically altered. actual  monitoring  1 4  The  users.  i s essential  closer  restore  of  1 5  b a s e d on  and  water  what  i s an  adjusting judgements different  t o d e t e r m i n e what water  quality.  29  Thus,  it  is  monitoring  critically  systems  " s u r p r i s e s " may Third,  spa  corrective hindered  be  are  water  the  for  a  Normally  r e d u c e t h e pH  little  problems  can  room  with  chlorine  or  We  safety  spa water 1.  are  spa  acid  can  hence  equipment.  bromine  (e.g.,  for lowering  of a c i d ) .  may  We  lower  affecting  With but  prone  margins.  build  spas,  to  for  to  tight  error,  and  attempts  to  water  quality  know, f o r i n s t a n c e t h a t pH  too  rapidly  bathers, high  In each case,  under  disinfection  be h a z a r d o u s i n t h e spa  the  pH)  they are a l s o  Thus,  Extraordinarily  levels  of  itself  or i n  must  ask;  we  "disease"?  summarize the t h r e e main d i f f i c u l t i e s  of  maintaining  quality:  Wide v a r i a t i o n s f r o m l o c a t i o n time  chemistry  of c h l o r i n e ) o r  necessary,  c r e a t e worse problems.  " c u r e " be w o r s e t h a n can  that  chemicals  (as i n t h e c a s e  waste water d i s c h a r g e s elsewhere. the  pools,  e s p e c i a l l y over-compensate,  conditions,  c a p a b i l i t y and  fact  the  i t s consequential  hydrochloric acid  ( i n the case  for  e x c e s s i v e a d d i t i o n of certain  that  by  water  t o a d m i n i s t e r a c c u r a t e l y , more  compensate, and  can  the  o f w a t e r and  t o l e r a n c e s make g r a d u a l a d j u s t m e n t s  leave  so  a d m i n i s t e r e d t o t h e p o o l so a s t o  "bank" o f d i s i n f e c t i o n  difficult  effective  operations  i s complicated  volume  f o r d i s i n f e c t i o n and  gradually  spa  adjusting  small  are metered or otherwise up  in  quality  r a p i d , dynamic n a t u r e . chlorine  used  t h a t f r e q u e n t and  avoided.  measures by  important  - which  create  t o l o c a t i o n and  problems  in  from time  maintaining  to  acceptable  30  2.  water q u a l i t y  conditions.  Non-linearity  between water q u a l i t y  of  u s e r s - which c r e a t e s  water q u a l i t y 3.  Potential the  problem  t r e n d s and p r e s c r i b i n g  dangers of c o r r e c t i v e  possibility  of  the  remedial  spa  measures.  - which  of over-compensating t o b u i l d  e x t e n s i v e human  not  be  precludes  a wide m a r g i n  substantially  or mechanical monitoring.  i s an e x p e n s i v e a n d / o r d i f f i c u l t been  conclusion task,  predicting  safety.  monitoring has  of  measures  These p r o b l e m s c o u l d c o n c e i v a b l y by v e r y  p a r a m e t e r s and number  widely  considered  i s inescapable  particularly  that  for  reduced  However, s u c h  p r o c e s s which  so f a r  worthwhile or f e a s i b l e .  spa  management  untrained  or  is  a  The  difficult  poorly-trained  spa  operators.  Controlling The c o n c e r n w i t h of  the  associated  pathogenic with  individuals  only  because  normal action  Pathogens*  problem r e l a t e s  organisms  which  spas or a r e p o t e n t i a l  spas,  discussed  this  Specific  of  early,  "debris".  are p a r t i c u l a r l y the  temperature  already  release protective  susceptible  * N o t e : See A p p e n d i x A f o r pathogenic hazards.  a  and  more  to  and w a t e r c h e m i s t r y is  dead  be In  t o pathogens, not  stripped  o f p o r e s and p o u n d i n g  oils  appear  recognizable hazards.  b u t a l s o b e c a u s e t h e body Dilation  to the i d e n t i f i c a t i o n  skin.  comprehensive  from This  factors of i t s  whirlpool has  discussion  two  of  31  effects;  first,  and  second,  the  body).  i t p r o v i d e s an The  the organisms then  occur  pathogenic —  i t provides a n u t r i t i o n a l e n t r y pathway  body, upon c o o l i n g  i n the on  skin  the  pores.  body.  Festering  from  "swimmer's  in  identified use.  days.  and  headache, breasts.  from  1 7  the  These  characteristics  i s disagreement Pseudomonas.  over  is this  trap  irritation  may  minor  typical  commonly bacteria  resulting  three ear  lymphadenopathy, are  health  called been  from  spa  to  pain,  well-agreed  the  has  after seven  weakness,  and  painful  upon,  o t h e r a s p e c t s , s u c h as o t h e r  From one  of  infections  i n 8 t o 48 h o u r s  in  itching,  auxiliary  can  so f a r been g i v e n  rashes  disappear  include:  not  is fairly  what  d i s e a s e appear  usually  sore throat,  has  lakes,  s o u r c e of s k i n  of  Symptoms  1 6  and  (but  spas.  causing  pools  a s a major  Outbreaks  exposure  there  ear"  as  organisms  spa u s e ,  or  r a s h e s and  Pseudomonas a e r u g i n o s a - T h i s o r g a n i s m Known  for  the s k i n  down a f t e r  to skin  common p r o b l e m  most a t t e n t i o n .  into  T h i s sequence  problems r e l a t i n g  a relatively  source  but  hazards  official:  If these were the only potential health problems, we w o u l d n ' t be as c o n c e r n e d a b o u t i t as we a r e . But t h e r e a r e o t h e r p o t e n t i a l problems i t can c a u s e . If i t becomes a systemic infection i n v o l v i n g the b l o o d stream, then t h e r e i s a f a i r l y h i g h p r o b a b i l i t y of m o r t a l i t y . S y s t e m i c Pseudomonas i n f e c t i o n s u s u a l l y o c c u r i n people who have p r i m a r y h e a l t h impairment, such as burn v i c t i m s , o r p e o p l e who have g u n s h o t o r p u n c t u r e wounds. Arthritic individuals are s u s c e p t i b l e t o o , because they a r e u s u a l l y p u t on i m m u n o - s u p p r e s s a n t d r u g s , and a l o t of p h y s i c i a n s a r e p r e s c r i b i n g spa p o o l s as t h e r a p y f o r a r t h r i t i s . 1 8  The  mortality  rate  referred  t o i s e s t i m a t e d a t 40  percent  32  i f Pseudomonas enters the b l o o d s t r e a m .  However, t h i s p o s i t i v e  19  statement about the danger of death from Pseudomonas i n a spa i s disputed and  by an industry  that  say."  a  more  kill  other  the  controversial  chlorine  questions  by  for  does  chlorination  chemicals  can  growth.  kill  Studies  21  Pseudomonas,  significantly  c h l o r i n e as a b a c t e r i c i d e . that  coating  Pseudomonas  around i t s e l f  material  which  2 2  itself,  Another  Compounding  attachment.  relates  linked  to  and  other  the  problem  of  i s the  opening  in  a  Hence, wood tubs or p o o r l y permit  Pseudomonas  the  associative  factors  to  the presence  of  the  of  Recreational  Program (U.S. Environmental  Protection  organism  is  more  to c e r t a i n i n d i v i d u a l s and other environments,  that there i s no c o n c l u s i v e between  densities  of i n f e c t i o n s .  is continuing,  other  effectiveness  Research by members of the  Criteria  Agency), suggests that  incidence  many  material, the  indicate  rendering c h l o r i n e l e s s v i a b l e as a d i s i n f e c t a n t .  Quality  relationship  to  that  i f i t can f i n d some porous  Pseudomonas with spas.  and  the  has the c a p a b i l i t y of producing a slime  allows  question  directly  seem  but  influence  maintained spas with s c a l e b u i l d - u p may attach  surround  and a l s o the chemical  f a c t o r s , such as pH, temperature, organic  Water  "supposition"  Among them i s the q u e s t i o n of the a b i l i t y  organism  parameters f a v o r a b l e  fact  it  accurate answer would be " I t ' s impossible t o  Pseudomonas b a c t e r i a .  that  calls  2 0  A number of  to  researcher who  2 3  evidence of a cause of  Additional  the  bacteria  research  on  and  effect  i n water and Pseudomonas  but at the present, there are s t i l l many s e r i o u s ,  33  unanswered that  questions.  D e s p i t e the a m b i g u i t y ,  Pseudomonas does p o s e  u s e r s -sure.  f o r what r e a s o n s As  noted  by  some measure o f h e a l t h and  one  health  official;  i n scummy w a t e r n e c e s s a r i l y .  I've  seen  The in  largest  March,  including North other  was  1981,  state  have a l s o  and  local  in public  75  York,  and  Oregon,  s p a s , even  i s , in fact, currently  world's  leading  Conn, has chlorine and  done l a b o r a t o r y conducted  was  chlorine  significant that  e x p e r t s on  have  organism  Atlanta,  may  Pseudomonas.  states,  Alabama,  and  Both  r e s u l t s o f t h e two  constantly  maintained  free  director  o f one  spa w a t e r q u a l i t y management;  "It  outbreaks  poor  of  is or  tests  l e v e l s are  t h e e s t a b l i s h m e n t o f Pseudomonas i n t h e tests underscores  o f New  the  no  Haven, showed  conditions The  most to  be  important  to  spa w a t e r .  the n e c e s s i t y my  opinion attempt  two  Decatur,  t e s t s appear  prevent  the  industry,  studies.  consistent  this  of  I n c . of  Pseudomonas, b u t  chlorine  one  Corp.  and  careful  work on  by  Bio-Lab,  testing.  Many  outbreaks.  deserve  From t h e  26  t e s t i n g and O l i n  in-field  because  Georgia  various  Special  l e v e l s d i f f e r e d between t h e two  occur  tubs  24  being conducted  e f f e c t i v e against  of the  have  i s o l a t e d Pseudomonas  study.  c o m p a n i e s have run t e s t i n g .  G e o r g i a has  not  don't  i f t h e y e x p e r i e n c e d no  further  problem  chemical  are  the c l e a n e s t  Minnesota,  officials  is  f o r spa  reported s i g n i f i c a n t incidents.  health  perhaps  of  Other  2 5  we  "You  occurred in  people.  Thus, t h i s p a r t i c u l a r b a c t e r i a l monitoring  One  Pseudomonas."  to date  involving  C o l o r a d o , New  Carolina  cultures  loaded with  outbreak  hazard  under what c o n d i t i o n s ,  outbreaks ever  the consensus  The  of  proper  that  these  to maintain  34  sanitized  water."  Legionella  pneumophilia  Disease" as  2 7  - T h i s organism  responsible  year,  reported been  for  public  the  deaths  isolation  health  of  indicated  that  contacting  appears  people  in further  and  u s i n g spas  have  i s good  Legionella  per year.  found  lakes,  in  experts  hospitals."  "there  do  10  not  Far  3 0  Pseudomonas,  are  B e i n g an  streams, less  and  causation-association  tubs.  research times  think  evidence  t o be a u b i q u i t o u s w a t e r o r g a n i s m . note;  Legion In  Vermont This  2 8  the  has  i n New York has the  Branch  chance  of  i s actively  this.  epidemiological  cautionary  American  Montpelier,  The CDC L e g i o n e l l a  2 9  work on  some  in  i n hot  others,  the d i s e a s e .  However, incident  by  many  in Philadelphia.  officials  o f L. p n e u m o p h i l i a  substantiated  involved  "Legionnaire's  -- a d i s e a s e d i s c o v e r e d s e v e r a l y e a r s ago a n d d i a g n o s e d  c o n v e n t i o n e e r s who s t a y e d a t one h o t e l past  produces  is  earth,  known  currently,  the  because  the  and even  focus  Legionella  instances  organism,  about  Vermont  The CDC a f f i r m s  50,000-70,000  aquatic  moist  that  this is  i t  is  this of also  shower heads i n disease on  than  determining  factors.  Although the geographic locations and temporal r e l a t i o n s h i p s of these f i n d i n g s a r e of i n t e r e s t and suggest that e n v i r o n m e n t a l i s o l a t e s may be somehow a s s o c i a t e d w i t h t h e o u t b r e a k s , t h e y must be i n t e r p r e t e d cautiously. This is b e c a u s e i n v e s t i g a t o r s have r e c o v e r e d LDB from l o c a t i o n s i n w h i c h c a s e s had r e c e n t l y occurred, but treatment on r e m o v a l o f t h e p u t a t i v e e n v i r o n m e n t a l s o u r c e o f LDB d i d n o t prevent the continued occurrence o f human i n f e c t i o n and disease. 3 1  35  Thus i t i s h i g h l y with  the d i s e a s e .  requires spas  us t o c o n s i d e r i t a p o s s i b l e  Fever  -  of a l i n k  derived  from  symptoms.  it  case  use  Hazards  and  part  an  open this  available  because  with as  It  3 2  is  different  reactions,  which,  complicates  source  and l i t t l e as  possible  spas.  but i t produces  - Traditional  of s t r e p  has  detail  on  this  c a n be s a i d  about  another  public  i n spas, they  to  be  also  water q u a l i t y figure  Some  health  i s rarely  Although  ingested  a concern.  officials  or  have  maintain  entry  In r e a s o n a b l y  careful  H e r p e s and o t h e r  social  as p o s s i b l e hazards, such d i s e a s e s a r e  physical  hazards  i n s p a s , y e t i t s h o u l d be n o t e d  b u t f o r t h e most  not  they a r e not c o n s i d e r e d hazards  require  concerns of  as p o s s i b l e  health  wound t o be a p r o b l e m .  have been r a i s e d  dismissed.  contact  and  i n any s i g n i f i c a n t  Streptococci  the i s o l a t i o n  of spas,  diseases  discovered  definitely  i t s possibility  strep v i r t u a l l y  through  health hazard  influenza-type  s p a s , b u t o n l y i n a m i n o r way.  that  of L e g i o n e l l a  i n t h e same d e g r e e  disease  organism,  spas,  Information  Pathogenic  reported  public  association  spas.  Staphylococci of  nature  recently  this  suffer  of  t o note  hazard with  Other  between  i s not c u r r e n t l y  except  has  the L e g i o n e l l a  identification. disease  CDC  Individuals  our  in  environment.  The  evidence  o u t spas  against i t s occurrence  i n any o t h e r a q u a t i c  for  to single  Regardless, the s e r i o u s  and t o p r o t e c t  Pontiac  unfair  impossible related  c o n t a c t , which c l e a r l y  to  t o spas  c o u l d take  36  place  anywhere.  Lastly,  viruses  s u c h a s p o l i o and  hepatitis  l i k e w i s e d i s m i s s e d as spa c o n c e r n s .  Viruses  ingestion  t o our o v e r a l l  and  These public  other  ignored,  water  bacteria  pathogens  need  cannot  (Legionella  feel  be v i e w e d  and  Dept.  this  gathering." statement will  3 4  of  they  be  strep.  follow  normal  as p r e v e n t i o n from  b i o c h e m i s t , "mutation previously  unknown  example) can a p p e a r ,  our c u r r e n t  level  so  of knowledge.  we We  h e a l t h h a z a r d s o f s p a s can b e s t  Public  by  Health.  an To  s p a s s h o u l d be c o n s i d e r e d a s Those  could  who  of  r e a s o n t o remain condemning  from  paraphrase  his  places  alert  to  of  (or l a c k  of), this  of  facilities Additional  s h o u l d h e l p us t o make this  potential  specific  s p r e a d them area  h a z a r d s t o some e x t e n t . hazards  where  public  Spas i n p u b l i c  recognition  any  any  knowledge  of sense.  official  d i s e a s e s can  in  our  these p o t e n t i a l but  have  happen  increase health  decisions,  necessarily  3 3  from a s t a t e m e n t  Regardless  i n f o r m a t i o n about  provides  New,  makes a good d e a l  always  better  time."  b e i n g a prime  summarized  congregate. and  to  elsewhere one  the b a c t e r i o l o g i c a l  comments: " P o o l s and  there  can  special  guard.  Illinois  people  have  a s n o t e d by  too secure about  Perhaps  does  practiced  the  as  i n t h e c a s e s o f s t a p h and  management  Further,  neither  require  environment.  be c h a r a c t e r i z e d  t o s p a s , but  especially  occurs a l l  t o be on  the  pathogens  procedures  these pathogens.  cannot  relates  quality  sanitation  of  presence  health hazards r e l a t e d  totally Spa  their  generally  are  facility  broad hazards  statement without  prematurely or  37  without  just  accepted yet  cause.  evidence  aware a p p r o a c h  Public  Until  we  develop  of any  of  the pathogenic  might  be  our  health protection  clear  documentation hazards,  best at t h i s  and  a cautious  time.  against pathogenic  hazards  would  involve: 1.  Development guidelines in  2.  of  spa w a t e r q u a l i t y  which e l i m i n a t e  Spa  operator  understanding and  of w a t e r q u a l i t y Spa  user  of u n s a f e  adherence of  Hyperthermia  Other  is  and  safety  to the  quality  degradation  standards. pathogenic  hazards,  conditions,  and  avoidance  i n regard to both  the  potential  spa  management  factors  biological  procedures  for  s h o u l d be c o n s i d e r e d a p a r t  concerns.  The  which can  of  temperature  management p r e c a u t i o n s t o p r o t e c t  certain  o c c u r s when d e e p body  may  first  of  these  c r e a t e problems of  o p e r a t o r s must be aware t h a t  characteristic  Hyperthermia  water  preventing  potential  h i g h water t e m p e r a t u r e Spa  for  spa  Hazards  h e a l t h and  hyperthermia. quality  organisms  hazards.  t h e c h e m i c a l and  factors  pathogenic  environments.  hazards  the  of  water q u a l i t y  R e s o l u t i o n of u n c e r t a i n t i e s  reducing  from  and  o f poor  spa  pathogenic  2.  procedures  understanding  recognition  4.  or c o n t r o l  and  spas.  characteristics  3.  management s t a n d a r d s  the  spa  require  u s e r s from  temperature  water special  harm.  is  higher  38  than the t h e r m o r e g u l a t o r y " s e t p o i n t " . The human t o l e r a n c e i s w i t h i n ±4° o f t h e normal 9 8 . 6 ° F . In g e n e r a l women are l e s s h e a t t o l e r a n t t h a n men and s m a l l p e r s o n s o f e i t h e r sex are at a d i s a d v a n t a g e when e x p o s e d t o t h e r m a l e x t r e m e s . Heat (hyperthermia) can cause drowsiness, lethargy, vasodilation, cardiodepression, decreased myocardial contractibility, hypoglycemia, hypertension, respiratory depression, decreased cerebral blood flow and altered cerebral tissue compliance. 3 5  The  potential  relatively 104°F on  h e a l t h hazards  well-understood,  knowledge  that  the  itself  at  temperatures  that  at  s h o u l d be  one  time,  h a z a r d , and them.  observed.  and  the  spa  problem  also  u s a g e can  any  length  of use  medical  problems  (e.g.,  high  circulatory  the  of  amounts,  is  likely  experimentation Medicine  also  precautions, minutes  alcohol  at  the  indicates  to  is  that  endanger  in a  more  to  may  be  these  spa,  subject unsafe  cases  b e i n g unaware o f  dangerous  for  by  people, people  elderly  blood  other  be  etc.), drugs,  dangerous.  pregnant  of  and  is  their  "average"  even  must  developing  under  i n moderate  Research  3 6  102°F  with  diabetes, anyone  Washington  women  g r e a t e r than the  the  pressure,  impairments, or  for  based  further  15 m i n u t e s are  of  exist.  University  as t e m p e r a t u r e s can  users  be  but  cardiovascular,  levels  of  person,  influence  10 t o  It  Some p e o p l e  acceptable  p e r s o n a l h e a l t h d e f e c t s can  Prolonged  of  is  its ability  t h e g e n e r a l recommended g u i d e l i n e s  Determining  difficult,  to lose  104°.  are  maximum l i m i t  This guideline  above  a maximum l i m i t  temperatures  suggested  t h e human body b e g i n s  recommended  to  and  high  (40°C) i s commonly a c c e p t e d now.  cool  to  from  School  take  and of  special  f o r more t h a n embryo  15 or  39  fetus.  Establishing  3 7  what t e m p e r a t u r e s ,  and  but a l s o ambiguous,  The medical  work  is  heart  The  of  rates  indicators tests  vaginal  and  As  helpful  in  to  information  the  can  be  Brown  certainly ability  to  withstand  recommended t o c o n s u l t  these  temperatures.  operational  or Such  standards.  of Washington  used  but  these are  purposes.  Another  the kinds felt  the  CPSC,  in  establishing  practical on humans. which  individuals. this  single and  and  dizzy  As a r e s u l t , leave There area  type  of  better is  our  other considerations)  open  we  of  the  the  high  temperatures  have t o  hyperthermia  is really  have  physician  this  drawback  who  their  of  b e f o r e an a c c i d e n t o c c u r r e d . of  improve  safety  pressure  indicators,  largest  ranges  susceptible  individuals to  as  aid  The  3 8  to e t h i c a l ,  done  water  and  c a s e s where p e o p l e have  extensive testing  that  important,  One  blood  i n f o r m a t i o n about  of  greatly  and  in  absence  to  for  spas, at  of W a s h i n g t o n  remain.  operational  Victoria  estimates  i s an  f o r normal  (due  hazards  spa  i n s p a s , but got o u t  would  still  changes  temperatures  inability  accept  use  health  women a t t h e U n i v e r s i t y  preventative measures.  conduct  developing  in devising  "near-misses" —  s u g g e s t e d by  may  the U n i v e r s i t y  shortcomings  be h e l p f u l  rectal  is  lethargic  and  for  relation  impractical  numbers o f  CPSC  i n f o r m a t i o n about  could  shortcoming  or  the  on p r e g n a n t  obviously  f o r what l e n g t h o f t i m e  However,  the l a c k  f o r who  matter.  of  school i s  guidelines.  other g u i d e l i n e s  n o t much  knowledge,  slightest  beforehand.  but  doubt  of  their  are  strongly  40  3.  Visual  Hazards  This  problem  from Poor Water area  hyperthermia concerns, consideration factor clarity  can  dissolved of  the  sized  it  mere  affect  be  not  but  beyond  which can  is  water  quality  aesthetic  reasons.  First,  i t is a  to  considerably.  A l l of these a f f e c t  build  up  in  f o a m i n g , and  mentioned  water,  b r o m i n e ) becomes s u r r o u n d e d by attack  and  kill  dissolved general  bacteria  solids  t h e maximum l e v e l  achieving effects levels  in  a  spa."  clarity  of d i s s o l v e d  Second, obscuring  clarity  prevent  from n o t i c i n g  Also,  in  of  may  child.  solids  (whether c h l o r i n e s o l i d s and  high  level  or  cannot  of  total  i s y e t no a g r e e d upon of about  1,500  ppm  that  should  be  important  to  solids  differently,  but  their  from  high  solids.  objects that us  dissolved  parameters  disinfection  presence be  to  a level  other  also  c a n be as e x t e n s i v e a s t h e e f f e c t s  p o o r water  the  of the d i s i n f e c t a n t  There  dissolved  The  3 9  limit  on c l a r i t y  pH.  A  i t appears that of t o t a l  a  these d i s s o l v e d algae.  abundance  be  sanitizer  also affects  s t a n d a r d , but  tolerated  and  of  Inadequately  can  "as t h e t o t a l  the  an  earlier.  systems  the a b i l i t y  F o r example,  the  Lack  a number o f p a r a m e t e r s s u c h as  excessive  substances  work e f f e c t i v e l y .  as p a t h o g e n i c and  deserves  or p o o r l y m a i n t a i n e d f i l t r a t i o n  factor.  is  serious  disinfection  h i g h pH,  "foreign"  as still  attributed  solids,  Clarity  u s e r s and  a  c a n be an o b s e r v a t i o n a l  broken spa.  glass  or  Conceivably,  a drowning  other it  problem dangerous  could  person, e s p e c i a l l y  o p e r a t o r s might  a  also small  be unaware o f m i s s i n g  or  41  b r o k e n g r a t e s or o u t l e t s  -- c o n d i t i o n s w h i c h e n g i n e e r i n g s t u d i e s  show i n c r e a s e t h e c h a n c e of h a i r The  i n s t a n c e s of water c l a r i t y  seem t o be q u i t e h i g h , m o s t l y this  is  and,  easily  Water c l a r i t y after  water  problems  a time,  through  solution  thoroughly,  is  and  conscientious Thus,  difficult  i n spas  and  refill  p r o b l e m must be  i t i s not relate  the  with  varying  spas Since  identify.  to bather  treatments.  load,  The  completely,  water. with  spa  for  basis.  clean  This  each  intervals  to accomplish  to  impossible to c l e a r  unit  on a u n i f o r m  addressed  public  difficult  primarily  fresh  recommending  establish  with  4 0  i t i s frequently reported  chemical  drain  maintenance,  to  problems  i t becomes v i r t u a l l y  to  guidelines  entrapment.  in heavily-used f a c i l i t i e s .  hazards,  filtration  then  body  n o t i c e d as a p r o b l e m ,  u n l i k e pathogenic  and  or  it  operation.  draining  spa  only  requires  Nevertheless,  proper  the  water  are this  quality  management.  4.  Drowning Hazards R e l a t e d t o the A final  systems  in  necessary  h e a l t h and spas.  safety hazard  For  in order  sufficiently  sized  than  r e q u i r e d without  by  these  pumps  body t o w a r d d r a i n leads  to  to produce  tend  to p u l l  flow  hair  relates  or  to  the  aeration  t h e water  booster  pumps  pressure must  be  r a t e s w h i c h a r e much g r e a t e r  aeration. people  s u r f a c e s or o t h e r  possible  A e r a t i o n Systems  to generate  for aeration, circulation  normally  Spa  spa  Velocities  generated  or p o r t i o n s of a water  outlets.  or body e n t r a p m e n t whereby  person's 4 1  This  individuals  42  cannot  r e l e a s e themselves  underwater drown.  (where o u t l e t s  I f an  prevents  from  individual's  leaving  possibility  are  the  Factors  such  as:  i s not  and  help  danger  (a)  outlets  for  outlet  grate  entrapment the  spa  effect is  special  all  occurring.  water on  covers  can  Thus,  quality  an  or b r o k e n  important  outlet  especially  relevant  under  Although  (note:  spa  the  there (c)  of  of  spa  victims  of  has  an  Filtration i n regard  d e t e c t i o n of entrapment  entrapment are h i g h e s t  broken  aware t h a t  circulation  management  of  are  possibility  o p e r a t o r s must be  t o v e r y young c h i l d r e n ;  the a e r a t i o n system it  is  important  spa management p o l i c y , controls  as  water  the p r i n c i p a l  examination  s e r v e as a b a c k g r o u n d  i s not  to  improper (this  is  t h e CPSC's r e p o r t s  i n t h e age  a  "pure"  to deal with  i t i s p a r t of quality.  the  bracket  Along  of  be  water  of  quality  simultaneously total  with  t h e r a p e u t i c b e n e f i t s of  c o n s i d e r a t i o n cannot  The  circulation  g r a t e c o v e r s ) ; and  allows easier  and  the  3 years o l d ) .  consideration,  its  designed  increase  aspect  grates  show d r o w n i n g s from  produces  unavailable,  outlets  characteristic  entrapment, as water c l a r i t y  which  is  may  entrapment  s a f e t y measures f o r p r e v e n t i n g e n t r a p m e n t .  also  children  submerged but  Improperly  (b) swimming p o o l - d e s i g n e d with  occurs  arises.  systems;  spas  I f entrapment  g e n e r a l l y l o c a t e d ) the person  head  spa  of h y p e r t h e r m i a  the o u t l e t .  spa  heat, spas,  in  system aeration  and  thus  hazard  areas  ignored.  the  f o u r main p o t e n t i a l  for identifying  the  specific  risks  and  43  uncertainties  associated with  the d i f f i c u l t i e s  Identification Potential In  Specific  within  base  is either  those  of  "risk"  situations  synthesized  reasonable  that are  to  reported  accumulating would be record spas." spa user  of 2  about  statistical  The  Yet,  to date,  consistent  validity  by  spas. or  the  most  they or  of the  time.  definition.  would  currently These a r e :  apply  the  find  very  it  has  been  that  it  not  probability  might  appear  hazards,  risk.  But  such  there  both  candidate  for  b a s i s i n the not  as is  number of c a s e s ,  U.S.  accumulated  a  a s s o c i a t e d with  on a c t u a l  probability  There  to  data  illnesses  data a v a i l a b l e  possible  i f we  logical  have  were  available  pathogenic of  areas  The  say  instance,  deaths  a r e a s where we  w i t h our  with  Pseudomonas from  at t h i s  be  a b o v e , we  i n f o r m a t i o n on a n a t i o n a l  infected  hazard  may  the a c t u a l  Hence, an a s s e s s m e n t  becoming  policies.  hazards  However,  i n the c a t e g o r y  F u r t h e r , t h e r e i s no  potential  stated  certain  disease-related  users.  risk.  For  unreported.  t h e CDC.  it  could reasonably  designate  this  spa  i n many a r e a s  known.  information and  of  of r i s k s  we  Pseudomonas a e r u g i n o s a , inadequate  areas,  as  insufficient  so  distributions  understanding  U n c e r t a i n t i e s Within  potential  situations  definition  actual  f o r then  spa management  R i s k s and  sections,  specific  few  and  Areas  preceding  itemize strict  of  and  use  faced in devising  Hazard  identified,  spa  spa use  numbers of of  a  spa  does not  have  appear  t o be  only  could  specify  two  risks  44  1. Hyperthermia  hazards  -  Previously  literature  on t h e e f f e c t s o f h e a t / a l c o h o l  reasonably  sound b a s i s  for determining  Spa use by p r e g n a n t women, and the  influence  w h i c h can be  2.  Drowning hair  This  are  from  i f visual  and a c k n o w l e d g e d .  enter  s i t u a t i o n s of  hazards  uncertainties A.  be  1 . The  we  available  e f f e c t s of And  the  be s p e c i f i e d ,  gone  to  However, t h e e v i d e n c e f o r  spa r i s k s ,  we  uncertainty.  eliminated,  Uncertainties are  a  number  of  reduced, or changed For  uncertainties to stochastic  example:  to pathogenic hazards  conditions knowledge  uncertainty.  under  situations  actually  t h e s e acknowledged  range of pathogens which c o u l d  various  are  - The  could  have  by a d d i t i o n a l i n f o r m a t i o n .  In r e l a t i o n  who  area.  exist.  that  Beyond  spa management, t h e r e could  in this  seems t o be o v e r w h e l m i n g l y a g r e e d  Informational  which  systems  entrapment  t h e s e i t e m s as r i s k s  us w i t h a  well-documented.  of s p e c i f y i n g t h e s e r i s k s .  upon  In  risks  and  risks.  i s not meant t o i m p l y  effort  labelling  as  entrapment  drowning  particularly  provide  individuals  h a z a r d s from spa a e r a t i o n  of  studies  of a l c o h o l or d r u g s , e x e m p l i f i e s  identified  and body  risks  the  cited  is  not  exist  known,  but  i n s p a s and an  c o u l d c h a n g e the c u r r e n t  under  assembly  of  situation  of  45  2. F o r  any  numbers  one of  bathers, could 3.  The  spa,  range  know t h e a c t u a l or  testing  being or  t y p e s and  introduced  monitoring  by  methods  i n f o r m a t i o n t o change t h e u n c e r t a i n t y .  and  effectiveness  against  sufficiently  not  present  conceivably  provide  various  of  possible  pathogens  preventative  in  spas  i s not  known.  4. The s p e c i f i c  effects  disinfection known.  do  pathogens  but  measures  we  of p h y s i c a l  efficacy  ( N o t e : most  and c h e m i c a l  factors  i n hot water c h e m i s t r y  upon  i s not f u l l y  f a c t o r s a r e known, b u t a few a r e  still  open t o q u e s t i o n . )  B. .In r e l a t i o n 1. The  t o hyperthermia  effects  heart  of  rates  existing  could  medical  2. S t a t i s t i c s  C. In r e l a t i o n  cases  2. The  be  the  and  in  numbers  assembly  of  hot  water  "near-miss"  hazards and c h e m i c a l  biological chemistry  factors  i s not f u l l y  as f o r d i s i n f e c t i o n  between  of  a r e not a v a i l a b l e .  i n h o t water c h e m i s t r y  relationship  identified.  kinds  of p h y s i c a l  same a p p l i e s h e r e  clarity  through  o c c u r r i n g i n spas  effects  clarity  upon b l o o d p r e s s u r e and  determined  t o poor water c l a r i t y  1. The s p e c i f i c  (The  temperatures  knowledge.  about  hyperthermia  water  spa  hazards  known.  efficacy.)  factors  have  upon  not  and  water  been  fully  46  Judgement These u n c e r t a i n t i e s informational by  to  interpretation  of  accumulation A. 1.  or  probability  of  requires  socio-economic  2. The  causing  individuals' The  area  How  probability  and  which  be  to various  reduced  of l i n e a r  about  through  entering which  still  geographic  a concern  depends  infecting  on  individuals  judgements  the appropriate  about  to a disease.  disinfectants)  "correct"  i)  in  much?)  r e s u l t s of p r e v e n t a t i v e and c o n t r o l  the  t h e spa potential  for a particular  of v a r i o u s pathogens  as  from  analysis.  pathogens  (e.g. i s cholera  resistance  the  however,  is differentiated  can  judgements  ( e . g . , w i t h t h e use of regarding  to  hazards  various  disease  probable  uncertainties,  This  s h o u l d be c o n s i d e r e d  North America?  3.  knowledge.  o f d a t a and a p p l i c a t i o n  pathogens  relationship  depends upon t h e w e i g h t a t t a c h e d  uncertainties  environment  some  j u d g e m e n t s c a n be a s s i s t e d  Judgement  In r e l a t i o n t o p a t h o g e n i c The  have  o f d a t a where a t t a c h m e n t o f p r o b a b i l i t i e s  available  informational  to  i n that  information.  outcomes s t r o n g l y  inputs  tend  uncertainties,  increasing  involve  Uncertainties  combination  require of other  measures  judgements factors  such  following; level  of d i s i n f e c t a n t  to maintain  at a l l  times ii)  appropriate  testing/monitoring organisms  methods disinfection  and  intervals  residuals  for  and pathogenic  47  iii)  the q u a n t i t y or dosage of d i s i n f e c t a n t s  bather  or per g a l l o n ( s )  iv) appropriate effective (Note:  i t may  trying in  to  intervals  be  that  spa  1. In  quantities  required  for  uncertainties  together  and  splash-out  of  much  quality  to  spa  an  physical of  spa  judgements.  which  would  be most  likely  physical  condition  unsafe  requires  temperatures judgements.  water c l a r i t y  hazards  of d i s e a s e a s s o c i a t e d spa  waters  for  w i t h v a r i o u s time specified  bather  ratios.  amounts the  special  u s e r s whose p r i o r  for draining  and  too  delineation  requires medical  practical  to poor  probable  individual  is  "safe"  procedure(s)  estimated risk  load/water  time  specific  having  the probable  settings  b o t h m e d i c a l and  intervals  t o one  hazards  individuals  exposure  In r e l a t i o n  risk  specific  in detecting  make t h e i r  The  these  to hyperthermia  management  effective  2.  a  advising  temperature  1. The  time.  t h e r e f o r e becomes a r e a l u n c e r t a i n t y . )  characteristics,  C.  taking  at  t a s k , and  In r e l a t i o n  The  and  assign a probability  analytical  2.  spa water o v e r  per  superchlorination.  a specific  B.  of  required  of  water  resulting  loss  effects  from upon  evaporation the  spa  and  water  chemistry. 3.  The  probable  (e.g.,  dirt,  bather  and  sunlight)  external upon  key  environmental interrelated  effects chemical  48  parameters. 4. The  estimated  intervals  risk  of  disease  for testing/monitoring  Real  to pathogenic  1. The a c t i o n s  o f spa o p e r a t o r s  implementing  measures i s not sense. terms  Actual  and  clarity.  public  recommended  health  c o n t r o l and  in  behaviour can o n l y  such e s t i m a t i o n s  any  true  would  judgement.  actor  behaviour  spa  j u d g e m e n t s made, b e h a v i o u r a l  preventative  be e s t i m a t e d  involve  officials  probabilistic  f o r e s t a b l i s h i n g management  about  different  hazards  determinable  as a b a s i s  information  water  with  Uncertainties  A. In r e l a t i o n  toward  associated  in practical policies,  However,  and  until  i s d e v e l o p e d and  f a c t o r s i n spa use remain  real  uncertainties. 2. The a c t i o n s spread the  o f spa u s e r s  of i n f e c t i o u s d i s e a s e  spa e n v i r o n m e n t  probabilistic 3. The  especially  levels  values  4. Our a b i l i t y practices hazards  can  of  spa  internal  pathogenic  users,  which can s h i f t be p r e d i c t e d  through to  both  contribute  to  the  and e x t e r n a l t o  i s a l s o not determinable  level  future  cannot  might  in  any  true  sense.  acceptable  social  which  never  be  over  on  time.  f o r spa u s e r s , individual  Thus,  and  acceptable  f o r the f u t u r e .  design,  eliminate  depends  risk  engineering,  or v i r t u a l l y specified  as  or  eliminate i t  sanitation pathogenic  would  invoke  49  predicting 5. The  a "future  probability  pathogens  state of  immune  emergence  to  p r o c e d u r e s a l s o cannot  B.  In r e l a t i o n  1.  The  The  acceptable  2.  The  level  users,  to hyperthermia  of  particularly  It  i s important to note exist,  management  purposes  steps  taken  uncertainties  to  reduced  until  Areas  the  officials  norms.  water  clarity  for  users.  hazards spa u s e r s t o w a r d  o b s e r v i n g and  warnings  from  temperature  when i n f o r m a t i o n  remain  apply  for  spa  susceptible  and  judgement  real  uncertainties  for  information  i s generated or  until  expert  judgement  to  convert  risks.  an a d d i t i o n a l  must be c a r e f u l granted.  spa  risk  that  they  to  health  f o r t h o s e i n d i v i d u a l s most  problems.  are  from p o o r  p r e c a u t i o n a r y temperature  uncertainties  sanitation  hazards  o p e r a t o r s , and  of r i s k  to  As  clarity  future  acceptable level  unknown  predicted.  b e h a v i o u r o f the v a r i o u s  enforcing  previously  recommended p r o c e d u r e s and  especially  In r e l a t i o n  1. The  be  water  implementing  spa u s e r s ,  C.  t o poor  of  normally-practiced  b e h a v i o u r o f spa u s e r s ,  toward 2.  of the w o r l d . "  not  to  where  t o r i s k s may  be  note  t o our d i s c u s s i o n  take  "facts"  uncertainties still  subject  related have to real  of u n c e r t a i n t y , to  hazards  for  been e l i m i n a t e d uncertainty  we  or  both  50  in  a  t e c h n i c a l and b e h a v i o u r a l  in  the  medical,  revolutionary For  biological,  and y e s t e r d a y ' s  example,  recent  against in  this  ability  information limited when  to  that  dangerous. that  about  fail  to  These  slime  coating  we s h o u l d  of  avoid  success  retain  for  i s not  We c a n n e v e r  predict  communications.  "veiled"  The  something" can  real  uncertainties  upon any one  critical  the  available  Real uncertainty  over-reliance  or  involved  we a l w a y s need t o q u e s t i o n  comprehend  types  myths. of the  the " f a c t s "  d e l i b e r a t e behaviour.  be  ability  "everyone c e r t a i n l y understands  overall policy  Major  the  protective  t o reduce hazards.  individuals will  individual's  Also,  can  become t o d a y ' s  indicating a  fields  o f i n d i v i d u a l s t o u n d e r s t a n d and  merely  suggest for  " f a c t s " may  produce  organism.  intended  assumption be  to  Advances or d i s c o v e r i e s  genetic  c h l o r i n e has r a i s e d q u e s t i o n s  killing  real  and  studies  Pseudomonas o r g a n i s m  sense.  "fact"  outcomes  to  an  health.  Policy Difficulties  A r i s i n g f r o m Spa Management  Uncertainties The  uncertainties  management These because  are manifested  difficulties of  their  uncertainties.  1.  The  create  involved  cannot strong  Examining  difficulty public health  i n four  of  be  with  major  areas  resolved,  t i e to  the  each d i f f i c u l t y  defining  and s a f e t y  (a)  hazards  spa  water  of  except  quality  difficulty. normatively,  judgement  and  real  separately:  the extent and,  (b)  t o which the  spas  precise  51  n a t u r e of  the  How policies that  hazards they  do  we  define  can  be  designed  create.  the  precise  to deal  nature  of  spa  effectively  hazards  with  so  that  the  hazards  and  drowning  exist? With  visual  hazards  hazards  from e n t r a p m e n t ,  s p a s has  been r e a s o n a b l y  exists.  Hyperthermia  evidence  has  duration  yet  Disinfection  there  are  well is  are  and  d e t e r m i n e d and  slightly  not  do  totally  official  only  remote  chances  specific  source,  of as  accurate  relationships  —  good d e a l  nature  of  a spa  determining  cause.  an  t o overcome t h e  attempt  subject  to strong  This because health health,  "cuts  hazards. it  In  becomes  about and  indicated linking  so  a n a l y s i s of of  luck.  4 3  the  s t u d i e s are but  that  a  disease  requires  prompt  very The  complicated dynamic  and  difficulty  of  commonly u s e d  as  t h i s method  i s often  4 4  i s important b o t h ways" the  doing  difficulty,  criticism.  Medical  h a z a r d s p o s e a major  securely  compounds  Epidemiological  difficulty it  water  difficulty  temperature  interviewed  c a r e f u l and  variable  since  and  defined.  investigation,  and  real  information  c o n t r o l of p a t h o g e n i c  health  no  hazards  difficult.  good  remain  One  problem to a  more  reasonably  doubts  thresholds  difficulty.  r e l a t i o n s h i p between h e a l t h  provided  hyperthermia,  from p o o r water c l a r i t y  t o our  i n a f f e c t i n g our  d i r e c t i o n of  difficult  policy  to  trying  to  considerations ability protect  document c a s e s  to  judge public  convincingly  52  enough t o s t i m u l a t e disease  and  outbreaks,  initiate  many  public  problems  in  incidents  in a j u r i s d i c t i o n  the  their  public's  problems quite  t o spa usage?  exposure.  and  Thus,  (or  may  unlikely  that  individuals  incorrect  blame  p r o b l e m may  is  find  large  would  have had  no  reported  of problems  i s Pontiac  are  days a f t e r  link  or  for relating  s u c h as r a s h e s  for several  relate  of  of  awareness)  n o t see t h e  example  for  much  for  a  prevalent  spa  between  the  F e v e r , where i t i s  flu-like  symptoms  to  same r e a s o n s , s p a s may The  Research  may  be  more  are  possibility locational identified. our  spas  still  and  the  pores allowing  bacterial  i t i s normal  raised source  that of  Hence, we  5  their  cause entry?  Even  to  and  factors  i f Pseudomonas  presence i n spas i s because  Or would  their  high  the cause  be  o f a u s e r t o remove a bandage on a wound  Pseudomonas?  policy  that  related  t o the o r g a n i s m . *  i n the spa, thus c h o o s i n g t h i s to  indicates  predominantly  i n other environments  to the d e c i s i o n  exposure  Pseudomonas  receive  numbers o f Pseudomonas i n many e n v i r o n m e n t s  temperature d i l a t e s related  the  disease.  t h a n human e x p o s u r e  unimportant,  in  An  be an example.  infection  while  lack  reports  use o f a s p a .  Conversely,  other  of  show up  i n d i v i d u a l s may  spa u s e .  that  the  t o a t r u e absence lack  not  and  to  Is  officials  Some of t h e d i s e a s e s  disease  their  due  Despite  health  jurisdiction.  inability  common  action.  a  particular  Therefore,  although  spas  problem,  the  might  erroneously  considerations at points  we may wrong  environment also be  the  factor  emphasize  have  for the  actual may  be  disinfection  where o t h e r management  53  considerations  The  foregoing  defining  the  problems define  the  conditions  is  industry.  those  p e r s o n who  feels  pathogenic cited  reduces  other  users  This benefits  of  or  most  also  health  benefits  prone  subjects  blood  variable faced  to prescribe the hazard.  health  o f f i c i a l s and reasons  are  to the p o t e n t i a l hazards. may go i n t o a  himself  to  patients  persons  problems.  r e s i s t a n c e to other  has  looking  And  diseases  spa  A to  hyperthermia or been  to relax  people  t h e f l u may u s e a s p a whereby t h e i r  their  a c t i o n by  against  r a i s e d by h e a l t h  and s t r e s s f u l pressure  to  policies.  ( t h e example o f a r t h r i t i s Tense  easy  highly  reduce or e l i m i n a t e  amongst a p p r o p r i a t e  but  may e n c o u n t e r h i g h  only  enough t o s t i m u l a t e because  of  two t y p e s o f  i t may n o t be  i l l a n d under m e d i c a t i o n  earlier).  colds  will  of b a l a n c i n g  also  dangers  from  spas c r e a t e s  Many p e o p l e who u s e s p a s f o r h e a l t h  are  better,  difficulty  w a t e r , and t h e u n c e r t a i n t i e s  a central question  who  feel  the  relations, i t i s difficult  measures t h a t  i n choosing  This the  Second,  o f use and i n t a k e  with  First,  convincingly  officials.  The d i f f i c u l t y  hazards  i n d i c a t e s that  hazards a s s o c i a t e d  hazards  preventative  of  discussion  defining cause-effect  2.  important.  f o r p o l i c y development.  policy-making  in  may be more  aching  i l l n e s s not  but a l s o  exposes  t o germs.  difficulty  stems from s e v e r a l  problems.  f r o m s p a u s e and t h e i m p o r t a n c e a t t a c h e d  s p a u s e v a r i e s among i n d i v i d u a l s i n a c c o r d  First,  the  t o the hazards  with  their  values  54  which cannot in  defining  be p r e c i s e l y m e a s u r e d .  Second,  h a z a r d s and t h e u n c e r t a i n t i e s  psychological  effects  of  spa  use  the  about  make  t o compare b e n e f i t s  fashion.  Third,  the  t o w h i c h an i n d i v i d u a l i s e n t i t l e d  extent  own  health  society. clear  3.  and  resolution  The d i f f i c u l t y  The  of e s t a b l i s h i n g  by  If  inappropriate  devised  management a n d f a i l  spa  range  of  a  absence  i n the face  his  of  a  at  certain fail  to  If  being  t h e y may be or  to  a  standards are  operators  t o p r o v i d e u s e r s and h e a l t h criterion  without  facilities  times.  and  in devising  formulated,  guide  time.  materials,  conditions  t o some s p a  o f wide  physical/chemical  difficulty  are too narrowly  t h e y may  precise  endanger  i n spa  officials  with a  for evaluating  conditions  of a  spas  guideline  for  facility.  An  example  periodically of  the  facility  too broadly,  sufficiently  i n the  ( s p a water  create  or i n a p p l i c a b l e  spa  to  a t d i f f e r e n t s p a s and o v e r  individuals)  standards  logical  d e t e r m i n a t i o n of  presence of b i o l o g i c a l / o r g a n i c  standards which cover  in a  o f o t h e r members o f  standards  three p r i n c i p a l variables  usage  specific  the well-being  f o r an  problems.  among c o n d i t i o n s  characteristics,  vague.  h a s n o t made a c l e a r  t o endanger  of these  difficult  and a d v e r s e e f f e c t s  Y e t , p o l i c i e s must be d e v e l o p e d  variability  spa  society  t h e p h y s i c a l and  i t  individual  uncertainties  the  of  draining  University  this  with  the u n i t s . of  British  is  the  An i n t e r v i e w Columbia  with the d i r e c t o r  Aquatic  Centre  well  55  illustrates  the  dilemma.  guidelines,  his  first  followed kinds spa  their  remark  recommendation  of problems.'" has  helpful.  The word  on  makes  ultimately  solved of all  might  by c h o o s i n g  bathers.  i s unclear  spa.  2-3  a specific  assumption), individual organic spa  one b a t h e r will  as  be  i s not  good  was t h a t UBC's  he t h i n k s  week.  that  The  effective of  month"  CDC  solution  trial-and-error  and even t h o s e  solutions  factors.  question  could  be  p a r a m e t e r , s u c h a s number  i s that held  the  wide  if  an  the drainage  i n t o the spa.  little  a  process  spa —  this  could  introduce  material  does  that  times  a more a p p r o p r i a t e  conditions  have a l l  and "once a  By e x p e r i e n c e ,  sense,  The p r o b l e m w i t h  other  would  but i f I  once a month" i s n o t v e r y  at least  be s u g g e s t e d  nice,  spa  or a t l e a s t  may be t e m p o r a r y due t o v a r i a b i l i t y  It  I  CDC  l o a d , and t h e CDC's vague  little  with  is  f o r h i s comment  r e s t s on t h e o p e r a t o r ' s  judgement  "This  the  bather  f o r that  needs t o be d r a i n e d  over  draining,  "continuously"  be d e f i c i e n t  guideline  and  was  an e x c e p t i o n a l l y h i g h of "continuously  it  looking  The r e a s o n  16  guideline  would  Upon  even  if  constant  same  as  Furthermore,  assumed  (not  the  variations  we  a  next.  good Each  o f b i o l o g i c a l and simply  i t i s not c l e a n e d  draining  a  properly prior to  refilling.  The earlier  difficulty described  question  of  reactions  of  r e s t s i n the b a s i c c h a r a c t e r i s t i c s  and a p p l i e s t o many o t h e r  draining. spa  water  The dooms  highly  of  spas  problems b e s i d e s the  variable  rigidly-formed  and  volatile  standards  to  56  failure.  Inevitably,  frustrating  of a l l ,  we  cannot  hardly some  eases  develop  and  adequately respond  be many e x c e p t i o n s o f  a l l  types  of except i o n s !  can  still  about  but  of  spa  users,  For p o l i c y  enough be  t o be  operators,  assuring  forced  to  anticipate  taken.  This  to  be  to  is  effective  effective,  have  high  be  however,  s o u r c e s of v a r i a b i l i t y  operators  of p r e d i c t i n g  spa  may  a l l o w s t a n d a r d s t o be more  d i s s e m i n a t e d and  difficulty  and  the e x i s t e n c e of  we  flexible  t h e t y p e s and  The  T h i s dilemma  developing guidance  t o t h e v a r y i n g water q u a l i t y  industry  arise  c o u n t e r i n g a c t i o n s can  4.  must  trained  be to  conditions.  or a n t i c i p a t i n g public  health  the  behaviour  officials  and  representatives.  In policy  most  are  the d i f f i c u l t i e s .  information  and  Consequently,  which  so t h a t  —  rule  will  over hazards,  is a reality.  reasonable despite  a  w o r r i e s about  ranges  variations  working  toward  alternatives  Columbia, incomplete behaviour  a  without of  There  d e v e l o p i n g a framework and  for  background  industry  management  and  make  measure o f c o n t r o l  variability  the  there w i l l  even  our  exceptions  public of  the  considering  spa  management  case matters  evaluation in  British  s t u d y p r o b l e m s would of  behaviour.  important  to  establishing  be The  spa o p e r a t o r s , government a g e n c i e s , spa u s e r s , is  of  appropriate  and spa  policies.  is  a  organizational  substantial behaviour,  body o f knowledge a b o u t and  where  individual  uncertainties  exist,  57  experimentation  can  T h u s , spa a c t o r address,  but  i n c r e a s e knowledge o f spa a c t o r  behaviour it  is  purposes,  predicting  important  even though  operator  or user w i l l  The  key  group  is  not  spa  water  influence  i n the  independence  water q u a l i t y "Keep used,  in  o r how  for purposes  still  not what used.""  behavioural  "spa  but  actual  spa  the  industry  how  to  this  of  control have the  an  most  of  i n spa  standards developed,  chemicals  equipment, u n l e s s the o p e r a t o r  here,  be  i s defined as:  the  spa,  the problems  is will  the development of s t a n d a r d s i s i t ' s how  statement,  an  those  the  standards  problems  related  are to  encapsulated.  defined  as  follows:  individual  or p e r i o d i c  spa o p e r a t i o n s on a d a i l y maintenance,  interested  written,  maintain  main spa a c t o r s can  units.  specific  consists  have  researcher  of  spa  a  is  has  c o n s i d e r a t i o n s are well  spas e n t a i l s  how  others  operators  facility),  of  actors  day-to-day  manager o r o t h e r employee o f a spa the  policy  involvement.  support  important  operator"  spa  implementation  Certainly,  summarize t h e n ,  Within  7  The  To  is  their  regardless  on  of  many of t h e v a r i o u s p e o p l e  good t h e  exist.  of  management, one  knowledgeable  of  For  must  behave.  direct  mind,  behaviour  policy  one.  i t i s impossible to p r e d i c t  process,  for  which  insurmountable  conditions.  and  Speaking  an  difficulty  "average"  t h e spa o p e r a t o r s b e c a u s e over  a  behaviour.  m o n i t o r i n g , and  The  (either who  is  an in  basis.  management  term owner, charge  Operation of  the  58  "Spa the  use  Users"  of  public  determinant do  not  constitute may  public  spas.  later  "Public directly  outside  of  scientists,  public health "Industry  profit  and  or  manufacturing  they  may  industry  have  t o consumer b u s i n e s s  with  suggestions  i n p o l i c y d e v e l o p m e n t and  significant  real  the  outcome of  eventual  uncertainty  important  consideration,  with  are  it  spa  list  of  actors  often  spa yet  and  our  inadequate.  who  indirectly  in this  deal  category. employed  i n the  i n t e r a c t with links  by  pool  and  the  spa  through  the  chains. i s provided  to account  for  As  in  their  both  a  factor in influencing  institutional The  daily  Legislators,  management p o l i c y , b e h a v i o u r  for p o l i c y design  questions.  uses  the  implementation.  a strong  never  any  these a c t o r s  a b o u t how  "non-  in  involved  indirect  term  within  individuals  directly  d e t a i l e d c h a r a c t e r i z a t i o n of  behaviour  included  are  T h e s e p e o p l e may  Appendix C along  of  not  others  users  who  involved  not-for-profit organizations  operators  A  or  a  individuals  legislation.  consultants,  representatives"  industry.  which  not  Spa  the  agencies  are  health  is  users. se;  population  health  agencies are  spa  use  i n c l u d e a l l the  people  public  p a r t i c i p a t e in  of  p u b l i c , per  to the  public  These  Frequency  i n d i v i d u a l s as  Officials''  for  administration  i n d i v i d u a l s who  general  applied  Health  work  as  facilities.  the  be  jurisdiction.  spa  spa  defined  for designating  users"  with  are  importance  is illustrated  abilities of by  the the  is to  an deal  behaviour following  59  1.  What  i n c e n t i v e s c a n be p r o v i d e d  manage t h e i r 2.  How  other How  their  own  hazards?  to take s u i t a b l e precautions  health  and h e l p  to  to  to minimize hazards t o  u s e r s and n o n - u s e r s ?  can p u b l i c h e a l t h  a constructive Scientific behaviour with  spa operators  so a s t o m i n i m i z e h e a l t h  c a n u s e r s be m o t i v a t e d  protect  3.  facilities  t o induce  provide  policies  be m o t i v a t e d  way t o u p g r a d e s p a  studies  can  officials  that  of  are  operations?  organizational  a basis  and  for constructive  responsive  to function i n  to  individual  experimentation  human  behavioural  characteristics.  Basic The  Issues  Involved  identification  of  management a n d t h e r e s u l t i n g pose  for  policy  How  are  resulting  2.  difficulties serve  must a d d r e s s .  users  "protected"  uncertainties  development  which p o l i c y design 1.  i n the Regulation  of  from  spas  potential  from s p a u s e ?  associated these  to c l a r i f y  These b a s i c  to  o f Spas  "protect"  themselves  impairment  of  i s the r e s p o n s i b i l i t y of the user?  - What  i s the r e s p o n s i b i l i t y o f spa  resulting  from from  spas  potential spa  their  or  be  health  Further:  - What  protected  issues  issues are:  i s t h e r e s p o n s i b i l i t y o f government?  a r e non-users of  uncertainties  the basic  - What  How  w i t h spa  to  operators?  protect  impairment  operations?  How  themselves of do  their users  or  be  health protect  60  themselves Again, operators, 3.  or be  p r o t e c t e d from  what  is  and  of  users?  responsibility  incentives)  deciding  spa  operations,  what m e a s u r e s t o the  role  of  - What s h o u l d be  the  role  of t h e  - What  the  role  of  users  (the general  - What s h o u l d be If  government  users about how  does  of  or  how  influence should  (e.g.,  i t go  about  institute?  - What s h o u l d be  s h o u l d be  of government,  users?  I f government does r e g u l a t e , c o n t r o l , by  4.  the  other  scientists  and  other  experts?  bureaucracy?  operators,  users,  and  non-  public)?  the is  role  of e l e c t e d  involved  risks,  i n " i n f o r m i n g " u s e r s and  uncertainties,  i t proceed  officials?  in developing  and  a p p r o p r i a t e spa  "reliable"  or  nonuse,  "accurate"  information? What  should  personnel, elected  How  officials  In  should  view  so as  t o be  and  learning  f o s t e r e d and  uncertainties, select  any  deciding  and  the  general  upon  the  government public  content  and and  or  incentives  be  effective?  experience.  emerge  of p o l i c y  advances How  can  must  emerge  creative  from  advance  and  facilitated?  from  difficulties  form  scientists,  regulations  uncertainties,  i s s u e s thus  of  industry,  government  of  be  role  communication?  experiment  The  To  in  f o r such  implemented 6.  the  operators,  procedures 5.  be  examination  of  a s s o c i a t e d with  spa  for public  spas  these  the  risks,  management. i s s u e s must  61  be of  addressed policy  developed Columbia.  w i t h i n the context is  based.  In  the  of w h a t e v e r p r e m i s e s next  chapter,  as a b a s i s f o r e v a l u a t i n g d e s i g n  our  design  a framework i s  of p o l i c y  for  British  62  Footnotes  - Chapter  2  'E.S. Quade, Analysis for Public Decisions, 2nd (North Holland; New Y o r k , Amsterdam, O x f o r d ) : E l s e v i e r P u b l i s h i n g Co., I n c . ) , 1982. 2  Ibid.  3  Ibid.  edition Science  "Ibid. 5  U.S.  D e p t . o f H e a l t h a n d Human S e r v i c e s , op. c i t . , p r e f a c e .  Victoria R. Brown, Spa A s s o c i a t e d H a z a r d s - An U p d a t e and Summary, U.S. Consumer Product S a f e t y Commission, Washington, D.C, Directorate f o r Hazard Identification and Analysis D i v i s i o n o f Human F a c t o r s , May, 1981, p. 1. 6  Ibid.,  7  p . 3.  "Drownings Spur R e c a l l 1982, S e c t i o n 1, p . 17.  8  26,  o f Spa P a r t , " C h i c a g o  Tribune,  Interview with Daniel Tarry, Environmental Health V i l l a g e o f A r l i n g t o n H e i g h t s , I l l i n o i s , J u l y 13, 1982. 9  June  Office,  Maj. William J . Sausker e t a l . , Pseudomonas F o l l i c u l i t i s A c q u i r e d from a H e a l t h Spa W h i r l p o o l , J o u r n a l of t h e American M e d i c a l A s s o c i a t i o n , June 2, 1978, p . 2364. 1 0  William J . McCausland and P a u l J . Cox, I n f e c t i o n Traced t o Motel Whirlpool", J o u r n a l of H e a l t h , M a r c h / A p r i l 1975, p . 458. 1 1  1 2  Ibid.  1 3  Great  Lakes B i o c h e m i c a l ,  op. c i t . , p p . 5-6.  Rand Green, P o o l & Spa News, I I " , A u g u s t 17, 1981, p . 59.  1 4  Part  i n t e r v i e w w i t h George June 28, 1982. 1  "Pseudomonas Environmental  Watson,  "Water C h e m i s t r y Great  Lakes  Workshop;  Biochemical,  John Washburn e t a l . , "Pseudomonas aeruginosa Rash A s s o c i a t e d With a Whirlpool," J o u r n a l of t h e American M e d i c a l A s s o c i a t i o n , May 17, 1976, pp. 2205-2207. 1 6  U . S . Dept. of Health & Human Services/Public Health Service, "Outbreak o f Pseudomonas aeruginosa Serotype 0:9 Associated With a Whirlpool," M o r b i d i t y a n d M o r t a l i t y Weekly R e p o r t , C e n t e r s f o r D i s e a s e C o n t r o l , J u l y 17, 1981, p . 324. 1 7  63  Pool Prevention 1 8  1 9  & Spa News, "ISTI Sought," February  Robert  Backs Pseudomonas 9, 1981, p . 148.  Study;  Causes,  J a n i s , o p . c i t . , p . 16.  Interview with J o h n P u e t z , Head o f R e s e a r c h , G r e a t B i o c h e m i c a l Co., I n c . , M i l w a u k e e , W i s . , J u l y 13, 1982.  Lakes  2 0  T e s t samples o f t h e pseudomonas b a c t e r i a were c u l t u r e d o u t of H e a l t h D e p t . , b u t when s e n t t o B i o - L a b , I n c . the organisms died i n 30 seconds at 1.0 ppm. P o o l & Spa News, op. c i t . , F e b . 9, 1981, p . 148. A l s o c o n f i r m e d i n l e t t e r and memo from James M i l l e r , D i r e c t o r o f M i c r o b i o l o g y , B i o - L a b , I n c . , J u l y 28, 1982. 2 1  G.P. F i t z g e r a l d and M.E. Der Vartanian, "Pseudomonas a e u r i g o n o s a f o r t h e E v a l u a t i o n o f Swimming P o o l C h l o r i n a t i o n and A l g i c i d e s , " A p p l i e d M i c r o b i o l o g y , M a r c h , 1969, pp. 415-421. 2 2  Victor J. Cabelli, H a r r i e t Kennedy, and M o r r i s A. L e v i n , "Pseudomonas aeruginosa-fecal Coliform Relationships in Estuarine and F r e s h Recreational Waters," J o u r n a l o f Water P o l l u t i o n C o n t r o l F e d e r a t i o n , F e b r u a r y 1976, p p . 367-376. 2 3  2 f t  Pool  & Spa News, op. c i t . , F e b r u a r y  CDC, Morbidity and c i t . , J u l y 17, 1981. 2 5  op.  2 6  Pool  Mortality  & Spa News, op. c i t .  9, 1981, p . 148.  Report  , February  Weekly  Report,  9, 1981, p . 148.  Letter from James J. Miller, D i r e c t o r of M i c r o b i o l o g y , B i o - L a b , I n c . , D e c a t u r , Ga., J u l y 28, 1982. 2 7  J o r i a n Clair, Editor, F e b u r a r y 8, 1982, p . 6. 2 8  Robert 1 6.  Janis,  2 9  p.  3 0  Jorian  Clair,  Pool  "Reflections,"  Pool  &  Spa  & Spa News, op. c i t . , A p r i l  News,  5, 1982,  op. c i t .  Gary L. Latimer and R i c h a r d A. Ormsbee, D i s e a s e , M a r c e l D e k k e r , I n c . , New Y o r k .  Legionnaire's  Interview with A u g u s t 11, 1982.  A t l a n t a , Ga.,  3 1  3 2  3 3  3  Interview  "Interview  3 5  Victoria  Dr. E l l e n  w i t h John Puetz,  E. Jones,  CDC,  op. c i t .  w i t h Dave A n t o n a c c i ,  op. c i t .  R. Brown, U . S . C P . S . C . , op. c i t .  64  3 6  V i c t o r i a " R.  Brown U.S.C.P.S.C., op.  cit.  p.  9.  Mary Ann S. H a r v e y , Marcella M. M c R o r i e , and David W. S m i t h , " S u g g e s t e d L i m i t s of E x p o s u r e i n t h e Hot Tub and Sauna for the P r e g n a n t Woman," From t h e D y s m o r p h o l o g y U n i t , D e p t . of P e d i a t r i c s , C h i l d D e v e l o p m e n t and M e n t a l R e t a r d a t i o n C e n t e r , and the Center f o r Inherited Diseases, U n i v e r s i t y of Washington S c h o o l of M e d i c i n e , S e a t t l e , Wash., 1980. 3 7  Interview with A u g u s t 10, 1982. 3 8  Victoria  Bob Lowry, "Hot F e b r u a r y 8, 1982, p. 96. 3 9  Water  Brown,  CPSC, W a s h i n g t o n ,  Chemistry,"  Pool  & Spa  D.C, News,  "°William N. Rowley, Director of Engineering and Gordon F. E h r e t , C h i e f E n g i n e e r , Swimquip, a D i v i s i o n of W y l a i n , Inc., "Primer on S u c t i o n E n t r a p m e n t i n Swimming P o o l s or T h e r a p e u t i c Pools". 4  'William  N.  Rowley and  G o r d o n F. E h r e t ,  ibid.  " i n t e r v i e w w i t h Dr. Steve C o c h i , Respiratory and P a t h o g e n s B r a n c h , CDC, A t l a n t a , Ga., J a n u a r y 27, 1983. "interview  Special  w i t h D a n i e l T a r r y , op. c i t .  ""William W. L a w r a n c e , Of A c c e p t a b l e R i s k , S c i e n c e and t h e D e t e r m i n a t i o n of S a f e t y , (Los A l t o s , Ca.: W i l l i a m Kaufman, I n c . , 1976), pp. 13-14. "interview referenced to al.) .  w i t h Dave Antonacci, op. t h e s t u d i e s by F i t z g e r a l d ,  cit. (also may e t a l . and C a b e l l ,  " i n t e r v i e w w i t h J i m Bremner, D i r e c t o r , UBC V a n c o u v e r , B.C., J u l y 26, 1982. " Letter from John Puetz, Head B i o c h e m i c a l Co., I n c . , M i l w a u k e e , Wis., 7  Aquatic  be et  Centre,  of R e s e a r c h , G r e a t A p r i l 22, 1982.  Lakes  65  CHAPTER 3  How  S h o u l d P u b l i c Spa a n d Hot Tub P o l i c y Be D e s i g n e d ?  One method o f a d d r e s s i n g chapter  is  literature evaluate areas  to in  the  a  where  subject  area  a  conceptual  health  exemplifies.  hazard  matters,  t o rage  problems  the  1.  o f government  and w e l l - b e i n g  technical  that  users  theory  spas,  acquisition for  most  1  the  2  3  Although  technical  of information users.  approach study  However,  Because  the  determine  consequences  spa u s e r s  could  information  technical  when  problem  they  do  views  is  complex  safety? market of  so  requires  acquiring  inform  w o u l d be t o o c o s t l y the  to  to p r o t e c t the  us t h a t an e f f i c i e n t  about  of  i n the l i t e r a t u r e  of spa f a c i l i t i e s  information  tells  be i n f o r m e d  good o r s e r v i c e . about  of u s e r s  and s c i e n t i f i c  Economic  are complicated  below a r e s u r e l y s u b j e c t t o  evaluation.  health  health  a p p r o a c h b a s e d upon w i d e l y - a c c e p t e d  i s the r e s p o n s i b i l i t y  on  be u s e d t o  in public  s u c h a s our c a s e  w h i c h c a n be a p p l i e d t o p o l i c y  What  then  best  d e p e n d i n g on o n e ' s p e r s p e c t i v e .  an o r g a n i z e d  based  the development  Debate  over  The p r e m i s e s c o n t a i n e d  disagreement  can  and u n c e r t a i n t y  is difficult.  i n p r a c t i c e continues  represent  which  t e c h n i c a l and s c i e n t i f i c framework  framework  Unfortunately,  s i t u a t i o n s of r i s k  complex  public  theoretical  alternative policies.  by  and  develop  the issues r a i s e d i n the preceding  themselves  complex  and  a  that  impractical  information  is  so  66  complex,  i t seems t h a t  communicate  neither  t o a spa user a l l t h e  make an i n f o r m e d c h o i c e . " Therefore, must  reasonably  "safe"  be  specified.  available  7  conditions Finally,  i f  that  we  information: been  to  this  information  any  have  constitutes  Uncertainties  a l s o need t o  be  a  means t o t r a n s f e r  conditions  that  a  of use a r e  being  item  in  kind  of  should  a  that  determining  have a c c e s s have  however, must be g e a r e d t o t h e l a r g e costs  or  employ  judgement o f what c o n s t i t u t e s  of " s a f e "  have been t a k e n  way  for  what  body a n d to  meet There  government  constitutes  to  body o f  "safe"  information  considered.  the s k i l l s "safe"  use  U s e r s who w i s h t o examine  to i t , including been  spa, i t  a user might u t i l i z e .  alternate  on  two i t e m s o f  l e g i t i m a t e l y recognized  information.  that  with  i s whether c o n d i t i o n s  spa  in  user  system  information  t o use a g i v e n  the ordinary  by  a  democratic  t o "good"  i t i s desireable  supply  utilized  the  liberal  reasonable precautions  uncertainties  afford  individuals what  must  "safe"  a p p e a r s t o be no r e a s o n a b l e  conditions  which  establish  of use.  that  established  conditions  supply  to  there  assume  The f i r s t  second, whether those  to  i n t o t h e d e v e l o p m e n t and i m p l e m e n t a t i o n o f  whether  practicable  have  in  an i n d i v i d u a l i s e n t i t l e d  which t o d e c i d e is  requires  8  Thus, requires  he  6  organized  information  nor p r i v a t e groups c a n  information  process  procedures which assure followed.  5  some  confidence  be  government  users  The who  about  system, cannot  t o make an i n d e p e n d e n t  conditions  and t o determine  67  whether It  such c o n d i t i o n s are must  be  additional  information  are  individuals  are  reasonably  entitled a)  recognized  to  who  be  information  some  unable  ensure  The  types  of  characteristic.  It  is  steps  these  required It  are  conditions  These  heart  special  precautions  taken  to  characteristics  that  individuals  are  condition,  precautions  age,  be  taken  of  inform  are  and  which s h o u l d  be  taken  government  to  see  prospective what s p e c i a l  users  for  that as  to  precautions  are  f o r each. should  be  recognized  of  Industry  generally  is  developing  and  Operators  and  ability  or  information.  i n f o r m a t i o n has  communicating users,  on  resources  an  users.  short,  it  the  serves  basis,  developing must  be  to absorb these  individual for  development  c o s t s w h i c h may  information  T h u s , government  and  that  reluctant  e s t a b l i s h a process  operators,  In  tolerate  (e.g.,  responsibility  communication  funds or  to  These  use.  each  reasonable  require  about:  special  the  will  i s r e f e r r e d to above.  which r e q u i r e t h a t "safe"  individuals  f o r most p e o p l e .  Individual characteristics  to  what  that  met.  b e y o n d what  "safe"  pregnancy)  b)  may  being  either  for collecting  significant. costs  their  do and  not  unless  interests. have  the  communicating  provide funds  and  from  necessary industry, •>  is  the  responsibility  of  government  to  68  prospective  spa u s e r s t o :  - e s t a b l i s h t h e c o n d i t i o n s under w h i c h s p a s c a n be u s e d reasonable  safety  by  the  average  member  with  of the g e n e r a l  public. - provide  reasonable  assurance that a given  spa  meets  these  conditions. -  see  that  about  the  individual  precautions -  see t h a t about  public  be  the p u b l i c  has  What  suffer  funding  o f government  or " t h i r d  p o s i t i v e or negative group,  without  some l e g a l l y  redress  being a v a i l a b l e .  "Third-party from s p a o p e r a t i o n s disease  should  information  be t a k e n  f o r each  of c o l l e c t i n g  f o r d e v e l o p m e n t and c o m m u n i c a t i o n  from t h e e x t e r n a l e f f e c t s  (or  that  to  or e s t a b l i s h a process  i s the r e s p o n s i b i l i t y  individual  access  information.  "Externalities" those  special  special attention.  f u n d s f r o m t h e spa a c t o r s  2.  to information  which r e q u i r e t h a t  reliable  precautions  meriting  public  necessary  access  taken.  characteristic  of  reliable  characteristics  the s p e c i a l  - provide  has  of spa party  effects  operations?  effects"  may be d e f i n e d a s  upon t h e w e l f a r e  mechanism  one  of another  f o r compensation  or  9  c o s t s " c a n be imposed if  who may  c a u s e d by t h e a c t i o n s o f  firm, etc.)  recognizable  t o those  a  spa  from a s p a and l a t e r  upon t h e g e n e r a l  user  contracts  infects  non-users.  an  public  infectious  Such c o s t s can  69  also  be imposed on s p a u s e r s  where  an i n d i v i d u a l  by  another  cases,  costs  on o t h e r s  without amount the  a  user  c o s t s of t h e i r  interests  effects.  is  form  impractical suffering as  who may  It  to  compensate  these  type  of the  these  beyond  users  monetary  o f government  and  effects  do  not  bear  external  infection  of  adversely  disease.  affected  value.  Therefore,  t o see that users  take It  party  i s generally  is for  regarded i t i s the  of p u b l i c spas  assurance  n o t impose e f f e c t s a d v e r s e  t h a t governments cannot  such  protection.  and p a r t l y  control  over  Government  establishing  or  effects  that the to the h e a l t h  non-users.  i s recognized  uncertainties  users.  such  for representing  adverse  c o s t s because one's h e a l t h  of spas w i l l  assurance  absolute  usually  In a s e n s e ,  institution  t h e g e n e r a l p u b l i c have r e a s o n a b l e  both  of  (and  be v u l n e r a b l e t o a d v e r s e  o f spa o p e r a t i o n s some  being  operation of  both  activities.  of  responsibility and  In  1 0  In t h e c a s e the  users.  who b e n e f i t b u t  the r e c o g n i z e d  of those  situation  an i l l n e s s o r  compensation  o f t h e harmed p a r t y ) .  Government the  providing  t o s u b s i d i e s f o r the u s e r s  full  to other  a  b e n e f i t s f r o m spa o p e r a t i o n s b u t imposes  without  consent  in  n e g l i g e n t l y e n t e r s a spa w i t h  open wound and t r a n s m i t s a d i s e a s e these  user  This  provide is  due t o t h e i m p o s s i b i l i t y  the  performance  responsibility  the c o n d i t i o n s of safe  of  spa  therefore use  and  partly  absolute due  to  of maintaining operators consists  taking  steps  and of to  70  enforce  such  negligent as  operator  as d r i v i n g  In v i e w o f  an  determination communicated What  of  affected  parties,  be  affect  for  by  be  the  information that  role  of  operators,  of  the  exist,  activities,  spa  made w h i c h and  should  scientists,  industry  t h e p u b l i c i n such liberal  takes which  democratic  into are  weighing In o r d e r  to decide informed  their  relate  to be  these  a b o u t how  are  the by  and  affected  policy  public  preferences their  of  values  the and  objectives with  d e c i d i n g what  parties  users,  members of t h e  preferences,  alternative  the  "good"  e l e c t e d r e p r e s e n t a t i v e s are  they  general need  management p o l i c i e s and  what  risks  alternative  t h e means o f m o d i f y i n g  complex methods as  a  d i f f e r e n c e s and  f o r the  associated  r e p r e s e n t a t i v e s , and  theory,  account  differ,  government  decision-making?  determined  upon t h e i r  individual  Since e f f e c t s such  human  procedures  i n d u s t r y r e p r e s e n t a t i v e s , and  uncertainties 1 2  kinds of  to pursue.  well  of  still  nature  government d e c i s i o n s be  When p r e f e r e n c e s  responsible  --  scientific  the  with  process  public  and  design/operating  spa  decision  operators,  must  laws f o r o t h e r  spa  members of  In a c c o r d  course  liability  to the p u b l i c ?  administrators,  interests.  the  n e g l i g e n t user  s y s t e m of  technical  should  concerned  of t h e  should  r e g u l a t i o n of  Nonetheless,  automobile.  the  management, how to  and  i t d o e s under our  such  3.  conditions.  engineering  them a r e  design  of  to will and  policies.  1 1  determined spas,  the  71  chemistry  of  w a t e r and  d i s i n f e c t a n t s , microorganism  s c i e n t i s t s must be  employed  of  information  affected parties require  factual  determine and  their  preferences.  understanding  affected  parties  seminars, order  of  for  the  Securing  costs  etc.)  (e.g.,  These c o s t s  decision-making  decision-making  effective  system  to  for  to  a l l the  awareness  accounted  function  must, t h e r e f o r e ,  by  public  must be  most  participation  a l t e r n a t i v e management p o l i c i e s  involves  pamphlets,  that  generate  and  human p h y s i o l o g y , the  to  growth  for  properly.  have t h e  in The  following  key  features: 1.  A l t e r n a t i v e management p o l i c i e s  should  all  the  of  the  supplied 2.  a f f e c t e d p a r t i e s on  by  scientists  Government process, They  should  scientists, to  the  Where or  facilitate (b)  should  engage i n t h e  the  (a)  parties,  p a r t i e s to achieve  agreement c a n n o t be  individuals  the  and  of  scientific  (c)  to  decisions  authoritative, elected  for  (a)  establishing out  deciding;  them  for  individuals  accountable enacting  where  makers.  of  qualified information  negotiation  among  representatives  should it  have  the  i s necessary  for  representatives  or  legislation,  regulations,  programs.  decision  them must have r e s p o n s i b i l i t y  necessary  appropriate  implementation  to  the  consensus.  responsibility t o be  information  decision  utilization of  by  specialties.  reached, e l e c t e d  accountable  of  facilitate  role  communication  qualified  interested 3.  not  conceptualized  basis  with appropriate  administrators  but  be  and  (c)  (b) for  for  carrying  72  4.  In  order  for  function there  in  encourage  actors  individuals  In  a l l stages  the  decision  process  4.  all  principles, incurred  understanding interests.  spa  the  the  amongst  What d e t e r m i n e s t h e  to e l e c t e d o f f i c i a l s  of  the or  legislation  management s h o u l d officials,  and  use  industry and  be  and  open,  interests  for  accessible, being  represented  Government  decisions  representative  future.  An  on-going  groups  with  risk  e f f e c t i v e n e s s of  and  to  interactive  affected interests is vital  laden  the  e n t i r e d e c i s i o n process  process.  all  issues  spa  should  i n the  to  Further, a l l of  respecting  health  mechanisms  decisions  the  decisions  affected  of  provide  challenge  costs  properly  them.  toward  information  throughout  d e a l i n g with  to  However,  with  also  decisions  scientists,  competitive  should  a l l affected  appeal  policy  possible.  development of  and  government  j u d g e m e n t s of  wherever  democratic  participation by  to  c h a n n e l s e s t a b l i s h e d which a l l o w to  regulatory  liberal  for  accountable  summary,  and/or expert  be  process  provisions  policies  should  other  with  funding the  alternative  decision-making  accord  must be  there  the  for  uncertainty.  implementation  measures? Government into which  two  implementation  categories:  are  incentives  monitored which are  (1)  regulatory  through aimed  measures are  to  controls  enforcement induce  generally (or  classified directives)  p r o c e d u r e s , and  behavioural  changes  (2) in  73  those  people It  is  officials cannot  t a r g e t e d by p o l i c y that  would be f u l l y  be  present  compliance. are  unlikely  objectives. regulation  effective.  in  spa  1 5  ways t o c i r c u m v e n t  and  enforcement  public  health  through  uncertainties  officials  at a l l times  t o ensure  i f enforcement  officials  Third,  spa  regulatory controls.  procedures budgetary  enforcement  of  may  operators  Fourth,  may  monitoring  i n v o l v e c o s t s w h i c h a r e beyond  constraints.  officials  enforcement  a l l ,  operations  o v e r l y p e r m i s s i v e or n e g l i g e n t .  1 4  through  First  Second, problems can occur  find  1 3  does  Finally, nothing  regulation  toward  o r m o t i v a t i n g s p a o p e r a t o r s t o go  reducing  beyond  minimum  compliance.  Although reasonably certain  some p o t e n t i a l  defined  as " r i s k s "  known e f f e c t s  controlling a broader  these  from  hazards  basis  (e.g., drowning  c a n be e a s i l y  base o f i m p l e m e n t a t i o n  Effective  implementation  (a) w e l l - t r a i n e d  for users  measures  and  operators,  and  appropriate  determining  entrapment,  conditions  specified  for  and e n f o r c e d ,  i s necessary  (b) e d u c a t e d  t o have some d e g r e e o f c h e c k i n g  penalties  c a n be  to assure  o f s p a management a c t i v i t i e s  " s a f e " c o n d i t i o n s , (c) p e r i o d i c  provisions  from  spas  spas.  to  standards  associated with  hyperthermia)  "safe" conditions in public  require:  hazards  for  monitoring  failures  conditions  f o r funding monitoring  of  to  users  would and  a  on t h e a d h e r e n c e of spa f a c i l i t i e s comply  "safe"  and e n f o r c e m e n t  use,  with  the  and  (d)  procedures.  74  An  effective  provisions 1.  system  f o r the  Educating  operators to  (a) how  the  (b) t h e  spa  (c) the  the  meet and  3.  biological  standards  including  user with  aspects.  or c o n d i t i o n s the  under c h a n g i n g  readily  a spa  is  c h e c k t o see  Providing  with  precautionary  readily  and  simple  understandable that  instructions  to  means  i f standards are being  characteristics  measures  information expected  p r o v i d i n g , to the extent p r a c t i c a b l e ,  individual  spa  conditions in  understandable  or c o n d i t i o n s t h a t  users  its  standards.  whereby u s e r s can  about  make  t o meet.  to u t i l i z e  to adhere to  standards  functions,  and  f o r any  i s expected  P r o v i d i n g each on  system  techniques  order  measures s h o u l d  understand:  chemical  rationales  system  implementation  following:  engineering,  2.  of  met.  information  require  special  about  to  how  take  such p r e c a u t i o n s . 4.  Requiring periodic agency  and  standards 5.  by  an  funds  government  c l o s u r e s when  violated.  public from  appropriate  p r o v i s i o n s f o r f i n e s and  monitoring/enforcement  within  obtaining  our  having  are being  Establishing either  monitoring  health  other  procedures  budgetary  which  constraints  or  conditions  and  sources.  T h u s , t h e e x i s t e n c e of c o n t i n u o u s  variable  desire  minimum c o m p l i a n c e  to  see  practical  limitations  standards  through  o p e r a t o r s exceed to e f f e c t i v e typical  are  implementation  regulatory  of  procedures.  create approved 1 6  More  75  effective  measures  developing and  then  higher goals,  procedures  to  use  spa  incentives  management  process  can  develop  5.  What  implementation  very  and  under c o n d i t i o n s doubts  (2)  steps  are  learning  operators  motivating To an  (a)  r a t e of  i s necessary  to  to  "safe".  provide  with  social users  each.  f o r both  effective  spa management will  approved exceed  guidance  these  and  norms always  standards  Thus, a p r o c e s s  1 8  these  learning?  Uncertainties  attempts  " a p p r o p r i a t e " or  area  our  of  for a  interact  of h i g h e r  toward  o p e r a t o r s and  social  policy  whether  whether  either  environment  t h a t both  uncertainty.  operators  accomplish  to e f f e c t i v e l y  critical  about:  a d e q u a t e , and  t o a c t as a c h e c k on  1 7  the attainment of  through  p l a c e , so  i n f l u e n c e the  a  instituted  for  best  to e s t a b l i s h  the c a p a b i l i t y  is  be  norms.  to take  factors  This  to  for users  i t i s necessary  learning  leave  appear  to  are  approved for  social  deal  with  described in detail  using  uncertainty. A  social  sociological purposes, limited  the  definition "a  can  be  i s ongoing. process  of a s o c i a l  recursive allow  a c t i o n s can  However, t h e  process  psychological principles.  mechanisms  corrective  learning  and  t o mean  feedback  process  learning  then  More are  important  or  taken  complete  learning  iterative  evaluation be  of  simplification process  process" results  will  descriptions  from  to p o l i c y  1 9  Dunn,  of 2 0  be  whereby which  to adjust c o n d i t i o n s .  p r o v i d e d by M a c k , element  For  a  and  considerations  This social  others. is  the  76  recognition  that  uncertainty  creative  and r a i s i n g  Uncertainty  is  efforts  standards  a  are  vital  to dealing  with  i n spa management.  dominant  characteristic  of  the  spa  r management the  problem.  nature  of pathogens  controlling (e.g.,  the  water  environment and  The  environment  respond  thus  to  improve  This  unpredictable  enforcing  discussion  regulatory  of  organism  the  and p u b l i c h e a l t h  officials  participate  i n the e f f o r t  reduce  management continuation  apply  practices.  the  Existing  in  we  of  applies  be  least  or behaviour  (e.g.,  may  spa  environments,  by o p e r a t o r s , e t c . ) of e f f e c t i v e l y  indicates  that  users,  need t o be s t i m u l a t e d  gained  uncertainties  of v a r i a b l e c o n d i t i o n s  from  o f s p a management  a l l three  knowledge  to p r o f i t categories  difficulties  operators,  and  health  which pose the g r e a t e s t  events  measures  uncertainty  spa  operators,  recognition  since  control  to  three  the c a p a b i l i t y  or extremely c a r e l e s s a c t i o n s  Previous  the  public  i s needed  uncertainty  a p p e a r a n c e o f a new p a t h o g e n i c malicious  various  foregoing  public health.  handle  of  spa management p r a c t i c e s .  t o a r e a s of r e a l  to  ways  e t c . ) of  a n d ( c ) t h e way u s e r s ,  to disrupting policy objectives  prepared  and  (b) t h e p h y s i c a l e f f e c t s  and d e t e r m i n e d e f f o r t  to protect  especially  spa  disease,  so a s t o r e d u c e t h e and  u n c e r t a i n t i e s I r e l a t e t o : (a)  disinfectants,  will  in actual  uncertainty  threat  of  temperature,  conscious  practices  the  on c e r t a i n u s e r s ,  arrangements  experience  in  spread  public o f f i c i a l s  A  primary  categories  to of  t o improving spa and  i n spa e n v i r o n m e n t s  expected require  77  greater  knowledge  effects, spa  spa  operators  from of  and  to  determining  gained  actors'  can  standards  be  deal  behaviour  is unavailable  (e.g.,  they  and  stronger  the  i n t e r v a l s for draining  standards,  Psychological  and  pathogens,  with v a r i a b l e conditions  A l t h o u g h p e n a l t i e s may and  about  be  to  and  factors  i n a r e a s where p o s i t i v e l e a r n i n g situations.  situations  also  for  groups  design it  identify  be  noted  and  relevant  i n economic  terms.  c u r i o u s i t y can  incentive  measures.  Positive expenditures. best  needs t o  The  Factors  a l s o be  These c o s t s  should  resolve  within  pride,  care  and  to  Finally,  2 2  be  the  required  experience  thought  altruism,  to advantage  require  current  in  of and  developing  be  current  and  a n t i c i p a t e d and  understanding  of  future  planned  spa  for  management  uncertainty.  above c o n s i d e r a t i o n s  Public  health are  not  to  2 3  may  possible  successful  thereon.  should  of  used  incentives  "good" s y s t e m of -  incentives  positive  i s important  comparative  report  learning.  most  positive incentives  that  learning  as  of  social  the  i m p r o v e d management p r a c t i c e s b a s e d  should  solely  i n d i c a t e that  to  being  Studies  2 1  problem  regulations  emphasizes  motivation  outcome of  as  that  guidance  stated  to enforce  literature  reinforcement  where  earlier  unsuited  sociological  assurance  spas).  necessary  are  physical  spa  to  the  management r e q u i r e s  health  aware t h a t  lead  the  officials reduction  and of  conclusion  that  a  that:  operators  are  made  uncertainties  and  keenly the  78  capability challenging -  to  deal  task  faced  with  surprises  officials,  concentrated  operators,  effort  the  most  i n s p a management.  P o s i t i v e incentives are provided health  is  to  stimulate  public  and u s e r s t o engage  t o reduce the three  in a  categories  of  uncertainties. - A  system  create  for  funding  awareness of u n c e r t a i n t y  i n c e n t i v e s must management This  be  and t o p r o v i d e  established  to  the d i s c u s s i o n  o f spa p o l i c y d e s i g n .  Although  a r e worthy of e x h a u s t i v e d i s c u s s i o n ,  reader  h a s been a b l e  section  and  their  of t h i s  criteria  From needed  to conceptualize relation  chapter  the  for Evaluating preceding  f o r addressing  reduced  experience policy  any  one  of  the  i t i s hoped t h a t t h e  from t h e s e p r e m i s e s  to alternative  of  these  The  final  evaluative  policies.  A l t e r n a t i v e Spa P o l i c i e s of the t h e o r e t i c a l premises  s p a management  p o l i c y i s s u e s , a v a r i e t y of  evaluative  to  provide  criteria  i n t h e U.S. a n d  for British  needs.  t h e main t h r u s t  a  basis  of e x i s t i n g and p r o p o s e d p o l i c i e s . to  spa  discussion  a r e a s have been c o v e r e d merits  current  to the p o l i c y design.  distills  w h i c h c a n be a p p l i e d  Criteria  meet  positive  of t h e o r e t i c a l premises f o r  areas  premises  learning aspects to  needs and t o a n t i c i p a t e f u t u r e  concludes  consideration  the s o c i a l  Columbia.  Canada  judging  the  T h e s e p r e m i s e s c a n be  applicable and  for  to  These a r e as  t o s p a management designing  follows:  a  model  79  Criterion provide hot  1 - Has government a c t e d  reasonable assurance  of " s a f e "  use of p u b l i c  that  s p a s and  tubs?  a) Government must (governing  take p o s i t i v e a c t i o n  standards)  reasonable assurance members  of  users w i l l b) Government  which,  that  the general be  must  take that  from  spa u s e .  Government must  p u b l i c and t h a t  to  adhere  reliable  characteristics as  well  use  people  be t a k e n  to  standards  to  may  by  most  of non-  to avoid  require hazards  for identifying public  for  "safe"  to information  require  u s e by most  to achieve  a s s u r e members o f about  individual  s p e c i a l precautions  a s i n s t r u c t i o n s a b o u t how  e) Funds n e c e s s a r y  health  the  public.  access  that  identify  have w h i c h  d) Government must e s t a b l i s h p r o c e d u r e s t h a t public  provide  the h e a l t h  action  e s t a b l i s h procedures  members o f t h e g e n e r a l  the  conditions  followed,  a spa i s " s a f e "  some  s p e c i a l precautions  that  if  positive  that  spas  to i d e n t i f y  protected.  characteristics  c)  to establish conditions  t o take  such  be  taken,  precautions.  t h e above s u b - c r i t e r i a s h o u l d  be  provided.  Criterion  2 - Are "safe" c o n d i t i o n s  processes  i n which users,  operators,  of use e s t a b l i s h e d and the p u b l i c  through  have  conf idence? a) A l t e r n a t i v e government management p o l i c i e s conceptualized  by a l l a f f e c t e d p a r t i e s  f o r s p a s must  (users,  be  operators,  80  industry basis  representatives,  of  information  and  the  supplied  g e n e r a l p u b l i c ) on  to  them  by  the  qualified  scientists. b)  Procedures reconcile with  should  exist  differences  decisions  to  be  be  "safe"  a)  Provisions the  f u n c t i o n i n g of  standards,  and  conditions) b)  Procedures and  practicable, whether c)  Procedures informed  must of  precautionary instructed  as  systems,  to  are  processes  undertaken  for in  to  implement  spas?  operators to  the  rationale  utilize  understand  for  approved  (under  changing  standards.  simple  and, users  seeing  that  characteristics be  about to  standards the  to  extent  check  on  individuals  are  met.  for  individual  use  means f o r  being  exist  t o how  be  utilized  to  "safe"  measures  exist  r e p r e s e n t a t i v e s or  for informing users  of  provide  standards  can  of p u b l i c  techniques  must e x i s t  spas.  should  that decision  made t o e d u c a t e  to adhere  conditions  processes  spa  parties  sub-criteria.  " s a f e " use  must be  for  procedures  elected  conditions  effective  c o n d i t i o n s which assure  by  t o see  c o n f o r m a n c e w i t h t h e above  3 - Are  i s made t o  t o them.  be p r o v i d e d  establishing  reached,  made  accountable  Funds s h o u l d  Criterion  effort  r e g a r d t o government management p o l i c i e s  individuals d)  w h i c h an  of p r e f e r e n c e s among a f f e c t e d  c ) Where agreement c a n n o t for  through  taken  t o f o l l o w such  and  that  that  require  individuals  precautions.  are  81  d)  An  a p p r o p r i a t e government a g e n c y must p e r i o d i c a l l y  spa  operations  possibly  administer  be  future  provided  needs  or  be  fines  and  violated.  implementation  considered.  the  of  measures,  Funding  industry should  be  obtained  considered  alternative.  4 - Do  Criterion  are  to enact  should  from u s e r s , o p e r a t o r s , a s an  penalties  c l o s u r e s when s t a n d a r d s  e) Funds s h o u l d and  and  monitor  spa  management p r o c e s s e s  progressive  advancement  uncertainty  and  thus  of  knowledge  provide  stimulate  in order  to  the  reduce  a b a s i s f o r improved  spa  management? a)  Public health o f f i c i a l s that  the  deal with spa b)  and  o p e r a t o r s must be  r e d u c t i o n of u n c e r t a i n t i e s and  keenly  aware  the c a p a b i l i t y  s u r p r i s e s i s t h e most c h a l l e n g i n g t a s k  faced  to in  management.  Positive health  incentives  officials,  effort  uncertainties  by  should  an  to  practices  in accordance  experience  process  should  can  U.S.-Canadian e x p e r i e n c e  be with  to stimulate p u b l i c  users the  social  and  with  c ) Funds t o p r o v i d e p o s i t i v e  criteria  and  key  in  new  a  c a t e g o r i e s of  indicators  adjustment  this  engage  three  of  This of  spa  management  knowledge.  i n c e n t i v e s and  be  to  learning process.  i n v o l v e r e c o g n i t i o n of  from  These  provided  reduce  on-going  problems  learning  be  operators,  concentrated  process  must  establish  a  social  provided.  used to q u a l i t a t i v e l y spas,  as  well  as  to  evaluate guide  the the  82  design also  o f a model become  a  spa p o l i c y means  implemented p o l i c y . premises  to  management premises  test  for The  the  for British  alternatives identified.  actual for  next actual  chapter  is  uses  experience  experience,  policy  The c r i t e r i a  judging the e f f e c t i v e n e s s  i n t h e U.S. and C a n a d a . with  Columbia.  the  to  By c o m p a r i n g a  examined,  range and  date  of  future  theoretical with  spa  the t h e o r e t i c a l of  reasonable  deficiencies  are  83  Footnotes - Chapter 3 E d i t h Stokey and R i c h a r d Zeckhauser, A Primer f o r P o l i c y A n a l y s i s , (New Y o r k : W.W. N o r t o n & Co., 197QT. 1  Economic 1981).  C o u n c i l o f Canada,  2  Reforming R e g u l a t i o n s ,  (Ottawa,  " T o x i c S u b s t a n c e P o l i c y a n d t h e P r o t e c t i o n o f Human H e a l t h " by P a u l R. P o r t n e y , P a u l R. P o r t n e y , e d . , C u r r e n t I s s u e s i n U.S. Environmental P o l i c y , Resources f o r the Future, (Baltimore: John H o p k i n s P r e s s , 1978), p p . 105-143. 3  "J.H. D a l e s , P o l l u t i o n , Property, Buffalo: U n i v e r s i t y of Toronto Press,  & Prices, 1968).  (Toronto  and  Richard Zeckhauser and C h r i s t o p h e r Zook, "Failures to C o n t r o l H e a l t h C o s t s : D e p a r t u r e s from First Principles", pp. 87-116, A New A p p r o a c h t o t h e E c o n o m i c s o f H e a l t h C a r e , Mancur O l s o n , e d ~ ( W a s h i n g t o n , D.C. a n d London: American Enterprise I n s t i t u t e f o r P u b l i c P o l i c y R e s e a r c h , 1981). 5  Robert G. E v a n s , P h y s i c i a n S e r v i c e s , (Ottawa: 6  P r i c e Formation i n the Market f o r I n f o r m a t i o n Canada, 1973).  B a r u c h F i s c h o f f , Sarah L i c h t e n s t e i n , Paul Slovic, Stephen L. D e r b y , and Ralph L . Keeney, A c c e p t a b l e R i s k , (Cambridge: Cambridge U n i v e r s i t y P r e s s , 1981). 7  G. Bruce Doern, The P e r i p h e r a l N a t u r e o f S c i e n t i f i c a n d Technological Controversy"in Federal P o l i c y Formation, (Hull, Quebec: C a n a d i a n Government P u b l i s h i n g C e n t r e , 1981 ) . 8  Jack Hirschleifer, P r i c e Theory and A p p l i c a t i o n s , second e d i t i o n (Englewood C l i f f s , N . J . : P r e n t i c e - H a l l I n c . , 1980). 9  1 0  Stokey  a n d Z e c k h a u s e r , op. c i t .  John Okay, Natural Resources: L. L i t t l e , Robert Colorado: Westview 1 1  "Economic Forces", pp. 78-100, Renewable A Management Handbook f o r t h e 1980's, D e n n i s E. D i l s , a n d John Gray, ed., (Boulder, P r e s s , 1982).  Irving K. F o x , " I n s t i t u t i o n f o r Water Changing World", Natural Resources J o u r n a l , O c t o b e r , 1976. 1 2  1 3  1  Z e c k h a u s e r a n d Zook, op.  "Economic  Andrew An A s s e s s m e n t 1 5  Council  o f Canada,  Management i n a 16: 743-758,  cit. op. c i t .  R. Thompson, E n v i r o n m e n t a l R e g u l a t i o n i n Canada: of the Regulatory Process, (Vancouver, B.C.:  84  Westwater 1 6  Research Centre,  Z e c k h a u s e r and  1980).  Zook, op. c i t .  Graham Atkinson and J a c k Cook, " R e g u l a t i o n : Incentives R a t h e r Than Command and C o n t r o l " , pp. 211-218, Mancur Olson, op. c i t . 17  1 8  Fischoff,  1 9  Ruth P. Mack, & Sons, 1971).  Wiley  e t . a l . , op. c i t . P l a n n i n g On  Edgar S. Dunn, Jr., P r o c e s s of S o c i a l L e a r n i n g , 1971 ) . 2 0  Uncertainty,  Economic and (Baltimore:  Social John  (New  York:  John  Development: A Hopkins Press,  J o h n a t h a n L. Freedman, J. Merrill Carlsmith, and David 0. S e a r s , S o c i a l P s y c h o l o g y , (Englewood C l i f f s , N . J . : PrenticeH a l l , I n c . , 1970). 2 1  2 2  2 3  Z e c k h a u s e r and Ruth  Zook, op. c i t .  Mack, op. c i t .  85  CHAPTER 4  Experience There  i n t h e U.S.  h a s been a d i f f e r e n t  emergence o f s p a s and h o t t u b s concern. using can  We  need  the c r i t e r i a be  British  evaluated  t o look  and Canada  response  as a  i n each c o u n t r y  public  health  at experiences  of the p r e v i o u s as a guide  i n both  chapter,  and  safety  and t h e n , by  existing  to structuring  to the  practices  s e t of p o l i c i e s f o r  Columbia.  B a c k g r o u n d o f t h e U.S.  Experience  Scope o f S t u d y Investigation a  review  actors the  o f t h e U.S. e x p e r i e n c e  of the l i t e r a t u r e (a l i s t  end o f t h i s  examined articles,  and i n t e r v i e w s w i t h  o f main s o u r c e s chapter).  The k i n d s  magazine  articles,  c o d e s , and g u i d e l i n e s , (5) specifications, (7)  are provided of  scientific  studies,  (8)  the  various  spa  i n the footnotes a t which  were  j o u r n a l s , (2) newspaper  (4) p o o l and s p a s t a n d a r d s ,  manufacturers'  and i n s t r u c t i o n s ,  spas c o n s i s t e d of  literature  i n c l u d e ; (1) p o o l and s p a t r a d e (3)  with  product  literature,  (6) government a g e n c y r e p o r t s ,  public  h e a l t h j o u r n a l s , and (9)  correspondence.  Personal federal,  and phone  state,  and  interviews local  were  conducted  with;  p u b l i c h e a l t h and s a f e t y  (2) members o f t h e N a t i o n a l Spa and P o o l  Institute,  (1)  officials,  (3) i n d u s t r y  86  scientists  and  managers, and researchers,  other  Federal, varying  (5)  maintenance people, (6)  and  spa  state,  degrees.  (4)  representatives,  users  and  The  and  local  spa  operation  independent  owners,  scientists  and  non-users. jurisdictions  research  focused  were e x a m i n e d  on  the  to  following  jurisdictions: 1.  Federal  (the  2.  The  State  of  3.  The  State  of  4.  Cook and  DuPage C o u n t i e s  5.  The  of  6.  Various  suburban  Arlington  Hts.,  City  two  main a g e n c i e s  i n v o l v e d ; CDC  and  CPSC)  Illinois Oregon in  Illinois  Chicago municipalities  Mt.  Prospect,  outside  Chicago  (e.g.  Schaumberg,  Downers  Grove,  Palos). The  s t a t e s of  represented Illinois of  the  has  public with  s p a s and  The  local  with  state  spas.  from  and  helps  Oregon.  regulatory a c t i v i t y with (with  the  minor built  been one  of  active  separate  the  standards  a l s o represented survey  of  provided  the  a the  and  codes  r a n g e of  spas.  with  new  states  for  spas.  regulatory  literature  and  f u r t h e r knowledge  about  jurisdictions.  substantiate  most  they  exception  when s p a s a r e  The  local  because  permits  interviews  and  s u p p l e m e n t s and Illinois  devised  Oregon were c h o s e n  p u b l i c spas  O r e g o n has  jurisdictions  information other  regulated  has  and  extremes of  construction  pools).  activity  two  not  issuing  Illinois  This  information  information obtained  from  87  Initial the  research  a p p l i c a t i o n of  i n d i c a t e d that  swimming p o o l  deficient  p r a c t i c e , and  in  practice  this  conclusion 1.  The  are  CDC  as  officials  The  4.  5.  not  examined.  and  CPSC  the  the  pool  j o u r n a l s and  adopt  separate  permit  regulation  separate In  spa  and  spa  reviewing  emphasis  officials  also  was  continued  reasons  clearly  for  this  show  necessity  of  interviews  agreed  that  regulated spa  that  treating  indicated  separate  spas  for  s t a n d a r d s and  in trying  in  to c o n t r o l  Illinois  regulation  of  spas by  jurisdictions  conclusion  a  spa  several  codes  spa  after  hazards  by  criteria.  health  local  the  through  separate  problems  Public  The  was  necessary.  realizing of  The  upon  pools.  chose to adopt  use  codes,  w h i c h have  reports  s t a t e of O r e g o n , w h i c h has  years,  and  jurisdictions  representatives  s t a n d a r d s were 3.  standards  have r e c o g n i z e d  from  in trade  industry  r e g u l a t i o n , based  follows:  spas s e p a r a t e Quotes  were  guidelines  federal  2.  hence  spa  some  the  in  s t a n d a r d s and the  they  would  were a v a i l a b l e  to  state. also the  concurred process  with  of  this  initiating  codes.  literature  placed  i f funding  studied are  indicated  and  upon  interviewing  the  following  spa  actors,  categories  of  information: 1.  As  perceived  hazards u s e r s and  by  the  associated the  public  various with  spa  spa  exposed  actors,  use  and  to these  what a r e  the  t o what e x t e n t hazards?  health are  spa  88  2.  What  efforts  industry, public  are  and  being  spa  taken  operators  by to  of the p o t e n t i a l hazards  Who  determines  regulation? they 4.  spa  standards  agencies,  i n f o r m spa u s e r s and t h e  and  a v o i d i n g c o n d i t i o n s of p o t e n t i a l 3.  government  about  procedures  for  hazard? and  other  instruments  What do t h e s e p o l i c i e s c o n s i s t o f a n d  how  of are  developed?  How  are  existing  i m p l e m e n t e d by p u b l i c understand  how  standards  and  other  health  agencies  policies  and  do  spa  being users  t o e v a l u a t e t h e c o n d i t i o n s of p a r t i c u l a r spa  facilities? 5.  Do t h e v a r i o u s s p a a c t o r s u n d e r s t a n d involved  in  spa  management  with u n c e r t a i n t y i n order is  being  done  to  what u n c e r t a i n t i e s a r e  and the importance  t o improve spa  reduce  of d e a l i n g  management?  uncertainties  and  What  improve spa  management?  A B r i e f D e s c r i p t i o n o f t h e U.S.  Experience  A d e t a i l e d d e s c r i p t i o n o f t h e U.S. e x p e r i e n c e in  Appendix  D.  The f o l l o w i n g  summary  i s merely  b a c k g r o u n d f o r t h e e v a l u a t i o n o f t h e U.S. As  described  in  earlier  pools  or  (2)  ignoring  knowledge and c o n c e r n this  general  and  avoiding  about h a z a r d s ) .  attitude,  mostly  in  provided  intended as a  experience.  chapters,  r e s p o n d e d t o s p a s i n one o f two w a y s : ( 1 )  is  the  U.S.  initially  t r e a t i n g them a s s m a l l them  (due  to  l a c k of  T h e r e were e x c e p t i o n s  to  t h e i n d u s t r y s e c t o r , where  89  anticipation  of  spa  differences stimulated  changes/innovations. began  to  As  information  communicate  knowledge  differences  throughout  operators.  Although  of  the  of  legislation,  across  the  country.  taken  place,  outlook  on  have  and  and  seemingly Since  must be logical  its  spas'  where p o s s i b l e , t o  action  warnings,  in developing  and  shift  has  are  can  occurred  be  relating  correspondingly  to  s t r a i g h t f o r w a r d , was  uniform  action i n the  water  has U.S.  as  different  spa  adjusted.  aware  ( i n terms  not  described  significantly  spa  educational  a major  matters  acceptance,  have been  considerable  spas  and  may  year,  shift  experts  characteristic  past  This  that  slow  product  industry  official  standards,  been  thus,  hence a l l  management  e a r l y date,  In t h e  spas.  acknowledgement  of  public health o f f i c i a l s  codes,  etc.)  developed,  i n d u s t r y and,  d i f f e r e n c e s a t an  programs,  pools,  the  r e s e a r c h and  an than  quality  This recognition,  not  though, a t u r n i n g p o i n t  quickly  gained.  for a c t i v i t y  was  reached. The  U.S.  t h r e e main 1) No 2)  kinds  of  Regulation  spas u s i n g e x i s t i n g controls (this  modified  e.g.,  of  suit  unique  swimming  to  include a  maximum t e m p e r a t u r e  Regulation the  pool  be  categorized  into  spas  regulatory  slightly spas,  of  t o spa management can  policies:  r e g u l a t i o n of  and  3)  approach  spas u s i n g  swimming  k i n d of p o l i c y few  special  standards  i s sometimes  provisions  for  limits).  standards  specifically  characteristics  regulatory  pool  controls  of  spas. are  often  designed  to  Traditional used  in  90  conjunction efforts spa  with  hazards  procedures  the  and  special  f o r adhering  jurisdictions  where  are  spas  jurisdictions  still  the  of  process  jurisdictions criteria, These evaluating below,  the  the  deficient third  already  a  in  two  with  approaches  is  of  set  most  of  spa  to  examine  jurisdictions  been d i r e c t e d  first  than  type  of p o l i c y  pools.  Some  but they  are i n  standards. t o use  Fewer  swimming  numbers.  a general basis f o r  spas.  For  the  reasons  may be g e n e r a l l y c o n s i d e r e d the e v a l u a t i v e c r i t e r i a .  interest  to  policies  for British  exist the  where  toward  spa  form  and  or i n depth), the  or continue  approaches  to  spa s t a n d a r d s .  represent s i g n i f i c a n t  s e r i o u s weaknesses a l s o  1) No r e g u l a t i o n The  still  policy  first  instructive  policies  t o r e g u l a t e spas  and i n c a p a b l e of meeting  recommending  most  specific  U.S. e x p e r i e n c e  approach  Although  to  and  rationales,  the t h i r d  differently  Some  potential  required  u s e swimming p o o l s t a n d a r d s ,  but they  basic  about  briefly  t o be toward  changing  fail  users  to the s p e c i f i c  treated  standards.  standards,  studied (either  trend appears  spa  precautions  o p e r a t o r s about  major p o l i c y  pool  specific  a r e u s u a l l y made t o i n f o r m  train/educate  In  these  the  in this  objective  The of  Columbia.  approach,  i t is  s t r e n g t h s and weaknesses o f considerable  regulating  efforts  have  spas.  of spas  kind  of  policy  ( o r more  precisely,  lack of  91  policy)  i s sorely  responsibility hazards  and  deficient  of  because  government  uncertainties  acknowledged,  and  it  with public  associated  hence  denies  users  spas.  with  and  the  public  are  both  hazards.  other  three  the  potential not  potential  result,  The  and  are  about  a  role  spas  u n p r o t e c t e d and p o o r l y i n f o r m e d As  the  public  criteria  health  cannot  be  satisfied.  2)  R e g u l a t i o n of spas  using existing  swimming  pool  s t a n d a r d s and  regulations The fails of  second  t o meet  policy  current  fails  t o meet  swimming better  regulation  at  potential  with  creates  some  for  because  jurisdictions,  of  this  hazards  deficiencies  spa  regulations  users  and  This kind  i t largely  knowledge about  s t a n d a r d s and  a l l , failure  the  in  f o r much t h e same r e a s o n s .  and s c i e n t i f i c pool  used  the c r i t e r i a  protection  recognize spas  policy,  the c r i t e r i a  technical  Although afford  kind of  the  policy  ignores  management.  may  possibly  public to  than  no  adequately  and u n c e r t a i n t i e s a s s o c i a t e d with  regard  to  a l l of  the  criteria.  3)  Regulation  of spas  using standards  specifically  designed f o r  spas  The  third  associated except  the  kind of p o l i c y  with  spas  decision  and  r e c o g n i z e s the tends  process  potential  hazards  t o meet a l l o f t h e c r i t e r i a ,  criterion,  where  it  fails  92  completely.  With  e x a m i n a t i o n of this  kind  principal them.  kind  the  of  to  pathogenic  actor  criteria,  i t has  s u b - c r i t e r i a exposes.  policy  Failure  spa  other  is  its  u n c e r t a i n t i e s and  n a t u r e of and  the  fully  a  lack  lack  of  of  recognize  The full  the  We  can  looking  at  most of  management are  the  main  the  development  categories  the  to  of  deal  involving  actors  picture. interested  of  who  are  of  response  participants. involved  C e r t a i n l y , there groups.  criteria  may  The  i n the be  so  to  others,  but  the  this  spas  overall  the  spas  that  chart  of  with  s t a n d a r d s , p h y s i c a l c h a r a c t e r i s t i c s of  p o l i c y i s d e f i c i e n t in a l l areas.  depicts  which  failure  recognition  uncertainties  of  the'  chief  strategy  b e h a v i o u r a f f e c t s a l l of  consider  weaknesses  by  below spa these  93  The  U.S.  S t r u c t u r e Of  Organizational Spas & Hot  Federal  Agencies  State  CDC CPSC Public Health J o i n t Committee on Swimming & Bathing EPA  Involvement with  Tubs  Agencies  Various state Public Health Departments State Envi ronmental Agenc i e s  Industry  Operators  NSPI (Wash.) NSPI ( L o c a l Chapters) ISTI ( L o c a l & National) I n d i v i d u a l Firms Other A s s o c i a t i o n s ( s u c h as ASPI)  H i g h Use P u b l i c Facilities Low use P u b l i c Facilities H i g h Use Commerc i a l /Private Low Use Commerc i a l /Private  Not-For-Profit  Users  - Am. Public Health Assoc i a t ion - NSF - C o n f . of S t a t e S a n i t a r y Eng. - Others  Social/ Recreational Therapeutic Occasional Users  Media -  Public  Trade Publications - R a d i o , TV - Newspapers  Local County H e a l t h Departments Municipal Health Departments Municipal Officials Organizations Code & A p p r o v a l Organizations UL IBOC IAMPO Others  Research Universities Foundations Individual Researchers  94  The The spa  Actors  key a c t o r s  operators,  state,  and  important public  And T h e i r  spas  users,  agencies.  role in  spa  and  (d)  Each  of  establishing  through  appropriate  To The System  i n t h e U.S. s p a s y s t e m a r e (a) i n d u s t r y ,  ( c ) spa  local  Relation  the these  "safe"  and  federal,  actors  conditions  implementation . of  management  various  have an  of  current  (b)  use  in  knowledge o f  development  of  improved  practices. Industry a  leading  has dominated the s i t u a t i o n t o d a t e .  actor  information, regulations, In has  development  (c) education,  including of  and (d)  "safe"  that  provision  guidelines  o f spa p r o d u c t s ,  potential  hazards  d e v e l o p e r and p r o d u c e r rely  upon  of  use.  spa  operating  conditions  Growth and s t a b i l i t y o f  on t h e p u b l i c ' s  Also,  industry's  o f spa p r o d u c t s c a u s e s  i t for current  and  industry  perceptions  the r e c r e a t i o n a l / t h e r a p e u t i c b e n e f i t s of spas weighed  the  of  research/studies.  by t h e p u b l i c .  s p a market a r e h i g h l y d e p e n d e n t  (a)  standards,  and p r o d u c t i o n  i n t e r e s t i n seeing  considered  the of  (b)  a l l areas,  the development  a strong  are  in  I t h a s been  knowledge and new  against  r o l e as the  other  actors  information  to  about spa  management.  Spa In  operators  their  facilities, "safe"  and u s e r s  respective  roles  t h e y a r e t h e most  conditions  are "the heart" as  providers  important  o f t h e spa system. and c o n s u m e r s o f s p a  actors  and r e s o l v i n g u n c e r t a i n t i e s .  in  establishing  The v a l u e s  and  95  behaviour of operators of  spa  use  conditions  roles  of o p e r a t o r s  other  actors  management  and u s e r s  health  officials  in administering  for  establishment  uncertainties.  to  actors  in to  mediate  serve  of  structure system, the  outcomes The  the e f f o r t s of  with  as  intermediaries  i n t r y i n g t o communicate  "safe"  respect  the  conflict  to  cannot  or  be r e a c h e d .  considered  conditions  that  and  conflict decisions  decisions  and  knowledge  resolution  that  among  officials  elected  Various  government  either  officials  the a c t i o n s  framework p r o v i d e d  seek when  health  own, b u t h e a l t h  officials officials  officials.  To e v a l u a t e taken  the  jurisdictions  above d e s c r i p t i o n summarizes t h e s p a management i n t h e U.S.  of  d e t e r m i n e and  advise  a c t on t h e i r  between  essential  occurs  certain latitude for public  remain a c c o u n t a b l e t o e l e c t e d  The  to "test"  procedures which a r e  In t h e event  t h e U.S. a l l o w make  both  "safe" conditions, public health  agreements  actual  i n f l u e n c e the performance of t h e spa  and o p e r a t o r s / u s e r s  establish  the  the f u r t h e r i n g o f knowledge. serve  and t o g r e a t l y  and  other  and  determine  system.  Public industry  and u s e r s  system  the a c t u a l performance of the  by U.S. s p a a c t o r s  by t h e c r i t e r i a  of t h i s  a r e weighed thesis.  within  96  Analysis  1.  of  the  U.S.  Experience  G o v e r n m e n t a l R o l e s and R e s p o n s i b i l i t i e s  a)  Have  U.S.  positive  public  health  action  to  standards) assurance of  the  will On  a  which, that  general  be  with  hyperthermia.  level,  regard The  CDC  which cover c r i t e r i a operation outbreaks  of  1)  questionable,  that  has  CPSC  developed  for design, has  the  CDC  though,  most members  identified  information  supplied  and  be  of  non-users  management  following  developed by  or  fail  and  and  guidelines,  installation  research  on  and  disease  bacteria.  i t s research  The  program  reasons.  with considerable  industry  to  hazardous  entrapment  Legionella  recommendations  biased  from  construction,  f o r the  upon  Because  by  has  spa  guidelines  were  reasonable  reasonable  health  a l s o undertaken  guidelines  possibly  provide t o use  taken  (governing  the  drownings  The  through  supplied consider  by all  reliance  NSPI.  The  NSPI  could  available,  options.  of  constraints, spa  and  i n v o l v i n g Pseudomonas and  information  2)  i s "safe"  the  to  s p a s , and  c o m p r e h e n s i v e n e s s of are  conditions  followed,  a spa  agencies  protected?  federal  conditions  safety  identify  if  public  and  innumerable the  pathogenic  CDC  has  hazards.  other not  public  health  concerns  e x a m i n e d a r a n g e of  Research a c t i v i t i e s  toward examining p o t e n t i a l p a t h o g e n i c  hazards  and  potential  are  oriented  after  they  97  occur  and  are  considered 3)  The  CDC  has  not  Although  positive  agencies of  to  the  particularly  local  work  with  relating  efforts,  trade  By  jurisdictions policies  King used  modifications such and  as  1  2  the  are  as  been  limited  4  with  "safe  use",  open t o  undertaken s t a t e of  and  studies  by  State not  according  to  health  state  Oregon's on and  spa local  effectively reports  in  officials  federal agencies  for  conditions  O r e g o n , U t a h , Dade C o u n t y These  the and  (containing  establishing  spa  of  use  whole  in  appear to part,  have making  C h i c a g o , have m e r e l y t r a n s f e r r e d swimming p o o l  policies  of  spas  local  or  Seattle-  Others  area  suit  "safe"  in Florida,  jurisdictions  in  municipal  conditions.  s t a n d a r d s t o the  to  question  5  identify  necessary  by the  by  the  and  responsibility  guidelines  spas.  taken  i n d u s t r y ) , some s t a t e , c o u n t y , and  have t a k e n  CDC  3  cases  hazards.  (e.g.,  made  on  been  in C a l i f o r n i a ) .  work of  in Washington).  the  for  problems  statements  which  County  agencies  jurisdictions  from  California,  work has  been  representatives.  input  conditions  County  have  among  statistics  clearly  to pathogenic  Alameda  primarily using  strong  i f such outbreaks  deaths a s s o c i a t e d have  Pseudomonas  j o u r n a l s and  industry  only  t h a t have been t a k e n a r e  health  however,  coordinated  or  actions  research  to  by  illness  regard  public  management  and  to compile  identify  steps  Some o r i g i n a l  (e.g.  attempted  disease,  adequacy  --  significant.  involving  federal  and  reported  (although  such  jurisdictions  98  may  be  i n the process  s p a s and a d o p t i n g have  not  and  overlapping has  Wisconsin).  other  spa  Overall, the  question  with  identify  levels  Inconsistencies For instance,  much  municipalities  t h e U.S. e x p e r i e n c e  the  clearly  and u s e r s  to  have  among  have  Third,  been  defined  as of  user  to  action  Second, c o n d i t i o n s f o r  open  seem  hazards  the e f f i c a c y  measures conditions  (note,  the  required that  Although,  derived  to  be see  of d i s i n f e c t a n t s  indicating  safety  behaviour  showering p r i o r  varying  answer  t h e j u r i s d i c t i o n s and  well developed.  of  relate  conditions  f r o m swimming  t o use, not e n t e r i n g  need  spas  pool when  wounds, e t c . ) c a n be r e a d i l y a p p l i e d t o  the s p e c i a l operator  the widely  such  a process  mixed  hyperthermia  t o meet t h e s p e c i f i c  not  (e.g.,  individuals  in  Illinois  a g e n c i e s have t a k e n  than pathogenic  for evaluating  governing appropriate  well  indicates a  varies  defined  work).  operators  experience  the s t a t e of  initiated  r e c e n t l y been d e v e l o p e d ,  additional  spas,  have  h a z a r d s o f e n t r a p m e n t and  spas has o n l y  spas  exist  of " s a f e " use.  situation  A p p e n d i x D: a means  for  also  standards.  conditions  more  jurisdictions  jurisdictions  o f government w h i c h a r e e x a m i n e d .  preventing  Some  standards f o r  spas a t a l l ( e . g . I l l i n o i s ,  o f whether p u b l i c h e a l t h  First,  of  deal  jurisdictions.  and  developing  in  to  spa s t a n d a r d s ) .  n o t t a k e n any a c t i o n , b u t s u b o r d i n a t e  Chicago  to  specific  attempted  Michigan,  of e l i m i n a t i n g use of p o o l  management p r a c t i c e s r e q u i r e d  conditions  and a p p r o p r i a t e  found  in  spas  practices specified.  have  because  not  been  99  b) Have  public  action may  to identify  require  health Much high  of  this  to  spa  has  been  users again  jurisdictions II.)  have  type  spa  The e x t e n t  jurisdiction  about  some  existing  which  this  i s examined.  others  have  s p e c i a l precautions  be  and Some  County, A r l i n g t o n H t s . ,  while  jurisdictions can  to  of  r e l a t e d t o spa c o n d i t i o n s  these concerns,  problems  avoid  e s p e c i a l l y related to  i s available within  knowledge.  information  to  vulnerability  ( e . g . Oregon, S e a t t l e - K i n g  overall,  addressed  increased  d e p e n d s on w h i c h  Although better desirable  of i n f o r m a t i o n ,  specifically  identified  be t a k e n  spa use?  diseases,  health  agencies taken p o s i t i v e  s p e c i a l precautions  from  certain  and s a f e t y  c h a r a c t e r i s t i c s of i n d i v i d u a l s which  e f f e c t s and  m e d i c a l and p u b l i c knowledge  that  hazards  temperature  individuals  health  which  have  considered  as  not.  might  seem  specifically having  taken  reasonable p o s i t i v e a c t i o n .  c ) Have  public  procedures standards Beyond installation the  the  for  (1)  Monitoring  (2)  Identifying  and  safety  identifying  for "safe"  also  public  agencies  spas  that  established adhere  to  use?  identification  and o p e r a t i o n  CDC g u i d e l i n e s  during  health  of  criteria  recommend  design,  for "safe"  spa  construction, conditions,  procedures f o r :  spas.  and t r o u b l e s h o o t i n g  the operation  of p u b l i c  health spas.  and s a f e t y  problems  100  As  noted  similar  permit  or  adhering  spa  some  guidelines.  construction  are  above,  Often  and i n s t a l l a t i o n licensing  in  have  these  criteria  procedures  to standards.  based  jurisdictions  operations are also  cases,  a r e used  in  order  In j u r i s d i c t i o n s  upon swimming p o o l  or  deficient  common.  The  licenses  issued i n this  allowing  individuals  conditions  f o r "safe" use.  Procedures standards  for  jurisdictions, procedures simply  for identifying "safe"  f o r operator monitoring  violation  of  conditions  are  standards  similar  as  that  have  procedures  identify  Some  The j u r i s d i c t i o n s  and of  the  jurisdictions  a r e not adequate.  a g a i n , swimming p o o l s t a n d a r d s  information require  similar  health agencies established  that  about  of  the  public  individual  special  a  spa i n until  use  both  u s i n g swimming p o o l s t a n d a r d s a s  but  members  Some  adopted  facility  utilize  assure  to  jurisdictions  a b a s i s f o r spa o p e r a t i o n c r i t e r i a  d) Have p u b l i c  for  operational  Other  corrected.  means  jurisdictions.  guidelines,  closure  permits  adheres  certification.  by  seems t o be  Thus,  adhere t o  among  criteria  appropriateness,  t o spas  spa  that  differ  u s i n g CDC o r  employ  procedures.  use  spas  a  a spa  or l i c e n s e s f o r  context a r e inadequate identify  design,  identify  o f r e c e n t knowledge.  to  or  basis for  these  standards, permits  fairly  in light  to  CDC  the  as a  where  however, o f a p p l y i n g swimming p o o l s t a n d a r d s strongly  adopted  procedures,  procedures  reliable  access  characteristics  p r e c a u t i o n s be t a k e n ,  that to that  as w e l l as  101  instructions The provide this  CDC  about  how  to take  such  g u i d e l i n e s recommend t h a t  this  k i n d of  information to  recommendation v a r i e s by  precautions?  warnings  be  individuals.  jurisdiction  in  posted  to  Acceptance  accord  with  of the  previous discussion. However, sufficient Signs  can  i t may  for be  themselves,  questionable  assuring  whether p o s t e d  reliable  access  to t h i s  inconspicuously posted  or may  be  for adequately  instructions an  be  about  communicating  special  possible  weakness.  The  important  i n f o r m a t i o n about  w h i c h has  county  has  special  are  information.  insufficient,  in  the c h a r a c t e r i s t i c s  and  precautions.  example of a j u r i s d i c t i o n  warnings  S e a t t l e - K i n g County i s  attempted  t o remedy  this  made p a m p h l e t s , c o n t a i n i n g precautions,  available  to  individuals. Procedures  have  therefore  jurisdictions,  and  some  reliable  than  others.  e)  access  Has  adequate  developing use  and  To  the  of c o u r s e , However,  extent  established' have  been p r o v i d e d  information to related  identify  to  -  in  some  provided  by  more  government  for  " s a f e " c o n d i t i o n s of  special  precautions  which  taken?  taken  been p r o v i d e d inadequate  jurisdictions  funding  matters  need t o be  been  toward p o s i t i v e  f o r the  funding  has  a c t i o n s , funding  activities restricted  described  has,  above.  development  and  102  provision  of i n f o r m a t i o n  (e.g., the s t a t e  of I l l i n o i s )  needs  due t o l a c k  about  spa h a z a r d s .  even  in  "gaps"  assessing  deficient  failed  some  t o meet  "gaps"  which  of  jurisdictions informational  of l a c k  information  have been  active  of concern  still  exist  with spas.  t o p a t h o g e n i c hazards) can  These  sometimes  be  t o funding problems.  criterion,  of  Second,  (mostly r e l a t e d  In  have  First,  o f f u n d i n g and n o t b e c a u s e  jurisdictions  attributed  i n two ways.  the  existing within  U.S. e x p e r i e n c e  policy  certain  the s u b - c r i t e r i a .  and  practices  jurisdictions  These  for  meeting  first  been  shown  and w i t h r e s p e c t  t o some  failures  may  ignored  public  have  our  be  categorized  as  follows: - Jurisdictions  w h i c h have  assume n e c e s s a r y r e s p o n s i b i l i t y for  s p a s have f a i l e d  for establishing  conditions  " s a f e " use.  - Jurisdictions through  potential spas.  which  application  standards  and  have of  attempted existing  policies  have  to  public  not  deal  users  and  adequately  the general  public  peculiar  jurisdictions.  pathogens  i n t h e spa e n v i r o n m e n t ,  the spa environment,  "gaps"  i n s p a management  of  jurisdictions  physical  f o r spas  (nature  which  have  from c o m p l e t e l y m e e t i n g  this  of  characteristics  and b e h a v i o u r o f spa a c t o r s )  information  to  have n o t been  in  - The t h r e e main u n c e r t a i n t i e s  pool  addressed  reasonable assurance of "safe" c o n d i t i o n s  these  spas  swimming  h y p e r t h e r m i a and p a t h o g e n i c h a z a r d s  Thus,  with  provided  of  to  prevented criterion.  create a l l  103  - Lack  of  adequate  from e n t i r e l y ability  2.  of  meeting  other  Decision-Making  "Safe"  funding  has  this  prevented criterion  jurisdictions  and  weakened  the  jurisdictions.  Processes  for Establishing Conditions  of  Use a)  Have  alternative  government  s p a s been c o n c e p t u a l i z e d basis  of  information  Jurisdictions eliminated  from  criterion. policies current  fail  t e c h n i c a l and  current  in  which  t o meet t h e scientific  federal,  state  knowledge  has  for  a l l a f f e c t e d p a r t i e s on  the  and  users,  health  assumption  officials  serve  operators  and  unjustified,  and  the  behind as  and  have  general  general  particularly  in  been  this  swimming  pool  criterion  regard  to  met  Industry,  involved, taken public  representatives public.  where  i s not  involved.  that  to  neglected.  processes  have been  is  be  meeting  been  p u b l i c have not  process  s p a s can  because a t t e n t i o n  decision  scientists  appropriate  the  to  knowledge has  the  scientists?  public  applied  criterion  local  this  qualified  regard  been u t i l i z e d ,  officials  operators,  by  ignored  b e c a u s e a l l a f f e c t e d p a r t i e s have not public  management  supplied  consideration  spas  by  policies  w h i c h have t o t a l l y  Jurisdictions  to  In  The  some  of  but  part. health users,  This  assumption  user  and  is  operator  representation.  As  key  actors  whose p r e f e r e n c e s  and  behaviour are  critical  104  determinants operators  of  actual  spa  management  s h o u l d be more d i r e c t l y  more d i r e c t  user/operator  (1) I d e n t i f i c a t i o n informing value  and  establishment about  judgements r e l a t i n g to r i s k s .  exposed t o whether having  spa  our  first  later, such  concepts  and  of  procedures  individual  it  is  criterion i n p u t from  seeking  assure  and  reasons f o r  difficult  is  language  it  are  for  determine  met  without  users.  implement  conditions,  imply  spa a c t o r s  to  effectively  i n f o r m a t i o n about  to  for  preferences  Since users are the primary  (2) I n p r e s e n t i n g n e c e s s a r y and,  Two  " s a f e " c o n d i t i o n s o f use  to  hazards,  significant  represented.  users  representation are:  individuals  aversion  outcomes,  is  "safe" conditions  measures  designed  important  understandable  that to  to  policy  users  and  operators. (3) O p e r a t o r s  can  practices The of  practical  w h i c h c a n be done  l a c k of u s e r / o p e r a t o r  the  public  provide  CDC  and  health  weakness  of  other  current  into  management  effectively.  participation  similar  agency/industry the  insight  i n the  development  g u i d e l i n e s a n d i n a number o f conferences  decision-process  demonstrates in relation  the to the  above c o n s i d e r a t i o n s .  Moreover, about " s a f e  1 1  process.  Thus,  represent  i n d u s t r y , by s u p p l y i n g t h e  conditions, the  has  ability  users/operators  has  tended of  to  public been  bulk  of  information  dominate  the d e c i s i o n  health  further  officials  eroded.  to  In u s i n g  105  guidelines users  s u b s t a n t i a l l y devised  and  operators,  into account  the  the  by  U.S.  preferences  industry  without  e x p e r i e n c e has  and  knowledge  consulting  failed  of  two  to  take  key  spa  actors. b)  Do  procedures  reconcile  e x i s t through which e f f o r t s are  differences  of  preferences with  made  regard  to  to spa  management p o l i c i e s ? There appear public  health  conferences, setting  a d e q u a t e p r o c e d u r e s among  officials  bargaining  groups  indicates, are  t o be  as  procedures  for  to  reconciling  sessions,  such  i n a d e q u a t e due  for  UL).  use  of  industry  differences  independent  However, as  the  lack  of  representation  of  of  (e.g.,  standards-  above  reconciling differences  and  discussion preferences  all  affected  interests. c)  Do  procedures e x i s t  representatives  for decisions  or  individuals  where agreement c a n n o t Yes,  public  health  legislation/ordinances t h e y have a u t h o r i t y make s u c h d)  to  t o be  be  accountable  agencies  to  elected to  them  reached?  elected  delegated  made by  officials,  them by  can  recommend  or  i n some c a s e s  elected  officials  to  decisions. Has  funding  processes undertaken  for in  been  established  establishing conformance  "safe"  to  allow  decision  conditions  w i t h a l l of  the  to  above  be sub-  criteria? There  i s no  c l e a r evidence  which  indicates  whether  this  106  sub-criterion  i s met.  jurisdictions funding  of  However,  (e.g. I l l i n o i s )  probably  without  w o u l d not meet  this  In b r i e f ,  the U.S. e x p e r i e n c e  providing  decision-making  conditions  of  confidence  b e c a u s e of  -  i t i s reasonable,  Some  " s a f e " use  and  decisions - Those  spa  and  unanswered  i n these  followed, actors  simply  express  how  questions  important (1) do  basis  for  decision  process.  be  The  leaves  users,  agree t h a t  been made.  (2) do  these  nature  questions  of  confidence  do  to r a i s e and are  affirmatively,  the  policies, i f  implemented?  of c o n f i d e n c e  and  (or  users  users,  two  these  policies  effectively  lack  specific  operators  conditions  and  answered a  thus,  r e p r e s e n t a t i o n of  to assurance  "safe"  why  and  hazards  --  adopted  knowledge n e c e s s a r y  understand should  considered  This  disagreement)?  logical  in  are  be  have  technical  t o s p a s have not  to allow  produce  cannot  establishing  interests  current  i n f o r m a t i o n and  public.  l a c k the  they  criterion  have p a i d a t t e n t i o n t o c u r r e n t  jurisdictions  will  sufficiently and  which  the d e c i s i o n p r o c e s s ;  public  and  the  which  for  affected  been  specifically  have f a i l e d  and  the  spas so t h a t p o t e n t i a l  not  scientific  policies  operators  in  have  jurisdictions  technical  t o meet  ignored  i n f o r m a t i o n about  relating  fails  processes  have  uncertainties  regulatory  f o l l o w i n g weaknesses:  jurisdictions  scientific  spa  sub-criterion.  i n which a l l  the  basic  t o assume t h a t  issues  operators important If  there  i n the  these  these is  a  existing  of t h e e x i s t i n g u n c e r t a i n t i e s  spa management, as d e s c r i b e d  in  chapter  two,  tend  to  107  indicate  3.  that these  questions  would be a n s w e r e d n e g a t i v e l y .  Implementation P r a c t i c e s  a)  Have  provisions  understand rationale adhering  to  functioning  of  f o r approved  (under  t o educate o p e r a t o r s . have a r r a n g e d  educate spa  standards,  have been made by  of NSPI a n d I S T I , materials.  the  made  to standards  Some e f f o r t s departments  been  operators to systems,  the  and t e c h n i q u e s f o r  v a r i a b l e spa c o n d i t i o n s ) ? both  industry  Industry,  and  under  health  the auspices  seminars and d i s t r i b u t e d  Some s t a t e s ( e . g . , O r e g o n ) have  developed  written training  programs f o r o p e r a t o r s . Where effective  implemented, in teaching  teaching  the  operators  rationales  effectiveness  of  variable  conditions  experts  spa are  management intervals these  educational  the  still  techniques  in  procedures  (e.g.,  important  considerable confusion  b) Do p r o c e d u r e s  be  approved being  for  handling  though,  because  appropriate  among  spa  experts  s p a management p r o c e d u r e s  exist  be  The  for disinfection  Disagreements  f o r operators  to  standards.  taught  about  methods  appear  f u n c t i o n and i n  questionable  disagreement  f o rdraining spas).  and other  how s p a s y s t e m s  for  may  programs  have  and on  caused  (see Appendix D ) .  t o inform  users  about  s t a n d a r d s and  108  c o n d i t i o n s o f " s a f e " use and t o for The advise  CDC  users  reasonable use.  users  guidelines  t o a v o i d use o f spas time  limits  advise  which  municipalities  these  these  warnings.  Chicago advise  users above  clarity, hazards.  In t h e s e  limited  other  levels,  provided  Procedures  for  limit  be  that  posted  individual  p r e c a u t i o n s be  in  Illinois  from  entrapment, seem  City  of  which  None  of  posting  of  poor  or  to  have  to post  be p o s t e d  hazards  be  water  pathogenic seriously  and c o n d i t i o n s o f " s a f e " u s e .  t o check  on s p a c o n d i t i o n s seem t o  of thermometers  c l o c k s f o r gauging spa pH,  proposed  recommend  users  taken.  Prospect,  o f 15 m i n u t e s .  or  visual  from  f o r users  wall  which  and  and  warnings  require  areas,  t o the p r o v i s i o n  disinfectant  that  a time  hazards hazard  Means f o r c h e c k i n g  ordinarily  require  standards  and  behaviour  o f Oregon a n d t h e  to potential  means  temperature  F  warnings  and Hoffman E s t a t e s  not t o exceed  related  Simple be  simply  about  104°  r e c o m m e n d a t i o n s and r e q u i r e o p e r a t o r s  drowning  uninformed  that  proper  jurisdictions  information  exceeding  require that s p e c i a l  The s t a t e  codes  a r e b e i n g met?  o f A r l i n g t o n H t s . , Schaumberg, Mt.  CDC  means  t h a t s i g n s be p o s t e d  recommend of  B u f f a l o Grove, P a l a t i n e , adopted  standards  simple  ( e . g . 10 m i n u t e s ) s h o u l d be o b s e r v e d i n  users  characteristics  the  recommend  The g u i d e l i n e s a l s o  which  The  t o c h e c k on whether  provide  water  informing  users  gauging  water  d u r a t i o n of spa u s e .  quality  bacterial  i n spa f a c i l i t i e s  for  parameters  counts,  (e.g.,  etc.) are  not  o r by spa p o l i c i e s .  of  appropriate  spa  use  109  behaviour, ways and  as noted  to  official  varying  standards  de-emphasized users  behaviour  and are  of  c) Do  procedures  previously users are  of  exist  about  importance  for  appear  to  i n the  a  result,  of c h e c k i n g on  any  that  individuals and  taken  i n spa  measures  use?  beyond  studied in  are  violated?  the  jurisdictions  regulated, this  U.S.  jurisdictions  also  probably  check  facility  test  water  meet  administer penalties  f o c u s e d upon sub-criterion  which f o l l o w  this  those  t h e CDC  facilities  f o r parameter  a d v i s e o p e r a t o r s on management  when  monitor  standards  where  spas  reasonably  met.  guidelines These  would  jurisdictions  on a p e r i o d i c  l e v e l s and  that  depth.  study  i s being  sub-criterion.  records, inspect  samples  in this  are  instructions  pamphlets) which would a s s u r e  jurisdictions  o p e r a t i o n s and  the  D).  seeing  be  As  these  t o become  a p p r o p r i a t e government a g e n c i e s p e r i o d i c a l l y  Other  The  neglected.  of  health  with  a r e a of c o n c e r n  p r e c a u t i o n s be  spa  are being  the  and  compliance  characteristics  special  not  informed  this  i n a number  operator  user  (see Appendix  described (signs,  d) Do  and  have c a u s e d  other users  do  gaining  unaware  requiring There  in  implemented  However,  sometimes t o t a l l y  informed  In  degrees.  frustrations  behavioural  many  above, have been  basis,  bacterial  counts,  check d i s i n f e c t a n t  levels,  procedures.  h e a l t h departments p r i m a r i l y  110 pH,  and c o l i f o r m c o u n t s  Pseudomonas some  counts)  inspectors  alkalinity, an the  during  may  turbidity,  a)  of  of  that  periods  acid,  operator  and c a l c i u m  on  However, of  total  hardness.  are required to  monitored  efficacy  tests  listed  As  maintain,  of f i l t e r  question  backwashing and/or  (i.e.  cleaning)  cleaned  equipment  operation  whether a p p r o p r i a t e  disinfectants  matter  by t h e c o d e )  and/or  and r e p a i r  i n determining  of  (as s p e c i f i e d  above  of r e c i r c u l a t i o n  However some e x p e r t s  organic  parameters  s p a s were e m p t i e d  malfunction  and  surveillance  inspections.  the  which o p e r a t o r s  and times  c) d a t e s  being  test  cyanuric  the parameters  dates  d)  run  s p a code r e q u i r e s t h e f o l l o w i n g : results  b)  also  on-premise  also  example o f r e c o r d s Oregon  (Oregon h a s  are  two  parameters a r e  presence of pathogenic (testing  common  for  organisms  Pseudomonas  suggestions  for  and  improved  monitoring).  The the check  biggest  reliance records  operators, noted  by  constraints  weakness  upon of  i n the current  public health o f f i c i a l s ' facilities,  and ( 3 ) c o n d u c t several  health  severely  limit  unrealistic  CDC's compared  (2)  personal  their  time  t o see t h a t  recommendation  problems  on-premise  ability  of  once  t o t h e c o n s t r a i n t s of  system  is  capacities to:  discuss  officials,  spas as f r e q u e n t l y as n e c e s s a r y violated.  monitoring  standards  many  week  As  budgetary  to actively  a  with  inspections. and  (1)  monitor a r e not  is  often  jurisdictions,  111  and  further,  the  effectiveness  e)  of  high  v a r i a b i l i t y of  once-a-week  Have p r o v i s i o n s been  s p a s c a s t s d o u b t upon  the  procedures.  for funding  of  e s t a b l i s h e d to provide  implementation  for current  measures  and  future  spa  state  and  needs? As  described  local  i n A p p e n d i x D,  officials  believe  that  i n a d e q u a t e b e c a u s e of p r e s s u r e s budgets  i n the  past  few  are  increase  over  problems  of  directing  major e x p e n d i t u r e s  of  spa  significant long  spas,  operations.  there  does not  from  other  all  U.S.  The  t o be  cannot  the  be  of  - Users  are  poorly  reduce  government  of  costs  implementation  usually the  public  health  existing  the  view of  t o assume, t h a t  has  not  as  other  similar  been met  or  of  budgets, funds  users.  The  applicable recent  to  economic  jurisdictions,  funding  i n the  to  inspections  schemes t o o b t a i n  accepted  have had  worth  agency  operators,  in  tend  variability  have q u e s t i o n e d  However,  U.S.  problems.  experience  weaknesses;  conditions  measures both d i f f i c u l t  generally  recognizing  broadly  Illinois,  spa  costs  industry,  f o l l o w i n g main  - Variability  or  been  t o w a r d measures s u c h as  any  i t i s reasonable  third criterion  b e c a u s e of  In  s o u r c e s s u c h as  Oregon and  restrain  these  O u t s i d e of  jurisdictions.  conditions besides  term.  has  The  and  Illinois  funding  some o f f i c i a l s  appear  above c o n c l u s i o n s  to  years.  measures  the  Oregon and  and  informed  have  made  implementation  ineffective. about  standards  for  "safe"  112  conditions  of  conditions. operators variable  n a t u r e of  is of  i n a d e q u a t e , and  Provision  a)  of  health  aware to  challenging  task  A w a r e n e s s has jurisdictions  the  variable  a l s o appear  secure were  officials  conditions.  in New  l e s s expensive  found  and  that  reduction  deal  with  faced  few  from  to  users,  in this  fail  to  the  regulate  indicates that  unaware.  p.  operators of  study's  made  is  and  the  most  management? answer was t h e n , but spas or  awareness 208).  been  uncertainties  surprises  i n spa  years,  i n A p p e n d i x D,  t o be  sound p o l i c y  a l w a y s be,  funding  not  s t a r t e d to develop since  t o swimming p o o l s quotation  last  which  to  Learning  capability  until  relation  jurisdictions.  for Social  keenly  Up  industry  Have p u b l i c  the  i t may  to  schemes  of U.S.  of  In v i e w of  i s not  implement  or  checking  behaviour  its  methods w h i c h a r e  research  (see  and  monitoring/enforcement  operators,  4.  upon the  over-dependence  problems  or  of  health.  presently the  means  officials.  conditions  hazards, t h i s  - Funding  little  health  spa  public  have  over-dependent  public  protecting  light  and  Users are and  potential for  use  clearly the  "no".  number  of  t r e a t them s i m i l a r  is still  insufficient  O p e r a t o r s , as  a  whole,  113  b)  Have p o s i t i v e actors  to  incentives  engage  in  been p r o v i d e d a concentrated  to  stimulate  effort  to  spa  reduce  uncertaint ies?  During  this  incentives think  study,  being  that  a  utilized  others probably  few  isolated  were  f o u n d , and  exist  However, p o l i c i e s and  practices  positive  being  incentives  (see  in  no a  of  positive  i t i s reasonable  A p p e n d i x D,  showed  used  cases  pp.  strong  216-218).  evidence  concentrated  F a i l u r e to acknowledge u n c e r t a i n t i e s ,  noted  i s one  reasons controls  may  times, include  rather  reason  traditional  than  positive  attempt  jurisdictions  and  spa  of  the  need  for  fully  realized.  learning  The learning  i s not  U.S.  yet  deal  experience  shows t h e s e  - Recognition developed  of  with  actors.  spas  B e c a u s e of positive  the  uncertainties  only  recently,  in  and  Hence,  learning  notion  concentrated unthought of  as  Other  among  lack  the  of  a  various  wide v a r y i n g and  for  degrees social  social  weaknesses:  the  - The  the  in establishing provisions  among j u r i s d i c t i o n s and  social  and  to  regulatory  incentives  considerably next.  upon  incentives,  well-organized  awareness,  to  for t h i s d e f i c i e n c y . reliance  of  effort  reduce u n c e r t a i n t i e s . several  to  the  i s not  of  need  fully  involving effort  by  other  to spa  spa  this  management awareness  f r o m one  spa  has  varies  actor  to  for p o s i t i v e incentives  and  realized. operators reduce actors.  and  users  uncertainties Earlier  in may  a be  discussion  1 14  relating  to  decision  c o n d i t i o n s would t e n d  Deficiencies  used  deficiencies  as a guide  British  to support  i n U.S.  Lessons The  processes  establishing  Spa  Policies  and  f o r Design  of M o d e l  Policy  observed  in  These  "safe"  this speculation.  the-  for avoiding similar  Columbia.  for  U.S.  Practices:  experience  problems  deficiencies  can  can  be  policy  for  summarized  as  i n spa be  follows:  1.  The spa  failure use,  and  i n some U.S.  the  public  conditions  of  individuals 2.  Within  to recognize p o t e n t i a l  the  representation  and  special  of t h e  key  allow  actors  and  determining  appropriate levels  The  failure  users  potential to  effective  informed  about  for  have  or encourage  creates  certain  use.  hazards  in  of  in  spa serious  "safety"  been  adequate  management problems and  to devise appropriate techniques c o n d i t i o n s of  implementation  o v e r l y dependent officials  users  in  effective  measures.  the h i g h l y v a r i a b l e of  —  prevented  requirements  precautions  where  failure  has  associated with  adequately  about  operators  implementation 3.  being  " s a f e " use  jurisdictions  recognized,  jurisdictions,  from  to take  hazards  spas  to e s t a b l i s h  hinders  the  and  leaves  users  of o p e r a t o r s and  health  measures  upon t h e a b i l i t i e s  for handling  "safe" conditions in  spas.  design  1 15  4.  The  failure  importance retarded  on  a  widespread  of r e d u c i n g or  incentives  uncertainties  prevented  and  a  basis  the  social  The  Canadian  Scope  could  learning  improve  Experience With  recognize  the  i n s p a management h a s  development  o p e r a t i v e and c o n c e n t r a t e d e f f o r t s health o f f i c i a l s  to  of  process  i n which c o -  by o p e r a t o r s ,  s p a management  positive  users  and  practices.  Spas  of Study The  study  primarily  to  significant  of the  Canadian Province  differences  e x p e r i e n c e appear  depicted  of  British  between  t o be: (a) fewer  C a n a d a , and (b) a l a t e r The  spa management  structure i n the chart  of  development the  below.  s y s t e m was  Columbia.  the  U.S.  limited  The  and  Canadian  numbers o f s p a s a n d u s e r s o f t h e spa m a r k e t  spa management  system  only  in  i n Canada.  i n Canada i s  11 6  Industry -  Canadian Swimming Pool Assoc. - Individual Firms  Spa  Spa  Description  of The  and  largely operation  to  provincial  and  organization  of  overlapping,  the  be  briefly  role  spas  Municipal Health Depts. - Medical Health Officers  Outside  Users  B.C.  with  regard  are,  therefore,  municipal  institutions  pools  Policies the  is fairly  limited the  responsibility  of  Although  complicated  structure in British  follows:  is  governing  jurisdictions.  institutional  d e s c r i b e d as  System  Spas  t o s p a s and  matters.  Influences  U.S. Industry U.S. Research U.S. Experience  Public Health  I t s R e l a t i o n to  educational  of  -  Social/ Recreational Therapeutic Occasional Users  - H i g h use p u b l i c Facilities - Low use p u b l i c facilities - H i g h use private facilities - Low use p r i v a t e facilities  federal  Municipal & Local  - Ministry of H e a l t h - Provincial Medical Health Officer - Local Health Boards - Union Health Boards  - D e p t . of Health & Welfare  Operators  The  Provincial Agenc i e s  Federal Agenc i e s  and  the  sometimes  Columbia  can  1 17  Under t h e and  the  B.C.  H e a l t h Act  provincial  responsibility swimming  of  pools,  delegate  Medical  of  Health  overseeing spray  1972,  Officer  the  pools,  primary  departments.  and  wading  for  inspections,  and  also  legislation,  draft  initiating  situation.  The  testing  samples and  of  approval) setting  on  Medical  matters  of  Health serves  charged  Health with  pertaining  pools.  They  of  permits,  related  and  to advise  carries (and  of  has  general the  and  lab joint  permits  water q u a l i t y ,  may  They  also provide  issuance  for sanitation,  the  out  to  making  pools.  keep t r a c k of  Officer  to  to  the  their  t h e M i n i s t r y of H e a l t h  programs monitor  of  inspectors within  issuance  pertaining  standards  and  In p r a c t i c e  responsibility  are  regulations  d u t i e s to various engineers  respective  the M i n i s t e r  and  public  safety.  At  the  including  municipal  Vancouver,  Vancouver,  and  departments regulation, Employees  level, Burnaby,  Victoria  and  a  they  primarily  in  their are  these  departments  municipality.  Other  areas  Ministry  departments of H e a l t h .  Officers related  the  not  the  municipalities  has  V a n c o u v e r , West  separate in  pool  p a i d by  their  province,  separate  the  roles.  separate provincial  Medical  responsibility  spa  respective  where by  health and  enforcement  are handled  without  MHO  and  are  exist,  In a r e a s  provincial  t o p o o l s and  Other  do  in  own  involved  monitoring  of  health  of  Richmond, N o r t h  have also  number  for  Health duties  spas.  institutions  a l s o can  get  involved with  p o o l and  spa  118  policy  decisions  at  the  local  have d i s c r e t i o n  i n m a t t e r s and  the  or  MHO  does  composed boards. the  They can  province  a  of  but  only  standards  thus serve  The British regulating swimming  in  pools.  Health  operators  hyperthermia compared  to  its one  are  jurisdictions  the  Municipal from  the  provincial  not  and  Spas  followed  existing  exception  More  scientific  domain of  The  With  based  provide  few  relate  to  previous provisions spas  the  in light  Visual, but  public  adequate guidance  incomplete  only  w h i c h have a c t i v e l y  of  temperature  upon  the  significantly,  addressed,  approach for  of maximum  are  information.  the  policy  specifically do  inaccurate  hazards  higher.  Experience  primarily  which and  outside  baseline.  has  users.  are and  Act  Health,  f o r areas  different  i n d i c a t e d i n A p p e n d i x E,  vague  and  provisions  are  water q u a l i t y s t a n d a r d s As  what  school  ordinances.  pass l e g i s l a t i o n  Columbia  With the  on  and  legislative  local  standards  the  municipalities  the  and  p u b l i c spas under  unnecessarily  technical  as  British  standards. the  i f the  Columbia  requirements, pool  can  influence  Health  departments.  guideline,  institutions  have  into decisions  health  supercedes municipal  L o c a l B o a r d s of  a l s o U n i o n B o a r d s of  from  input  local  province,  can  There are  provide  general  local  they  representatives  jurisdiction  As  and  of  says.  level.  are for  existing of  current  drowning,  t o a minor d e a l t with  and  degree spas.  119  Provisions  for  pathogenic Overall, seen  public  hazards posed spa  in  policy  the  U.S.  treated  as  been  extensively  U.S.  small  experience,  critique, of  health by  spas  i n B.C.  jurisdictions  swimming p o o l s . covered  a detailed  standards  describes  their  seriously  experience  elsewhere  Provinces  of  public steps  7  Thus,  considered.  of  the  here.  A  knowledge,  for  i n B.C.  f r o m t h e U.S.  spas reviews  is  existing  experience  Brief  Ontario  s p a s and  process  times,  aimed 6  The  at  a new  The  growing  need t o  take  handling  the  Canadian  devising  of  argument.  the  that e x i s t i n g  and  this  examination  recognized  of  that  have e x p e r i e n c e d  spas.  i t seems e v i d e n t the  has  scientific  critique  associated with  i_s l a g g i n g b e h i n d  of p o l i c y  unnecessary  specifically  A s s o c i a t i o n i s i n the  standards. B.C.  hazards  principally  is  i n Canada s u b s t a n t i a t e s t h i s  policies  policy  weaknesses.  S a s k a t c h e w a n and  to develop  k i n d of  are  type  special  neglected.  evaluation  deficient.  h e a l t h problems with  potential Pool  evident  the  the  This  and  is  this  regulations  provisions  approach  spas  and E.  be  second  t e c h n i c a l and  Appendix  should  the  Since  analysis  in  from  completely  where  in  contained  It  are  resembles  b a s e d upon c u r r e n t  existing  protection  Swimming  specific spa  policy  policy should  spa in be  120  The  C a s e F o r Spa P o l i c y Change i n B r i t i s h  Using of  the  spas p e r m i t t e d  assume t h a t province there  each  spa  hour  are  just  there  t h e UBC  a minimum  users,  affected  Spas  spas  a  of time,  substantial spas.  In  of  view  are  now  being  in this  require  spa  developed established observation  to protect extensively  public used  thesis, public health government  of safe  use.  management in  with  B.C. i n  in  chapter  o f t h e U.S.  action New  to  policies  problems accord three  and with and  experience.  there  within  multiple  the  use  10 p e o p l e  that  spas d a i l y  people  of  the  who  are often  even c o n s i d e r i n g number  day  conclude  public  in  I f we t h e n assume  an a v e r a g e o f 10 p e o p l e a  and t h e h a z a r d s a s s o c i a t e d  conditions for  1).  s p a ) , t h e n we c o u l d  government a c t i o n  earlier  i n Chaper  of 2000 p e o p l e u s i n g  by p u b l i c  involved that  spas o p e r a t i n g  (not a t a l l unreasonable as there  using  f o r t h e number  1977, 1980, and 1981, we c a n  200 p u b l i c  as s u p p l i e d  are at least  Taken o v e r a p e r i o d by  by t h e p r o v i n c e  i n the years  are at least  (figures  that  an  figures supplied  Columbia  are  B.C.  exposures  undoubtedly  number  of  people  spa u s e , i t i s e v i d e n t health  is  required.  i n B.C.  and a s i n d i c a t e d  hazards  associated  establish which  and  implement  accurately  uncertainties  account  should  the  evaluative  the  lessons  with  be  framework  gained  from  121  Footnotes  - Chapter  4  R o b e r t J a n i s , P o o l & Spa News, "SPEC M e e t s on A f f a i r s " , A p r i l 5, 1982, p . 16. 1  Governmental  Jorian Clair, P o o l & Spa News, "Spa H e a l t h Code A c t i o n P l a n n e d : ISTI t o Meet w i t h NSF i n O c t o b e r " , September 21, 1981, p. 98. 2  interview  w i t h Dave A n t o n a c c i ,  "Interview  with  interview Washington D . C ,  op.  J i m Brown, O c t o b e r  with Larry Paulick, A u g u s t 10, 1982.  c i t . 1 8 , 1982. Vice  President,  NSPI,  Letter from L. J . C o r k e r y , Consultant Public Health Inspection, Saskatchewan H e a l t h , Regina, Saskatchewan, February 14, 1983. L e t t e r from P e t e r J . B l o c k , S e n i o r C o n s u l t a n t Swimming Pools, Public Health Branch, Ontario M i n i s t r y of H e a l t h , Toronto, O n t a r i o , F e b r u a r y 7, 1983. 6  ibid.  Main S o u r c e s of  Information  U.S.  Center  for Disease  Consumer P r o d u c t s State  Control; A t l a n t a , Georgia S a f e t y Commission;  of I l l i n o i s ,  Cook C o u n t y P u b l i c  Dept. of P u b l i c  Washington,  Health;  D.C.  Springfield,  II  H e a l t h D e p t . ; Maywood, I I .  DuPage C o u n t y H e a l t h Dept; Wheaton, I I . Northwest M u n i c i p a l Conference; State  of O r e g o n ,  Public  Mt.  Prospect, I I .  Health Division;  National  Spa  & Pool  Institute;  National  Spa  & Pool  I n s t i t u t e Midwest  Great  Lakes B i o c h e m i c a l  Bio-Lab,  Inc.; Decatur,  The Meadow C l u b ; Chicago  Spa P e t i t e ;  Club;  Inc.; Milwaukee,  Ga. Meadows, I I .  R o l l i n g Meadows, I I .  Westmont, I I .  & Spa News; L o s A n g e l e s ,  Swimming P o o l Age;  F t . Lauderdale, F l a .  P o o l Scope; W a s h i n g t o n , Tribune;  Ca.  D.C.  Chicago, I I .  Oregon  D.C.  Chapter;  Schaumberg, I I .  Health Fitness;  Chicago  Washington,  H e a l t h C l u b ; Maywood, I I .  Contintental  Pool  Rolling  Co.,  Portland,  Chicago, Wis.  II  123  Canada  B.C.  Ministry  Vancouver  of H e a l t h ;  Public  Richmond M e d i c a l  Saskatchewan  Health O f f i c e r ; Health O f f i c e r ;  Ontario Ministry  Harrison Vancouver  Regina,  of H e a l t h ;  Centre;  Brentwood Racquet Vancouver  Health O f f i c e r ;  Health;  U.B.C. A q u a t i c  Club;  Springs  Vancouver,  Burnaby,  B.C.  B.C.  B.C.  Saskatchewan Toronto,  Burnaby,  Ontario  B.C. B.C.  B.C.  Community C e n t r e ;  Sun; V a n c o u v e r ,  B.C.  Richmond,  Vancouver,  YMCA; V a n c o u v e r , Hot  B.C.  H e a l t h Dept.; Vancouver,  Vancouver M e d i c a l  Burnaby M e d i c a l  Victoria,  B.C.  Harrison,  B.C.  124  CHAPTER 5  Recommendations F o r a Spa P o l i c y  Since which  there  d e a l w i t h spas  framework, a c o m p l e t e the  following  with  exception  of  criteria  the d e f i c i e n c i e s  maximum  judge  establish  the  procedures.  Specific  The  (especially  appendix  assumed  that  legislature, any  policies  a i f  which  ( a ) t o meet  the  will  be made t o i n d i c a t e  will  government a g e n c i e s m i g h t  Further,  no a t t e m p t  standards,  may  as t h i s affected wish  to  scientific  necessary,  committee will  is  is  interests consult  The recommendations  best  within the  left  British  appendices t h e s i s as a  Finally,  ministers,  have f i n a l  or  recommendations  in this  concerns.  to  required to  i s considered  of  made  regulations,  and s c i e n t i f i c  B) a n d r e f e r e n c e s c i t e d and  In t h e  " a p p r o p r i a t e h e a l t h agency"  policies,  the  tubs.  have  hot  legislation  and  which  and  new  minister,  adopted.  The  for  technical  reader  technical  levels).  s h o u l d be r e s p o n s i b l e  or l o c a l  not i n c l u d e d ,  Columbia.  to  h e a l t h agency The t e r m  to  spas  no a t t e m p t  provincial  decision-makers  guide  public  proposed  are p u r p o s e f u l l y to  public  extent  designed  jurisdictions  i n s p a management.  the  i s designed  be  i n those  policies.  involved  to  found  s e t of p o l i c i e s ,  be  needs  d e v e l o p e d , a n d (b) t o d e a l  regulate  t o whatever  with the e v a l u a t i v e  have been  recommended  refer  Columbia  which  to  the v a r i o u s  Columbia  British  temperature  framework  endeavored  which p a r t i c u l a r  in  i n accord  s e t o f new p o l i c i e s  proposed p o l i c y  evaluative  forBritish  i s not a s e t of p o l i c i e s  specifically  (with  Framework  or  i t  is  the  responsibility for  a r e as f o l l o w s :  1 25  1.  Development  Spas and  Hot  The  P r o v i n c e , under initiate  Procedures  for  swimming  pool  utilized for  following  aspects: spa  installation public and  conditions c)  specific  d)  safety  hot  criteria  Standards British  from  public  scientific and  and  conditions  should  reasonable cover  construction  the  and  management  disinfectant  counts,  etc.)  for  criteria,  levels,  pH,  "safe"  spa  identified. hazards  individual  to  spa  u s e r s and  characteristics use  and  specific requiring  instructions  on  how  precautions  emergency  procedures  user behaviour  r e c o r d - k e e p i n g and  Standards  should  in  which p r o v i d e  design,  p r e c a u t i o n s d u r i n g spa  and  Tubs  standards  standards  (e.g.,  of  about  such  "Approved  spa h a z a r d s  tub  agency,  recent  t u b o p e r a t i o n and  bacterial  e) a p p r o p r i a t e spa f)  for Public  criteria  warnings  special  The  hot  s h o u l d be  information  to take  use.  parameters  temperature,  spa  most  potential  and  spa and key  The  Hot  to devise standards  "safe"  a) p u b l i c  and  separate public  knowledge a b o u t  be  to develop  Spas  standards.  assurance  b)  process  Public  w h i c h would  should  Procedures  the a p p r o p r i a t e h e a l t h  a  Columbia",  technical  and  Tubs  immediately and  of A p p r o v e d S t a n d a r d s  monitoring  which cover  of p o s i t i v e  action  criteria procedures  these aspects to i d e n t i f y  s e r v e t o meet our c o n d i t i o n s of  "safe"  subuse  1 26  which  a.)  will  protect  requiring  special  necessary  t h a t the  Spa  facilities  permits  based  b)  Spa  c)  precautions.  should  s h o u l d be  be  should  with  with  established policy.  accord with  approved  s h o u l d be  w a r n i n g s of p o t e n t i a l  (ii)  instructions  (iii)  (iv)  occurrence  individual people  of  which  hazards  instructions  of  spa  special on  operating and  standards.  how  permits  management  criteria  other  requirements  conspicuous  warnings  cover:  f o r the average  appropriate  spa  use  user.  behaviour  to  hazards.  characteristics  to take  be  renew  and  to post  standards  (i)  prevent  initial  the approved  standards  required  the approved  would  construction,  t h e o p e r a t i o n and  specified  in  by  it  be e s t a b l i s h e d :  r e q u i r e d to p e r i o d i c a l l y  by  facilities  addition,  individuals  posted.  established  Spa  the  those  design,  established  be  and  r e q u i r e d to o b t a i n  conspicuously  upon c o m p l i a n c e  by  In  f o l l o w i n g procedures  criteria  facilities  based  non-users,  upon c o m p l i a n c e  installation Permits  users,  which  require  certain  p r e c a u t i o n s d u r i n g spa special  use.  precautions should  be  taken. d)  The  a p p r o p r i a t e h e a l t h agency  "Safe to  Use  the  of P u b l i c public  through  health agencies. and  instructions  These  Spas and spa  should develop Hot  T u b s " t o be made  facilities  T h i s pamphlet  a pamphlet  should  and  available  through  i n c l u d e the  on  public  warnings  d e s c r i b e d above.  provisions  meet  the  other  two  sub-criteria  for  1 27  establishing  procedures  standards  and  regarding  special  development  (2)  In  order the  processes  in  confidence,  reliable  to  information  individuals.  w i t h i n t h e above  Thus,  format  fully  f o r a "good" s p a p o l i c y .  P u b l i c Spa/Hot Tub S t a n d a r d s  standards  criterion which  and management p o l i c i e s  of  having  users,  and  Awareness  These  users,  seminars  Seminars"  the  should  serve  through  public  arrange  which  a  series  are  open  of  the  to illuminate  composed  interests  (public  industry, be  scientists.  spa  final  health o f f i c i a l s ,  The  by  purpose  standards  from  to a l l public.  of  the  committee  a l l affected  committee  by  qualified  committee  f o r adoption  public,  This  supplied  a n d management  recommendations  a  spas.  members o f t h e  a n d spa u s e r s ) .  information  of  and c l a r i f y t h e  establish  representatives  operators,  aided  proposed  of  should  have  be made:  i s s u e s i n v o l v e d i n the r e g u l a t i o n of p u b l i c  equally  review  and  o p e r a t o r s , a n d members  The a p p r o p r i a t e h e a l t h a g e n c y  should  should  for public  established  the f o l l o w i n g p r o v i s i o n s should  interested  basic  been  operators,  The a p p r o p r i a t e h e a l t h a g e n c y  make  spas a d h e r i n g t o  access  for certain  standards  of P r o v i n c i a l  that  "Public  b)  identify  Policies  s p a s meet  a)  (1)  precautions  criteria  Determination  Management  assuring  of approved  meets t h e f i r s t  2.  which  should  policies  be t o  and  to  o f s t a n d a r d s and  policies. c)  Prior  t o making  final  recommendations,  t h e committee  should  1 28  invite,  r e c e i v e , and r e v i e w  policy  from  notifying allowing d) The  the  general  complete access  be d e c i d e d ,  specific  outlining should  provisions  also  be s u b m i t t e d  to regulate  The a p p r o p r i a t e acceptance  authority.  If minority  regulate  In  second  to  providing  means  3.  be  model  policy  for enacting  is  outside  a minority  for  the  report  objections  body w i t h t h e  a u t h o r i t a t i v e l y decide and  in  for final  whatever  or d e l e g a t i n g  i t should  body h a v i n g  be  the a u t h o r i t y  and  process  management  met b y : a l l o w i n g conceptualizing  determination  f o r the policies,  a l l affected the  policy;  t o be r e c o n c i l e d ; where a g r e e m e n t s  reached.  Measures  f o r Implementing  the  determination.  above-suggested  fully  issue  the p o l i c y  for differences i n preferences a means  and  t o t h e spa p o l i c y or  objections exist,  the  participate  providing  cannot  should  s p a s t o make f i n a l  criterion  policies  If a minority  t o the a p p r o p r i a t e  o f p u b l i c spa s t a n d a r d s  interests  and  reasons  of t h e a p p r o p r i a t e  establishing  determination the  the  necessary  to  and  spas.  directives  responsibility  arguments  the p o l i c y ,  h e a l t h agency of  and management  objections  of  i n t e r e s t s by  of the p r o p o s a l s  of the committee.  t h e o b j e c t i o n s and  authority  on  vote  proposed  content.  weighing  t h e committee has s t r o n g  to  e)  to their  after  the  p u b l i c and s p e c i a l  f o r standards  comments, by m a j o r i t y of  about  the p u b l i c of the e x i s t e n c e  recommendations  should  comments  Spa S t a n d a r d s and Management  1 29  Policies  in  The for a)  B.C.  e s t a b l i s h e d spa  implementation. Part  VII,  "Every  The  swimming-pool  of  and  and  compliance  with  This  in  should  operated  of  and spa  of  The  should so  be  be  and The  spa  obtained  through  an  as  evidence  program.  best  approved of  for A  sample  on  f o r approved  to  deal  training  with  program i s  F. required  management p u r p o s e of  to  formalize  policies this to  management  with  obligatory  department i n s p e c t i o n s .  approved "Plans  of  provision i s twofold: consciously  o n - g o i n g o p e r a t i o n of a f a c i l i t y compliance  the  into  daily,  an  spas  training  knowledge  rationales  operators  to  participate The  current  quality  as  a  Health  of  operators  water  simply  that by  of  a c t i v a t e d in regard  systems,  to encourage o p e r a t o r s  viewing  provides  Department  course  t h a t a l l spa  conditions.  owners s h o u l d  Operation".  procedures  maintained  completion  training  techniques  i n Appendix  standards  Act  and  competency  i n c o r p o r a t e the  functioning  provided  (1)  Health  a provincially-sponsored training  variable  Spa  effective  this section."  provision  standards,  b)  be  successful  therapeutic pools  program the  B.C.  manager.  require a c e r t i f i c a t e  swimming-pool o p e r a t o r ' s  and  the  shall  operator  attendance  must have  recommended m e a s u r e s i n c l u d e :  s e c t i o n 81  competent may  policy  as  a  think  primary as  goal  and  task  passing  spa  i n the  opposed  standards for  of  to  regulations health  130  (2)  to  provide  on  a  regular  services, The  "Plans  flexible  consider  Operation"  to  individual  b)  training  well  users  e) m o n i t o r i n g ,  testing,  and a p p r o v a l being  knowledge.  Approval  purposes,  and  be  plans  creative way,  standards  of  officials.  hazards  and p r o p e r  operators  should  within  and  "safe"  i n simple  near  be  procedures  be b a s e d limits  methods  closely  approval.  current  would  require  a set t r i a l by  about  This  the f o l l o w i n g :  post  health facility  Users  to a f a c i l i t y ' s to  these  of  l o a d of each  required  conditions.  on  monitored  bather  the spa u n i t ,  terms,  (as  procedures  be f o l l o w e d t h r o u g h  judging  should  the  unusual  s h o u l d have a c c e s s  observable  affecting  of p l a n s  for  in  behaviour  procedures  Also, anticipated  be w e i g h e d  procedures  this)  and r e c o r d - k e e p i n g  experimentation  general public  and  personnel  met  substantiation  include  should  operating  and e q u i p m e n t m a i n t e n a n c e  provisions  easily  facility  to design  needs,  of  s a f e t y and emergency  Evaluation  Spa  any  as p r o v i s i o n s f o r e n f o r c i n g  water q u a l i t y  should  for  of the approved  of f a c i l i t y  c) n o t i f y i n g  period  conditions,  and p r o v i d e f o r :  satisfaction  prior  facilities'  However, e a c h p l a n would have t o , i n some  a)  f)  spa  means t o e v a l u a t e  and p e r f o r m a n c e . of  abilities.  d)  basis  an a d d i t i o n a l  i n a l l o w i n g an o p e r a t o r  according  c)  users with  and  the  plans,  information,  key  parameters  information  should  131  (i)  the  parameter  and  a  simple  definition  of  the  parameter (ii)  a  simple  possible not  explanation consequences  followed  disinfection  of  i f the  (e.g., -  what  the  parameter  parameter  "chlorine  prevents  bacterial  and  standard  is  levels  -  for  growth  in  the  spa"). (iii)  t h e range o f v a l u e s the approved  (iv)  a  simple  actual  standards  means o f d i s p l a y i n g  than  hourly)  should  be  assure  users  are informed  advised  injuries Spa  or deaths  operators  individuals  measures  of s p e c i a l  advise  have  a medical  should  recommended  appropriate monitoring  precautions  insurance  to  be  amounts coverage  and r e c o r d - k e e p i n g  These p r o c e d u r e s  product  with risk  establish be  The  basis.  for similar  to  would  taken.  consistent  should  those  which  be r e q u i r e d t o o b t a i n  h e a l t h agency  appropriate agencies.  to obtain a  history  s h o u l d be u p d a t e d on a y e a r l y  operators  compensation  f o r spa use, p a r t i c u l a r l y  approval Spa  which  precautions in  spa u s e r s  special  current  for  take  warrant  liability  e) The  who  (no  occur.  should  physician's approval  (ii)  to  and r e q u i r e d t o p r o v i d e a d e q u a t e means o f  should (i)  that  or p e r i o d i c  basis.  Spa o p e r a t o r s  use  the parameter v a l u e s of  spa c o n d i t i o n s on a c o n t i n u o u s  greater c)  f o r the parameter which adhere t o  the  areas.  procedures  administered  should include:  by  132  (i)  Submittal  by  parameters submitted reviewed the (ii)  spa  operators  of  (recorded p e r i o d i c a l l y , on  a weekly b a s i s .  periodically  by  public  health  inspections basis  of  to  adhering  spa  facility  to  approved  key  hourly)  and  should  h e a l t h agency  on  be and  file.  should  conduct  premises  whether  of  records  the p u b l i c  agency  ascertain  e.g.  These  r e c o r d s s h o u l d be m a i n t a i n e d  The  records  on  spa  standards  a  on-site periodic  facilities and  are  management  policies. (iii)  Public  health  communication example,  agencies between  phone  health agencies personnel handle  (iv)  or  posted  s h o u l d be  compliance  and  health  agencies  to  from  u s e r s and  the  inquiries  or  through  developed  health agencies  these by  channels,  agencies  to  problems. should e s t a b l i s h  c l o s u r e s a s a means t o e n f o r c e  with  For  facilities  letters  recurring  of  of a p p r o p r i a t e  i n spa  in  channels  agency.  non-user c o m p l a i n t s ,  s e r i o u s or  f i n e s and  the  addresses  s h o u l d be a d d r e s s e d  Appropriate of  c o u l d be  and  procedures  resolve  and  numbers and  calls  User  problems and  users  be made a v a i l a b l e  phone  public.  should e s t a b l i s h  the approved  standards  and  a  system  operator  management  policies. (v)  Appropriate procedure  health for  agencies  arbitration  between u s e r s and  should to  establish  a  r e s o l v e any  problems  o p e r a t o r s o r o p e r a t o r s and  agencies  133  w h i c h a r e not either  clearly  application  approved  or  the  channels  communication.  of may  arise  (2)  of  to s h i f t s  behaviour  scientific  relating cannot in  readily  are  codifiable  terms,  specific  instances  which  changes  in  policy.  spa  arbitration  should  appropriate  body h a v i n g  above p r o v i s i o n s f u l l y education  and  receive  approved  that  individuals  providing  public  procedures, problems policy.  standards,  and  health  in specific  The prior  authority  of  factors  procedures problems  approval  criterion  agency  monitoring  cases  not  warranting  and  overall  by  for the  spas. by:  (1)  against assures  informed,  (4)  enforcement  for resolving overall  in  (2) p r o v i d i n g  conditions  precautions are  and  such  procedures  special  p r o v i d i n g procedures  "safe"  policy  to regulate  spa  and  Since  justify  to operators,  as;  (3) i s s u e s  (3) p r o v i d i n g a mechanism w h i c h  requiring  (5)  future  meet t h e t h i r d  training  and  arbitration  not  factors  values  anticipate  do  u s e r s w i t h a means f o r c h e c k i n g a c t u a l the  actors'  resolving  that  standards  "fairness".  to f u l l y  for  such  advances,  expected  important  of  and  normal  envisaged  perceptions  i n spa  t o q u e s t i o n s of be  is  approved  c o n d i t i o n s due or  It  changing  standards  established  as a r e s u l t  interpretation  procedures,  r e s o l v e a b l e through  the  policies  (1)  providing  of  management  problems  The  d e f i n e d and  future  changes  in  134  4.  Policies  t o Reduce U n c e r t a i n t i e s and Improve  and  Enforcement Because  related physical actors, and  a)  existence  the  Provincial  a process  this  the  nature  characteristics  management of  Procedures  of  t o : (1)  Spa Management  of  social  practices  significant  pathogenic  of spas,  spa p o l i c y  for  of  hazards,  (2)  a n d (3) t h e b e h a v i o u r  should  the  o f spa  include positive incentives  learning  beyond  uncertainties  in  order  to  i t s current state.  improve  spa  Recommendations  k i n d are as f o l l o w s :  The  appropriate  scientists existing  health  and  industry  uncertainties  uncertainties  should  suggestions  reduced.  The  b) " P l a n s  of  learning  with  (i)  and  on how  these  should  in  should  actions  be d i s t r i b u t e d  be  to a l l public  should  serve  spa  to  further  management. could  be e n c o u r a g e d  to include i n their  might  collection  help  reduce  of bather  techniques ( e . g . methods  of  be  of  which  "Plans  use and  for to  social  Identified  utilization  experimental  intervals  a written report  u n c e r t a i n t i e s might  and problems of t o p p r i o r i t y  conditions  (iii)  identified  improve  (e.g. data (ii)  the  i n t h e P r o v i n c e and s p a o p e r a t o r s .  through  Operators  clearly  from  i n spa management; by p r i o r i t y ,  Operation"  uncertainties  should  co-operation  the  report  officials  with  identify  be  along with  health  agency  dealt  Operation". plans:  uncertainties behaviour)  handling  determine  variable appropriate  f o r d r a i n i n g spas)  development  and  implementation  of  special  135  recreational increase  and t h e r a p e u t i c  user  benefits  participation for  public  operators quality (iv)  the  and  which  to  of  "safe"  health  compete  conditions.  levels  user  responsible This  p r o t e c t i o n and a l s o on  which  promote  i n u n d e r s t a n d i n g and b e i n g  establishment  improve  programs f o r u s e r s  may  stimulate  related  to  water  conditions,  use  of  trained  professionals  who may  perspectives  to  recreational  and  therapeutic  b r i n g a d d i t i o n a l knowledge  the  " s a f e " and " b e n e f i c i a l "  and  use o f  spas. c)  The a p p r o p r i a t e public to  health  (i)  agency,  agencies,  encourage  management.  health  should  operators  to  Examples o f s u c h  r a t i n g systems published  presentation  (iii)  financial  contribution  other  develop p o s i t i v e incentives  improve  the  level  i n c e n t i v e s might  of  spa  include:  which a r e posted  o f awards f o r w e l l - m a n a g e d  standards  with  or  inspection.  incentives  approved  conjunction  f o r spa f a c i l i t i e s  for public  (ii)  in  or  to elevate  for  operations  operators  who  make  who  exceed  an  outstanding  s p a management  knowledge and  practices d) The a p p r o p r i a t e research  for  management be  health reducing  as funding  conducted  representative  by  agency  should  commission  uncertainties allows.  individuals  Studies or  and  s t u d i e s and  improving  and r e s e a r c h  groups  outside  body w h i c h recommends o r a p p r o v e s  spa  should of  the  standards  1 36  (e.g. u n i v e r s i t i e s , relevant (i)  private  s t u d i e s might  the  range  of  consultants).  of  include: pathogenic  measures which  Examples  can  hazards  most  and  effectively  preventative reduce  these  hazards (ii)  methods  (iii)  which  effectively  deal  appropriate  intervals  to  Many o t h e r undertaken,  but  and  spas,  gauging  t o s p a management spa  operators  (e.g.,  use  rules,  t o handle spa  tasks, etc.) that  these  Provincial  are  Spa  health  i f significant adjusted  might the  and  should  be  public  health  be  worthwhile  primary areas  which  p r o b l e m s become  which  followed.  practices.  be  could  be  should  be  reviewed  be  apparent  The t y p e  includes  authority  rested  outside  developed  remain c u r r e n t  in  from  by two  before  of d e c i s i o n  input  Communications  jurisdictions  and  should  a g e n c y a t a minimum o f e v e r y  final  U.S. s h o u l d  information  Policy  accordingly.  described,  interests  and  (e.g.,  first.  earlier  the  teach  more  etc.)  compliance with  effectively  studies  appropriate (or  user  to  conditions  draining  studies relating  management  The  for  behavioural  to achieve  utilize  variable  of d i s i n f e c t a n t s ,  how  e)  with  can  application  how  examined  operators  the years then)  process,  a l l affected  i n the l e g i s l a t u r e and  o f B.C., order  meetings  with  i n Canada and to  on s p a management  exchange policies  1 37  This  final  criterion,  as  identification "plans  of  process  they of  spa  for  in  order  provide  fully  for:  (a)  to allow  the  fourth  acknowledgement  for  operators  to  spa  to  develop  management  motivate  gathering  knowledge  learning  within  a learning  learning; (5)  a  whole  (4)  process  from e x p e r i e n c e  the  and (the  performance;  operator  r e d u c e u n c e r t a i n t i e s ; and  and  meets  management u n c e r t a i n t i e s ; ' (2) a t o o l  incentives  review  provisions  improving  s t u d i e s w h i c h may policy  of  operation")  and  positive  set  spa  (3) new for  elsewhere management  system.  N o t e s on  Provisions for  A detailed related  to  considered be  an  d i s c u s s i o n of development  outside  attempt  importance  Funding  of  the  to  funding  of  a  s c o p e of  provide  funding  to a  B.C.  this  detail the  deserves  mention  of  few  which are  b a s e d on  observations  and  other  model  thesis, here.  success  economic spa  and  policy  the  through  not  obvious  model  g e n e r a l comments and gained  were  there w i l l  However, t h e of  matters  policy  suggestions,  r e s e a r c h on  this  thesis.  First,  the  created  pressures  reduce  budgets  economic on —  all  climate government  public  health  Costs  involved in developing  the  above  generally  spa  policy  r e q u i r e on-going  can  and  of  the  agencies agencies  past  few  to are  no  years  has  restrain  or  exception.  a d m i n i s t e r i n g programs such  become  expenditures  substantial. w h i c h can  They  often  as also  increase  138  over  time.  the  primary  in  But  concerns  society.  toward  Public  them,  concern,  public  health protection of government and  spas and  are here  public  hot  tubs,  t o s t a y ; and  budgets  should  appears  that  is  considered  vital  one  of  to a l l i n d i v i d u a l s  r e g a r d l e s s of one's  as m a t t e r s  adequately  of p u b l i c account  view health  for  spa  regulation.  Second, kind  it  of s u b s i d y f o r those  on a r e g u l a r efforts than  with  other  a  considered a any  properly)  who  appears  require  activities,  spa  users,  "special  interest".  it  is  of  Therefore,  the  that  future),  officials  economic  two  as  possible,  budgets  will  t o implement alert  rather study  be spa  s h o u l d be  spa  regulatory  expenditures swimming.  regular  users,  hence they can  toward  unfair  public  t h e q u e s t i o n of  be to spa  whether  involved.  s u g g e s t i o n s a r e made: carefully spas for  both the  policy  until  analyze f o r the  funding  short-term  long-term.  inadequate,  legislators  than wait  a c t as a  particularly  i t w o u l d be  funds  should  regulating  should  as p o s s i b l e , (2) An  following  for  as n e a r l y  appears the  that  especially  reasonable to r a i s e  health agencies  requirements and,  spas,  greater  Although  public  efforts  s u c h as p u b l i c  u s e r s s h o u l d b e a r more o f t h e c o s t s  (1) P u b l i c  use  m i n o r i t y o f t h e p o p u l a t i o n , and  allocation  regulation,  far, i t also  that  regulatory  individuals  similar  i t appears  constitute  spa  So  ( i f undertaken  Further,  deny  basis.  spa  (either  If now  effectively, and  the p u b l i c  problems  immediately  it  or i n health  as  soon  arise.  undertaken  which  139  considers alternative for  spa  spa  regulation.  users  should  be  (and  methods f o r o b t a i n i n g n e c e s s a r y T a x e s or  applied  c o n s i d e r e d as  "regulatory  tax" could  regulation,  over  special  through  one  of  be  devised  and  operators  which  and  users  serve  so as  tax  on  industry) Perhaps a costs  public  amounts.  of  health Such  a  t h e added p u r p o s e of p r o v i d i n g o p e r a t o r s  w i t h an  effectively  or  uses  comparative  p r o g r a m s , as a b a s i s f o r c o m p u t i n g system might  assessments l e v i e d  the a l t e r n a t i v e s .  above  funds  incentive  to  t o manage spa  i n c u r the  least  needs  facilities for  more  government  regualtion.  Although detailed  analysis  options, study.  these  and These  considered  failure  Expected  about  policy,  they  derived  spa and  responsibility  outside a  experiences,  work on  suggestions  should  at  interested  i n spas  and  this  case  least  be  pursued  if  investigation.  R e s u l t s : How  the Model  Policy  Deficiencies  spa  hazards the  are  reflect  through  in  present  B.C.  incorporate recent t e c h n i c a l  potential  potential  suggestions  thesis,  and  further  main weakness to  and  policy-makers  Correct Present The  this  comments  deemed w o r t h y of  Can  in  observations  by  Summary and  comments  hazards are  not  Province  and being  is  spa  and  policy  scientific  spa management. adequately  failing  As  dealt  to f u l f i l l  i n p r o t e c t i n g t h e h e a l t h of u s e r s  is  its  knowledge a  result, with  by  i t s role  and  and  non-users  140  of  spas.  Although  the U n i t e d  some  S t a t e s have  recognized  taken  positive  should  o n l y be p a r t i a l l y  jurisdictions (1)  steps  include operators  these  handling  matter  and u s e r s  users  first  for  in  spa  spa  for  u n c e r t a i n t i e s and  the u n c e r t a i n t i e s  policies  (problems to this  taken  the  actors  development  i s essential.  change  by  have  takes  protect been  meeting  from  B.C. s p a  and then  reasonably  Recommendations  in  s t e p s must  their  the  policy  public  presented  health  which  a l l of the c r i t e r i a  active spa  i n present  elements  which  the a d d i t i o n a l  that  Further,  for deficiencies  resulting  being  recognize  that  in  and p r o v i d e  additional  and  with  However,  health i s  that policy-makers  key  knowledge A  problems.  that t h e i r  r e c o g n i z e and a c c o u n t  spa hazards  deficiencies  have  t o be e f f e c t i v e  confidence  are  in policy  management  to  these  i n t h e use o f s p a s ,  users  uncertainty.  serve  management  and  must  potential  process  policies  s p a management  to deal with  It i s also crucial  participation policies  decision  s t e p of r e c o g n i z i n g the problems a s s o c i a t e d  protected  operators  the  i n t h e U.S. and Canada  and t h e p u b l i c w i t h  taken.  These  of u n c e r t a i n t y ) .  reasonably be  actions  t h e v a r i a b l e spa c o n d i t i o n s a r e l i n k e d  s p a s and a t t e m p t i n g order  their  and  f o r B.C. p o l i c y .  and management  acknowledge  Some j u r i s d i c t i o n s crucial  hazards,  hazards  failed to:  devise a strategy for reducing in  i n Canada and  potential  u s e d a s a model  spa s t a n d a r d s  sufficiently  elsewhere  the  to deal with  have p r i m a r i l y  developing (2)  jurisdictions  of  recognizes steps  and  correct set forth  will  safety. existing in this  141  study. be  If these  expected  recommendations a r e  and  how  would  they  accepted,  what r e s u l t s  actually  overcome  can  present  deficiencies? 1. R e c o g n i t i o n Health  and  standards to  of p u b l i c h e a l t h h a z a r d s efforts  and  before  t o be  prepared  The  and  of heavy  model p o l i c y  necessary  to develop  spa  information  about  be  use  and  of  effects 3.  public  in  due  spas  spa  use  t o spa  policies  for  preferences  spa  about for  provides  a l l spa  problems  spa  actors  which  This will  may  allow  spa  p r e v e n t a t i v e measures they  have  hazards  and  hot  and  the  and  operators  tubs.  in  places  and  of  preventative so  that  lead to  This w i l l  to p r o t e c t  spa  "safe"  serve  the  to  health  g e n e r a l p u b l i c from e x t e r n a l  n o n - u s e r s and  assure,  accounted  c a u s e a l l spa  more e f f i c i e n t  establishing  will  appropriate  use.  I n c l u s i o n of u s e r s , process  of  development.  government's r e s p o n s i b i l i t y  users  Ministry  recommendations emphasize communication  m a r k e t mechanisms w i l l  fulfill  as  market  measures t o u s e r s , n o n - u s e r s  of  will  tub use.  occur  the  more  potential  hot  s e r i o u s p r o b l e m s do  with a h i s t o r y 2.  examine t h e  from p u b l i c spa and  actors  develop  management p o l i c i e s  realistically  arise  to  by  spa  i t also will  s y s t e m by  utilizing  and  conditions will  policy  a c t o r s with  process,  standards  i n the d e c i s i o n management  as w e l l as p o s s i b l e , t h a t  " s a f e " spa  in  spa  operators  decisons.  confidence  be  adequately  This in  not  the  p r o d u c e a more e f f e c t i v e  more f u l l y  individual  the c a p a b i l i t i e s  only  decision  overall of  spa  users,  1 42  operators  and  health  officials  i n implementation  of the  policy. The  proposed  the  spa a c t o r s '  by  implementation capabilities  variable  spa  recommendations w i l l interaction This  will  spread  and t h e  encourage  conditions  o f use and  operators,  i t  successful  s p a management  will  and h e a l t h  enhance  by p r o v i d i n g :  conditions  so  various  that  spa  the  prospect  actor.  The  model  policy  r e q u i r e s , and (b) a to  conditions  check a r e not  the  to protect  future.  provided  by  u n c e r t a i n t i e s i n s p a management  and  recommended improve spa with  as  management  therapeutic  t o cope w i t h  effectively  P o s i t i v e i n c e n t i v e s and s o c i a l  ways  s p a management  greater  acknowledge  t o be a b l e  public health  "plans  will  of  operations"  and  t o encourage and allow beyond provide  confidence benefits  ignored  the  f o r spa a c t o r s  can  i t s current users  that be  by  spa  both  recommendations  the  order  on  one  of reducing  in  f o r spa  any  importance need  of  i f n e c e s s a r y , on  because of d e l i b e r a t e or u n i n t e n t i o n a l n e g l e c t spa  and  officials.  (a) a means  actors  hazardous  the  f o r establishing "safe"  b a s i s which v a r i a b i l i t y  means f o r a l l t h e  of  participation  t o be m o n i t o r e d and c o r r e c t e d ,  a more f r e q u e n t  created  Adoption  active  the r e s p o n s i b i l i t y  consider  difficulties  conditions.  among u s e r s ,  conditions  measures r e a l i s t i c a l l y  surprises  now  and  learning  tools  studies  are  spa a c t o r s t o  state.  Improved  and the g e n e r a l  spa  in  recreational  enjoyed without  public and  endangering  143  public  h e a l t h and  safety.  In c o n c l u s i o n , the p o t e n t i a l public  spas  and  underestimated that  sound  tubs  are very  by  many  people.  spa  significantly safety  hot  management  reduce  the  p r o t e c t i o n can  be  reasonably  this  through  Yet,  the  the  conditions  control  of  policies  should accept  suited  to  policies basic  complement  regulatory  The  and  following  the  necessitates an  h e a l t h and  be  for a better  a  and  u s e r s and  the  spas  involved  to provide use.  serve and  hot  in  spa  effective  Effective solutions  Adaptive  and  spa best  flexible  spa  management p r o v i d e d to  the  by  establishment,  standards.  Columbia can  with both  lessons gained  provide a  reasonable  theory in  from  and  this  spas  experience thesis.  existing  elsewhere  of  This  policies  can  be  by  used  and as  system.  willingness  by D o w n s , K a s p e r s o n s , 1  can  health  of p u b l i c  f o r spa  agree  effectively  devise  related spa  probably  s a f e t y p r o t e c t i o n i n t h e use  consistent  of how  t o spa  spa  and  a w i l l i n g n e s s t o change  Creating noted  from  recommendations o u t l i n e d  understanding  a guide  of B r i t i s h  public  can  of government  framework  of  that  assured  uncertainty.  requirements  Province  would  the  so  policy  reality  enforcement  of p u b l i c  which  this  are  practices  uncertainty  resulting  d e a l i n g with  monitoring,  level  problems  they  and  regulation of  management weaken t h e a b i l i t y  and  a s s o c i a t e d with  Most e x p e r t s , however,  hazards  Government p u b l i c  tubs.  real  policies  general p u b l i c . objective  h e a l t h hazards  2  t o change p u b l i c and  others,  direction  i s often  a  i s , as  difficult  144  task  until  a crisis  prerequisite spas  and  for achieving  hot  tubs  similar  efforts will  public  spas,  direction  occurs.  in  for taking  "safer" B.C.  create  encourage  Overcoming  conditions  of  i s hoped t h a t  awareness  others  action.  It  this difficulty  to  about take  use  is  for  the  public  this thesis  the  problem  action,  and  and with  provide  1 45  Footnotes  - Chapter  5  A n t h o n y Downs, "Up a n d Down with Ecology: The IssueAttention C y c l e " , The P u b l i c I n t e r e s t 29 (Summer 1972), p p . 3850. 1  Roger E. Kasperson, "Environmental Stress and the Municipal Political System", in R. E . K a s p e r s o n and J . V. M i n g h i , eds., The S t r u c t u r e o f P o l i t i c a l G e o g r a p h y , ( C h i c a g o : A l d i n e P r e s s , 1971) , pp. 481-96. 2  1 46  APPENDIX A  Pathogenic  Hazards  Spa/Hot Tub New  Robert  A.  Hot-water activity years.  has Along  disease  health State  and  as  rapidly  C.J.G. M a c K e n z i e ,  a  recreational  gained  with t h i s  popularity  spa and  hot  (e.g.,  Centre  from  both  health  problems  has  with  federal  public  Numerous c a s e s  disease  this  from  organism  t u b s compared  Although  indicate when  that  and  hot  skin  have  or  tub only  infection  been  well-  there i s a higher r i s k  individuals 1  has  to  concerns  poorly  involving  t o swimming p o o l s . "  aeruginosa  tended  serious spa  are  Pseudomonas a e r u g i n o s a  studies  also  of  Oregon  maintained.  and  incidence  f o r D i s e a s e C o n t r o l and  marginally  documented,  six  state  where f a c i l i t i e s  organism  last  and  particularly  the  the  the  t u b use  2  therapeutic  within  increased popularity,  with  M.D.  and  H e a l t h D e p a r t m e n t ) have e x p r e s s e d  public  spas/hot  2  1  Health  facilities,  from  1  Facilities:  United States o f f i c i a l s  Public  about  Crandall  bathing  agencies  Public  Challenges to Public  associated  increase.  and  long  are  exposed  of to  6  been  associated  with  Robert A. C r a n d a l l , M.A., Dept. of Community and Regional P l a n n i n g , U n i v e r s i t y of B r i t i s h Columbia. C.J.G. MacKenzie, M.D., CM., D.P.H., FRCP(C), Professor, Dept. of Health Care and Epidemiology, University of B r i t i s h Columbia.  147  swimming p o o l s , t h e with  spas  and  environmental Comparison  increased rate  hot  tubs  conditions  of  the  for  t h e e s t a b l i s h m e n t and  increased  the  range  spa/hot  of  of  medium  pathogenic  As  the  range  organic  from  when  growth  of  with  applied  sanitation,  hot  precedence perhaps  is  disease.  more  (7.0-8.0),  materials  new  between p o o l s  and  conducive The  warmer  aeration,  due  to high  t u b s and  a variety  and  bather  a l l foster of  aeruginosa  a  potentially  tubs.  to  recommending  management, and  f o r spa water q u a l i t y  pathogenic  practices  proper  regulatory  may  design,  methods  for  R e l i a n c e upon swimming p o o l e x p e r i e n c e as may  be  i n some i n s t a n c e s , e x p o s e p u b l i c organisms.  create  increased  thought  toward  suggest  general alternatives  * * D e f i n e d as  demonstrates,  u n d e r l y i n g swimming p o o l water q u a l i t y  engineering, and  the  experience  misleading  spas  these  growth of m i c r o o r g a n i s m s . pH  problem  organisms.  assumptions be  for  a  about  characteristics  l o a d * * a r e common c o n d i t i o n s f o r s p a s / h o t suitable  as  infectious  tub environment  (35°-43°C),  presence  questions  sources  differing  shows t h a t  temperature  raises as  spas  of o c c u r r e n c e  awareness  The of  grossly  users to  purpose this  more a p p r o p r i a t e and  ineffective,  of t h i s  possiblility,  comprehensive  for future  greater paper  a  and risk  i s to  stimulate  solutions,  and  direction.  " t h e number o f u s e r s p e r volume o f w a t e r o v e r  time."  148  Research  B a c k g r o u n d and  This  research  recommendations  whereby  knowledge  relating in  typical  spa  microorganisms  the  for  the  relating  examination problems  findings  perspective  the e x t e n t  and  A  on  the  growth  data  the  modelled  reasonably  chosen  and/or  Using  was  was  to  establish  wide r a n g e of  basis  shown  previous  study.  of  springs  of  Additionally, was  briefly  by a  in  epidemiological  these  areas  was  hot also  investigations  of b a s i c p u b l i c  tubs,  An  and  undertaken. were  h e a l t h and  analyzed  epidemiologic  search  to  1,  those  studies  extensive  studies for infectious  spas,  tub  Table  microbiological  examined.  their  spa/hot  obtained  categories  of  personal  the  w i t h i n the  then  to  British  of t h e v a r i o u s o r g a n i s m s were compared  related of  in  Prior  7  industry  parameters.  i n swimming p o o l s ,  recreation  about  hazards.  spa  relating  policy  raised  tub environment  tub model.  t o hot  work  s e r v e d as a b a s i s f o r t h e  Microbiological  spa/hot  by  public  were  and  survival  literature.  tub  pathogenic  pool  hot  characteristics of  hot  were s e l e c t i v e l y  environment. of  to  operational  potential  and  above a l s o  and  motivated  concerns  the  research c i t e d  The  was  f o r spa  Columbia,  experience  Methods  disease  other  water  Finally,  the  from  the  principles.  Findings The empirical between  results studies. the  are  i n c o n c l u s i v e due  Although  characteristics  there of t h e  is  to  insufficient  a  positive  spa/hot  data  and  correlation  tub environment  and  1 49  those which organisms,  favor other  disinfection,  t h e growth o f a number o f p o t e n t i a l important  origin  and  individual  susceptibility  outbreaks  are  determination comparison contained  of  of  little  of  risks  hazard.  of  organism,  and  lead  to  disease  T h i s complicates the  The  and  pertinent raised  potential  results  potential  as p a r t in  epidemiological  from  the  pathogens  are  studies  and  several  q u e s t i o n s of p a r t i c u l a r  which,  t o d a t e , have been g i v e n  hazards  attention.  considering  pathogenic  the  (efficacy  2.  o r no p u b l i c  be w o r t h  of  known.  environment  research  about  factors  t o i n f e c t i o n ) which  sufficiently  the  review  experimental  transmission  potential  in Table  The  interest  not  interconnecting  pathogenic  These  of  an  speculative overall  correspondence  with  findings  effort the  to  might reduce  environmental  conditions.  1.  Are the  allowing  a  environmental wider  range  conditions  of p a t h o g e n i c  of  spas  and  hot  tubs  s p e c i e s and a c t i v i t i e s t o  occur? Besides matter, result  t h e more e v i d e n t f a c t o r s  spas/hot  tub environments  o f pH, a e r a t i o n ,  Brock  8  Park  suggests that  for  on  alkaline  consistent slightly  organisms  the  acid  organisms  pH r a n g e ,  and o r g a n i c  i n c r e a s e hazards as a  efficacy.  Research  by  i n hot s p r i n g s a t Yellowstone  many o f t h e s e o r g a n i s m s  pH a n d d i e under  alkaline  may a l s o  and d i s i n f e c t a n t  thermophilic  with  of temperature  pH.  This  examined  7.2-7.8,  a l s o have an pattern in  currently  this  affinity is  quite  study.  recommended  The as  150  the  i d e a l range f o r  for  the  g r o w t h of  ammonia  loads  s p a s and  the  hot  tubs,  identified  from b a t h e r  use  is also  pathogens.  frequently  Moreover,  consistently  drive  ideal  increased  pH  in  the  alkaline direction. Blanchard  and  Syzdek  transferring  pathogens  protecting  the  p r o c e s s may it  not  ears). of  transmitted  usually  T h e r e may  aeration  w h i l e on  the  forming  with  role  the  of  air  the  i n spa  a i r and  water  hand  aerobic  efficacy.  to  Finally,  (particularly  themselves  and For  wooden  develop example,  forming a p r o t e c t i v e  organism's apparent  the  nose, mouth,  slime  may  be  solids  chloramines porosity  1 0  reduce  of  limit  spa/hot organisms  evidence as  the  Ammonias  mechanisms  cites  coating  resistance  and  killed,  further  allows  protective Brown  the  direct effects  disinfectants.  units)  which  flourish.  dissolved  produce  in  significantly  i n f e c t a r e a s of  some  in  aeration  organisms  (e.g.,  ones  also  The  i n v o l v i n g the  one  bubbles  and  more  i n f e c t i o n from  total  of  disinfection.  some t r a d e - o f f  chlorine  disinfectants.  the  to  commonly-used h a l o g e n a t e d  disinfection  for  be  for  through  immersed  build-up  of  aeruginosa  from  o t h e r hand h i g h l y  efficacy  structures  water  upon o r g a n i s m s ; on  Rapid  attach  organisms  opportunities  normally  body  from  the  r e d u c e d i s i n f e c t a n t e f f i c a c y , but  introduces  are  describe  9  an  to c h l o r i n e  tub to  against of  P.  explanation under  certain  conditions.  2.  Are  current  practices  sufficient  to  protect  spa/hot  tub  151  users  from Two  of  less  organisms  withstanding  Legionella currently after  investigating  spas.  appear  from  The  1 1  pneumophilia  and  speculation originates  that from  spas/hot  is  tubs  environmental  source.  1 3  One found  deaths  algal  in L^  despite  the  possibly  "The  of  There  non-lethal  and  produces  regard  presence. elimination  warm  products has  been  influenza-type  tubs. implication  despite  L^  between  d i s e a s e which  to premature  pneumophilia  tubs  that  or a l g a l  (a  hot  spas/hot  suggests  1 2  tubs,  Disease  relationship  pneumophilia."  w i t h s p a s and  is  Department  Legionnaire's  colonization  Fever  spas/hot  Health  conditions  pneumophilia  urged  to  Public  photosynthesis  L_j_  first  for Disease Control i s  link  from  The  acknowledged  pneumophilia of  of  the  outbreaks  environmental  1 4  e x p l a n a t i o n f o r t h e e p i d e m i o l o g i c u n c e r t a i n t i e s may  that  legionellas by  2  i n work by R o w b o t h a m  suggest  Center  Vermont  bacterial  continued  capable  the  Pontiac  and  dangerous pathogens  pneumophilia.  symptoms) i s a s s o c i a t e d Caution  disease?  possible  for  L^  fatal  the  w h i c h a r e open t o a l g a l  be e n v i r o n m e n t s  have  U.S.  environmental  f o r L^_  s e v e r e or  preventative practices. The  implicated  suitable  habitats may  emerge a s h i g h l y current  reports  with  but p o t e n t i a l l y  pneumophilia.  etiologically  L.  likely,  ameoba  feed  15  1 6  and  on  L_;_  Nagington  pneumophilia  sometimes s u r v i v e as a r e s u l t  amoeba.  As  stated  be a mechanism by  in a Lancet which  and  Smith and  legionellas  1 8  could  .  They  that  of p r o t e c t i o n  editorial,  1 7  be  the  afforded  "This  might  survive  in  152  water, of  but  more i m p o r t a n t l y  legionellas  Inhalation  of  pathogens  the  from a c o o l i n g Limax  swimming p o o l s , amoebic  be one  delivered vesicle  i n which  to  a  respiratory  1 9  tower,  amoeba  system,  and  an  have  large  and  spa c o n d i t i o n s  host.  l e t 50-1000  it  would  amoeba i n an  evaporative been  numbers  potential  o r an amoeba c o u l d  i f t h e r e were not more t h a n one  shower."  appear  aerosol  condensor,  routinely  be  or  isolated  more  a  from  favorable  to  growth.  The amoeba  second commonly  identified cases  from  Africa,  2 1  o r g a n i s m of i n t e r e s t found  in  soils  as the cause of f a t a l such d i v e r s e  Australia,  Virginia, India.  only  into  surprising coming  could  i t i s a way  Georgia,  New  and  i s Naeglaeria water.  2 0  fowleri,  It  has  been  m e n i n g o e n c e p h a l i t i s i n over  a r e a s as C z e c h o s l o v a k i a , E n g l a n d , Zealand,  California,  the and  U.S. New  (Florida,  York),  an  100 East  Texas,  Belgium,  and  2 2  I n d o o r swimming p o o l s , t h e r m a l s p r i n g s , h e a t e d pools, and waters used to cool m a n u f a c t u r i n g p r o c e s s e s have been i n c r i m i n a t e d as s o u r c e s of t h e fatal i n f e c t i o n s . . . . In nature, it feeds primarily on bacteria. Thus, contamination of warm water with bacteria substrate provides an excellent environment for rapid g r o w t h . . . . Water i n swimming p o o l s s h o u l d be circulated frequently enough to r e d u c e o r g a n i c c o n t a m i n a t i o n and t o c o n t r o l temperature e l e v a t i o n . The v a l u e o f chlorine has not been d e m o n s t r a t e d . " ** 2 3  N.  fowleri  grows r e a d i l y  a t body t e m p e r a t u r e and above,  **Anderson & J a m i e s o n (1972) c o u l d n o t e l i m i n a t e N a e g l e r i a swimming p o o l u s i n g s u p e r c h l o r i n a t i o n up t o 10 ppm.  and  in a  153  may  grow b e s t a t ±45°C.  9.1.  Being  also  favorable  excellent To tub.  a highly  date,  fowleri  organism  Moreover, into  transformed  an  individual  The  The  1962  of v i r u l e n t  and  reported  1965.  to  process i s provide  an  o t h e r amoeba.  isolated  in a  spa/hot  environment.  Limax  nasal  allowing  infection  transmission  below water  mucosa, ' 2  movement  fowleri  further,  are  easily  through in  the  aerosol  the p o s s i b i l i t y in a  and  spa  or  of hot  non-virulent The  organism  polluted  waters  o f N_j_  dominant  meningoencephalitis Additional De  N_;_  fowleri  would  appear 2 9  fowleri  work by C a r t e r , 3  De  3 1  De  in  deaths  thirty-three  strains  from t h a t  same p o o l  t o be more h a z a r d o u s  concludes  also cites  3 0  influencing  Jonckheere, "  16  enhance t h e g r o w t h  Singh  from  resulting  isolated  2 8  Jonckheere  fowleri. factor  of the d i s e a s e o c c u r r e d i n a  pool  Kadlec  2 7  thermally  ,  and  outbreak  De  3  of  h i s head  waters.  3  and  37°C,  facilitating  earlier  warm, spa  al.,  At  i n d o o r swimming  and  later.  strains  can  7.6  exists.  Czechoslovakian  years  the  form c y s t s ,  possibility  submerging  largest  between  does  flagellates,  2 6  filters  n o t been in  is  the a e r a t i o n  fowleri  has  other environments.  has been m e n t i o n e d  tub always  Pool  range  from human t h r o a t s and  the organism  nasal passages. form  organism,  is free-living  isolated  into  f a v o r a b l e pH  f o r N_;_  medium of g r o w t h  The  entry  aerobic  to i t s s u r v i v a l .  amoeba have been 2 5  I t s most  that  warm  12 in or  of the p a t h o g e n i c  temperature  incidents  of  as  the fatal  i n water. Jonckheere,  Jonckheere  and  3 2  van  Willaert de  et  Voorde,  3 5  1 54  Kadlec  et a l . ,  Chang,  and  4 0  contributed  amoeba  studied  the on  to  of  enhance  the  spas  hot  and  Are  agents,  to  found  of  t o be If  in  spas  effective  and  control  fowleri  are  the  have  strains  high  of  Further  relationship  of was  including  tubs  P.  I t may  could  also  of  o f N_j_  P.  limit  aeruginosa  for establishment  4 2  i n c l u d e d , but  occurrence  P^  Brent  chromogenic  t o t h e amoeba.  hot  and  commonly  G r o s c o p and  bacteria,  the  above.  in diagnosis.  (N.gruberi  toxic  3 9  i t i s conceivable that  determine  the  so,  Neva,  3 8  have been d i a g n o s e d  overlooked  opportunities  N.  might  fowleri  in  tubs.  disease  misdiagnosis  than  of N_j_  encephalitis  of amoeba  Three  Das  findings presented  twenty-four  strains  reported  and  other microorganisms.  fowleri.  Thus,  viral  needed  effects  were  aeruginosa  3.  and  five  Singh  7  and  been  be  fowleri).  aeruginosa,  and  have  may  between  fowleri.  3  s t a t e s t h a t more c a s e s  4 1  to b a c t e r i a l  investigation  N^  al.,  meningitis  sources  bacteria  et  s u b s t a n t i a t e the  Singh  Since  attributed  toxic  Lawande  to meningoencephalitis  reported.  not  6  others  Finally,  amoebic  3  or  outbreaks failure  of  going  undetected  individuals  to  because  formally  of  report  problems? Intuitively, and  i t seems q u i t e r e a s o n a b l e  p a t i e n t s would have d i f f i c u l t y  many  of  determining  the d i s e a s e s which c o u l d p o t e n t i a l l y  These c o u l d fever  t h a t both p h y s i c i a n s  i n c l u d e : P.  (flu-like  aeruginosa  symptoms),  (rash  Giardia  the  source  d e r i v e from symptoms),  lambali  of  spas. Pontiac  (diarrhea),  1 55  Trichamonas  (vaginitis),  E.  fowleri  (headaches  Albicans  (vulvovaginitis).  Empirical of  undetected  cases  of  and  Other one  unreported  Pseudomonas  these  1980  outbreaks  surveillance  misdiagnosis the P u b l i c  The  efforts  The  study  their  significant  the  conclude  public  culturing  a wide range  uncertain.  and  of The  that  health  spas  effectiveness  here  pathogenic  show t h a t  hot  do  cases a s s o c i a t e d investigation.  i n f o r m a t i o n , and  persons  failed  several  failure  treatment  not  risks  to  in  seek  instances  to report cases  provide  of s p a s  and  the p o t e n t i a l concerns.  of p a t h o g e n i c  hot  of  u n i t s as  t u b s , nor  of to  is  for do  constitute results  environments  microorganisms  f o r hazard  basis  hazards  p r e s e n t p r e v e n t a t i v e measures potential  a  However, t h e  tubs p r o v i d e e x c e l l e n t  major w e a k n e s s e s w h i c h o f t e n o c c u r the  74  Department.  findings presented  they, a d e q u a t e l y  (1)  evidence  formally reported in  similar  noted  Candida  Recommendations  determining  and  also  shown  follow-up  of a f f e c t e d  and  N.  study, n i n e t y - t h r e e  additional  produced  by p h y s i c i a n s and  Health  Summary and  An  were  were d i s c o v e r e d by  program, 75%  care.  In one  3  foot),  fatal),  i n Oregon have  cases.*  1982.  (athlete's  i f not  folliculitis  and  investigation  medical  backaches,  s t u d i e s conducted  Oregon between with  and  floccosum  and  that  do for the  i s questionable  increased  in various public  by  two  facilities;  " s m a l l swimming p o o l s " and  (2)  156  poor maintenance direct risks  and o p e r a t i o n .  attention  t o more a p p r o p r i a t e  on a more c o m p r e h e n s i v e  develop  which  Thus,  4 4  do  management a n d r e g u l a t o r y  aspects,  this  paper.  development  -  provide clearcut w h i c h may  of  The p u r p o s e  of  new  design/engineering  the  seem which  before  wise  major  considered  to  can reduce problems  evidence of hazards. be  to  b u t t h e y a r e beyond  here  ideas  of  solutions  basis  a r e numerous a l t e r n a t i v e s  i t would  There improve  t h e scope  i s t o urge c o n s i d e r a t i o n and  and  devices  systems,  water  relating  to  purification,  and  test ing/monitoring.  These 1.  general  Solutions  range  of  s h o u l d be b r o a d l y - d e s i g n e d t o encompass  potential  t h e most common  2.  g u i d e l i n e s a r e recommended:  pathogenic microorganisms  t o s h a r e t h e common spa/hot  draining thorough  tub  and  spa/hot  tub  of  environment,  3.  principles  agent  the  be d i r e c t e d  organisms.  host,  and  of f r e q u e n t l y  problems  than  just  and s t r o n g l y  of  the  filtration  unit,  system,  treatment of the toward c o n s t a n t l y thereby  placing  of e p i d e m i o l o g y and  environment  a l l  appear  disrupting  Such methods i n c l u d e :  cleaning  o r shock  upon p o s s i b l e  The b a s i c  to correct  environment.  cleaning  superchlorination  efforts  factor  thorough  s o l u t i o n s might  wide  ones.  So f a r , t h e s i n g u l a r  the  rather  the  frequent  frequent and  water.  and  frequent  Thus,  new  d e - s t a b i l i z i n g the considerable  public  stress  health  of  s h o u l d be u s e d a s a g u i d e , a n d a  157  minimum o f two o u t o f t h r e e a r e a s s h o u l d be s u f f i c i e n t l y in  4.  covered  a l l situations.  Regional  solutions,  considerations taking  into  should  be  account s o c i a l ,  incorporated economic,  into  and r e s o u r c e  factors. Brief  examples  of  alternative  technical  solutions  might  include: - Flow-through This  water  system might  as t h e P a c i f i c - A  heat  systems  be a p p r o p r i a t e  desired  system  tub  unit.  even  s o l a r ) might  just  material when  a  cooling-down  prior  consider  this  schemes i n v o l v i n g  Development  levels  and of  (Japanese  multiple ozone  which  are  deficient  UV)  shock  and  treat  standards . f o r  of  4 5  the spa/hot (perhaps  improved  d e v i c e s which monitor  change  daily).  the  use of d i s i n f e c t a n t s  or  permanganate v a l u e s f a r l e s s water  to  approach.  and a u t o m a t i c a l l y  necessary.  into  supply of energy  require  areas  such  within the  process  to re-entry  Areas with p l e n t i f u l  (e.g., chlorine/bromine filtration:  f o r water-rich areas  p r o c e s s f o r s u p p l y water  with  temperature  - Combination  exchanger.  Northwest.  sterilization  circulation  c o u p l e d w i t h a heat  This in  t h a n 25  the  water  heated  baths  mg/litre  a p p r o a c h might both  water  organic  and  and  apply to energy  resources. - Development  of  (e.g., organic  devices  material,  which  sense  disinfectant  critical free  parameters  residual,  pH,  158  total  dissolved  s y s t e m and made. The the  This could  important  aspects  technical  enjoyable  valuable  used are  social,  c o s t s can hot-water  difficulties  productive  automatically  re-starting be  which  and  until  i n any not  behavioural,  surround  the  of  in this  spa  instance,  water  and/or quality.  but  adjustments  are  reduce  ignore  any  hazards  and  confident  and  both  f o r the  which d i r e c t l y  conceivably  they  useful  not  could to  and  However,  management may  products  nor  economic, p o l i t i c a l  situation.  Efforts  water q u a l i t y  the  to supplant  extremely h e l p f u l  bathing.  information  concerned with  be  proper  shut-down  area.  meant  advances which e f f e c t i v e l y  operational  the  prevent  above s u g g e s t i o n s  other  legal  solids)  confront only  be  provide  other  areas  159  References  Cited  1  Center for Disease Control, " M o r b i d i t y and Mortality R e p o r t " , 2 4 ( 4 1 ) : 349-350, O c t o b e r 17, 1975.  Weekly  2  Center for Report",  Weekly  3  Sausker, M a j . W i l l i a m F., MC, U.S.A. e t a l . , "Pseudomonas F o l l i c u l i t i s A c q u i r e d from a H e a l t h Spa W h i r l p o o l " , J o u r n a l of the American M e d i c a l A s s o c i a t i o n , 2 3 9 ( 2 2 ) : 2362-2365, J u n e 2, 1978.  Disease 30(27):  Control, " M o r b i d i t y and 392-330, J u l y 17, 1981.  Mortality  "Washburn, John A. e t al., "Pseudomonas A e r u g i n o s a Rash A s s o c i a t e d W i t h a W h i r l p o o l , " JAMA, 2 3 5 ( 2 0 ) : 2205-2207, May 17, 1976. 5  M c C a u s l a n d , W i l l i a m J . and Cox, P a u l J . , "Pseudomonas I n f e c t i o n Traced to Motel Whirlpool," Journal of Environmental H e a l t h , 3 7 ( 5 ) : 455-458, M a r c h / A p r i l 1975.  6  B r o w n , James C , " P u b l i c H e a l t h P r o b l e m s i n Spas and Hot T u b s " , a d d r e s s t o the N a t i o n a l E n v i r o n m e n t a l Health Association Annual Education Conference. New O r l e a n s , L a . , J u n e 20, 1 982.  7  C r a n d a l l , R o b e r t A., "Spa Management Uncertainties and the Design of Policy f o r P u b l i c Spas and Hot Tubs i n B r i t i s h Columbia", Masters T h e s i s , Department of Community and Regional Planning, U n i v e r s i t y o f B r i t i s h C o l u m b i a , due t o be c o m p l e t e d 1983.  8  B r o c k , Thomas D., Temperatures,  9  Blanchard, Duncan C, and Syzdek, L a u r e n c e D., " W a t e r - t o - A i r T r a n s f e r and E n r i c h m e n t o f B a c t e r i a i n D r o p s from Bursting Bubbles", A p p l i e d and Environmental Microbiology, 43(5): 1001-1005, May, 1982.  Thermophilic Microorganisms 1978.  and  Life  At  High  1 0  B r o w n , James C . , o p . c i t . , J u n e 20,  1982.  1 1  B r o w n , James C., p e r s o n a l communique from D r . Ken Spitalny, E.I.S. O f f i c e r , Vermont S t a t e H e a l t h D e p a r t m e n t , J u n e 14, 1982, u n p u b l i s h e d m a n u s c r i p t , 1982.  1 2  F l i e r m a n s , C.B. e t a l . , " E c o l o g i c a l D i s t r i b u t i o n o f L e g i o n e l l a pneumophilia", Applied and Environmental Microbiology, 41 (1 ) : 9-16, J a n u a r y , 1981.  1 3  Myerowitz, Richard L., "Letters", American M i c r o b i o l o g y News, 4 8 ( 5 ) : 183, 1982.  Society  for  160  " L a t t i m e r , Gary L., Disease, Marcel 181 .  a n d Ormsbee, Richard A., Legionnaire's D e k k e r , I n c . , New York a n d B a s e l , pp.- 180-  5  Rowbotham, T . j . , " P o n t i a c F e v e r E x p l a i n e d ? " , (Vol. I I ) :969, November 1, 1980.  6  Rowbotham, T . J . , " P o n t i a c F e v e r , Amoebae, and L e g i o n e l l a " , The L a n c e t , 8210 ( V o l . I ) :40-41, J a n u a r y 3, 1981.  7  Nagington, J . , and S m i t h , D . J . , " P o n t i a c F e v e r a n d Amoeba", The L a n c e t , 8206 ( V o l . I I ) :1241, December 6, 1980.  8  The  9  Lyons, Thomas B. a n d K a p u r , Ramesh, "Limax Amoebae i n P u b l i c Swimming Pools of Albany, Schenectedy, and Renssler Counties, New Y o r k : T h e i r C o n c e n t r a t i o n , C o r r e l a t i o n s , a n d Significance", Applied and Environmental Microbiology, 3 3 ( 3 ) : 5 5 1 - 5 5 5 , M a r c h , 1977.  Lancet ( e d i t o r i a l ) , " L e g i o n e l l a I I ) :703-704, March 28, 1981.  °Singh, B.N., MacMillan Press  1  Singh,  The L a n c e t ,  a n d Amoeba",  8201  8222 ( V o l .  P a t h o g e n i c and N o n - P a t h o g e n i c Amoeba, L t d . : London a n d B a s i n g s t o k e , 1975.  The  B.N., i b i d . , 1975.  2  Maxcy-Rosenau ( P h i l i p E. S a r t w e l l , e d . ) , P r e v e n t a t i v e Medicine and P u b l i c H e a l t h , 1 0 t h e d i t i o n , Appleton-Century-Crofts: New Y o r k , 1973.  3  Maxcy-Rosenau (John Last, e d . ) , P r e v e n t a t i v e M e d i c i n e and P u b l i c H e a l t h , 11th e d i t i o n , Appleton-Century-Crofts: New Y o r k , 1980.  "Wang, S.S, a n d F e l d m a n , H.A., Species from Human Throats", M e d i c i n e , 277:1174-79, 1967.  "Isolation of Hartmannella New England Journal of  5  C e r v a , L . , S e r b u s , S k o c i l , " I s o l a t i o n o f Limax Amoeba from t h e Nasal Mucosa o f Man," F o l i a P a r a s i t o l ( P r a g u e ) 20: 97-103, 1 973.  6  C e r v a , L . , Novak, K., C u l b e r t s o n , C.G., "An O u t b r e a k o f A c u t e Fatal Amebic Meningoencephalitis", American J o u r n a l of E p i d e m i o l o g y , 8 8 ( 3 ) : 4 3 6 - 4 4 4 , 1968.  7  K a d l e c , V., " D i f f e r e n t V i r u l e n c e o f N a e g l e r i a F o w l e r i I s o l a t e d From a Swimming P o o l " ,  Strains  161  2 8  K a d l e c , V., i b i d . , 1981 .  2 9  De  3 0  Singh,  3 1  Carter, R.F., "Primary Amoebic Meningoencephalitis. An Appraisal o f t h e P r e s e n t Knowledge." Trans. Roy. Socl. Trop. Med. Hyc., 66:193-213, 1972.  3 2  De  3 3  Willaert, E. e t a l . , "Epidemiological and Immunoelectrophoretic Studies on Human and E n v i r o n m e n t a l Strains of N a e g l e r i a F o w l e r i " , Am. Soc. Beige Med. T r o p . , 5 4 ( 4 / 5 ) . 3 3 3 - 3 4 2 , 1974.  3i|  De  1981.  Folia  Parasitol  (Prague),  28:97-103,  Jonckheere, Johan, "Use o f an A x e n i c Medium f o r Differentiation Between Pathogenic and Nonpathogenic Naegleria fowleri Isolates", Applied and Environmental M i c r o b i o l o g y , 3 3 ( 4 ) : 7 5 1 - 7 5 7 , A p r i l 1977. B.N., op.  cit.,  1975.  J o n c k h e e r e , J . , " S t u d i e s on P a t h o g e n i c in Swimming Pools", Bull. Inst. 1 979.  Free-Living Amoebae P a s t e u r , 77:385-392,  Jonckheere, J . , "Differences i n V i r u l e n c e of N a e g l e r i a Fowleri", Path. Biol., 27:453-458, I979n rlw2h1 De Jonckheere, J. and van de V o o r d e , H., " C o m p a r a t i v e S t u d y of S i x S t r a i n s of N a e g l e r i a with Special Reference to Nonpathogenic V a r i a n t s of N a e g l e r i a F o w l e r i " , J . P r o t o z o o l , 24:304-309, 1977. 3 5  3 6  Kadlec, V. e t a l . , " V i r u l e n t N a g l e r i a F o w l e r i i n an I n d o o r Swimming P o o l " , F o l i a P a r a s i t o l ( P r a g u e ) , 27:11-17, 1980.  37  L a w a n d e , R.V. e t a l . , Amoeba in Zaria, 73:51-56, 1979.  "Prevalence of Nigeria, Ann.  Pathogenic Free-Living Trop. Med. Parasit.,  3 8  Singh, B.N., and Das, R.S., "Occurrence of Pathogenic Naegleria aeoriba, Hartmanella c u l b e r t s o n i , and H. r h y s o d e s i n Sewerage S l u d g e Samples o f Lucknow", Curr. S c i . , 41:277-281, 1972.  3 9  Neva. F.A., New E n g l a n d  a o  C h a n g , S.L., " E t i o l o g i c a l , P a t h o l o g i c a l , E p i d e m i o l o g i c a l , and Diagnostical Considerations of Primary Amoebic Meningoencephalitis", C r i t . Rev. Microbiol., 3:135-159, 1974.  "Amoebic M e n i n g o e n c e p h a l i t i s - A New D i s e a s e " , J o u r n a l o f M e d i i c n e , 282:450-452, 1970.  162  " Singh, 1  B.N.,  op.  c i t . , 1975.  " Groscop, J.A., and Brent, M.M., "The Effect of S e l e c t e d S t r a i n s o f P i g m e n t e d B a c t e r i a on S m a l l F r e e - L i v i n g Amoeba," Canad. J . M i c r o b i o l . , 10:579-584, 1964. 2  " B r o w n , James C ,  op.  ""Crandall,  A., op.  3  Robert  c i t . , J u n e 20, 1982. c i t . , 1983.  " Hoadley, A.W., "Potential Health Hazards Associated Pseudomonas a e r u g i n o s a in Water", A m e r i c a n Soc. T e s t i n g M a t e r i a l s , STP 635, 1977, pp. 80-114. 5  with for  163  Additional  References  Consulted  D u B o i s , Rene J . , and H i r s c h , James G. (ed)., B a c t e r i a l and M y c o t i c I n f e c t i o n s of Man, 4th edition, J.B. L i p p i n c o t t Co.: P h i l a d e p h i a and M o n t r e a l , 1965.  4 6  " C h r i s t i e , A.B., I n f e c t i o u s D i s e a s e s : E p i d e m i o l o g y and C l i n i c a l P r a c t i c e , 3rd edition, Churchill Livingston, Edinburgh, London, M e l b o u r n e , and New Y o r k , 1980. 7  fl8  Cerva, L. e t al., Power P l a n t s , " J . 2:152-161, 1982.  "Naegleria Fowleri in C o o l i n g W a t e r s of Hyg. Epid., Microbiol. and Immun.,  tt9  Wadowsky, Robert M. e t a l . , "Hot Water S y s t e m s as S o u r c e s of L e g i o n e l l a pneumophilia in Hospital and Nonhospital Plumbing Fixtures", Applied and Env. Microbiol., 4 3 ( 5 ) : 1 1 0 4 - 1 1 1 0 , May 1982.  5 0  Donders, D.J., "An Outbreak of Associated With a Contaminated Tower", New E n g l a n d J . Medicine,  5 1  Baylor, 764,  5 2  Beech, J.A. " E s t i m a t e d Worst C a r e T r i h a l o m e t h a n e Body Burden of a Child Using a Swimming Pool", Med. Hypotheses, 28(2):97-103, March 1980.  5 3  Beech, J.A. e t a l . , " N i t r a t e s , C h l o r a t e s and T r i h a l o m e t h a n e s i n Swimming P o o l Water", Am. J. Public Health, 70(1):7982, J a n u a r y 1980.  5  "Water-to-Air 1977.  "Hoeprich, Harper  Paul & Row  Transfer  D., ed., Publishers,  of  Legionnaire's Disease Air-Conditioning Cooling 302:365-370, 1980.  Virus",  Science  197  :763-  Infectious Diseases, 2nd e d i t i o n , I n c . : H a g e r s t o w n , Md., 1977.  1 64 TABLE I A C o m p a r i s o n o f Spa E n v i r o n m e n t C h a r a c t e r i s t i c s W i t h C h a r a c t e r i s t i c s of S e l e c t e d P a t h o g e n s PATHOGENS 1 . Brucellae 2. C a n d i d a a l b i c a n s 3. C o x s a c k i 4. C r y p t o c o c c u s 5. E. c o l i 6. E. f l o c c o s u m 7. G i a r d i a l a m b a l i 8. G o n o c o c c u s 9. H e r p e s s i m p l e x 10. H. i n f l u e n z a e 1 1 .Legionella pneumophilia 12. L e p t o s p i r o s i s 13. M y c o b a c t e r i u m balnei 14. N a e g l e r i a fowler i 15. N a e g l e r i a gruberi 16. Penumococc i 17. Pseudomonas aeruginosa 18. S a l m o n e l l a 19. S h i g e l l a 20. S t a p h l o c o c c i 21 . S t r e p t o c o c c i 22. T r i c h a m o n a s 23. T. t o n s u r a n s 24. V i b r i o s c h o l e r a 25. V i r a l hepatitus 26. A c t i n o m y c e t e s  A  B  C  NO NO YES NO YES YES YES NO NO NO  YES YES YES YES YES YES YES YES YES YES  NO YES YES YES YES YES YES YES YES  NO YES NO ? YES YES YES YES YES 7 ? YES NO YES YES YES YES YES 7 YES NO YES YES NO NO YES YES YES YES YES  YES YES  YES YES  YES YES  YES YES  YES YES  YES  YES  YES  YES  YES  YES  YES  YES  YES  NO YES  NO  YES YES NO YES  YES YES  YES YES  NO YES YES YES  YES YES YES YES YES NO YES YES YES NO  YES YES YES YES YES YES YES NO YES YES  YES YES YES YES YES YES YES YES YES  YES YES YES YES YES YES YES YES YES YES  YES YES YES YES YES YES YES YES YES YES  *Total © of Matched 9,18,19,23,38,39,46,47,54 A. C. D. E.  ?  D  ?  E  F  H  G  *  YES ( I ) YES (DC) NO ( I ) YES (DC) YES ( I ) YES (DC) NO ( I ) YES (DC) YES (DC) NO (R)  3 6 7 4 7 8 5 6 5 6  NO YES NO YES  NO YES  (R) (I)  6 7  7  YES  (DC)  6  NO  (I)  5  NO YES  NO NO  (I) (R)  5 6  YES YES YES YES YES YES YES YES YES NO  YES NO YES YES YES YES YES NO NO YES  (DC) (I) (I) (DC) (R) (DC) (DC) (I) (R) (I)  7 6 7 7 7 7 8 5 7 4  NO NO NO NO NO YES YES NO YES 7  NO YES YES NO YES YES YES YES YES YES  I  7  Characteristics  Sources:  Waterborne B. Can s u r v i v e a e r a t i o n S u r v i v a l a t s p a t e m p e r a t u r e (35°-43° C) S u r v i v a l a t s p a pH r a n g e (7.2-7.8) Survival through spa filtration (Note: effective filtration for various media i s : sand 18-20 microns, c a r t r i d g e 8-10 m i c r o n s , d i a t o m a c e o u s e a r t h 4-6 m i c r o n s . Some o r g a n i s m s may be a b l e t o s u r v i v e i n t h e f i l t e r u n i t s . ) F. S u r v i v e s c h l o r i n e o r b r o m i n e (.225 - 3.0 ppm) G. T r a n s m i s s i o n between p e o p l e i n s p a e n v i r o n m e n t p o s s i b l e H. C a p a b l e o f i n f e c t i n g p a r t s o f body t y p i c a l l y immersed i n s p a I. T y p i c a l mode of t r a n s m i s s i o n : (D) D i r e c t contact; (I) I n g e s t i o n ; (R) R e s p i r a t o r y  165  TABLE I I Classification Potential  o f P a t h o g e n s by t h e i r  1. 2. 3. 4. 5. 6. 7.  Known but R a r e  Coxsacki E. coli E. floccosum Mycobacterium b a l n e i Pseudomonas a e r u g i n o s a Staphlococci Steptococci  Potential  Or  H a z a r d s i n Spa/Hot Tub E n v i r o n m e n t s  Known & I d e n t i f i e d P r o b l e m s 1. 2. 3. 4. 5. 6. 7.  Established  Problems  1. L e p t o s p i r o s i s 2. S a l m o n e l l a 3. S h i g e l l a 4. V i b r i o s  P o t e n t i a l but Found Commonly in other Environments  Problems  Candida a l b i c a n s G i a r d i a lambali L e g i o n e l l a pneumophilia Naegleria fowleri Naegleria gruberi Trichomonas T. t o n s u r a n s Unlikely  1. G o n o c o c c u s 2. H e r p e s s i m p l e x 3. H. i n f l u e n z a e 4. P n e u m o c o c c i 5. V i r a l hepatitus  Problems  1. A c t i n o m y c e t e s 2. B r u c e l l a e s 3. C r y p t o c o c c u s  (Categorization characteristics  of pathogens i n T a b l e I.) )  based  on  number  of  matched  166 TABLE I I I C u m u l a t i v e T o t a l s o f M a t c h i n g C h a r a c t e r i s t i c s Between Spa/Hot Tub E n v i r o n m e n t s a n d S e l e c t e d P a t h o g e n s  Spa E n v i r o n m e n t Characteristics  © of Pathogens With Corresponding Characteristics  % of Pathogens Which May Be H a z a r d o u s Under Spa E n v i r o n m e n t Characteristics  © Found/Total © A. B. C. D. E. F. G. H.  1 7/26 26/26 23/26 23/26 23/26 9/26 20/26 16/26  Water Aeration Temperature pH Filtration Disinfection Human T r a n s m i s s i o n Region of I n f e c t i o n  65% 1 00% 88% 88% 88% 35% 80% 64%  Comments A.  Non-waterborne pathogens, particularly viruses, t r a n s m i t t e d from one s p a u s e r t o a n o t h e r .  E.  The amoeba examined a r e t h e o n l y p a t h o g e n s c a p a b l e o f b e i n g f i l t e r e d . However, p o o r filtration or c i r c u l a t i o n could allow these organisms t o pose a hazard. Also, these o r g a n i s m s may be c a p a b l e o f s u r v i v i n g and growing inside the f i l t e r .  F.  A high degree efficacy.  G.  Some o f t h e p a t h o g e n s w h i c h a r e n o t t r a n s m i t t e d from human to human may n o n e t h e l e s s e n t e r t h e spa environment as cysts.  H.  A l l of t h e pathogens can i n f e c t t h e human host in circumstances where i n d i v i d u a l s submerge t h e i r heads under w a t e r a n d where a e r o s o l conditions allow spread of the organisms through the a i r .  of  uncertainty  exists  c a n be  as t o d i s i n f e c t i o n  167  APPENDIX B  Current There  Knowledge & G u i d e l i n e s f o r Spa Management  is  management  disagreement  procedures,  Experts  disagree  limited  to):  solids, been are  made  not  comprehensive, recommendations expertise.  maximum  i t  does  provide  compiled  Center  of t o t a l  is  generally charts, and  values, dissolved  Progress  has  s t a n d a r d s , but g u i d e l i n e s  but  h a s been  levels.  pH  spas and t u b s .  below  not a  meant  a  list  synthesized  to  comparison  recognized  apply to public  ( i n o r d e r as they appear  - The  level  chart  the  quality  (but a r e not  levels,  The  several  water  include  firm.  from  spa  acceptable  bromine  developing uniform  s o u r c e s . These procedures  Sources  and  which  fordraining  Following  procedures  or  intervals,  toward  still  matters  chlorine  and i n t e r v a l s  various  parameters,  about  superchlorination  over  of  sources  be of of  recommended  from  the  same  spas and h o t t u b s .  on t h e c h a r t s ) :  f o r Disease Control,  U.S. D e p t . o f H e a l t h a n d  Human S e r v i c e s - Jacuzzi - Great  W h i r l p o o l Bath,  Lakes  - Robert Leisure  B i o c h e m i c a l Co.,  Lowry,  Vice  Time C h e m i c a l  Committee  S u b s i d i a r y of Kidde, I n c . Inc.  President Corp.,  and  Technical  member NSPI C h e m i c a l  Director, Standards  168  OPERATIONAL Public  PARAMETERS  Spas & Hot T u b s MINIMUM  IDEAL  MAXIMUM  1.0-1.5 3.0  3.0 5.0  A. DISINFECTANT LEVELS 1 . Free  Chlorine  2. Combined (ppm)  (ppm)  Chlorine  3. Bromine  B. CHEMICAL  1.0 1 .5  None None  None None  0.2 0.2  0.8  1 .5  3.0  1 .0  2.0  -  7.2 7.2 7.2 7.2  7.5 7.2-7.6 7.4-7.8 7.2-7.8  7.8 7.6 7.8 7.8  VALUES  1 . pH  2. T o t a l A l k a l i n i t y (ppm as CaCo )  60 80  75 —  3. D i s s o l v e d (ppm)  solids  4. H a r d n e s s (ppm as CaCo  )  5. T r a c e M e t a l s (ppm) (Iron, Copper)  100 80-125 Plaster,Tile 125-150 V i n y l , FG  -  80-140  -  -  —  —  300  50 175 100 100  -  125 200-275 100-400 150-400  200 175  150 —  1500 1500 1500 1500 500 275 400 400  0  -  —  —  —  -  -  .2  169  C. BIOLOGICAL  VALUES  1. A l g a e  No  2.  Bacteria  D.  STABILIZER  1 . Cynanuric  None  Acid  (ppm)  visible algae None  30  30  —  Refer to local health c o d e o r APHA standard  1 except 100 by health 1  50, where local dept. 50  E . ALGICIDES Follow directions of EPA registered products F. REMEDIAL  PRACTICES  1. D a i l y Shock T r e a t m e n t C h l o r i n e (ppm)  5 10  2. A d d i t i o n a l Superchlorination C h l o r i n e (ppm)  10  3. Water  Replacement  -  -  _  Water i n s p a s w h i c h have h i g h b a t h e r use s h o u l d be r e p l a c e d c o n t i n u o u s l y o r a t l e a s t once a month. At  least  once v e r y  30 d a y s .  F r e q u e n t r e p l a c e m e n t o f 1/4 o r 1/2 o f water; or c o m p l e t e l y p e r i o d i c a l l y (1-2 m o n t h s ) . E v e r y two months o r more i f needed.  often  170  G. TEMPERATURE 1. T e m p e r a t u r e  -  -  1 04°F (40°C) 1 04°F 104°F  0 0  0.5 o r l e s s 0-0.5  1.0 1 .0  -  -  -  -  Bather preference  H. WATER CLARITY 1. Water T u r b i d i t y (Jackson T u r b i d i t y Units)  171  PUBLIC SPA/HOT TUB OPERATOR'S GUIDELINES  Initial 1. 2. 3. 4. 5. 6. 7. 8. 9.  or R e f i l l  Clean & p o l i s h spa. Pre-filter water during fill; do n o t u s e d e i o n i z e d o r softened water. Add s e q u e s t e r i n g a n d c h e l a t i n g c h e m i c a l s . Test and b a l a n c e water f o r pH, total alkalinity and hardness. Add s a n i t i z e r and b e g i n c i r c u l a t i o n . Shock t r e a t . T u r n on a e r a t i o n pump o r b l o w e r . Start up c h e m i c a l feed pump & begin adding s a n i t i z e r continuously. Turn o f f aeration and use o n l y a s needed, but run c i r c u l a t i o n s y s t e m 24 h o u r s / d a y .  Check 1. 2. 3.  Start-Up  Hourly C h l o r i n e ( o r Bromine) pH Temperature below.  - M a i n t a i n 1-3 ppm r e s i d u a l . - M a i n t a i n 7.2-7.8 Maintain a t 1 04°F (40°F)  or  Daily 1. 2.  Shock t r e a t t o 10 ppm. T e s t and c o r r e c t i f n e c e s s a r y  total  alkalinity,  turbidity.  Weekly 1. 2.  T e s t and a d j u s t h a r d n e s s , c y a n u r i c Clean f i l t e r s or f i l t e r elements  Monthly  1.  Drain,  c l e a n and r e f i l l  unit.  acid  ( i f applicable)  172  Periodically 1. 2. 3. 4. 5.  Add s e q u e s t e r i n g and c h e l a t i n g c h e m i c a l s . Add d e f o a m i n g a g e n t as n e c e s s a r y . Clean areas a d j a c e n t t o spa/hot t u b . Check and m a i n t a i n s u p p o r t e q u i p m e n t . Add make-up s u p p l y water a s n e c e s s a r y .  Additional 1. 2. 3.  Procedures  P r o v i d e t r a i n i n g t o a l l e m p l o y e e s a c t i v e l y i n v o l v e d i n spa management with regard t o equipment, c h e m i c a l h a n d l i n g , w a t e r t r e a t m e n t , and s a f e t y & emergency p r o c e d u r e s . Provide a c c e s s i b i l i t y to i n s t r u c t i o n a l materials, f i r s t a i d e q u i p m e n t , and s a f e t y & emergency p r o c e d u r e s . M a i n t a i n r e c o r d s on d a i l y b a s i s f o r : - Amounts o f c h e m i c a l s a d d e d . - Amounts o f f r e s h water a d d e d . - R e s u l t s o f a l l water t e s t s . - D a t e and t i m e o f f i l t e r backwash o r c l e a n i n g . Periods of recirculation equipment operation and/or m a l f u n c t i o n and r e p a i r .  4. E n f o r c e t h e f o l l o w i n g r u l e s and p o s t a c a u t i o n s i g n . - No p e r s o n s h a l l use t h e spa a l o n e Children under 14 shall n o t use u n l e s s a r e s p o n s i b l e observer i s present. - B a t h e r s s h a l l t a k e a c l e a n s i n g shower. - Swimwear s h a l l be c l e a n . No person suffering from a communicable disease transmissable v i a water o r under t h e i n f l u e n c e o f a l c h o h o l or drugs s h a l l use the s p a . - No p e r s o n s h a l l engage i n h o r s e p l a y i n o r a r o u n d a p u b l i c spa. Persons using medications such as anticoagulents, antihistamines, vascoconstrictors, vasodilators, stimulants, hypnotics, narcotics, or t r a n q u i l i z e r s shall use t h e s p a . - E l d e r l y p e r s o n s , p r e g n a n t women, and t h o s e s u f f e r i n g from heart disease, diabetes, or high blood pressure should consult t h e i r p h y s i c i a n before using the spa. - Observe a reasonable time period (e.g., 10 minutes). Shower, cool down, and i f you w i s h , r e t u r n f o r a n o t h e r b r i e f s t a y . I f f e e l i n g s of d i z z i n e s s , nausea, or f a i n t n e s s o c c u r , l e a v e spa immediately. - Do n o t u s e s p a a t t e m p e r a t u r e s above 104°F.  173  The  above  cross-section not  guidelines  of  spa  necessarily  represent  current  demonstrating  some of  from for  guidelines swimming p o o l  spas. F i n a l l y ,  collection  of  recommendations  merely  intended  management r e c o m m e n d a t i o n s ,  a u t h o r i t a t i v e or  the  these  are  irrefutable.  state-of-the-art the  discrepancies.  have c h a n g e d o v e r  the  It should few  work  parameters and  from other  they sources.  and are  guidelines often  and  they  as be  well noted  years,  s t a n d a r d s w h i c h were d e t e r m i n e d the  represent  a are  However, t h e y  knowledge  past  to  do as  that  evolving  inappropriate represent  duplications  a of  174  APPENDIX C  Spa  B e h a v i o u r a l C h a r a c t e r i z a t i o n s f o r Spa O p e r a t o r s , U s e r s , H e a l t h O f f i c i a l s and I n d u s t r y R e p r e s e n t a t i v e s  Spa It  i s u s e f u l to  commonly  found  generalization  Operators  categorize  managing  the  spas,  i s never complete,  types  of  bearing fully  spa  in  operators  mind  accurate,  that or  any  without  exception.  1. The  Fastidious  This  type  conditions  of p e r s o n  of  operations.  Operator  the  spa  takes and  are  highly  individual's  own  personal  eager  and  information. Although  the  a c t i o n may  dominant  outside  2.  l e a r n e r and  The  public motivating  an  punitive  h i s own  Compliments,  recognition  factor  d e a l of p r i d e  ability  and  factors  t o keep a b r e a s t  financial  in  the  knowledge of  the  and as  type  the  realm  of  as  of p e r s o n  of new  type  general  well  the is  developments  i n c e n t i v e s and/or  i n f l u e n c e upon t h i s  remains  i n both  approval,  pride. Usually this  tries  have  a great  of  threat  of  individual,  self-pride  and  approval.  "Know-It-All"  The all  the  be  done  Operator  "Know-It-All"  characteristically  a n s w e r s ; what he  difficult  his  way  person  or  assumes  does i s always c o r r e c t ; not  at  to deal with,  a l l . This b e c a u s e he  that and  defy  has  t h i n g s must  i s probably  will  he  the  most  regulatory  175  efforts prove  ( o v e r t l y and a  point  significance  on  he  an  assumes  (even pride  by  at and  initial  reinforcement). deceptive  covertly), disregard his  approval level  Occasionally, pretending  to  t o weigh a l t e r n a t i v e s , but his  own  direction  i s to apply  as  to allow  3.  The  profit  He  operator  and  strong  or  on  f o r him.  easy  to deal  The  and  rare  logic  instances,  that  further will  be  suggestions  will  proceed and  most o f t e n  techniques  or in  common  the  best  i n such a  way  principles  of  determines  his  behaviour.  for  behaviour,  to  work  the  strongly  i n p o s i t i v e and  biases  these  c l o s e l y to  "bottom l i n e "  safety  and  negative  toward  maintaining  health.  He  matters  as  to  h i s c o n v i c t i o n and  a n a l y s i s of  To  this  a l a r g e degree,  but  around  often the  advantage. Economic most s e n s e t o h i s  which t h r e a t e n this  to  t y p e of  regulations  or  framework of  spa  likely  show  weak  what  is  are  person q u i c k l y to exert  the  show  concern,  financially is  can  fairly direct. modify  learns  influence  because they  understanding  water to  c l e a r and  impose c o s t s  i n c e n t i v e s work b e s t  directions.  i s as  t y p e of p e r s o n  w i t h because h i s m o t i v a t i o n s  Sometimes r e g u l a t i o n s his  both  special  public  best  needs no  i n p r a c t i c e , he  i n d i v i d u a l , but  adheres q u i t e  actions,  concern  depending  to advice  little  reason  individual  to  Operator  e x h i b i t s no  quality  then  and  of  chosen m o t i v a t i o n  maximization.  decisions  listen  for expected discrepant  Greedy  This  this  kind  place  ( f o r the  expertise  this  incentives  e x p e n s e ) , and factors  of  anyhow. In  s e n s e work t o m o t i v a t e approach  own  economic  world.  to  make  ways his the  176  4.  The F e a r f u l o r S e c u r i t y - S e e k i n g This  best  type  overall  job,  his  related this  person  course  of d i r e c t i o n  reputation,  characteristic  to  attention  sake o f s e c u r i t y  particular  amongst  his to  similar  some  itself.  concerns of o t h e r s  each of the  various  his  reinforcement  and encouragement  long  excessive  and  well  as  extreme  and  with  there  This being,  last  maturity,  him,  exists  kind  concerned  hassles with  of  any  trade-offs f o r w h i c h he  Combinations  generally and  which  of i n d i v i d u a l ,  or other  self  the types  secure  t h e s p a so l o n g a s t h e y  needless  his  positive  expression for  of  are  controlling  might  be  but j e o p a r d i z e  highly  others.  Operator  in  This  but  provisions  behaviour  to  consistent.  by  security for  making  security,  of l a t i t u d e  indifferent operating  forms, t h e  handling  purpose.  advantageous t o h i s sense of s e c u r i t y ,  5. The " E a s y - G o i n g  in  regarding  intent  share  i s never p r e d i c t a b l e , because  engaged  concerns  his  his  directly  categories  i s distinguished  As a r e s u l t ,  work  so  facility,  d e g r e e and i n v a r i o u s  i s continuously  conceal  his  t o o b t a i n i n g and m a i n t a i n i n g  motivations  best,  to protect  phase of t h e o p e r a t i o n  individual  tends  and  do w h a t e v e r he deems t o be t h e  or s e c u r i t y - s e e k i n g " operator  inordinate  this  will  to h i s p u r s u i t s . Although  "fearful  the  of  Operator  operator and  of p o l i c i e s  traits,  almost  reasonably  by  the  rules",  often having  he  is  involved fair  i s p r i m a r i l y concerned with and  well-  always  and r e q u i r e m e n t s are  entanglements,  "playing  because of f i n a n c i a l  and  avoiding is  most  things  run  177  smoothly, This of  and  type  d o i n g what  of p e r s o n  his flexibility,  willingness are  to  which  such  considered  spa  operator.  a  greatly  person t o any  either  spa  of  fairness, or  a  it  probable  of  those  very d i f f i c u l t  evaluate  the  of each  or  possible  cover  spa  than  identify  key  motivating  type  of b e h a v i o u r in order  these  to develop  a n s w e r s , but  c o n s i d e r a t i o n of t h e s e  along  careful  thought,  and  within  situations.  The  possible  factors,  one  other  of  the  wide range  characteristics, the  relative  spectrum  of  spa  i d e a of  be most e f f e c t i v e  a r e o b v i o u s l y no  behavioural and  of  important  some r e a s o n a b l e  judgement,  each  undoubtedly,  most  assess  the  will  There  true for  r e p r e s e n t t h e most  a significantly  operations.  i s to  in different  and  cannot  construct  of ones a b o v e . And  i n c e n t i v e s and/or d i s i n c e n t i v e s  with  to  p o r t i o n s of more  and  in  o p e r a t o r s a s a whole  efficient  singularly  However, t h e s e c a t e g o r i e s do  behaviour  consideration  is  or v a r i a t i o n s  common c h a r a c t e r i z a t i o n s  and  requirements  advantage  become  because  process.  operator possesses  characteristics.  what  can  concerned.  to deal with  sense  take  comprehensive  Certainly  characterizations  extent  parties  summary, t h e s e c a t e g o r i e s of o p e r a t o r s c e r t a i n l y  be  each  f a r the e a s i e s t  open-mindedness,  f o r m i d a b l e opponent  In  i s by  for a l l  c o o p e r a t e . However, i f p o l i c i e s  implemented  attributes,  is "right"  and  patent  characteristics, experience  are  necessary.  Although management  in  the behaviour B.C.,  it  of spa is  o p e r a t o r s i s key  helpful  t o sound  to characterize  the  spa  other  178  a c t o r s who  are  familiarize following  participants  the  reader  brief  with  in  various  d e s c r i p t i o n s are  Spa  The  Uninformed This  being  covers  the  They  assume,  poured  into  contracting  diseases  biggest  spa  are  for  that  An  A spa desire their  to use.  things  or  neglect  to  to  p e r s o n a l i t i e s , the  danger  and  which  they by  that  that  spa  chemicals  about  such  as are  answers  health  becomes and  is  misleadingly  Herpes. prone  to  to  "safe"  officials  safeguarding  user  danger  from  users  know t h e  consistently  the  They  them  media,  public  users.  " a l l those  worry the  spa  protect  uninformed  really  that  uninformed  or  automatically  popularized  and  of c u r r e n t  exposure to both a d d i t i o n a l i n f o r m a t i o n  Careless  order  provided.  instance,  scientists  conscientiously  The  In  Users  Instead,  fallacies  management  welfare.  r a n g e s of  majority  i s no  spas"  disease.  believe  vast  there  infectious  The  situation.  User  assume e i t h e r t h a t remote.  the  are  the  public  informed  through  experience.  User  user  can  avoid  be  informed  them, but  about  spa  some u s e r s  will  risks still  and be  I n d i v i d u a l s , e i t h e r through preoccupation by  simply  shower b e f o r e  failing use  or  to  stop  proceed  and  have  a  careless in with  other  t h i n k , can  easily  to enter  a spa  with  an  179  open  wound.  careless  Reminders  u s e r s cannot  means f o r i n s u r i n g Another they  feel  think  particularly  or o b e y i n g ,  ones w h i c h  are  the  best  tend to i g n o r e warnings  which  use.  of u s e r s w i l l  p r e c a u t i o n a r y warnings  but  that  hazards  posed  present  the  challenge  and  measures a r e wise  they are exaggerated  f o r them. B e c a u s e  that to  they  the  dangers  their  are  may  f o r most of  the  somehow beyond b e i n g a f f e c t e d  "average  person",  to  in  them  assumptions  by  an  it  is  necessary  to  immediate c o n t e x t and  straightforward  by  to  logic.  Risk-Taker I n d i v i d u a l s do  exist  and  aware  that  heavy  alcohol  immediately  prior  to  this  "thrill  even o u t r i g h t  who  risky,  Yet,  sort,  avoid noticing  more c a r e f u l  class  misperception  The  some  a r e u n n e c e s s a r i l y p r o t e c t i v e . T h e s e t y p e of p e o p l e  that  people,  of  d e a t h . One prohibit  living" method  these  u s e r s . Another some way  dangerous,  by a c t i n g  of  or  a spa has  finds  for dealing types  situations.  consumption  using  k i n d of person in  maintain a fascination  a  They may  smoking  of  behaviour  u s e r s or c e r t a i n  of  is  a  injury  or  simply  i s to  the p e r c e p t i o n of danger  risk. or  b e h a v i o u r s of  a l t e r n a t i v e method, where f e a s i b l e ,  t o remove o r d i l u t e  of  well  marijuana  excitement  t o the border  with t h i s  facing be  a h i g h element  sense  close  with  to  these  develop  for  this  individual.  The  " P i c k y " User Some  spa  users  will  find  fault  with  spa o p e r a t i o n s o r  180  public  health efforts  management. followed really  h i s own a  involve  and  to  individual  of  seeking  as  a  would  be  attention.  should  clearly  from  kind  and  of  Since a  but  the  a r e made w i t h  unhappy even  This  participant,  or d e t r a c t i n g  realize  what a t t e m p t s  t o have h i s v i e w s e x p r e s s e d ,  him  excluding  matter  recommendations.  form  attention  Policy  This  no  " p i c k y " user  at  interests  the  only  the  of  interest  is  wants  worthwhile  to  expense  other  u n e q u i v o c a l l y f o r c e the  t h a t h i s i s not  i f policy  behaviour  i t is  not  spa  of  people.  "picky"  which  user  must  be  satisf ied.  The  "Willy-Nilly" This  fears  User  i s a very  are  difficult  generally irrational  operation.  It  encounter  situations  is  obvious  presence  medical  reasons  "willy-nilly" deal  with  people trained a  exist  not  of  use  peer be  and  to provide  operators these  The  behaviour special  one  glance,  due  i n spa  to  use  only e f f e c t i v e  i s to recognize  their for  that a way  that  to such  arranged  user. This probably be  spa  that  by  will  be  anticipated.  User  the b e h a v i o u r a l c h a r a c t e r i s t i c s  "ideal"  because  regularly  conceivable  circumstances,  which s h o u l d  Intelligent  will  people,  t o engage  t o work w i t h t h i s but  appear  that by  to deal with,  u n r e l a t e d to the a c t u a l  a concern.  potential  first  and  pressures  this  personnel,  user might  of  u s e r may  I n f o r m e d and At  likely  of u s e r  f e a r . However, i t i s  or  rare s i t u a t i o n ,  The  type  for  spa  management.  of  However,  this an  181  informed wise  approach  own  selfish  of h i s views toward  imposing  certain  even not  intelligent  f o r that person's  nothing In  and  risks  inconceivable that  hazards  deliberately  appear  of i l l n e s s  at  "spa  i n order  --  it  implies  o r c o s t s on o t h e r s .  decision  f o r other  i n a crowded  a u s e r may o n l y be  interests  c a s e s , an " i n t e l l i g e n t "  involve raising  evidence  by s u c h  f o r one p e r s o n  u s e r s . F o r example, facility  side"  it is  an i n d i v i d u a l  w i t h an u g l y body  may  might  rash or  t o c r e a t e more room i n t h e s p a f o r  himself. Furthermore, ignoring  this  the r e a l  type  uncertainties  should  consider  effects  and i n a c k n o w l e d g i n g  with  this  type  means  both  Strict  officials  perspective"  corrected  associated in  accounting  the r e a l  be l u l l e d  with  spas.  into  Policy  for "third-party"  uncertainties  Health  in  dealing  Officials  will  demonstrate  i n w h i c h s p a management  through  some e n f o r c e m e n t  which s t i r  and  covert  operator  Rigid  positions  animosity  regulations,  provision.  and  also  cause  "engineering  this  can  formula  Rigid  positions  toward h e a l t h  produce outward or  in increased risks officials  of  e v a l u a t e d and t h e n  within operators  defiance, resulting can  an  i s v i e w e d as a  o r g u i d e l i n e s w h i c h c a n be r e a d i l y  may be t a k e n officials  can s t i l l  Enforcer  Some  standards  user  of u s e r .  Public  The  of  to  to users.  overlook  the  182  weaknesses better of  of  recommended  To  allow  motivate  reduction; methods  and  form  lead  not  by to  management risk  focus too narrowly  on  success  merely  with  than  in risk  based  evaluate  from  positions  s h o u l d not where  upon s u c c e s s  encourage  judgements  in enforcing  r e d u c t i o n , ( e . g . , i t would  the  officials'  of d i s e a s e o u t b r e a k s closings  spa  to  g o a l s of  rather  facility  s h o u l d seek  overall  are  reduction  situation  in  performance  to  and  success  their  preferable  our  emphasizing  into entrenched  success  in  policy  of spa management. F u r t h e r , p o l i c y  officials  i g n o r e new  applicable  of b e h a v i o u r ,  officials  which  and  variability.  for this  these  objectives,  The  management  ideas. This i s p a r t i c u l a r l y  h i g h u n c e r t a i n t y and  such  spa  failure  rather  performance  than  upon  o f o p e r a t o r s t o meet  methods be  more  based  the  of  upon  number  of  standards.)  Zealot This  official  everywhere w i t h i n out  a l l  the  generally  and  which  be  tendency  zealot and  to  T h i s behaviour  in  develop a cause  may  direct  users.  correct  can  other important  what  i t may  participants areas  for  "root at  individual  avenues of he  lurking  to  attention  This  sometimes be  s h o r t - s i g h t e d . Moreover,  situations  and  to f i n d dangers  sometimes b l i n d l y ) p u r s u e  designed  polarizes  problems.  The  operators  (and  actions  problems. also  at  the  spa e n v i r o n m e n t s  evils".  or  demonstrably  has  views  helpful,  as but  creates  resolving  spa  will  criticism serious it  take a d e s t r u c t i v e  and  spas  can form  stalemate management  183  Officials  of t h i s  type  more p o s i t i v e  directions  questioning.  Similar  "strict through  The  enforcer",  can  by  perhaps  exposing  to the  rigid  behaviour  motivated  positions  and  in  participants'  a s s o c i a t e d with  also  be  largely  clear  policy  the  modified  objectives.  Clockwatcher He  has  a  job  to  do.  And  t e r m s of m a i n t a i n i n g a p h y s i c a l periods.  Although  professional not  guide  this  that  presence  person  responsibility  job i s l a r g e l y  may  h i s a c t i o n s . Anything to extend  will  i g n o r e d o r done s u p e r f i c i a l l y .  a l s o p r o n e t o becoming a unreasonable  The  "I'm  t o o busy  This with  leeway  for that  respect to public by  officials  sees  deal  in regulatory  spas.  spas  on  "job  does health  description"  T h i s k i n d of o f f i c i a l o p e r a t o r s and  to  is  allow  Official  (or  and  and  official as  being  projects,  to  spa p r o b l e m s as b e i n g m i n o r  and  until  to avoid  this  having  taking action  tries  health  perceived  h e a l t h concerns  as a n u i s a n c e  procrastinate  sense  of  enforcement.  Besieged  rationalizes  time  semblance  this  common t y p e o f p u b l i c  numerous p u b l i c  w i t h them. He  will  now"  a  as a p u b l i c  his  "buddy" of spa  is a relatively  besieged)  beyond  defined in  specified  carry  in his role  which appears  be  during  d u r i n g work h o u r s ,  official  he  be  them t o o t h e r  can  d e v e l o p i n g more f l e x i b l e  best  pressures  for doing  so mount. The the  individual  problems,  i s motivated  but p u b l i c  or  partiallly  legislative  by  education  pressures are  about  necessary  184  to  really  The  stimulate this  Guardian An  or S t e w a r d of  official  public  of  interest.  from o p e r a t o r s ,  Policy into  can  he into  is highly  does  concerned  try  to  about  protect  reducing  the  risks  the c o - o p e r a t i o n  in  needed  industry to obtain s u c c e s s f u l r e s u l t s . firm  can  to  maintaining  also carefully  spa  sound p u b l i c  weigh economic  management p o l i c i e s .  effective  g r e a t l y b e n e f i t by  leadership  Health  truly  being  hold  but  factors  often  type  and  will  health principles,  official  Public  i s a l s o w e l l aware o f  users  individual  behavioural  this While  spa management he  This  official.  in  promoting  policy these  Thus,  and this  implementation.  types  of  officials  roles.  Industry  Order-Takers An  industry  requests  and  demands of  questioning The the  order-taker operators  the p r o d u c t s  underlying attitude services  or  undesirable.  Through  costs,  o p e r a t o r s may  safety  of  users.  being  and  the  and  their  nature  ignorance use  spa  attempts  of or  to  consumers  purchased  i s that their  goods  point. Unfortunately,  merely  job  or  their  spas  makes  attempts  products  which  the  without  ever  intended  use.  i s merely  responsibility  meet  to  provide  ends a t  that  this  behaviour  to cut  purchasing  jeopardize  the  185  Order-takers aware  of  their  motivated forces spa  can  to  assume  buying  dealt  after-sale  comparison  user  be  of  w i t h by  making them  responsibilities.  more  sufficiently  They  r e s p o n s i b i l i t y whenever  p r o d u c t q u a l i t y as  a  factor  are  also  competition  in operator  and  decisions.  Evangelists Certain their  members i n the  revenues  or  spa  status  through  c a m p a i g n s t o d e v e l o p good spa of  person  will  committees. His will  serve  principle.  the  However,  becomes f i x e d described Options  the  in a pattern  of  overlooked  management  objectives  can  approaches  for dealing  with  same way  as  zealous public  to  via  committees  the  be  lost.  industry health  type  which,  i n some c a s e s ,  behaviour  and  This  and  and  the  officials  increase  codes  "evangelism",  with c e r t a i n health become  on  selfish,  interest  when  organizing  appear  is usually  public  attempt  management g u i d e l i n e s .  frequently  motive  industry  standards  "invisible of  this  the  hand"  individual  rigid  features  become a p p l i c a b l e  larger  picture  Policy  of  should  "evangelists"  here. spa  consider  in  much  the  officials.  Gypsies There paint  is  an  industry  t h e i r name on  "qualified  pool do  numbers.  can  They  backwards,  and  such c h a r a c t e r s  j o k e a b o u t p e o p l e who  spa  in fact go  service exist  i n and  out  and  suddenly  p e o p l e " . The -of  and  buy  call sad  truck,  themselves  truth  sometimes  b u s i n e s s as  a  is  in  quickly  that large  as  a it  186  takes of  them t o f i n i s h  knowledge  their  a particular  of t h e i r  trade  j o b and g e t p a i d .  and u n d e r l y i n g  Their  lack  l a c k of concern f o r  c u s t o m e r s c a n l e a d t o h a p h a z a r d work, s a l e s o f u n n e c e s s a r y  or d a n g e r o u s  products,  c u s t o m e r s who t h e n Licensing eliminate  and  advice  to  operators,  i n d u s t r y members  certification  and  other  of " g y p s i e s "  with  requirements  better  alternative  angry  in general. can  o r f o r c e them t o " c l e a n up t h e i r  customers  c h a r a c t e r s and effects  distrust  "gypsies"  effectively,  bad  information  services  may  perhaps  act". about  decrease  More these the  upon s p a o p e r a t i o n s .  Sharks These  people  have t h e same e f f e c t s  operations  as " g y p s i e s " ,  knowingly  pursue  except  selfish  their  grandmother these  gypsies,  a different  their  challenge  effects  element "they to  for their  of  conscience  would s e l l  the  behaviour  to  on s p a management a r e a k i n  motivation  to policy.  the behaviour  necessary  protection  concern  and  their of  types.  the "sharks'"  in c o n t r o l l i n g also  i s no r e a l  to cut a deal" aptly applies  industry  intentionally  without  a c t i o n s and t h e o l d e x p r e s s i o n  Although of  "sharks"  interests  customers or the p u b l i c . There in  that  upon s p a management and  have  of e x c e s s i v e  Consumer  of these provisions  and means f o r r e c o u r s e .  greed  t o those presents  information  i s helpful  industry types,  but i t i s  which  provide  consumer  187  T e c h n i c i a n s and This "behind  g r o u p of the  products,  people  scenes"  services,  Technicians  and  the  industry  t h e y can  information developed not  o n l y produce  t o spa management p r o b l e m s ,  but  they  situations  However,  for other  technicians  understanding to  comprehend  design  of p r o d u c t s  and  and  management  situations.  as  to  and  in-field  perspective  Honest  it  It  be  is  use  help  solutions  clarify  and  tend to e x h i b i t  consulting  and  willingness  of  of o p e r a t o r s  information  important  considered  little  that  can  which  of  spa  kinds  of  of o t h e r p e o p l e  "irrational  are e x c e l l e n t  of t h e t e c h n i c i a n s and  vehicles  to  confuse  reality  these  and  lead  as  well  behaviour"  u s e r s . S e m i n a r p r e s e n t a t i o n s t o o p e r a t o r s or  of t h e word  d o e s not  refers  to  "honest"  necessarily a  refer  behaviour  Honest  commitments  in transactions.  of  users  f o r e n l a r g i n g the  engineers.  will  what n o r m a l l y m i g h t  be  with t h i s to moral  consistent  businessmen  f o r b u s i n e s s " , they  beyond  engineers  t o a wide r a n g e  principles.  good  industry.  technical  a l s o can  on  Businessmen  The people  the  u s e r s o r w h i c h does n o t match t h e  might  o p e r a t o r s and  and  output  are exposed  what  influence  spa management. T h i s a t t i t u d e  operators  individuals  by  operates  industry people.  of t h e a b i l i t i e s  users  usually  have a p o w e r f u l  engineers  analyze  and  yet  in  Engineers  live  In t h e i r be  c a t e g o r y of i n d u s t r y qualities; with  up belief  to  The  solid  rather  business  their  stated  i n t h e maxim " i t ' s  facilitating  expected.  but  with  behaviour  customers of  honest  188  businessmen best  on  i s motivated  their  a t t i t u d e that  a r e c i p r o c a l b a s i s . These  strong  contributions  aware  that  profits. with,  by  safe,  Honest but  it  individuals  will  important.  It  industry  life  people  t o spa management  problems,  happy o p e r a t o r s and  users w i l l  businessmen are g e n e r a l l y cannot  be  be aware of is  situations  necessary  for  u s u a l l y make as  easy  assumed where  others  they  produce  quite  automatically  functions  are  future  to  deal  that  these  reciprocity  is  t o draw a t t e n t i o n  to  problems.  Marketers Such an  i n d i v i d u a l s are a v e r s i o n  important  d i f f e r e n c e . Marketers  perspective specific  concentrate  behaviour  individuals  can will  be  take  group  this  of p e o p l e .  marketers'  talents  to  with  longer-term  rather  spa  initiative  from  The  concepts  invaluable  t h e most c r e a t i v e and  negative  have a l a r g e r and  on  Frequently,  utilizing  businessmen,  than  just  transactions.  Their these  and  of h o n e s t  to  innovative  P o l i c y can toward  management, find  ideas  solutions. will  particularly  restructuring  as  emerge  benefit  by  potentially  situations into positive d i r e c t i o n s . above  descriptions  behaviour  which can  involved  with  spa  spa  o p e r a t o r s , no  is  made.  for  other p o s s i b l e  be  from  management. As  claim  However,  expected  conclude  of t o t a l  behaviour,  it  the  with  accuracy  i f policy-makers is  an  overview other  main  of  the  actors  t h e c h a r a c t e r i z a t i o n of or  are a l e r t reasonable  comprehensiveness to the p o t e n t i a l to  use  these  189  characterizations  as a f o u n d a t i o n  for behavioural  assumptions.  190  APPENDIX D  A Detailed As it  a guide  Description  to understanding  i s helpful to c l a r i f y  their  o f t h e U.S.  important  the r o l e s of each p a r t i c i p a n t ,  the c a t e g o r i e s  contributions  Experience  and  indicate  t o s p a management  some  progress  of thus  far.  The  Industry's The  Role  spa i n d u s t r y  splintered  off  on  o r i g i n a t e d from t h e p o o l  i t s own, and more r e c e n t l y ,  moved c l o s e r t o g e t h e r .  The e a r l i e r  was  a d i r e c t r e s u l t of d i f f e r i n g  the  people  whose  splintering industry thus  was  highly  impetus  characteristics. business  products.  trade their  objectives. National  to the  retailing,  types  predominantly because  and  accommodating  the  spread  are  sectors  spas.  i t forced the  "industry", engaged  in  represent  we  spa  a  very  the pool  a b o u t spa  refer  the  This  differences;  of i n f o r m a t i o n  and s e r v i c i n g o f  firms  two  needs and i n t e r e s t s a s s e e n by  was  term  later  t h e two g r o u p s  f r a c t u r e of the  significant  which  These  organizational  despite  By  firms  distribution,  The  business  into recognizing  adding  industry,  to  the  manufacturing,  and wide  spa-related scope  of  i n s i z e and s t r u c t u r e .  association  groups  have  n o t - f o r - p r o f i t status  The N a t i o n a l  Swimming P o o l  Spa  &  Pool  Institute),  been  classified  here  and s t a t e d p u b l i c - i n t e r e s t Institute  located  (formerly  i n Washington,  the D.C,  191  is  the dominant  it  is  unique.  international U.S.,  "ma  spite  sales  e f f e c t i v e and  role,  20  firms  which range  small  and  elevate  foreign  diverse  and a c t i v i t y .  of  swimming  for  the design, spas."  pools  In  in  technical  appropriate  government  associations,  and  education  other  the  NSPI  agencies, public  Red C r o s s and t h e N a t i o n a l  of  as;  works  respect standards  closely  universities,  service  agencies  conducts  research,  and d e v e l o p s  the other  hand, t h e a s s o c i a t i o n a l s o c l e a r l y  pools with code  such as the  S a n i t a t i o n Foundation.  information  "to  and spa  swimming  shares  "industry"  service  with  t h e s e g r o u p s , NSPI  On  respect  to i t s public  and e q u i p p i n g  function  and  organization  and s p a s ; and t o e s t a b l i s h u n i f o r m  this  In  a s s o c i a t i o n , NSPI  t h e s t a n d a r d s o f t h e swimming p o o l  construction,  health  others.  i t s objectives  t o conduct a program of p u b l i c  to  and  service  In r e g a r d  one  public  as  makes t h e a s s o c i a t i o n  as b o t h a p u b l i c  lists  The  such  regarded with  What  the  corporations  members  consultants,  particularly  in  countries.  from g i a n t  It i s highly  integrated  member f i r m s  s i z e as a trade  active,  association,  vertically  institutions,  an arm o f t h e i n d u s t r y .  industry;  American  other  It includes  trade  2000  over  status  t h e NSPI c h a r t e r  dignify  o f more t h a n  relations efforts.  i s i t s dual  as  completely  representatives,  i t s effectiveness  unique  a  architects, financial  government  and  and  of i t s r e l a t i v e l y  very  and  is  & pa o p e r a t i o n s " .  officials,  to  a s s o c i a t i o n , and a s a  association  represents  independent  is  It  Canada,  association to  trade  With  and s e r v i c e s r e c i p r o c a l l y ,  programs.  interests. It specifically  develops  and  represents implements  192  promotional  and  marketing  programs  consumer demand and i n f l u e n c e Its  annual  primarily The is  convention,  public  though  preferences partly  importance  of t h i s  two-fold. F i r s t ,  background  and  raises  regarding c o n f l i c t s  questions  1979 NSPI  Disease  Control  management and  received  the  a $9,000  for  guidelines CDC o p e n l y  work  as  a  people  have  represent this  is  There  firms  the l a r g e s t  manufacturers  of i n t e r e s t .  relating  to several  some e v i d e n c e recently  acted  to  standard  will  and  F o r example,  the  times  Center  for  of spa  in this  factual  study)  ramifications.  dominated  the  As  than  of  their  requirements  a  new  If  these  benefit.  the  Council  National Sanitation  to  be r e a c h e d  also  w h i c h does p r o v i d e this,  the  changes  having  large  that  the  present  pool  f o r spa e q u i p m e n t  The b a r g a i n i n g i s n o t c o n c l u d e d ,  a compromise w i l l  be m o d i f i e d r a t h e r  the  some  association.  to  Council,  prevent  adding  by  exists  policy  example  making  and 1  an and  to the  possibility  public  fact,  other c o n t r i b u t i o n s  s o u r c e of revenue  from  and l i s t i n g . if  dues  try  filtration  as  whose  of t h i s .  (NSF)  looks  is  a Manufacturers'  Foundation  testing  NSPI  influence  i s ,in fact,  function  t o the development  that  then  may  i t s dual  from  study  on t h e p o l i c y  of c o n t r o v e r s y , not e s t a b l i s h e d  charged  true,  serves  a c k n o w l e d g e s NSPI a s a m a j o r c o n t r i b u t o r t o  matter  manufacturing  opinions.  products.  Secondly,  t h e g u i d e l i n e s . T h i s has b o t h v a l u e and First,  and  influence  contract  (referred  stimulate  information to this  NSPI has s u b s t a n t i a l locally.  to  educational,  a s a showcase f o r m a n u f a c t u r e r s '  process n a t i o n a l l y  in  designed  but i t  whereby t h e s t a n d a r d code  written  for  193  spas.  2  The  that  these  significance f i r m s have a  whereas  other  do  —  not  their  distinction the p u b l i c may  types  can  of stake  of  possibly  be  (i.e., is  products.  effect  times  at  policy  by  manufacturers,  though,  involvement toward  in public  products;  and  retailers)  products.  This  detrimental for  ( o r g r o u p of  manufacturers)  they  may  of u n d e s i r a b l e o r  have  a  more d i s c e r n a b l e and  interests,  ramification  i s that  (as  often  be  influence  to suggest  formation  industry  beneficial  knowledgeable  amount of  i s reasonable  policy  is  and  of t h e a c t u a l  it  any  toward acceptance  being  about p r o d u c t s . R e g a r d l e s s  sell  beneficial  Conversely,  control  specific  wholesalers  to  both  manufacturer  selling  i n t e r e s t . A manufacturer  influence public  biased  in  firms  interest  unnecessary  NSPI  possible  is  to  possibly  at  of  that close  some  degree  the expense  of  others.  A second important  policies  individuals  or c o m p a n i e s ,  factual  concerns,  information  Also,  recommendations that  accepted  time  this  after  being  there  separately  published  as  gone  having  investigation,  questioning,  the  standards. materials  and  a  also  lead  empirical  to a tendency knowledge.  to ignore  The can  the  the  important  of  same of good  accidentally  or  duplication  of  danger of be  process  analysis.  n o r m a l v a l u e q u e s t i o n s , t h e dominance of  by  possibility  frequent  through  organizations)  From a s t a n d p o i n t  overlooked,  is  i n g u i d e l i n e s and  many  dominated  time.  creates  or a l t e r n a t i v e s  otherwise.  is  can  in  Thus, same  this  deceptively of  separate aside groups  from can  o u t s i d e a c t i o n s or  194  Against other  considerations  actuality, retained the  an a c c e p t a b l e  do r e c o g n i z e  this:  i t s dual  level  (1)  in  always  service  order  to  objectivity, to  remain  endeavour  do  and  t o i t s own  its  the  association interest  (2)  almost  can  disputes.  As  influence  standards  "proper" bromine  spa  an  detrimental inferior,  check  the  to  strive  against  could  be  surely  interests.  (3) NSPI  of  industry  people.  As  fairness,  to  for  no  may  "prove"  members  in  one  the  specific  provoke  of  who  t r i e s to as  the  draw t h e w r a t h o f t h e acts  as  i t can a l s o  p r o d u c t s , w h i c h may  standards  disaffected to  serious  chlorine  as  i s consistently  by t h e t r a d e p u b l i c a t i o n s ,  non-NSPI  order  abuses, but i r o n i c a l l y ,  in  must  the a s s o c i a t i o n  manufacturers. This  tolerated  NSPI  suicidal  manufacturer  acceptance will  for  the eyes of  for  a f f e c t o t h e r s and  disinfectant)  i n the  or unreasonable a c t i o n s i n  example, a c h l o r i n e toward  in  public,  in  diversity  to f a c t u a l concerns. Certain  appease those criticism  and  i.e., unfair  disinfectant  (or other  effective  "legitimate"  interests  large  d i r e c t i o n can n e g a t i v e l y  shown  in  There a r e reasons  i n e v i t a b l y guarantees that  dominate,  objectivity  sectors  o t h e r w i s e and p e r h a p s a t t i m e s  posture;  s u c c e s s f u l l y and  i n t e r e s t . I t w o u l d be  have t o a c t c o n t r a r y  and  role quite  organization.  and t h e p u b l i c  conflict,  but s i g n i f i c a n t d e g r e e s ) NSPI a s  organizations,  consciously  NSPI  o f a l l , NSPI h a s , i n  of c r e d i b i l i t y  (to varying,  public  government, o t h e r  one  potential  must be w e i g h e d . F i r s t  accomplished  legitimate  NSPI  about  minds o f many p e o p l e . A l l o f t h e o t h e r  chart a  these c r i t i c i s m s  an be be  an e f f o r t t o the target f o r NSPI  members,  be e x p e c t e d ,  criticism  195  usually  aims  improper, retain  exploiting  or done  i n poor  criticism  too, A  it  i s u n l i k e l y that  NSPI to  to  i t s goal  to  as  the  final  confict  of  indicate anyhow.  an  alert  other  of  without  otherwise  organizations  i n d i v i d u a l firms  selfish  and  this  exceedingly  that  abuses.  postulation  not  to  and  objectivity.  i n t e r e s t i n a c t i n g as  3  consideration  that  industry  If t h i s in  a  important  the  NSPI. Many occur,  and  would  have  substitute  would have  potentially  would be  what  little  destructive  non-existent.  This  justification  for  is  i s true  not.  often and  i t truly  Studies  "captures"  we  are  of the  unable  matters  other  industries  regulatory to  if a  devise  process better  t h e n what d i f f e r e n c e does i t make whether  influence  i s exerted  Some m i g h t a r g u e t h a t  identified  whether  general,  whereby  In  might  biased,  increase  seeking  s p a s would be  checks against  a s s o c i a t i o n , at  way,  the  i n t e r e s t e x i s t s or  industry  manner?  and  be  be  role.  A  systems  and/or  is  i t by  the  government o r  restrain their  consideration NSPI's  is  f u n c t i o n s . Moreover,  efforts,  an  appears  e f f e c t i v e check a g a i n s t  contributions  wherewithal  reason  t r y to avoid  s i t u a t i o n for pools  i t s recognized  the  j u d g e m e n t . In  consideration  of  for  and  forms an  second  overall  the  whatever  membership, NSPI must a l w a y s c o n s t a n t l y  potential This,  at  and  i n an  when i n f l u e n c e  l e a s t i t i s done  decisions traced  and  in  actions  i f questionable  summary, NSPI, b o t h on  organized  an can  or  unorganized  i s exerted orderly, be  through organized  more  readily  situations arise.  a national  and  local  level,  has  196  the  potential  affect  for  p u b l i c p o l i c y and may  However,  experience  that  where p o s s i b l e  more  tolerable  association. NSPI and  demonstrating  a b u s e s may  discard  been  quite  raised  basic  —  on p u b l i c  and w i t h i n  i t really  those abuses of  firms,  the funding, NSPI w o u l d  objectivity marketing support  —  still  the  be r a i s e d ; why  doesn't  the  t h e arm o f t h e  the i n d u s t r y  does n o t m a t t e r  that  aspect  activities  itself.  and  ones p r e s e n t This the U.S.  other  lengthy  experience  with  group.  As  taking  place  a  result,  what has t a k e n p l a c e  order  of the  for firms  against  service  o f NSPI  Of  to  various  and l a c k of and  to join  and  from  this  b u s i n e s s abuses f a r  i s more p e r t i n e n t  i t i s the f o c a l  interaction  i t serves basis  role.  a l l the a c t o r s ,  direct  on a r e g u l a r  does  e f f e c t s w h i c h would be beyond any  because  spas.  most  in  so be i t . The b e n e f i t s  public  involved,  For  to p o t e n t i a l bias  checks  discussion  actors  The answer i s  i f the a s s o c i a t i o n  motivations  negative  in a purely  w h i c h h a s had t h e  for  offer  self-induced  outweigh the p o s s i b l e  question  would n o t c h a n g e . I f p r o m o t i o n a l  the a s s o c i a t i o n , then  support  industry  The  and c o o p e r a t i o n  be s u b j e c t  perhaps  having  s e r v i c e matters?  information,  are  not  p u r s u e p r o m o t i o n a l and m a r k e t i n g a c t i v i t i e s . obtain  interest.  i s l a r g e l y n o t t h e c a s e and  alternative  then might  of i n t e r e s t which  to the p u b l i c  the r o l e of being  s o l e l y concentrate  has  this occur,  the  The q u e s t i o n  simply  be c o u n t e r  shows t h a t  than  conflicts  than  point  f o r the  i t i s t h e one  with  as a "weathervane"  every  other  f o r what i s  and a l s o a s a c u l m i n a t i o n  through the e f f o r t s of  for  others.  point  197  Federal,  State,  and L o c a l  These a c t o r s their with  roles regard  and  within  and  vocal  action  have been lumped  to d i f f e r e n t level  public  responses  officials  s p a s . But t h e r e  prefer  interviews  to avoid  possible  from e a c h l e v e l  who  have  steps  varied  some  very  active  u r g e d and t a k e n  or could  both  o f government  a r e a l s o a l a r g e number  their  stereotypes  of  with  that  of  public  officials  n o t . The r e a s o n s  spas.  This  for  runs  contrary  who to  such as "they or  somewhat  jump a t any o p p o r t u n i t y  to stick  i n t o a s i t u a t i o n and attempt  health"  to garner p o s i t i o n s of  i s , as p r e v i o u s l y  l a c k o f knowledge and l a c k  d e e p e r and i s q u i t e  are o f f i c i a l s  officials  to protecting public  o r power". The r e l u c t a n c e  t o both  there  public health  "public agencies w i l l  nose  authority  revealed  involvement  always d e d i c a t e d  opposite,  due  have been q u i t e  are i n t e r e s t i n g .  In-field  are  f o r c o n v e n i e n c e , but  i t s e l f . T h e r e have been  who have n o t wanted t o t a k e this  Agencies  together  i n t h e U.S. e x p e r i e n c e  each  with  Government  of c o n c e r n ,  understandable. Public health  mentioned,  but  it  goes  officials  have  i n n u m e r a b l e e x i s t i n g and p o t e n t i a l h e a l t h  c o n c e r n s , a l l of which  could  on  conceivably  manpower,  all  demands  coping  with  present  that  by t h e r e c e n t  of being  possible  to  rash  the  departments'  they a l r e a d y  attitude  added  less.  Thus,  administration  a r e not  so t h a t t h e has  o f government c u t - b a c k s .  a s k e d t o do more w i t h avoid  their  responsibilities,  o f new ones a r e n o t d e s i r a b l e . T h i s  exacerbated situation  high  b u d g e t s , and t i m e . Some f e e l  satisfactorily prospect  place  been  It i s a  i f i t i s at costs  and  198  p r o b l e m s of the  other  departments  n e c e s s a r y . The  budgets The  some p u b l i c  officials  has  program,  simply  Illinois  the  i s one  reduced  for  spas —  to  pool  did  d r a f t proposed  regulation  —  been  a cost i s not  legislation  despite  the  important  and  more o f  a health  s h a p e , as  The  at  spa  allows  In  the  but  differing  abilities  in getting  The  first  which  to  failed  normal  totally  pool  sampling,  A new  program  f o r one  similar  the  get  that  problem than  treatment  d i r e c t i o n may is  often in d a i l y  authority,  and  spa  department legislative  regulation  is  nothing  is  pools, Michigan  are  eliminate  left  willingness with  e f f e c t i s the which with  p o t e n t i a l squabbling  particularly primary  inspections.  fact,  to  shrinking  to eliminate  f e a s i b l e . In  view  jurisdictions.  their  $200,000/year  of  involved  t r y i n g to deal  U.S., it  "look  i n worse  their  pool  ft  of  it  With  t i m e . W i s c o n s i n and forced  regulatory  process  this  and  i n some  agency's b e l i e f  t h e y were  jurisdictions effects.  soon  what t h e y  costs  forced  number of  So  done  rising  example.  has  the  estimated at  of  support.  programs.  j u s t as  a f f o r d t o do  public activity  department  l a b t e s t s , and  cannot  combination  constrained  s t a t e of  being  would  way".  Some as  spas,  be to  obvious has  amongst t h e given the  delegate  by  the  has  lack  added  s p a s . The  administration may  spas  (or  of  the  various  three  main  uniformity  confusion  to  in the  second e f f e c t i s t h a t l e v e l s of  government.  federal  government,  direction tasks.  of  The  of  each  state,  states,  having  contract)  the  duties  to  199  county  governments.  cooperatively. involved to  or c o u n t i e s , may b e g i n  third  state  and  municipal  are subordinate. there  standards  with  the  may a l s o g e t  that municipal  levels,  governments  run counter  hence c r e a t i n g  jurisdictions  with  All  outside  they  very  important  appears  demonstrate  problems,  potential  of  more  spas  situation minutes,  and  officials  of spas  that  final  regarding  of  is  the  Besides  water  the  short-cuts  real  in  occurrences  weaknesses. Another which,  aspect  as of  typical  Chapter  costs  for  excessive i n the  effective  enforcement  In r e f e r e n c e t o 2,  we  budgetary  i s created.  a  change i n and  and the e f f o r t s  frustrating.  expression  some  of  health  counter-productive.  liability and  have  monitoring  weakness i s t h a t p u b l i c h e a l t h  to avoid  of y e t , effective  c o n d i t i o n s can l i t e r a l l y  r e g u l a t i o n may be  liability  exists  discussed  become  major  represent  an a d d i t i o n a l p r o b l e m .  i s reflected  have t o show c a r e light  spa  thus  may  in part,  This  present  where  enforcement  In  weakness  severe  i s weak o r d e t r i m e n t a l .  of the c u r r e n t  regulations.  variability  A  some  unresolvable.  enforcement  This,  which  o f t h e above c o n s i d e r a t i o n s  and  the  information  to  conflicts.  b u d g e t a r y c o n s t r a i n t s a r e more s u s c e p t i b l e t o s e e k i n g or a c c e p t i n g  work  i s t a k e n by s t a t e s  or r e g u l a t i o n s which  that  then  s t a t e s and c o u n t i e s  Where no a c t i o n  government  is  county  governments  i s the l i k e l i h o o d  of other effect  and  own o r i n c o o p e r a t i o n  imposing  principles A  Local  on t h e i r  whom t h e y  The  departments  i f s e r i o u s problems  enforcement  problems,  arise.  a dilemma  The u n c e r t a i n t i e s i n v o l v e d  place  200  a great  deal  of  liability  does  directions  are  sort  through  satisfactory reasonably  The  b u r d e n on arise.  a l l p a r t i e s concerned Because  lacking, i t will a  problem  government  clear be  case.  consistent  more c o m p l i c a t e d The  question  responsibility  e s t a b l i s h e d to o f f e r  and  i f a question  policy  and  i s ; has  of  messy  to  a norm of  toward p u b l i c  spas  been  guidance?  Operators There  behaviour aspect the  is on  of  absolutely  the  part  of  operation,  104°F  temperature from  same o p e r a t i o n  from day  informed  of  proper  they  have  information from:  they  experience, instructions, public  written  Invariably, b a s e d on  and  by  management  differing  These b i a s e s are them.  and  confused of  sources.  with,  comparing has  b i a s e s w h i c h may  so v a r i e d t h a t  receiving  They p i c k up  a or  by  different  operation  other  trial  and  may  not  i t i s impossible  and  operators.  error be  to  product  industry  with  been  information  pool  both  the  poorly  have  manufacturer  notes  become  observing  often  they  previous  materials,  every  even w i t h i n  are  where  from  of  or  extraordinary  and  Operators  e d u c a t i o n a l programs p r o v i d e d  agencies,  operation  virtually  is  to o p e r a t i o n  procedures,  deal  In  there  day.  been  of  the p o s s i b l e e x c e p t i o n  operation to  pattern  operators.  limit,  from a l l k i n d s  vendors  clear  the  with  inconsistency  informed,  no  process  justified disaggregate  201  The spa The  a b s e n c e of any  systematic  o p e r a t i o n makes i t f u t i l e only  reliable  operators operation  seem --  with  want  the  opportunity  consuming,  and  of  the  least and  weakness f o u n d  The  Spa  the  guidelines  of  by  the  time  overwhelmingly  by  they  been  The  industry reach  the  to  time-  operation.  experienced  of for  according  simplest, least  method  confusions  T h i s has  the  the  and level  outstanding  experience.  county  health o f f i c i a l  done w i t h public  bottom!"  of a w a r e n e s s of  time  s p a s now  would be  to take  not  get  any  to  foamy,  and  meaning was  spa  use  As  shown i n C h a p t e r  they  understanding a problem  in  discolored,  realizes  his  and  health risks  suggested;  This health o f f i c i a l  5  spa  i s e x c e p t i o n a l l y p o o r among t h e  excessively  the  want  practices.  majority  for f l e x i b i l i t y  costly  i n t h e U.S.  level  water q u a l i t y  be  All  authoritative  current  Users  The  one  some  f a r more e v i d e n t  operator.  p a t t e r n of  to c h a r a c t e r i z e a c t u a l  to  circumstances.  government a r e  logical  c h a r a c t e r i z a t i o n i s that a large  individual  uncertainties  or  clear:  general  public.  spa As  best  thing that could  out  full  page ads  whirlpool or  which  you  being  telling  is  can't  dirty, see  the  somewhat  dramatic  at  that there are a l s o other  problems,  but  needs  i d e a of what r i s k s there  is a real  of h e a l t h h a z a r d s  t o spa  proper  "The  the p u b l i c s o r e l y  have no 2,  was  and  and  usage. T h e r e f o r e ,  with  education  they  are  exposed  weakness w i t h being  complaints  able  about to.  the p u b l i c  to  to h e a l t h  correlate agencies  202  or  t o spa o p e r a t o r s which might a l e r t  going  undetected Further,  us t o a p r o b l e m a r e l i k e l y  i n many i n s t a n c e s .  spa users a r e n e g l i g e n t  consequences of t h e i r  behaviour.  drugs p r i o r  and/or  Specific  of  reasonable  d u r a t i o n s o f use a r e a l l f a i r l y  behaviour  users.  Among  case spa.  However, hygiene  showers  prior  sweaty  from  wounds, subtances  time.  pools  loss  to  use  her  being  and  armpits  entry  into  the spa with  o i l , cosmetics,  to  undesirable, failure  take  a person i s  exposed  deodorant,  violated  cuts or  or  other  observe with  these  spas  the vast majority regulations  can e f f e c t i v e l y  impractical convinced  with  c a n be c a t a s t r o p h i c t o  f o r p r o p e r l y m a i n t a i n i n g water q u a l i t y .  method  to  body. T h e s e have l o n g been p r o h i b i t e d by  failure  employing  i n the  failure  i s even worse a f t e r  enforce  procedures.  Operators these  Still,  of the importance  so a s t o a c t r e s p o n s i b l y on t h e i r  be  i n spa a n d a n o t h e r  violated:  w i t h p o o l use and p r o b a b l y  must be s u f f i c i e n t l y  some  legs  other  common b e h a v i o u r a l p r o b l e m s a r e w i t h  (which  excessive  a s t o how t h e y  without  most  practices  Although  is  efforts  the  on t h e u s e r ' s  regulation  a  have been made t o h e a l t h d e p a r t m e n t s by  exercise),  and  t o observe  common. C o m p l a i n t s o f  them; a woman w a s h i n g h e r h a i r  standard  of  or d u r i n g u s e , and f a i l u r e  where a woman was s h a v i n g 6  of the  problems of h o r s e p l a y ,  ingestion  unusual  ignorant  are at  provisions either  of these  own, o r o p e r a t o r s must  users things devise  f o r e n f o r c e m e n t . Good s p a management o t h e r w i s e  s e v e r e l y l i m t e d by t h e s e  behavioural  abuses.  may  203  The  above  weaknesses can U.S.  of the four  be c o n s i d e r e d By t h i s ,  involved they  discussion  principal  peripheral  made a f o c u s  actors.  the  they  experience  The o t h e r  to the o v e r a l l  i t i s meant t h a t  or  should  characterizes  have  and  participants  spa s i t u a t i o n i n t h e not  been  constantly  o f p a r t i c u l a r o b j e c t i v e s . Even t h o u g h  n o t be d i s r e g a r d e d ,  they  are  not  central  to  our  considerations.  S t e p s Toward Since  Spa Water Q u a l i t y Management the t u r n i n g  spas, concrete an fall  effort  actions  to  into  This  (1)  has  For to deal  actors  h a z a r d s . The  Guideline  and  in  efforts  regulatory  (3) E d u c a t i o n ,  (4)  measures.  S t a n d a r d s and R e g u l a t o r y  area  concerned.  health.  spa p u b l i c h e a l t h  categories:  and o t h e r  1. G u i d e l i n e ,  developed  by t h e v a r i o u s  d e v e l o p m e n t , (2) S t u d i e s / r e s e a r c h ,  Incentives,  U.S.  of a c k n o w l e d g i n g t h e u n i q u e n e s s o f  have been t a k e n  alleviate  these  standards  point  i n the  received spas,  the  most  guidelines  with three  Developments  aspects  attention  and which  They a r e :  a.  D e s i g n and C o n s t r u c t i o n  b.  Installation  c.  Operation  Criteria  Criteria  and M a i n t e n a n c e C r i t e r i a  by  everyone  standards  have  affect  safety  been and  204  Design, direct  construction concerns  operations by  phase.  failing  to give  operational  out  water  quality  and i n s t a l l a t i o n  management,  However, o p e r a t i o n s  Further,  and i n s t a l l a t i o n  publicly  c a n be s e v e r e l y  the  for  process to  operators.  finances,  and a t t i t u d e m i g h t a l s o c o n s i s t e n t l y " c u t c o r n e r s " i n p h a s e . Of c o u r s e ,  provide  this  t r u e . Nor c a n i t be assumed t h a t  operator  for  to  will  properly  be l o g i c a l l y design,  consistent  carry  said i s this;  construction,  level  standards,  effectively  attention safety.  lack  p h a s e . What  first,  phase w i l l  mean  following  groups  public in  the purpose  installation  (the l e v e l  being  of a b i l i t y  areas  t o promote a  dependent  on  operators,  concern  on  of standards  additional users,  costs  implies  the  ability  who,  for  to such  reasons  inadequate health  and  i n the p r e - o p e r a t i o n a l  for  some  operators,  a restriction  the  o f them) i n t h e  for public  or  a l l of  consumers  a g e n c i e s and t a x p a y e r s . And f o u r t h ,  these  is  standards  o r w i l l i n g n e s s , may g i v e  disregard  imposition  --  of  and manage spa water q u a l i t y . S e c o n d ,  or completely Third,  does not always  on i n t h e o p e r a t i o n a l  a r e a s w h i c h have an e f f e c t  operate  facilities,  "unworthy"  s t a n d a r d s c a n be u s e d t o d i s c o u r a g e either  proper  inference an  is initially  initially  and  of q u a l i t y  who  and t h e a d h e r e n c e t o and e n f o r c e m e n t  pre-operational  of  operator  The  u n w i l l i n g or unable  can  an  design,  reluctant,  hold  that  undesirable  pre-  can  operational  drawn  and  hampered  to  standards  the  inference  the  be  in  can a c t as a s c r e e n i n g  desirable  are not  as  t h o r o u g h and c a r e f u l a t t e n t i o n  concerns.  construction, sort  of  (and m a t e r i a l s ) ,  t h e use o f  of c h o i c e  the  i n general, standards  for potential  205  public  users,  assume  i . e . , those  the risk  i n d i v i d u a l s who might  of a "lower" q u a l i t y f a c i l i t y  f e e would n o t have t h e c h o i c e Ideally, of  safety  considerations  operation also  (both  ideally  with  which a r e into  want  market  of  versus  recognize  solid  For  and  the  and  guidelines  NSPI, was t h e f i r s t April,  1978  operational Public  they and  Spas  and  government w o r k i n g health  to  recommend  published operational Hot  Tubs".  issued  standards,  and t h a t a  both phases  who  have  specifically  standards.  In  for  As  7  "Minimum  cited  with  NSPI  "Suggested  of  publications are s t r i c t l y  or l e g i s l a t e d  develop  together.  phases,  for Public  binding  standards.  pre-  Guidelines these  just  a s e t of g u i d e l i n e s c o v e r i n g  i n conjunction  departments  of the  l e t us  The i n d u s t r y ,  and  certain  i s a close relationship  operational  and standards.  would  issues  h a s been t h e a p p r o a c h by most o r g a n i z a t i o n s  developed  proper  consistent  for a  moment,  take  We  pre-operational  there  materials  for  treatment).  argument c a n be made f o r c o n s i d e r i n g This  allow  up t h e common  of composing  t o understand that  pre-operational  to user  sound,  t o make s u c h c h o i c e s  brings  intervention.  i s important  t o choose  w i l l i n g n e s s t o pay  This  the d i f f i c u l t y  between  account  the operator  facilities.  a t a reduced  structurally  f o r equipment a n d c h e m i c a l  p o t e n t i a l public users'  quality  It  and d e s i g n  willing  t o do s o .  we would want t h e s p a o p e r a t o r  construction  be  Spas and Hot T u b s "  Standards  earlier, and Health  in April,  the federal  state  public  and 1981.  Safety 8  Both  r e c o m m e n d a t i o n s a n d have no  p r o v i s i o n s upon o p e r a t o r s  or users.  At the  206  state  and l o c a l  actively any  level,  use swimming p o o l s t a n d a r d s  s t a n d a r d s . Even  some m u n i c i p a l i t i e s example. The s t a t e and  there are disarrayed e f f o r t s .  i f states  f o r spas,  some do  have n o t d e v e l o p e d  have gone a h e a d on t h e i r h a s done n o t h i n g w i t h  Some  not  own. I l l i n o i s  miscellaneous  a c t i v i t i e s t a k i n g p l a c e , t h e h a n d l i n g of which  by  The s t a t e  the  case  pool  —  and  covered  spas  spas  handles  in  that  he  the permit  approval process  According  interested  Du Page C o u n t y , t h e s t a t e  regulation directly  drain  the  does  a  permit.  f o r the s t a t e head  of  construction  provisions.  directly  not  undertake  specific  handles  spa  be i n v o l v e d , b u t o t h e r  a c t i o n s appear  of Chicago,  Northwest M u n i c i p a l Conference implemented  than  in  their  the  the group e a r l i e r has  developed  In  permits  To d a t e , Du  inspection  permitting  t o have t a k e n  and  1 0  a c t i v i t i e s . In t h e s m a l l e r c o u n t i e s , t h e s t a t e  suburbs  that  disinfection,  may t a k e c a r e o f o p e r a t i o n a l m a t t e r s .  a b o v e , no s i g n i f i c a n t Northwest  to  i n the f i l t r a t i o n ,  neighbouring  Page C o u n t y  pool  t h e CDC g u i d e l i n e s a s a b a s i s f o r a p p r o v a l  main  the county  of the  a r e not r e q u i r e d t o o b t a i n  county.  uses  he i s m a i n l y  but o n l y  i n conjunction with a p u b l i c  anti-vortex  but  spas,  varies  t h e s t a t e a c t f o r swimming p o o l s and b a t h i n g  Otherwise,  9  department, and  under  County  for  f o r new  t h e n , a s p a i s c o n s i d e r e d an " a p p u r t e n a n c e "  beaches. Cook  does approve p e r m i t s  where a s p a i s b u i l t  i s an  r e g a r d t o spa s t a n d a r d s  regulatory  in  use  spa s t a n d a r d s ,  n e i t h e r have t h e c o u n t i e s . However, t h e r e a r e  locale.  states  or  would  described  p l a c e . In t h e mentioned, the  standards  will  be  r e s p e c t i v e communities  1982.  T h i s work was done w i t h t h e h e l p o f l o c a l members  which in Fall of  the  207  NSPI,  Midwest  provided The  by  the  to  added  Bath  and  as  prohibiting  The has  Inc.  relied  located  in  California.  v a r i o u s ways. F o r  trade  separate  have  also  Plumbing  and  "Uniform  Swimming  This  Building in  the  also 1979 have  next  and  on  acted.  developing  standards  spa  Whirlpool  seems t o be  coordinator  Perry  throughout  (a  NSPI) has  The  Spa,  way  1 6  and  formed a  from  Meikle,  nation  county. "  f o r the  Hot  Tub  Underwriters f o r spa  has  Code"  out  scale,  regulations  plumbing. Congress  separate  Laboratories  electrical  are  has  requirements  but  1 7  of  published  for  their  guidelines UL-1563. smaller  committee  Association  International  phasing  pool  Peripheral  1  (IAMPCO)  in  Associated  joint  International  and  t o a g r e e on  a  the  small  for their  Officials  Pool,  on  a  regional  standards  place  input  a  pregnant  association  recently published  taken  major  made  standards  three y e a r s .  working  to  the  Mechanical  Officials  hazard  i n Dade C o u n t y F l o r i d a ,  from  document p a v e d t h e  the  and  t o add  i s a l s o close to enacting  The  1 2  being  example  Industries  actors  definitions  1 3  are  to e s t a b l i s h  the  with  reviewing  (They) a l s o p l a n  test/standards  Swimming P o o l group  tubs.  "are  r e p r e s e n t a t i v e s from J a c u z z i Co.  from t h e i r  they  some of  sign regarding  upon  and  word,  revising  of C h i c a g o  Kohler  efforts  last  wood  caution city  and  Other  of  a view t o w a r d  to the  NSPI  guidelines.  filtration  Jacuzzi  with  CDC  more s t r i n g e n t p r o v i s i o n s , n o t a b l y  11  code and  the  suggestions  few  considering  women."  drew p r i m a r i l y upon t h e  a  code w i t h  paragraph  and  t h e NSPI Minimum S t a n d a r d s and  group  regard  Chapter  Other  major  underway  1 5  of code been  since efforts  efforts and  at  will  208  continue has  through  been the  stated  1983.  It  p r i m e mover  i n September  i s i n t e r e s t i n g to note t h a t  in t h i s  d i r e c t i o n . One  industry  industry  member  1981;  The g r a c e p e r i o d i s up. Codes a r e c o m i n g . I t i s now j u s t a m a t t e r of d e c i d i n g whether we want t o have t h e c o d e s f o r c e d on us, or w h e t h e r we w i l l p a r t i c i p a t e i n f o r m u l a t i n g these regulations. Do we want t o a c t , o r r e a c t ? I t ' s t a k e n us e i g h t months t o i s o l a t e t h e c o u r s e of a c t i o n — now we need t o move q u i c k l y . Morrow observed that there are 10 states actively involved in initiating codes that will a f f e c t t h e spa i n d u s t r y . He a d d e d t h a t many states already have codes, most of which are based upon i n a c c u r a t e d a t a and l a c k b u i l t - i n updating mechanisms. 1 8  The by  a  public  most  significant  action,  group  composed of  industry  health  officials,  sponsored  by  initiated  the  National  i n September  available  sometime  the  has  standards.  been  and  are  Fall  Thus,  1 9  evident  that  guidelines  are  despite  a number  continuing. 1982.  Results  The of  insufficient.  This  of  uncertainty  developing  experts  and  may  purpose  people  spa  a l l prior activity  of  agencies,  organizations  s e l e c t g r o u p of  on  undertaken  F o u n d a t i o n . E f f o r t s were  significance  working  being  safety/health  q u a l i t y management. T h i s  sectors  is  1981  is  members, r e g u l a t o r y  Sanitation  during  conference underlies water  other  however,  think  committee  this  in  spa  from many  health in this  that  be  code  area,  the  it  present  i s addressing  five  priorities: 1) D e f i n i n g the 2)  a r e a s of  s o l u t i o n of  Biocides hot  the  and  water  how  research  problems of they  the  which w i l l industry  r e l a t e to the  microbiology  of  hot  organisms  give  insight  to  groups. tub  rash  i n the  hot  as  well  as  water,  as  209  compared w i t h t h e c o o l e r swimming p o o l 3) Hot water c h e m i s t r y  water.  as i t r e l a t e s  to  the  fluctuation  of  the  of  the  human  body  to  relates  to  temperatures. 4) H y p e r t h e r m i a  and  temperatures  above  5)  the general safety hair As  has  and body  104°F. o f spas  entrapment.  and h o t t u b s a s  i t  2 0  a means f o r a d d r e s s i n g s p a w a t e r q u a l i t y ,  developed  evaluate  reaction  a format  sanitizing  - a pH f a c t o r  f o r s t a n d a r d i z i n g water  p r o d u c t s and p r o c e d u r e s .  organic carbon  - total  Kjeldahl  a s 200 ppm  50 ppm p o t a s s i u m  sulphate  magnesium c h l o r i d e  - additional  urea  (k  SO ) chloride  (Ca  sodium b i c a r b o n a t e  a s 50 ppm J o h n s o n  C I );  200  chemical  measures  innoculation  tests:  (1)  10  5  per  Pseudomonas a e r u g i n o s a , and S t a p h - s a m p l e s a r e t o be s t i r r e d  (Na Co )  include;  (2) o x i d a t i o n r e d u c t i o n  (1)  potential; ml  each  of  electric and f o r E  disinfection  1,  d u r i n g the t e s t  p e r i o d , and  5, 10, 15, 30, a n d 60 m i n u t e s —  efficacy  of  the  Coli,  aureus.  i n t h e m e d i a , t h e y a r e t o be removed a t u n i f o r m —  ppm  & J o h n s o n Baby O i l  conductivity,  periods  (Na C I ) ;  (Mg CI )  a s 100 ppm  - o i l and g r e a s e  placed  to  I t i s as f o l l o w s ;  s o l i d s a s 300 ppm sodium c h l o r i d e  a s 200 ppm c a l c i u m  - alkalinity  used  glucose  n i t r o g e n a s 100 ppm  dissolved  - hardness  samples  o f 7.2 t o 7.8  - total  - total  2 1  the committee  chemical  or  once time  to assess  disinfection  210  device. The  efforts  represent water and  acceptance  understand  of  considered. efficacy  A  with  spas  so  consensus  far.  use and  the  The  with we  have  primary  conclusions  1. The only  spa  water It  the  is  (of  work  exist  difficulty U.S.  has  had  of  results  awareness key  to  easier  to  of  this  group  point  is the  tells  in  spa  a r a p i d growth i n health  understanding  f o r spa  major  gauging  uncertainty  of d i s i n f e c t i o n .  spa  lack  significant clear  may  of  the  to t h i s  experienced  no  the  about  up  NSF  area  much  of  opinion)  by  is  i n c o n s i s t e n c y and  does not  aspect  Whether  risks  of how  or  to  not  this  management p o l i c y  use,  emerge.  a p p l i c a t i o n of inappropriate,  efforts  technical  to observe that  potentially  group produces worthwhile two  the  when  the  sponsored  problems.  confusion,  disinfection  spa  attached,  the  d e a l about  management  in  u n i q u e n e s s of  with  solid  of  us a g r e a t  evaluate  the  a l l the  action  public  committee  It i s significant  progress  public  this  a major b r e a k t h r o u g h  quality.  making  by  t o remedy t h i s  swimming p o o l  standards  but  be  it  may  situation  are  to  extremely  spas  is  not  misleading,  imperative  for  and  reducing  risks.  2. to  S t a n d a r d s and revision  recently  and  possible extensive  begun t o  effectiveness  r e g u l a t i o n s developed  of  formulate  an  disinfection  up  until  revision.  accepted  For  now  are  i f we  subject  have  only  means f o r e v a l u a t i n g  specifically  for  spa  the  water  21 1  conditions, determine  i t our  facilities. including  take  actual  This  time  spa  could  to  lead  a recent survey  indicate  rely  on NSPI  the  respondents  that  standards  of  this  50%  more o f f i c i a l s  about the  t o major changes  2 2  that  they  illustrates  of the  90  reported  used  were  public areas  guidelines.  January health  part  on NSPI  NSPI  1982,  officials  part  codes  of  of those  for  public  o f N S P I s s t a n d a r d s and 14 1  t o observe  that  almost  f o r p o o l s , b u t n o t s p a s , and o n l y f o r p o o l s but not  senior  motivation  a l l or  using  It i s interesting  used codes  10% more r e l i e d response  by NSPI,  in  in several  t e c h n i q u e s and u s e r  number, 36 u s e d  them e n t i r e l y .  status  f o r p o o l s and s p a s . S i x t y - o n e p e r c e n t  said  used  quality  t h o s e methods and  the m a j o r i t y of p u b l i c  s t a n d a r d s . Of 95 r e s p o n s e s , pools;  to e s t a b l i s h  water  e q u i p m e n t , management  Finally, seems  will  vice  for  spas.  president  industry  Further,  Larry  Paulick  involvement  with  standards;  . . . wide spread u s e o f NSPI s t a n d a r d s e n s u r e s a more u n i f o r m s e t o f c o d e s among s e p a r a t e g e o g r a p h i c a r e a s . T h i s , in turn, provides a more unified method for industry products. The more public o f f i c i a l s who use NSPI s t a n d a r d s , t h e b e t t e r i t i s f o r o u r members. When a builder can use identical specifications from one j u r i s d i c t i o n t o a n o t h e r i t s a v e s t i m e , money, and g r e a t l y r e d u c e s the chance f o r m i s c a l c u l a t i o n s . U n i f i e d use o f s t a n d a r d s s i m p l y p r o v i d e s a better market. 2 3  It industry the  i s neither  has been t h e major  above s t a t e m e n t  benefits  accidental  of t h e i r  nor a matter  initiator  demonstrates,  participation  and  of a l t r u i s m  of standards  industry  i s well  initiative.  that the  f o r spas.  As  aware o f t h e  212  Studies/Research A number of e f f o r t s referred  to  unnecessary The  first  other  is a  $41,000 Spa  &  this  will  Tub  on  on  the s t a t e the  preceding  later  organized  section.  University  and  Water  of S o u t h e r n  California  d e s i g n a t e d as the i n s t i t u t i o n s A second the  study  of n o t e  a u s p i c e s of the D i v i s i o n  County, Ca. w i t h a s s i s t a n c e health an  officials.  operator  period  to  2 5  o f one y e a r and  it  spas  influence  described further  also  in  the  studies  Body",  among  will  conduct  on  covering  others.  The  university  redwood  produced  the r e s e a r c h . " 2  a few y e a r s ago  of E n v i r o n m e n t a l  a  to  on  and UCLA have been t e m p o r a r i l y  The s t u d y d e v e l o p e d  install  expertise  have had  Human  conducted  from  the  t o wooden h o t t u b s and  aspects,  who  was  by  of the organism  the  psychological  backed  for  Conference  and  mention.  noted  ISTI h a s p l a n s t o promote  t h e whole a r e a o f "Hot physiological  NSF  is  ( 1 9 7 7 ) . T h i s work,  work so f a r may  of Oregon's o p p o s i t i o n  mention  (ISTI)  the r e l a t i o n s h i p  hot t u b s . R e s u l t s of t h i s  previously  do d e s e r v e  Pseudomonas  Institute  and  been  duplicate  two o t h e r e f f o r t s  study  study  have  and  by an Oregon m i c r o b i o l o g i s t ,  Pseudomonas,  upon  area  chapters  h e r e . However,  International conducted  in  in  H e a l t h i n Alameda and  other  from a p e r m i t h o t t u b . I t was  these  under  immensely  public  r e q u e s t of run f o r a important  results: First,  The  m e a s u r e s were a  conclusion  of  the  t a k e n , a redwood  s a f e and s a n i t a r y  manner."  2 6  study  "showed  that  i f proper  h o t t u b s p a c o u l d be o p e r a t e d  in  213  Second, from  a  the  number of s u g g e s t e d study  elsewhere. minimum Third,  factor  chlorine  residual.  study  places  parameter  levels  for controlling it  was  thorough  instructions  consistent These  efforts  procedures  the  slightly  from  Environmental In  reasonably  considered  the  more  attention  meant t h a t t h e s t u d y , proved  that  knowledgeable quality  ppm  and  important  p r o p e r and  t h e spa c o r r e c t l y , t o conduct over  too  a p e r i o d of  difficult  obtained  even  f r e q u e n t and  sampling  were  and  time.  and t e s t i n g ,  for  operators.  good —  differing  only  the  Division  of  by  sampling. fact  that t h i s  study  on one o f t h e t o u g h e s t  is  was c o n d u c t e d spas  with  stage  of the  guidance  s p a and h e a l t h a u t h o r i t i e s  management. T h e r e f o r e ,  knowledge o f how  this  was  Further,  to  learning i t  i t would process would  and  for a  operate  (a  i t i s surprising  n o t p a i d t o t h i s work. By t h i s ,  a t an e a r l y  operators  effective.  consistent  given  redwood t u b ) w i t h h i g h demands on t h e o p e r a t o r , that  o f 2.5  highly  operators  efforts  results  the  l o n g time  formulated  The m a i n t e n a n c e o f a  bacteriological  considered  Health's of  was  and water a n a l y s i s  operators'  view  maintenance.  that  included  the  on  and  they had the a b i l i t y  normally  Further,  emphasis  could operate  monitoring  others  developed  pathogens.  shown  importantly,  than  i s t h e recommendation  strong  monitoring  Fourth,  more  stringent  interest  conscientious chemical  more  Of s p e c i a l  free the  are  operational guidelines  U.S.  i t  is  experience,  cooperation  from  could handle  spa  seem l o g i c a l  to exploit  was a c h i e v e d seem  and  reasonable  water  why  it  t o pursue  214  additional  similar  efforts  in other  places.  Education Attempts made  to educate both operators  to v a r y i n g  b o t h w i t h i n and materials, product has  run  shows s u c h as  precaution  to  the  the  problems are  maintenance,  due  sponsored  of  printing  available for  front,  NSPI  is  industry,  programs a t  consumer  use.  i n 1981.  safety  2 7  have  80  on  been  percent  knowledge  quoted  NSPI  spa  attempts  operator  been  printed  w h o l e . In b e l i e v i n g t h a t  of  The  specific  education  have  seminars,  i n Long B e a c h , Ca.  held  t o a l a c k of  governmental education  sources.  one  the  Paulick  users  educational  length  on  differing  spa  special  governmental minor  by  NSPI, has  s i g n s which are  relatively spa  outside  and  gone  On  d e g r e e s and  and  of  the  of  proper  subject  of  efforts;  We r e a l i z e that public officials are understaffed and u n d e r b u d g e t e d and so t h e y c a n ' t be depended upon t o g e t t h e information to the owner/operator. T h u s , we r e a l i z e t h e need f o r d e v e l o p i n g i n f o r m a t i o n and d i s s e m i n a t i n g i t t o t h e o w n e r / o p e r a t o r , a l s o p o i n t i n g out t o him that this will i n c r e a s e h i s r e t u r n on h i s i n v e s t m e n t . 2 8  Our  earlier  government  discussion regarding  agencies  i s c o n s i s t e n t with  relatively  modest e f f o r t s  is  from b o t h c o n t i n u i n g  evident  interviews  with  the  by  operators  current  this  constraints  explanation  public health agencies. spa  that  p r o b l e m s and educational  for  on the  However, i t  field  efforts  research are  still  215  deficient. industry  P a r t of to  "do  the  reason  it  all".  important.  One  the  i n v o l v e d i n spa  risks  direction  would  maintenance. sporadic  i s the  without  institutional b e c a u s e our of p e o p l e  educational for  both  may  (where  Seattle  pamphlet Tub".  2 9  is  entitled, Reports  and  are  a second  financial evidence  appears  that  attempts  place. King  on  been  built-in  high  turnover a  result,  procedures  initial  to  published  publishing  rash problems  a  the  consumer  i n Your Spa  8,000 c o p i e s  r e q u i r e d . And  educate  County, Washington  Happy & H e a l t h y  was  proper  b i g g e s t weakness  inadequate  "Staying  &  rapidly  Hot sold  even Vogue M a g a z i n e  in  its  i n spas  and  yet  been  January  1983  hot  3 0  tubs.  Measures  that  incentive  through  recently  t h a t the  or  of this  have  p e r s o n n e l . As  located)  issue a short a r t i c l e  It  the  be  experience.  to take  printing  Other  approach  in  to  educational efforts  operator  lost  of  public  given  must d e a l w i t h a  moved t o warn c o n s u m e r s ,  I n c e n t i v e s and  being  spas  be  beginning  the  i s probably  i t i s noteworthy  are  to n o t i f y  This  u s e r s and  limitation  o t h e r c o n s i d e r a t i o n s may  organized  t r a n s m i t t i n g knowledge and  consumer  has  spa  efforts  However,  out  with  the  P e r h a p s g r e a t e r emphasis  the  any  mechanism.  two  is  attention  secondly, having  this  failure  use.  more  situation  —  But  seeming  spur  And  for  there  has  a c t i o n s taken  of non-monetary  not in  the  i n c e n t i v e s through  U.S.,  any but  type there  of is  praise, recognition,  216  and  cooperation  efforts  seem t o be  Department for  from p u b l i c h e a l t h o f f i c i a l s fairly  in Florida  outstanding  has  also  or  to o f f e r  p o o l s and those  begun a p r o g r a m of a w a r d i n g  has  individuals  been  spas."  And  3 1  who  " t o come  in v i o l a t i o n  assistance in  people  Seminole County  m a i n t e n a n c e of w a t e r q u a l i t y  department's p h i l o s o p h y facilities  s u c c e s s f u l . The  to operators.  the  they  and  the  prevention  on  The  those  S a n i t a r y Code of  work h a r d  operators  hard  problems  b e l i e v e i t i s important  conscientiously  Health  appearance.  down  of  These  to  but with  recognize  to protect p u b l i c  health.  Another interview believes on  type  with that  more  of c o o p e r a t i v e one  municipal  i t i s important  than  just  a  enforcing  r e g u l a t i o n s . Many of  with are  small  resources  or  constraints official, to  when e n c o u n t e r i n g operator  b a s e d on  the  the  i s given  operator Further,  viewed  operator that  t o make c h a n g e s  r a t h e r than  an  on may  general be  business  inability  and  deals  or  time  health  has  found  on  a  staged  priority  the  owner's  financial  and  to s t r e t c h  and  i t successful  all  at  once,  the c o s t s  health officer  over will  management p r a c t i c e s  o v e r l o o k i n g . In t h i s  operator's  He  financial  poorly. This  demand c o m p l i a n c e  the o p p o r t u n i t y  he  pressures,  business  violations,  standards  limited  ignorance,  3 2  an  facilities  facilities  have  where i t i s a p p r o p r i a t e , t h e  suggestions  w h i c h an  of  of m e e t i n g  who  in  in I l l i n o i s .  owners o f  owners of  element of h a z a r d  Thus,  offer  the  people  reasons  capabilities.  time.  level  g e n e r a l l y manage t h e i r  r e q u i r e the  method  for  described  health o f f i c i a l t o work w i t h  simply  business  a p p r o a c h was  instance,  it  to p r o p e r l y maintain  is the  217  facilities  may  be  the  r e s u l t of  making management a d j u s t m e n t s These in  other  e f f o r t s are places.  specifically that  This  been  the  solutions impetus  be  mention  but  be is  merely  applied not  to  to point  out  ones have been t r i e d  l e a s t moderately  public  in  successful.  p o l i c y formation,  s u c h a l t e r n a t i v e s or  that  the  has  originated  h e l p f u l and  i n the  from  i t is  even p o s s i b l y  The  threats  the  serious  users  m a r k e t would l e s s e n sound r e a s o n  to  pursue  water  spas  and  think  public  of  would  spa  the  more  industry  based  on  the  for i f spa to  industry  quality objectives  can  have  be  selfish  action.  water q u a l i t y i s rise  probably decline  industry  with  government  in and  maybe even c o l l a p s e . T h e r e f o r e ,  that  water  industry  undesirable  continue  spa  i n t e r e s t . However, i t  are  i s that  problems  of  the  motivation  reality  for seeking  by  these e f f o r t s  have been a s t r o n g  and  awareness,  spa  that  foremost.  importantly, solved  driving force  from government. E f f o r t s  recognized  intervention  not  their  for  maintenance.  perhaps c o u l d  typical  proven at  to  need  Experience  i s apparent  interests  More  the  in considering  U.S.  generally  should  for  the  ones.  quality lesser  than  to p o s t u l a t e  Summary of It  reason  s p a s and  suggests that  creative  in areas unrelated  i n t e r e s t i n g and  The  other  with  worthwhile  recognizing  recommend t h o s e a p p r o a c h e s ,  methods  conjunction  not  counted  w i t h as much, or  public the  spa  there  is  upon  to  possibly  218  more, e n t h u s i a s m The  properly  only  government  agencies.  dominance o f t h e i n d u s t r y r a i s e s  questions  there  than  though.  The  and a d e q u a t e l y  a  "process  first  informed  of  industry  has a tendency  the  public  wanting  the  reporting  this  disparagements  risks  can  their  and s e r v i c e s  is  normal  concern  about  information  with  d i d not warrant  a weakness e x i s t s  present  question non-users  are  in  to muffle  this  still  safety.  for  operator  The  This raises  reason  of not  In f a i r n e s s  to the  doubts  any  false  alarms  or  void  of  a  Even i f  at a particular might  of having  not  that  t o almost for  stage,  n o t have t h e  It i s  but a l s o  their  substantiated.  areas of hazard.  warning  about  casting  leaves  depend on o p e r a t o r competence and d i s p o s i t i o n and  that  minimize  r e p o r t s about  permitting  ignorance,  the p o s i t i o n  public  or a c t i o n s . For i t i s q u i t e  f o r themselves.  of user and non-user  and  without  b e c a u s e u s e r s and n o n - u s e r s  means o f j u d g i n g t h e h a z a r d s  i.e.i s  question could  downplay,  i n the gray  explicit  --  being  extensive  the reports are well  slander. Regardless,  hazards  an  u s i n g spas.  be  unwarranted  the p u b l i c  serious  study. Yet, i t i s c l e a r  intentions  until  That  f o r the obvious  f o r any g r o u p o r i n d i v i d u a l  products There  on  of t h i s  away from  attitude  of  hazards?  through  to discourage, of  to scare people  industry,  normal  scope  the  standards"?  be a n s w e r e d a u t h o r i t a t i v e l y beyond  couple  i s ; a r e u s e r s and n o n - u s e r s  f o r approved  survey,  a  just  a  u s e r s and  exclusively  their  health  the e x i s t e n c e of a  "process  by i n d u s t r y d o m i n a n c e  concerns  accountability".  second  question raised  219  the  ability  on  the  and r i g h t of t h i s group t o e x e r c i s e  overall  process. There i s l i t t l e ,  from o p e r a t o r s and spa u s e r s a p p a r e n t management  policy  but  without  doubts  the  i f any a t a l l ,  not only  regarding  active  the  involvement  is  so  well-recognized  raises  spa  obvious  the  two  discussion  of  major of  problems h i g h l i g h t s t h i s p o i n t . by  input  effectiveness  of  p a r t i c i p a n t s s h o u l d a l s o be r a i s e d . E a r l i e r management a n d b e h a v i o u r a l  influence  i n the development of  p o l i c i e s and d i r e c t i o n . T h i s  value questions,  such  the If i t  the e x p e r t s that maintenance i s the  overwhelming key t o spa water q u a l i t y s o l u t i o n s , i t would natural  to  place  greater  emphasis  on  the  involvement  o p e r a t o r s and u s e r s i n t h e p o l i c y p r o c e s s or a t l e a s t t o much the  more  e f f o r t and i n s t i t u t i o n a l  learning  and  forefront. This  experience  question  creates  of a " p r o c e s s f o r s o c i a l It  does  specifically education for  seem the  of  s t r u c t u r i n g toward these  evident of  that  the our  the  real possibility "tools  dealing  water  quality  of u n c e r t a i n t y that  technical  and  the health  meeting  U.S. e x p e r i e n c e  to  the  i n t h e U.S.  management  experience  safety  certain criteria  i n C h a p t e r 2. T h e r e i s  hazards  which  established  i s largely ignoring  The  of standards  t h i s t e c h n i c a l approach w i l l  and  (also  policy.  consideration  stated  approach,  regulation  b e c o m i n g o u r o b j e c t i v e s . " By d e s i g n i n g  with  operators the  problems  bringing  participants  the  standards  c r i t i c i s m here r e l a t e s t o our e a r l i e r and  devote  learning".  route  spa  of  c o n c e r n s about t h e a v a i l a b i l i t y  where p o s s i b l e ) , h a s p r e v a i l e d  developing  seem  the  lead  to  a system f o r focuses  on  by t h e e x p e r t s ,  vital  interactive  220  factors  concerned  criticize prove  the u s e r - o p e r a t o r  t h e work w h i c h has  excellent  made t o work long  with  f o r the  taken  p l a c e --  s h o r t t e r m . The  i n the c u r r e n t c o n t e x t  of  Spa The within spa  state  users  and  (and  these  and  policy  have  those  any  provisions only  epidemic started,  takes of  i s not  to  very  well  i s ; can  i t be  design  for  the  serious deficiency  truly  spa  standards  in  providing  information  Interviews  type  t o be  have  with  and  been not  are  operators  self-serving  spa  subject  i n t h e U.S.  spas,  i s very  amongst t h e p o p u l a t i o n a t  H e r p e s and  the  to  public  to industry.  toward  to  but  always c o n s i s t e n t  operation  difficult  guidance.  helpful,  always  for externalities  be  necessary  of a u t h o r i t a t i v e  efforts  poorly-managed  disease  with  b a s e of  of o r g a n i z e d p o l i c y  to account  one  of  b e c a u s e o p e r a t o r s , u s e r s , and  efforts  form  Effective?  is a failing  diffused  industry  t o Make  absence  initiatives  been  t h e p r o b l e m may  experiences  No  wanted t h i s  questions  Without  complete  reducing hazards.  Further,  credibility  More  jurisdictions  other p r i v a t e  efforts  suspect  or  operators) a s o l i d  t h a t they  themselves.  It  local  e v a l u a t i n g and  Industry  of  may  question  Experience  Management S a f e r and  inconsistency  indicated  may  it  This  term?  What I s M i s s i n g From t h e U.S.  for  sphere.  the  lack  disturbing.  to  start  large,  and  contain  as  an once  recent  AIDS d i s e a s e have shown. T h i s i s a situation  representative process  for  with public  spas.  decision-making  with  221  spas  has  y e t been u n d e r t a k e n .  few  local  has  allowed  rarely  areas  (and  this  f o r user  been  d o m i n a t e d by  i s q u e s t i o n a b l e ) , no  or p u b l i c  involved. the p u b l i c  T h e r e does not a p p e a r consistent  w i t h our  Little,  if  t o be  any,  the  what a r e  r i s k s and  experts  intuitively  educational have  instructions training  their  In criteria ecause  spa  are  because  brief,  and  devising  learning  need as  of  sectors. standards"  no  real  an  have  identified most  been  efforts, more or  for  environment  because  of  significance  has  minor they  providing  effort  with  and  directed  where on  no  spa  operator  f o r s c a t t e r e d and  dealing  and  non-existent  of  indicators  for  incentives  clearly  has  focused little  studies  Although,  private  risk  process  toward  users,  or  spa  hazard  for a  social  factors  listed  been a t t a c h e d  to  yet.  t h e U.S.  experience  f o r spa p o l i c y policy  and  No  importance  except  with  warnings  operators,  and  problem  or  Positive  been  been p a i d t o m e a s u r e s f o r  safety, l i t t l e  have  problems.  above  spa  the  undertaken,  process  has  of h a z a r d s  recognize  the  a  learning  extent  to o v e r a l l  installing  have  have  interest  i n spa management.  programs. P u b l i c  been  process  operators  f o r approved  what a r e u n c e r t a i n t i e s .  with  and  decisions  industry  "process  attention  examined  dealing  any  all  decision  criterion.  really  at  far,  h e a l t h and  with u n c e r t a i n t i e s  behaviour  participation,  Thus  dealing  user  W i t h t h e p o s s i b l e e x c e p t i o n of a  has  not  fails  design. This  to  i s not  meet  all  surprising,  been g i v e n a d e q u a t e a t t e n t i o n  of  our  though, overall.  222  Footnotes  Spa  - Appendix D  ' " M a n u f a c t u r e r s C o u n c i l T a k e s S t a n d on NSF News, F e b r u a r y 22, 1982, pp. 8 & 108. 2  Skin 36.  Nancy I r a n P h i l l i p s , "Hot Water I n d u s t r y Rash P r o b l e m s , " Swimming P o o l Age, A p r i l ,  Issues,"  Pool &  P u l l s T o g e t h e r on 1982, p p . 11 &  A l l e n V. Kneese and C h a r l e s L . S c h u l t z e , P o l l u t i o n , P r i c e s , and P u b l i c P o l i c y Resources f o r t h e F u t u r e and The B r o o k i n g s Institution, (Washington, D.C: The B r o o k i n g s Institution), 1975, p . 7. 3  "Interview  with  interview Department, J u l y 6  Interview  Dave A n t o n a c c i ,  with Roy 12, 1982.  with  op. c i t .  Dzieranowski,  Cook  County  Health  D a n i e l T a r r y , op. c i t .  ' N a t i o n a l Spa & P o o l Institute, "Minimum P u b l i c Spas & Hot T u b s , " W a s h i n g t o n , D . C , 1978.  Standards  for  U.S. Department of H e a l t h a n d Human S e r v i c e s , S u g g e s t e d H e a l t h a n d S a f e t y G u i d e l i n e s f o r P u b l i c Spas and Hot T u b s , Public Health S e r v i c e , Centers f o r Disease Control, Atlanta, Ga., A p r i l 1981. 8  Illinois, Minimum S a n i t a r y R e q u i r e m e n t s f o r t h e D e s i g n and O p e r a t i o n o f Swimming P o o l s and B a t h i n g B e a c h e s , Department of Public Health, Division o f Swimming, Pools and R e c r e a t i o n , S p r i n g f i e l d , I l l i n o i s , F e b r u a r y 1976. ( N o t e : these regulations have been r e v i s e d somewhat s i n c e t h a t t i m e , b u t p u b l i s h e d c o p i e s are not a v a i l a b l e . ) 9  1 0  Interview  with  Roy D z i e r a n o w s k i ,  op. c i t .  letter from Daniel Tarry, Enironmental V i l l a g e o f A r l i n g t o n H e i g h t s , A u g u s t 3, 1982. 1 1  1 2  1982,  John Frantz, p . 128.  "Midwest  News,"  Pool  Health  Officer,  & Spa News,  F e b . 8,  City o f C h i c a g o , P r o p o s e d P u b l i c Spa Code, R e v i s e d M a r c h 8, 1982, P e r r y M e i k l e , J a c u z z i W h i r l p o o l B a t h , W a l n u t C r e e k , C a . 1 3  '""Florida p. 86. 15  1982,  News,"  Pool  "IAPMO, ICBO Agree p p . 1 and 114.  & Spa News,  on  September  Code", P o o l  21,  1981,  & Spa News, A p r i l  5,  223  1 6  Ibid  "UL Looks a t Spa S a f e t y H a z a r d s " , 1982, pp. 40 & 42. 17  5,  Pool  & Spa News,  April  Jorian Clair, "Spa H e a l t h Code A c t i o n P l a n n e d ; ISTI t o Meet w i t h NSF i n O c t o b e r " , P o o l & Spa News, September 21, 1981, p. 98. 1 8  1 9  2 0  Ibid Nancy  Iran P h i l l i p s ,  op. c i t .  Jorian Clair, "Spa H e a l t h Code A c t i o n P l a n n e d ; Meet w i t h NSF i n O c t o b e r " , op. c i t .  ISTI t o  2 1  "New Awareness Shown F o r P o o l / S p a Safety News, J a n u a r y 25, 1982, pp. 146 & 148. 22  Spa  2 3  2  Pool  " " I S T I B a c k s Pseudomonas S t u d y ; C a u s e s , P r e v e n t i o n & Spa News, F e b r u a r y 9, 1981, pp. 1 & 148.  J o u r n a l of E n v i r o n m e n t a l 189-193.  2 6  Ibid  Health,  "Spa Spectacular Attracts 13,000 News, A u g u s t 17, 1981, pp. 8 & 96. Nancy  Iran P h i l l i p s ,  Seattle - King County W a s h i n g t o n , M a r c h , 1981.  23,  Vogue M a g a z i n e , J a n u a r y ,  H e l e n Donigan, 1981, p . 14.  3 1  January/February,  1979,  Consumers,"  & Spa  Pool  op. c i t . , pp. 11 & 36.  2 9  3 0  Sought,"  , p . 192.  2 7  2 8  Pool &  Ibid  2 5  pp.  Needs",  Dept. of P u b l i c  Health,  Seattle,  1983, p . 84.  " I n d u s t r y News," P o o l  & Spa News,  February  224  APPENDIX E The  B.C. H e a l t h  A c t And I t s P r o v i s i o n s  f o r Spas  The following s p e c i a l provisions f o r therapeutic pools are c o n t a i n e d i n t h e B.C. H e a l t h A c t i n t h e s e c t i o n s pertaining to regulation of p u b l i c swimming p o o l s , s p r a y p o o l s , a n d wading pools. Part  IX--Therapeutic  Pools  84. ( a ) P a r t s X a n d XI o f t h e s e r e g u l a t i o n s s h a l l not apply to therapeutic pools. (b) P r o v i s i o n s of P a r t IX o f t h e s e r e g u l a t i o n s s h a l l govern the c o n s t r u c t i o n , o p e r a t i o n , and maintenance of the therapeutic pool, notwithstanding any conflicting p r o v i s i o n s elsewhere i n these r e g u l a t i o n s . 85. The r e c i r c u l a t i o n r a t e t h r o u g h the f i l t e r system shall be s u f f i c i e n t t o p a s s t h e e n t i r e volume o f t h e p o o l i n one hour o r l e s s . 86. I f a t h e r a p e u t i c pool i s o p e r a t e d \as a health establishment, t h e manager shall be r e s p o n s i b l e f o r t h e continuous supervision of bathers. At a l l other establishments where a therapeutic pool i s operated, the manager may be r e q u i r e d by t h e M e d i c a l Health Officer to employ a person t o be responsible f o r the continuous s u p e r v i s i o n of bathers. 87. S e a t s and b e n c h e s s h a l l have a n o n s l i p s u r f a c e and t h e edges s h a l l be marked i n a c o n t r a s t i n g c o l o u r . 88. Pool walls shall have a smooth finish to f a c i l i t a t e cleaning. 89. A maximum v e l o c i t y o f w a t e r t h r o u g h t h e d r a i n s of any o f t h e r e c i r c u l a t i o n s y s t e m s s h a l l be 1 1/2 f e e t p e r second. 90. A minimum o f one t o i l e t a n d one shower shall be p r o v i d e d c o n v e n i e n t l y near the p o o l f o r each s e x . 91. P o o l s l e s s t h a n 100 s q u a r e f e e t i n a r e a may have a r e d u c e d walkway w i d t h o f 2 f e e t f o r up t o 75 p e r c e n t o f t h e p o o l p e r i m e t e r . The a c c e s s t o t h e p o o l shall be from a walkway 4 f e e t o r g r e a t e r i n w i d t h . 92. A clearly v i s i b l e n o t i c e o r w a r n i n g s i g n s h a l l be posted at a l l entrances to the pool, stating such d i r e c t i o n s necessary f o r the safety of the patrons. 93. A clock of s u f f i c i e n t size a n d d e s i g n s h a l l be l o c a t e d t o be seen by t h o s e i n t h e p o o l . 1  In a d d i t i o n t o limit  of  have  been  agenc i e s .  104°F given  these  is to  provisions,  a  maximum  now recommended a n d n o t i c e s spa  facilities  by  temperature  to this  appropriate  effect health  225  An  examination  following  of  the  above  weaknesses i n e x i s t i n g  (a) S e c t i o n 85 a d d r e s s e s systems.  However,  r a t e may  be  turnover  rate  of  of  the  guidelines recommend address  The  every  (b) S e c t i o n 86  guidelines  15 m i n u t e s .  spa f i l t r a t i o n  i s a helpful  cleaning  guideline  of hyperthermia  provision  i s adhered  officials.  However, i t assumes t h a t  adequately  and  Pool  (c)  section  S e c t i o n 87 reduce  trained  cleaned  f a i l s to  such  as  filters.  drowning  to  spa  assist  the  i n regard to  hazards  if  facility  bathers  health  personnel  and  such  this  to  take  assurance,  i s c o n s i d e r a b l y weakened. is  a  typical  (d) S e c t i o n 88 a p p e a r s  and  Association  matters of  a  proposed  t o by o p e r a t o r s and e n f o r c e d by  a c c i d e n t s caused  sanitation.  turnover  This section  a p p r o p r i a t e measures i f n e c e s s a r y . Without this  filtration  the  particularly  prevention  are  the  recommend  and  Swimming  and r e q u i r e d  spa  o f a one h o u r  minutes,  Canadian  important  types of f i l t e r s  improved  CDC  30  a r a t e of every  other  for  requirement  inadequate.  reveals  spa p o l i c y :  t h e need the  provisions  safety  by v i s u a l  t o be a  provision  w h i c h may  hazards.  provision  designed  However, i f s p a s a r e n o t r e q u i r e d at  periodic  help  intervals,  this  to  improve  t o be d r a i n e d section  is  meaningless. (e) S e c t i o n 89 drowning  appears  hazards  to  from  water  i s o n l y one p a r t  other  outlet  openings  be  a  provision  i n t e n d e d t o reduce  e n t r a p m e n t . However, t h e of the problem. and t h e t y p e  The s i z e  of o u t l e t  velocity  of  o f d r a i n and  grate covers i s  226  equally  important  especially  p r o n e t o p u t t i n g p a r t s of (f)  S e c t i o n s 90 protection  & 91  weakness of  are  separate  required; limit  of  (1)  Health  specific  with  heart  Act's  and  judgement.  directions  inconsistent  to s p e c i f y  be  i n a spa  be  two  that  observed not  Another operator  posts his  the  that  advised  problems should  upon  with  demonstrated indicated  facility  what  Interviews  users  from t h e  a  and  use  a  was  spa  aware  he  knew of  no  a  number  of  knowledge  v a g u e n e s s of S e c t i o n 92  p r a c t i c e s f o l l o w e d by  exists  appropriate  in  informing  behaviour.  regard  relies  upon t h e  inspectors  special  precautions advised  experts,  the  or  operators  and  users  of  discretion  operators. in other  vagueness  of  of  92  and  spa  policy  either  local  the  jurisdictions Section  the  hazards  of  In l i g h t  and  that a serious  It appears that e x i s t i n g  health  most  failing  operator  based  safety  spas.  facilities  2  are  3  i s evident  weakness  h e a l t h and  posted.  that  who  openings.  g e n e r a l p r o v i s i o n , but  r e q u i r e d warnings. His  warnings  It  added  be  10 m i n u t e s  a physician's approval.  the  this  should  p r o v i s i o n . One  individuals  of  in  of  this  maximum t i m e  without  provide  of c h i l d r e n  into  a s s o c i a t e d with  directions  operators  (2)  bodies  i s u n n e c e s s a r i l y vague by  w a r n i n g s and  warnings  their  not  from h a z a r d s  (g) S e c t i o n 92  two  do  i n the case  numerous and  by  i s a serious  deficiency. (h) S e c t i o n 93 of  spa  use.  provides  u s e r s a means f o r j u d g i n g  However, no  p r o v i s i o n s are  made  their for  duration providing  227  means  for  users  temperature, In in  B.C.  disinfectant  are  other  levels,  and  scientific  recommended  drowning,  and  provisions  hazards,  presence.  therapeutic i n view  one  as  pools  of c u r r e n t  e x c e p t i o n i s the limit. only  related  Visual, to a minor  to spas,  are  addressed.  present  legislative  set-up  it  only  is  not  be q u i t e  parameter  inadequate  d a n g e r o u s t o do  requirements  major  potential  technical hazard  One  maintained  expected  is  nature  allow  chlorine of  insufficient  spa for  repeatedly pointed  out,  spas  like  pools —  of  i t can  specific  Health Act underscore  scientific  that  weaknesses  water  public  has  in  emerged  key  some o f the  four  from  the  disinfection more  residual  proved spas.  were  variable  this  guideline changes  be  basis  originally  bank c a p a b l e o f  The  Where  must  consistent  for pool chlorination  in pools. has  of  h i g h e r and  for a free  demand  which  levels  on a s i g n i f i c a n t l y  to  study  so. Examination  factors  with p o o l s . Standards  designed  l e a v e s our  of pathogens -  of the c r i t i c a l  experience  As  to treat  i n t h e B.C. and  i n B.C.  areas.  Disinfection/control  than  The  specifically  v u l n e r a b l e to problems.  U.S.  for  are addressed  jurisdiction  the  such  or b a c t e r i a l  temperature  hazards as  conditions,  vague  knowledge.  maximum  hyperthermia  Pathogenic  The  also  pH,  i n a c c u r a t e , i n c o m p l e t e , and  recently  not  judge  summary, t h e e x i s t i n g  technical  degree.  to  meeting  and  volatile  t o be  terribly  and  resultant  228  pathogenic  hazards  disinfection surprising chlorine the  capability  and  bromine  importance  of  destroy  microorganisms.  Under  the  in their  of  encourages  poor  application  o f swimming p o o l  spa  jurisdictions,  chemical  residuals  feeders.  by  The  one  superchlorination, Act  —  this  The  there  i s a very  crucial  0.5  s i n c e these  Further, initially  ppm,  levels  does n o t g i v e as bather  default,  up an  load  actually  advantage  a r e r e q u i r e d t o have  of  the  t o many  automatic  f e e d e r s a r e c a p a b l e of  they  unless  as  i n B.C., compared  monitored  levels  to  nourishes  higher  particularly  they  sufficient  use  specifically  low  o f 1.0 ppm  standards  i s t h a t spas  maintained.  that  i n B.C., o p e r a t o r s a r e  b r e a k i n g down o r o p e r a t i n g i m p r o p e r l y , and  suggest  each bather  as  standard,  management.  However,  now  d o e s recommend  the l e v e l  this  bromination  instructions.  of s a f e t y f o r spas, use  higher  and s t r e s s e d  Co. has  r e g u l a t i o n s here  chlorine  in  i s not  much  otherwise  Biochemical  user  However, even  margin  after  it  and  experts  which  h e a l t h department  i n c r e a s e s . The  U.S.  of  let-down  Thus,  chlorination  be t a k e n  Lakes  current pool  1.0 ppm.  adequate  dangerous.  material  to maintain  although  a temporary  ( a s h i g h as 3.0 ppm)  number  procedures  Great  change  levels  a  organic  allowed  be  automatic  Further,  superchlorination  made t h i s  can  occur,  t h a t many U.S. e x p e r t s have recommended  equipment.  to  c a n so r a p i d l y  must be will  periodically not  maintain  a d j u s t e d t o do s o . As f o r  i s no m e n t i o n o f i t i n t h e  B.C.  Health  serious deficiency.  chemical  parameter  of  pH has a l s o n o t been  229  appropriately  addressed  B.C. o p e r a t o r s similar  to  must  the  B.C. o p e r a t o r s  within  maintain  a  U.S. " i d e a l "  are  allowed  to  above  it  efficacy this  understood  Again,  chlorine  with  the  capability  at this  especially  as bather  operators  i n B.C. t e c h n i c a l l y  l e v e l s and s t i l l conceivably chlorine  may  Furthermore, increase. create  as pH  Scale  properly  and  the  supply  Water C l a r i t y  To  scaling  equipment  make  —  insufficient,  the  point,  levels,  as  a  chlorinators.  equipment  but  of d i s i n f e c t a n t  could  but  as  scale to  also  g r o w t h and  filters,  these  the  bactericide.  calcification  If  lead  spa  h i g h pH  t h e s p a water  and  such  the  than  items  pumps, a r e not  build-up  will  not  reduced  flow  and  p r o v i d e d by a u t o m a t i c  feeders.  -  With t h i s  as  o f pH i s l i k e l y  ineffective  and f r e q u e n t l y c l e a n e d ,  inadequate  spas  automatic  damage  higher  s e r v e a s a medium f o r o r g a n i s m in  levels  disinfection  c o u l d run a t r i d i c u l o u s l y  virtually  can  At  the r a t e of d i s i n f e c t i o n  to the standards  increases  considered  spas.  show a c c e p t a b l e c h l o r i n e  calcification  heaters,  only  be  and  roughly  However,  7.8, a l e v e l  that chlorine  of spas,  load increases.  be c l e a r ,  7.2-7.6.  of 1.0 ppm a t pH  allowable level  conform  7.4  The H e a l t h A c t c o m p e n s a t e s f o r  levels case  of  pools  i s c o n s i d e r a b l y reduced.  by r e q u i r i n g  7.8."  well  standards.  of a t l e a s t  exceed  i n t h e U.S. f o r b o t h is  level  range  unacceptable 7.8,  existing  concern,  the a p p l i c a t i o n  of  the  Health  Act  to  i s a l s o d e t r i m e n t a l . The c h e m i c a l - d i s i n f e c t a n t p a r a m e t e r s ,  indicated  above, would  eventually  hinder  clarity.  Another  230  important  factor  is  filtration  that  rate  of one  experts  affected  is filtration.  equipment  h o u r . T h i s may  have a d v i s e d  be  15 m i n u t e s .  I f so,  system  as p i p i n g , i n l e t s ,  be  strict  requirement  f o r a maximum for  turnover as  some  a s a maximum of once  every  e t c . would a l s o have  to  a d j u s t e d a c c o r d i n g l y . Backwashing or c l e a n i n g requirements  of  media  believe  that  only  sand  should  water.  the  The  examined. F u r t h e r ,  earth  cartridge  finer  or  particles  Health  Act  and  allows  spas  the  requires  proper  from  periodic  use  of  Despite  experts  do  clarity  and  B.C.  not  time  this  now  filters,as  to e a r l i e r  total  with  disregarded  is  spa  do  the  mention  of  standards.  highly  factor  i n the  recommended d r a i n a g e  factor  in  dissolved solids  how  rigorously  regulations suffer  to user and  recommends a maximum l i m i t  determine  Moreover, c u r r e n t as  sand  of  in for  Health  intervals,  important  to  -  Although  t h e U.S.  over  that  disinfection.  Hyperthermia  did  that  and  d r a i n i n g as a c r i t i c a l  i s completely  controversy  concur  b u i l d - u p of spa  spas  experts  f i l t e r s are capable  i n d u s t r y involvement  eventual  management. T h i s  for  some  amounts of o i l p r e s e n t  c o d e s . T h i s p o s s i b l e weakness r e f e r s  Finally,  study  be  i s inadequate  a weakness r e s u l t i n g  Act.  outlets,  filtration  diatamaceous  capturing  U.S.  also  involving  spas,  the  such  factors  current  t h e h y d r a u l i c s of  filter  for  sized  inadequate  r a t e s as  other  be  The  a w a r e n e s s of  temperature,  and  the  risks, other  this  of is  104°F,  this  enforced.  same d r a w b a c k s f a c e d i n individual  thresholds  u n c e r t a i n t i e s . Though  this  231  hazard the  has  been a d d r e s s e d  current  from  o b v i o u s and  is  the  a b s e n c e of  and  o u t l e t covers  included  i n spa  Monitoring  and  to those  used  once  year  operation  most  requirements  Eduational and  still  weaknesses i n  as  s y s t e m , and  a  i t may  of  spa  facility  of  From  interviews  a  items  policy drain  should  be  criteria.  r e g u l a t i o n s are is  procedure  inspected for issuance  with  health  i n some j u r i s d i c t i o n s f e a t u r e of  as  the  s e r v i n g t o overcome  at  least  of  annual  existing of  and  conducted  o f t e n as  some  similar  official  that p e r i o d i c i n s p e c t i o n s are  positive be  These  installation  part  much more f r e q u e n t l y ,  in e x i s t i n g  f o r s p e c i a l l y - d e s i g n e d spa  enforcement  appears  is  weakness  Efforts  f o r p o o l s . Each  it  This  important  (i.e. anti-vortex).  permits.  operators,  week.  are  entrapment  c o n s t r u c t i o n and  Monitoring  a  there  policies.  Drowning hazards The  i n B.C.,  once  a  management the  policy  deficiencies.  Educational toward pool  efforts  operation.  well-written  booklet  primarily  The  for  operators,  Operator's Guide".  educational  materials spa  public  spa  about  to  be  M i n i s t r y of H e a l t h  Swimming P o o l  concerned with  seem  on  This  programs  management or hazards,  5  with  has  published  entitled  study  did  which  spa  find  any  specifically  users use  a  "Commercial  not  were  educating  recommended  d i r e c t e d only  and  behaviour,  the or  232  necessary  special  precautions.  Through comparison elsewhere  in  Canada  existing  provincial  considerations  t h a t use  deficient  —  may it are  simply  recommending the  t h a t the  far afield  can  cannot  be  a matter  effect,  t h e more  "best"  spa  of  of  The  difficult, operators.  quality.  greater  possibilities  The  The  i n the  The  spas of  increase serious  from t h e U.S.  spas  is  "splitting  under  above  hairs"  flagrantly  obstacles  in  for  public  hazards.  disease  be  may  point  remain i n alter  and  the  lessened  achieving health  and  or death  should  this  If e x i s t i n g  numbers  Act  inappropriate  to  resistance  concern,  experience  be  yet  knowledge.  policies  will  of  Experts  Health  scientific  these  or  parameters, B.C.  to  seriously  standards.  the  and  it  subject to p o t e n t i a l  and  of  Increased  water  Of  for  these  too,  become r e a l  arouse  shown.  water q u a l i t y  longer  t o change may  Lessons  formed  weaknesses  h a z a r d o u s t o p u b l i c h e a l t h --  ability  continue  regulations  unnecessarily high  application  overstated.  unnecessarily  be  Act  requirements  is potentially  behaviour  other  from c u r r e n t t e c h n i c a l  continued  policies  U.S.,  the  policy  and n o t  i s obvious  and  of t h e H e a l t h  d i s a g r e e about  The  and  standards  o n l y d e s c r i b e the major ones. I t i s important  understand  some e x p e r t s  t o spa  may  spa be  policies  usage,  the  also increase.  c o n v i n c i n g enough  to  concern.  I m p o r t a n c e of P u b l i c Awareness About  present  situation  is deficient  and  Spa  Hazards  public values  are  233  poorly  represented  management  and  s t a n d a r d s and already  been  Until  an  a  as  awareness  "herpes  scare"  stilled  by  experts,  that of  report  subsequent  spa  newscast. Ubyssey. prank", being  In  8  this  claimed  closed  fairly  a  about  local  herpes.  editor  revealed.  laxity  that  beseiged  an the  article, UBC  tend with  were q u i t e  in  a  s e r i o u s and  This hot  the  being  with  a  develop public  refers  tubs  health  extent two  November  Centre  a  as  "cry wolf" real  initially  subsequent though, syndrome  dozen the  issue  which  of  "college was  ruse  was  believed  the  letters  false  p o t e n t i a l hazards.  that  ( p o o l & spa)  a herpes e p i d e m i c . A l t h o u g h the  upset,  was  after  as  to  being  and  over  is by  report  to the  intended  Aquatic  More i m p o r t a n t ,  to c r e a t e  the  immediately  occurred  as  exemplified  1982.  a t t e n t i o n --  hours  have  will  medical  soon u n c o v e r e d , a number of p e o p l e and  these  case,  in  from  pool  Act  policy  public  Although  6  spa  spas.  media a b o u t  statements  example  b e c a u s e of  reports  Health  s p a s , as  which o c c u r r e d  few  Another  7  to  about  swimming  hazards. Instead,  raised significant  within  of  B.C.  general  news d i r e c t o r of CFOX R a d i o was  calls  i n the  the  information  transmitting  it  awareness use  inappropriate  w h i c h were made i n t h e for  current  contained  i t i s doubtful  sources  the  The  public  government a c k n o w l e d g e s c u r r e n t  to misleading  reports  l a c k of  hazards.  identified  accurate  subject  to  regulations  the  deficient,  due  reports may  to such lead  the as to  234  Footnotes  - Appendix  E  B.C. H e a l t h A c t , B.C. Reg. 289/72, December 1, 1972, "Swimming-Pool, S p r a y P o o l , and W a d i n g - P o o l R e g u l a t i o n s " , p. 14. 1  2  Club,  I n t e r v i e w with Lorenzo Lepore, B u r n a b y , March 21, 1983.  I n t e r v i e w with March 21, 1983. 3  Jim  Manager,  Bremner, D i r e c t o r  ""B.C. H e a l t h Act," B.C. p. 13. (At pH h i g h e r t h a n 7.8, must be at 1.0 ppm, free b r o m i n e l e v e l s must be a t 1.5  Brentwood  U.B.C. A q u a t i c  Racquet Centre,  Reg. 289/72, December 1, 1972, free available chlorine levels available c y a n u r a t e c h l o r i n e and ppm.)  British Columbia, "Commercial Swimming Pool Operator's Guide," Ministry of Health, Division of Environmental Engineering, V i c t o r i a , B.C. 5  6  CFOX Radio,  m o r n i n g n e w s c a s t , V a n c o u v e r , B.C.,  September  9,  1982. ' I n t e r v i e w w i t h G a r y M a r s h a l l , News V a n c o u v e r , B.C., September 9, 1982. 8  B.C.,  Director,  The U b y s s e y , University of B r i t i s h November 16, 1982, pp. 1 and 3.  CFOX  Columbia,  Radio,  Vancouver,  235  APPENDIX F  A Sample Spa A  Operator  5-day p r o g r a m c o u l d  Training  be  established  to  spa  Program with  this  outline  as  their benefits  and  follows:  Day  1:  Introduction  operations;  problems a)  Therapeutic/recreational  benefits  and  public  health  protection b)  Day  2:  Equipment  and  facility  Water C h e m i s t r y and  a)  Water b a l a n c e and  b)  Disinfection  the  operation  and  maintenance.  Disinfection e f f e c t s of  procedures  and  various  parameters.  relationships  to  other  parameters.  Day  3:  Spa  Water Q u a l i t y  Management  a)  observing  b)  drawing  c)  a n t i c i p a t i n g problems  d)  methods f o r a d j u s t m e n t s and  Day  4:  p a r a m e t e r s and  variables;  r e l a t i o n s h i p s from  Dealing  with  a)  t r a i n i n g of  b)  modifying  c)  safety  and  t e s t i n g and  management  user  monitoring  observation  evaluating  corrections  Others  spa  spa  Skills  personnel  behaviour  emergency p r e p a r a t i o n s  and  procedures  236  Day  5: Designing Spa Operation  a) general  Plans  requirements  b) c r e a t i n g a l t e r n a t i v e s and developing plans c) d e t e c t i n g  needs  f o r adjustments  and  i n c o r p o r a t i n g the  changes.  Certainly,  this  program  could  be  m o d i f i e d or made more  e x t e n s i v e , but i t r e p r e s e n t s the b a s i c areas which we would want to  cover with o p e r a t o r s . Advanced and r e f r e s h e r  be  devised  i f the  need  and  programs  demand developed.  Such programs  should be c a r r i e d out at a c t u a l spa f a c i l i t i e s and fees should be charged Specifically,  could  registration  t o cover c o s t s .  we  want  to  provide  an  understandable  framework f o r o p e r a t o r s ; With P u b l i c h e a l t h : the importance  of sound spa  management  and  r a t i o n a l e s f o r standards With equipment:  i t s i n t e r r e l a t e d n e s s to spa water q u a l i t y and  subsequent s a f e t y / h e a l t h concerns. With water chemistry and d i s i n f e c t i o n : a) Teach o p e r a t o r s quality  to  conditions;  first  understand  their  initial  water  i . e . , t h e i r water supply and i t s parameter  components of pH, t o t a l a l k a l i n i t y ,  hardness,  trace  elements,  etc. b)  Teach  first  o p e r a t o r s how to a d j u s t the l e a s t v a r i a b l e parameters and  how  to  elements(e.g.copper,iron).  eliminate  undesired  chemical  237  c)  Teach  operators  disinfectant  how  t o f o c u s on t h e t h r e e  levels, clarity,  and t e m p e r a t u r e .  main  f a c t o r s of  Use a s g u i d e s t h e  following: 1) c h l o r i n e high  o r bromine  load  spas:  free r e s i d u a l / d i s i n f e c t i o n  3.0 ppm  med. t o low l o a d  spas:  1.5 ppm  pH f o r b o t h : 7.2-7.6 superchlorination: high low  load load  pathogenic  - 10 ppm d a i l y a f t e r s p a shut-down -  5 ppm d a i l y a f t e r  control:  Pseudomonas  s p a shut-down should  be  used  as  an  indicator.  2) w a t e r high low  load load  Total high  clarity - l e s s than  .5  - .5 t o 1.0  (JTU's)  Dissolved load  (JTU's)  Solids:  - replace - 2/3 when  1/3 o f water when 500 ppm 1000 ppm  - a l l w a t e r when low  3)  load  i s reached  i s reached  1500 ppm  i s reached  - replace  1/2 o f water when  - replace  a l l water when  1000 ppm  1500 ppm  i s reached  i s reached  temperature high low  load load  - m a i n t a i n temperature  a t 102°F o r l e s s  - m a i n t a i n temperature  a t 104°F o r l e s s  238  The proper to  above  levels  account  uses  f o r the  shown these  for other  initial  encouraged  and  to  B.  The  should  important  carefully and  It  bather  be  and  also  flexible  provide  (3) methods s h o u l d  be  and  the  (1)  as  that  operators and  less variable  a general  effects  taught  such  v a r y i n g them,  h a r d n e s s ) on  c h a n g e s and  and  L o c a l a c t o r s might  to maintain  alkalinity,  to  tries  loads  p o i n t s , though., a r e ;  taught  the  points.  spa  ( w i t h i n reason) with  monitor  o p i n i o n as  o p e r a t i o n a l methods,  should  be  (e.g. t o t a l  main a r e a s ,  starting  standards  p a r a m e t e r s and  to experiment  parameters  person  parameters.  initial  guidelines  operators  u s e d as  recommended  different  i n Appendix  reflect  t w o - t i e r e d d i f f e r e n c e of  conservative  guidelines  merely  w h i c h m i g h t be  want t o a d o p t  (2)  guidelines  for  of  basis  the  three  handling  the  most v a r i a b l e c o n d i t i o n s . d)  Operators  should  then  external  effects  on  bathers,  types  bathers,  These a g a i n  should  W i t h Management This  area  from the  first  context  of  levels  appear  increase  of  the  spa  be  be  taught  water the  related  how  to observe  quality;  environment t o our  such  and as  associate number  o u t s i d e the  t h r e e main  spa,  of etc.  factors.  Skills of  training  two  should  d a y s , and  practical  perhaps to decrease  the  this  should  considerations,  inadequate, dosage  then  i n t e g r a t e the  until  the  operator  the  dosage  e.g.,  l e a r n i n g process  be p l a c e d if  should  into  the  disinfectant incrementally  p r o b l e m s seem r e c t i f i e d  incrementally in order  to  —  then learn  239  the  proper  range  With D e a l i n g Spa people  with  Others  operators  should  i n v o l v e d i n the  management people.  of  spa  behaviour  and  should  be  water  would  Spa  attempt  pull  learning.  Spa  operators  should  reducing  uncertainty  operators  a plan  for approval, plans  encouraged their  to  facilities  how  references, should  be  of  can  b e h a v i o u r a l and to  should  and  the  The  be  and  then  u s e d as  and  patrons.  technical obtain  or  monitoring how  these  other  be  s e c t i o n of  previous  aware  of  with  be  e x a m p l e s ; and and  Plans  design should  d a y s of  h i g h l i g h t e d and importance  surprises.  on  It  of  should  included in  alternatives.  operators  should  be  plans appropriate be  devised using  consultative  arrangements. F i n a l l y , h i s p l a n as  training  four  the  s t i m u l a t e thought  professional  t o use  and  prepared  p e r s p e c t i v e s . I d e a s c o u l d be  to  taught  good  cooperative  f e a t u r e s w h i c h must be  think c r e a t i v e l y  or  behaviour  also  final  the  dealing  basic  other  emergencies.  Plans  keenly  on  achieving  management u n c e r t a i n t i e s s h o u l d  inform  Existing  of  for  Operators  together  be made  control  i s dependent  methods  Operation  to d e a l with  that  characterization  taught.  to  thow  and  quality  practical be  taugh  system  have p r o v i s i o n s f o r h a n d l i n g  With Designing  as  spa  Theoretical  motivations  and  for his operation.  a guide  the  to  both  suggested services, operator  for operation  —  240  i.e.,  using  operator the  i t in c o o r d i n a t i o n with  would want t o u n d e r s t a n d  plan  and  submitted  then  t o the  Overall, and even  ideally fun,  atmosphere  we  how  t o make  for  so  as  to  create  w h i c h h o p e f u l l y would toward  as  point,  starting  spa  this a  format  i n an  problems  with  should  could the  for  be  and  the  then health  operators  interesting,  operator  operation. Using  remainder of o p e r a t i o n a l m a t t e r s with  the  Changes  willing  foster  operators  Thus,  approval.  a general  would want t o p r e s e n t  way  to evaluate  adjustments.  want t o p r o v i d e  conscientiousness a  how  h e a l t h department  we  implementation.  and  cooperative  creativity basic  and  format  negotiate department.  the  241  APPENDIX G  A Sample  Safe & Healthy 1 23  S.  x 25  m.  10  Centre  racquetball/squash  swimming p o o l ,  exercise  and  weight  restaurant,  snack bar,  Membership  information:  $100.00; c o u r t  time,  H o u r s of O p e r a t i o n : a.m.-9:00 p.m.;  Description separate are  of  spas,  Equipment  l o u n g e , and  1000  10  ladies'  merchandise  M-F,  6:00  and  the  Centre  110  volumes of  1 spa  f t . each with  purpose,  1  spa  i s for special  specifications,  sizing,  Saturdays  i s equipped 2000 U.S.  * T h i s i s u s e d s o l e l y as an example and i t i s not r e p r e s e n t a t i v e o f any p a r t i c u l a r spa f a c i l i t y .  per  with  4  gal. 2  therapeutic  r e c r e a t i o n a l purposes layout  7:00  spas  i s for special  and  of  holidays.  hydrotherapy  Spas & E q u i p m e n t : The  rooms,  extra.  a.m.-11:00 p.m.;  regarding  jogging  m o n t h l y dues  merchandise  closed  change  75  room.  member e n r o l l m e n t ,  drinks  sq.  tennis courts,  spas. 2 saunas,  room, mens' and  Sundays Noon-6:00 p.m.;  general  purposes only,  courts,  4 hydrotherapy  food,  Information  spas  Operation"*  B.C.  Facilities;  track,  Fitness  of  Ma i n  Vancouver,  m.  Spa  "Plan  only.  architectural  intended  to  be  242  and  engineering  Expected 200  Bather  blueprints.  Load  g a l . of water  R a t i o Per  (10 p e o p l e  Methods of Water Q u a l i t y 1.  Bromine and  2.  Ozone  Spa:  Not  allowed  } }  1  person  per  i n at a t i m e ) .  C o n t r o l and  oxidizer  to exceed  Sanitation:  disinfection & shock t r e a t m e n t  }  3. Sodium bisulphate n e c e s s a r y t o c o n t r o l pH  ( a c i d ) or and t o t a l  sodium c a r b o n a t e alkalinity.  (soda ash)  as  Staff 1 - Manager  (on d u t y  at a l l times)  1 - Physiotherapist (regularly  scheduled  to conduct  therapeutic  programs) 1 - Recreational/Fitness Specialist conduct  recreational  16 - P a r t - t i m e A t t e n d a n t s attendant per  spa  ( s c h e d u l e d on  1 - C o n s u l t i n g P h y s i c i a n (as  I.  Training  o f Spa  - Managers and  they w i l l  facility.  They  a staggered basis with 1  necessary) schedules)  Personnel  have a d m i n i s t r a t i v e b a c k g r o u n d and be  familiar will  to  at a l l times)  (alternate  Facility  will  scheduled  programs)  on d u t y  2 - Maintenance People  (regularly  with  all  operations  attend Province training  training of  the  s e s s i o n and  243  also hold  a recognized  - Physiotherapists Physiotherapy  lifesaving  will and  hold a  certification.  an  accredited  background  in  degree  water  in  therapeutic  techniques. - Recreational/Fitness degree  in  specialist  will  recreation/physical  hold  education  an  accredited  and  appropriate  background, - Attendant and  be  will  hold  trained  a recognized  in-house  equipment, p r o c e d u r e s , - Consulting  physician  available  for  chemical  - Maintenance chemistry  and  Physician  spa  and  and will  will  Use  member of  Warning Public  3.  Public  water  chemistry,  licensed  on  be  spa  in  user  spa  users.  B.C.  and  p r o g r a m s , s a f e t y and  be  health  consultation  familiarized  with  as  physical  and  operations. people w i l l  be  thoroughly  m a i n t e n a n c e of  spa  will  be  provided  t r a i n e d on  equipment  programs  P r o v i s i o n s ' f o r N o t i f y i n g U s e r s of  1. E a c h  2.  be  individual  through a v a i l a b l e t r a i n i n g  11.  spa  certification  i n t e r a c t i o n s with  consultation  recommendations requested.  on  lifesaving  spa  in-house  water and  elsewhere.  Hazards  a c o p y of  the  pamphlet  "Safe  Spas".  signs posted  per  the  "B.C.  Approved  Standards  for  Spas".  Requirement  of a p h y s i c i a n ' s  for  user;  e a c h spa  t o be  approval  m a i n t a i n e d on  and  any  file.  restrictions  244  4. P r i n t i n g  and d i s t r i b u t i o n  o f any a d d i t i o n a l  information  as  necessary.  III.  User  Behaviour  1. A l l u s e r s w i l l 2. No  person  external  R e q u i r e m e n t s and Methods o f be r e q u i r e d t o t a k e  3. No p e r s o n  showers.  w i t h an open wound, l e s i o n  d i s e a s e problem  will  or observable  be a l l o w e d  with serious i l l n e s s  Enforcement  will  s i g n of  t o use t h e spas.  be a l l o w e d  to  use  the  women  will  spas. 4. No c h i l d r e n be  under  allowed  consulting  t o use t h e spa ( u n l e s s approved  allowed  under  the i n f l u e n c e  of a l c o h o l  food, d r i n k s ,  the  spas  minutes  consulting All if  users trained request  be a l l o w e d at  in  through will  a  will  o r any o b j e c t s w i l l  be a l l o w e d .  be a l l o w e d i n  vicinity.  t o remain  time  unless  be p r o v i d e d w i t h  their  membership  design of a s p e c i a l  have t o p a s s  t o see t h a t any  will  i n a spa f o r l o n g e r given  prior  than  a p p r o v a l by  p h y s i c i a n and/or p h y s i o t h e r a p i s t s .  members w i l l  necessary)  assured  tobacco  o r i n t h e immediate  8. No u s e r w i l l 15  or drugs  t o use t h e s p a s .  6. No h o r s e p l a y o r o t h e r d a n g e r o u s a c t i v i t i e s 7. No  by t h e C e n t r e ' s  physician).  5. No i n d i v i d u a l be  3 y e a r s o f age a n d no p r e g n a n t  through  these  violator  these  packet.  (and  Showers  "shower c u r t a i n "  either  refrain  others will  will  by t h e p a t r o n s  from  be  which a l l  t o use s p a s . A t t e n d a n t s  r u l e s are observed  to  rules  be and  the v i o l a t i o n or  245  leave  the  referred will  facility. to  the  be e x p e l l e d  Any  manager.  Equipment  and  Per  t h e "B.C.  Approved  health  the  Per  reserves  department  Monitoring,  Per  t h e "B.C.  reserves health  Visible a)  the  to  changes  to  right  changes  Spas".  (The  modifications  Centre  subject  to  and  Spas".  (The  modifications  Centre  subject  to  and R e c o r d - K e e p i n g Standards f o r Public  to  changes  o f Water  1 temperature w a l l c l o c k  of  comply  and  Spas".  (The  modifications  Centre  subject  to  approval).  Notification  c) d i s k  to  approval).  Approved  wall  and  Standards f o r P u b l i c  Testing  department  b) d i g i t a l  refuses  be  S a n i t a t i o n Procedures  right  VI.  who  will  Maintenance Procedures  Standards for P u b l i c  Approved  the  individual  compliance  approval).  Q u a l i t y and  t h e "B.C.  health  Spa U n i t  right  department  V. Water  An  with  f r o m membership.  IV.  reserves  problems  Conditions and  to Users  1 thermometer  d i s p l a y o f b r o m i n e and pH  for judging  water c l a r i t y  will  per spa.  levels.  be embedded  on  bottom  spa w h i c h must be o b s e r v a b l e t o u s e r s a t a l l t i m e s .  246  d) one t i m e Users Spas",  will  which  potential posted  near  each  maintain  records  coordinated  from  display  the  of  S a f e t y and Emergency  Per  the  "B.C. A p p r o v e d the r i g h t  h e a l t h department  to  Therapeutic  levels.  office  Signs w i l l  this chemical  to  levels.  an  be  indicate  Parameter  and  and  readings  alarm  Attendants  information  will will  will  and b i o l o g i c a l  data  be as  adjustments.  Procedures Standards  changes  for Public  and  Spas".  modifications  (The C e n t r e subject  to  approval).  Special  I.  and  levels  conditions  minimum  with other p h y s i c a l ,  VII.  parameter  of  reach  usage  " S a f e Use o f P u b l i c  to standards.  b a s i s f o r f u t u r e management  reserves  a guide,  Centre's  parameters  d u r a t i o n o f spa u s e .  insufficient  according  into  if  as  recommended  wall  levels  be w i r e d  to observe  provided  indicates  indicate  the  be  consequences  recommended will  clock for users  Programs  and I I . R e c r e a t i o n a l  Note; It  i s beyond t h e s c o p e o f t h i s  programs areas  in  detail.  thesis  t o suggest  P r o f e s s i o n a l s with  appropriate  e x p e r t i s e i n these  s h o u l d be c o n s u l t e d . I t i s recommended  that  programs  247  be  devised  objectives might  with  further  as d e s c r i b e d  implementation  i n Chapter  to  problems of  program  areas  or o t h e r  specific  health  individuals  for stress  c)  f o r t r e a t i n g and  programs joint  programs  friends  on  programs into  for  special are  relaxation s p e c i f i c m u s c l e and  by p a r t i c u l a r  athletic  skiers, etc.)  organizations  or  gathering  of  occasions.  possible  effective  while enhancing  and  relaxing  ( i . e . for joggers,  social  developed  reduction  a r e a s which a r e s t r e s s e d  activities  health  5. G e n e r a l  treat a r t h r i t i c  b) programs  Other  learning  include:  a) programs  d)  and s o c i a l  spa  and  measures benefits.  creative which  ideas protect  can  be  public  

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