The swimming pool serving a tourist-accommodation business is, to all intents and purposes, a swimming pool for public use. The Italian legislation on the hygienic-sanitary safety of swimming pools, in fact, does not consider public or private ownership as a discriminating factor, but rather the type of use. Since the publication of the State-Regions Agreement relating to the hygienic-sanitary aspects for the construction, maintenance and supervision of swimming pools for swimming in 2003, the swimming pools of tourist-accommodation structures have fully entered among the swimming pools for public use. In fact, these structures belong to category A2 (swimming pools for collective use): “They are those inserted in structures already used, mainly, for other accommodation activities (hotels, campsites, accommodation complexes and the like) as well as those serving the community, gyms or similar, accessible only to guests, customers, members of the structure itself”. Since 2003, therefore, the swimming pools of campsites, those of hotels or those installed in bathing establishments, being structures for public use, have been subject to controls by the bodies in charge and subjected to precise control obligations also by the manager himself. The 2003 Agreement, in fact, established that the controls on swimming pools for public use are divided into two categories: external controls, i.e. those carried out by healthcare companies, and internal ones, i.e. those implemented by the manager of the structure or by a his appointee.
The first obligation is to identify and appoint the person in charge of the swimming pool, who is the one who “must guarantee the correct management from a hygienic-sanitary point of view of all the functional elements of the complex which contribute to the safety of the swimming pool in compliance with the indications of set out below” (point 6.1). In some Regions, such as Tuscany for example, any fines provided for by the relevant regional law are imposed directly on the Pool Manager and not on the business owner.
The internal controls are described in point 6.2 of the 2003 Agreement: “The internal controls must be performed according to management and self-control protocols: to this end, the manager of the swimming pool must draw up a risk assessment document, in which it is considered each phase that could prove to be critical in the management of the activity.The document must take into account the following principles: a) analysis of the potential hygienic-sanitary dangers for the swimming pool; b) identification of the points or phases in which these dangers can occur and definition of the relative preventive measures to be adopted; c) identification of critical points and definition of their critical limits; d) definition of the monitoring system; e) identification of corrective actions; f) verification of the plan and periodic review, also in relation to changes in the initial conditions, risk analyses, critical points, and control and surveillance procedures. The manager must ensure that the procedures set out in the risk assessment document are applied, maintained and updated”.
This document, which over time has been defined as a “self-monitoring plan” also to distinguish it from the DVR on worker safety, indicates the swimming pool management procedures, including daily (in the field) and periodic (laboratory) water analyzes ).
Furthermore, still according to the 2003 Agreement, “the person in charge must also keep the following documents at the disposal of the authority in charge of control, drawn up according to appropriate control systems, possibly automated: a) a register of the technical-functional requirements with an indication of the size and volume of each tank, the number and type of filters, the flow rate of the pumps, the maintenance system, etc. b) a register of the water controls in the tank containing: b1) the results of the checks of free active chlorine, combined active chlorine, temperature, pH; b2) the reading of the meter installed in the specific supply water delivery pipe, useful for calculating the amount of make-up water; b3) the quantities and name of the products used daily for water disinfection; b4) the date of collection of samples for water analysis; b5) The number of visitors to the facility. The documentation relating to the checks and registrations carried out by the person in charge is available to the Local Health Authority which will thus be able to acquire all the information concerning the nature, frequency and results of the analyzes carried out. If, following the self-check carried out, the manager finds values of the hygienic-sanitary parameters in contrast with the correct management of the swimming pool, he must provide for the solution of the problem and/or the restoration of the optimal conditions. If the non-compliance found could constitute a health risk, the owner of the system must promptly notify the local health unit. The documentation referred to in the previous paragraphs is available to the health authority for a period of at least two years”.
The reference parameters of the substances contained in swimming pool water are those listed in Table A of Annex 1 of the 2003 Agreement. But what are the checks to be carried out, and with what frequency? The UNI 10637 standard comes to our aid, which lists them in table 2 of the standard and we report them in the following table.
For type A pools, the microbiological analyzes of the pool water must be carried out on a monthly basis. If the analyzes of 4 consecutive months have not revealed differences from the limits shown in Table A of the 2003 Agreement, the reduction of the frequency from monthly to bimonthly is permitted. If one of the subsequent bimonthly analyzes detects non-compliance, the monthly frequency must be restored, until a further 4 consecutive compliant months are reached. The first analysis must be carried out before starting the activity.
In conclusion, when managing a swimming pool for public use it is necessary to put in place a management process with the relative monitoring, carrying out checks of which records must be kept. The pool manager is the reference person who must draw up the self-monitoring manual and decide the operations to be performed, as well as the verification analyses, to keep the pool healthy and safe.
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