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Contingency and emergency response plans

Contingency and emergency response plans

The purpose of this suggested practice is to provide public swimming pool owners, pool operators, and local health department personnel with suggestions for implementing the requirements for contingency and emergency response plans.

Michigan’s Public Health Code, 1978 PA 368, as amended (Act), and the administrative rules adopted pursuant to the Act, contains the statutory requirements for public swimming pools. The requirements for contingency and emergency response plans are set forth in Rule 325.2194a. This rule reads as follows:

  1. The owner of a swimming pool shall prepare and implement a contingency and emergency response plan. The owner of a swimming pool shall have the contingency and emergency response plan available for review at the pool.
  2. The contingency plan shall, at a minimum, outline a program for rapid mitigation of contamination or water quality deterioration according to R 325.2194.
  3. The emergency response plan shall outline minimum topics including the following:
    1. Rescues and submersions
    2. Equipment failure
    3. Injury requiring medical attention
    4. Other conditions or events that create a hazard to the health and safety of persons using the pool

Responsibilities

Owner

The swimming pool owner is responsible for the development of a contingency plan and emergency response plan. The pool owner’s prime objective in developing these plans is to outline the steps necessary to protect the health and safety of those using or operating the pool when the events or conditions noted in the rule occur. Further, these plans must be tailored to meet the specific needs and circumstances for each pool.

When completed, the owner is also responsible for implementing the plans. The Department of Environment, Great Lakes, and Energy would suggest the first step the owner should take is to provide the local health department representative with the plan and solicit their comments, but this is not a requirement. Next, the owner needs to ensure that all employees are informed of their role in the implementation of the plans and that copies of the plans are placed where they will be readily accessible for reference and use by key personnel.

The pool operator has specialized knowledge regarding pool operation and plays a vital role in the implementation of these plans. Thus, the owner should consult with the pool operator in the development of the plans. Further, the owner and pool operator need to treat these plans as working documents, review them periodically, and make changes as appropriate.

Local health department

The local health department’s involvement is limited to providing review comments, if requested to do so, as the rules do not provide any authority for approval or rejection of the plans. It is suggested that the local health department put their review comments in writing and maintain this correspondence with their pool file. If plans have been prepared, the local health department representative should also ensure copies of the plan are readily available to the operator and the facility manager, and offer suggestions for updating the plans when conditions warrant. If the owner fails to prepare a contingency plan or emergency response plan, the local health department representative should simply note this violation on the inspection report. The local health department should not issue a closing order, initiate any form of enforcement, or indicate the pool is not approved for operation if the owner fails to provide the required plans. However, it would be appropriate to suggest that the owner consult with an attorney regarding the legal ramifications of not preparing and implementing these plans.

List of contacts

One of the most important parts of the contingency plan and the emergency response plan is a list of contacts, and this should be on the first page of each plan. These lists should be reviewed and updated periodically.

  • Emergency services

    The list should include the name and telephone number for emergency services such as emergency medical assistance, fire department, and police department.

  • Pool resource personnel

    Another list should provide names and telephone numbers for pool resource personnel such as local health department representatives, personnel from pool service companies, equipment suppliers, and aquatics professionals.

  • Chain-of-command for pool owner and management

    This list should not only indicate the names and telephone numbers of the personnel in the chain-of-command but also indicate who is responsible for notification of these individuals, i.e., the first person that should be informed regarding a pool contamination or emergency. 

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Contingency plan

Emergency beacon

Emergency response plan

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