This introduction to the Health & Safety Guidance (HSG) 282 is an attempt to summarise the new online only advice from the Heath & Safety Executive (HSE) which was designed to supersede the old Management of Spa Pools publication from 2006.
Please note that due to some errors that occurred in the first version in January 2017 these have been corrected, so please make sure that you are using the April 2017 version (marked 04/17 on page 62). It is envisaged that a further issue will be required, as an error is to be amended in paragraph 162 (where action should be taken at 1000 cfu Legionella species per litre and not per 100/ml).
Although HSG 282 supersedes the former Management of Spa Pools book, certain items such as Guidance on the taking of water samples have been omitted, so do not throw away your old Management of Spa Pools publication yet. Readers of this article are recommended to read HSG 282 in full, and the relevant web link is included at the end of this article.
As HSG 282 provides key information about the requirements and expectations of those people responsible for managing spa pools (including those involved in supplying the spa pool systems) it is vital for duty holders (those managing spa pools) and everyone connected to the supply of goods and services for commercial spas (typically found in leisure centres or hotels) and the domestic-type spa pools (hot tubs) used as part of a business activity.
It is important to ensure that the right type of spa or hot tub is used in the correct setting, HSG 282 should be read in conjunction with other advice on Legionnaires’ disease, covered in HSG 274 and L8, the Approved Code of Practice (ACOP) on Legionnaires’ disease, both freely available on the internet.
The importance of having competent people involved in managing the spa pool is highlighted and the use of a risk assessment, supported by an effective Pool Safety Operating Procedure (PSOP) comprising a Normal Operating Plan (NOP) and an Emergency Action Plan (EAP). The NOP sets out the way the system operates on a daily basis (including a schematic diagram of the spa / hot tub), while the EAP clearly sets out what steps to take in the event of an emergency. Advice is given that the Risk Assessment must be written where there are 5 or more employees.
The careful reading of HSG 282 is required to determine which sections relate to commercial spas and which sections refer to ‘business use’ of domestic hot tubs. The ‘business use’ of hot tubs is growing in importance with the boom in holiday parks offering hot tubs as part of the package. The important element is that the hot tub is used exclusively by a single family (or group) during any single letting period.
HSG 282 makes it clear that the owners of a holiday park site do have a legal duty imposed on them, so it is these private owners of Lodges who will need to follow any guidance issued by the site owner.
The HSW Act does not apply to domestic – privately owned spas where there is no financial gain and so is outside the scope of HSG 282.
Commercial-type spa pools are typically designed for higher bather loads than business use of a hot tub, and they typically have a deck-level overflow, greater number of bathers, a separate filter and continuous chemical dosing system with automatic control, and a balance tank and plantroom.
In terms of a hot tub used for’ business activity’, it is possible that the usage will be very light, with a couple of people using the hot tub for less than an hour per day, but of course the next group of users may be a larger party who stay in the hot tub all evening (despite advice limiting the use of the hot tub to a shorter period) hence the guidance for using some form of inline sanitiser to maintain the residual levels of chlorine or bromine.
The Guidance states that the water should be replaced in a hot tub used for business activity each week, or after each group of users.
HSE specifies the importance of having at least twice daily water testing for chlorine/bromine and pH and monthly microbiological testing of water (including quarterly for Legionella).
Table 3 (on page 45 of the Guidance) gives the chemical parameters and actions required when the sps is outside the typical pH range of 7.0 to 7.6, or when the chlorine is outside the typical range of 3 – 5 mg/l for Chlorine, or 4 – 6 mg/l for Bromine. There is also advice when the combined chlorine is >1 mg/ or when the Total Dissolved Solids (TDS) is greater than 1000 mg/l higher than the incoming fill water.
The various microbiological tests to be carried out are outlined, and Table 4 (on page 49 of the Guidance) sets out the appropriate actions to take, subject to the microbiological results found.
Readers of this article are advised to download a free copy of HSG 282 and to read the Guidance in full (and not to rely on this summary alone) via http://www.hse.gov.pubns/books/hsg282.htm
Please remember that the HSE may from time to time update the Guidance, so please make sure you regularly check their website for any newer versions.
Please also note that PWTAG has indicated an intention to produce more detailed advice for hot tubs in early in 2018.