Swimming Pools on School Grounds

Policy

This policy outlines the risk management requirements for schools that own or manage a swimming pool on their site.

Summary

• The Occupational Health and Safety (OHS) Act 2004 (Vic) requires the department to provide or maintain systems of work and working environment that are, so far as is reasonably practicable, safe and without risk to health, including in relation to swimming pools on school grounds.
• The Public Health and Wellbeing Regulations 2019 (Vic) outline a number of actions that must be taken to ensure the safety of swimming pools, spa pools and any interactive water features on school grounds, including registration of the facility from 14 December 2020
• The OHS Regulations 2017 (Vic) and the Dangerous Goods (Storage and Handling) Regulations 2022 (Vic) requires the department to manage the risks associated with dangerous goods and hazardous chemicals stored and used in schools that have swimming pools, for example, swimming pool chlorines, like sodium hypochlorite, swimming pool sanitisers like hydrogen peroxide.
• The principal and/or their delegate must identify, assess, control and monitor OHS risks in relation to swimming pools at their site.
• Under the OHS Act 2004, employees while at work must take reasonable care for their own health and safety and the safety of others who may be affected by their actions or omissions.
• Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well, including access to the OHS Advisory Service and local regional officers who can provide free advice on managing risks related to swimming pools.
• The Swimming Pools Risk Management Procedure (in the Procedure tab) must be followed, and sets out the practical step-by-step instructions for implementing this policy.
• This Policy forms part of the department’s OHS Management System, refer to OHS Management System (OHSMS) Overview for further information.

Details

The principal and/or their delegate is responsible for ensuring the pool is managed in a safe manner at all times, regardless of the user(s).

The Public Health and Wellbeing Regulations 2019 (Vic) outline the minimum water quality requirements for aquatic facilities and the duties of aquatic facility operators. By definition, a swimming pool, spa pool or interactive water feature located at the premises of an early childhood service, school or other educational institution is categorised as a category 1 aquatic facility. All category 1 aquatic facilities must be registered with local council from 14 December 2020.

Schools should contact the OHS Advisory Service on 1300 074 714 for support in registering their facility, including meeting the registration requirements.

For detailed information about registration requirements, refer to Frequently asked questions – swimming pools regulation changes 2021 (DOCX).

Principals or their delegate are responsible for ensuring that the standards and requirements for a category 1 aquatic facility on school grounds are met. The Water quality guidelines for public aquatic facilities – managing public health risks require all category 1 and 2 aquatic facilities to have a water quality risk management plan in place. This is to minimise illness transmission from aquatic facilities and protect vulnerable groups including young children, and students living with additional health needs such as low immunity. For further information on developing a water quality risk management plan refer to Section 4 Water Quality Risk Management Plan in the Procedure tab.

The principal and/or their delegate should, in consultation with the Health and Safety Representatives (HSR) and employees, also ensure that:

• the Department’s pre-populated Swimming Pool Inspection Checklist (DOCX) is reviewed and amended for relevancy to the area being inspected and complete an inspection once a term or as required in consultation with the OHS Advisory Service
• hazards identified during the swimming pool inspection are recorded in the Action Plan within the Inspection Checklist and in the ‘Hazard type’ column of the OHS risk register (XLSX)
• the risks associated with their pool are managed. These include:
  • chemical management
  • water safety
  • plant and equipment management (plant rooms)
  • gates and fencing
  • ladders and diving boards
  • slips, trips and falls
• chemicals are identified, recorded on the Chemical Register and the appropriate controls are put in place for their storage, use and disposal
• that there are appropriate emergency procedures in place in the event of a chemical spill as outlined in Guidance Sheet 4: Chemical Spill Management (DOCX)
• the identified hazards are risk-assessed and documented in the OHS Risk Register
• OHS risk controls are implemented in consultation with employees and HSR as documented in the OHS Risk Register and Action Plan
• controls that are implemented are monitored and reviewed to ensure their effectiveness in managing the risk and incorporate any changes to controls on the OHS risk register (XLSX).

For schools who share their pool with the community or other organisations, the principal and/or their delegate must ensure that these organisations have appropriate occupational health and safety management systems in place to address hazards they may be exposed to.

This policy should be read in conjunction with the:

• OHS Risk Planning and Management policy
• Workplace Safety Inspections policy
• Plant and Equipment Management policy.

Definitions

Dangerous Goods
Dangerous goods are substances that may present an immediate safety hazard through exposure to their explosive, flammable, radioactive, corrosive or toxic properties.

They are easily recognisable by the diamond shaped sign displayed on the substance label. They are designated into nine classes according to their immediate physical or chemical effects.

For further information, refer to Guidance Sheet 2: Dangerous Goods Classification System (DOCX).

Emergency Management Procedures
Procedures in place to manage hazardous substances and/or dangerous goods spills and leaks (ie spill containment, spill kits, spill clean-up, appropriate disposal) including local emergency management plan detailing evacuation directions, medical treatment and assistance and alerting emergency services.

For further information, refer to:

• Guidance Sheet 4: Chemical Spill Management (DOCX)
• Guidance sheet 5: Major Chemical Spill Management (DOCX)
• Guidance Sheet 6: Hazardous Chemical Disposal (DOCX).

Hazard
Anything with the potential to cause harm, injury, illness, or loss.

Hazardous Chemicals
Hazardous chemicals are classified based on their health effects, both short and long term. They can enter the human body through inhalation, ingestion and contact through the skin and mucous membranes such as the eyes. The level of subsequent risk depends upon both the substance itself and the nature of the work being done with it.

Examples of types of hazardous chemicals (depending on their concentration) include:

• acids
• caustic substances
• disinfectants
• herbicides and pesticides
• solvents and thinners

Inspection
A formal check of physical conditions existing within a defined time and area against pre-established criteria (checklist).

Risk
The likelihood of harm arising from exposure to any hazards and the consequence of that harm.

Relevant legislation

• Dangerous Goods Act 1985 (Vic)
• Dangerous Goods (Storage and Handling) Regulations 2022 (Vic)
• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• Public Health and Safety Regulations 2019 (Vic)

Swimming Pools Risk Management Procedure

The Swimming Pools Risk Management Procedure must be followed, and sets out the practical step-by-step instructions for implementing this policy.

The Procedure contains the following chapters:

1. Hazard Identification
2. Swimming pool Inspection Checklist
3. Risk management
4. Water Quality Risk Management Plan
5. Risk assessment
6. Legislation, codes of practice, standards and guidance

1 Hazard identification

There are many potential hazards surrounding the management of pools, including:

• Chemical Management — swimming pool chemicals control bacteria and algae. In concentrated form these chemicals are toxic and can become unstable and produce poisonous fumes or even fire when mixed with other chemicals.
• Water Safety — drowning is the second leading cause of accidental death for people between the ages of 5 and 24. Lack of supervision, horseplay or running, and inexperienced swimmers can all lead to serious incidents or drowning — refer to the Specific Activity Guidelines — Swimming and Water Activities in the Department’s Excursions Policy.
• Plant and Equipment — broken or poorly maintained equipment such as missing or broken grating or exposed electrical wiring can pose a serious risk to the health and safety of pool users.
• Gates and Fences — gates and fences must be in good working order, free from damage and maintained such that there are no overhanging branches or objects nearby that can be used to climb over the fence.
• Ladders and Diving Boards — ladders and diving boards must be free from damage, rust or corrosion.
• Slips, Trips and Falls — slippery changing room floors, spills on the floor, uneven surfaces, equipment on floor, slipping of ladders, getting caught in the ladder are examples where slips, trips and falls can occur.

Where or when would these issue be relevant?

These issues are relevant in all schools that own and/or manage a pool on their site.

Please note that for schools who share their pool with the surrounding community or other organisations, the principal or their delegate must ensure that these organisations have appropriate occupational health and safety management systems in place to address hazards they may be exposed to.

The principal and/or their delegate is responsible for ensuring that the pool is managed in a safe manner at all times, regardless of the user(s).

2 Swimming Pool Inspection Checklist

In order to identify health and safety hazards, the department requires principals and/or their delegate to conduct periodic inspections of their swimming pool.

2.1 Review the pre-populated Swimming Pool Inspection Checklists

The principal and/or their delegate should be in consultation with the Health and Safety Representatives (HSR), while employees review and amend the department’s pre-populated Swimming Pool Inspection Checklist (DOCX) for relevancy to the area being inspected.

The principal and/or their delegate may also choose to use an alternative template. This template should include at a minimum:

• inspection area
• hazards identified
• corrective actions to be taken to address the hazard(s) identified
• person(s) responsible
• corrective action completion date.

2.2 Frequency of conducting the swimming pool inspection

The principal and/or their delegate in consultation with the HSR and employees are to conduct quarterly inspections — once a term, using the Swimming Pool Inspection Checklist.

The principal and/or their delegate, in consultation with employees and HSR, can delegate the responsibility for the completion of the inspections to employees.

The accountability for implementing and documenting any hazards identified remains with the principal.

2.3 Recording hazards identified during the swimming pool inspection

If a hazard is identified whilst conducting the inspection, it is to be documented in the Action Plan section of the Swimming Pool Inspection Checklist.

The checklist and associated Action Plan should then be provided to the principal or their delegate and/or HSR.

The principal and/or their delegate must ensure that the identified hazard is recorded in the ‘Hazard type’ column of OHS risk register (XLSX).

Through the planned and systematic management of swimming pools, a safer environment can be achieved.

3 Risk management

For schools that have a pool on their site, the principal and/or their delegate must ensure the risks associated with their pool are managed. These include:

• chemical management
• water safety
• plant and equipment management — such as, plant rooms
• gates and fences
• ladders and diving boards

3.1 Chemical management

The principal and/or their delegate must ensure that hazardous substances and dangerous goods are managed in accordance with the Chemical Management Policy. This includes the following:

• identify all pool chemicals that are classified as dangerous goods and/or hazardous chemicals in consultation with relevant parties, including the HSR and employees
• record all such substances on the workplace Chemical Register (XLSX) or equivalent template, and make the register available to all relevant parties
• obtain and review Safety Data Sheets for each substance to determine the risks to employees, students and other pool users
• conduct a Risk Assessment (DOCX) in order to rate the risks associated with chemical management and identify ways to eliminate / reduce the risks to all users of the pool
• ensure chemicals are stored in a secure area away from weather extremes
• ensure emergency evacuation, safe containment and management procedures are in place for any dangerous goods stored and used on site
• develop a Safe Work Procedure — for chemical risks that are identified as 'high' using the Safe Work Procedure Template (DOCX) and provide the necessary training for employees to comply with them
• investigate incidents, review risk controls and keep records of the process for at least 5 years
• monitor and review the safety systems to make sure the risk is being adequately managed
• ensure quantities of chemicals are kept to a minimum to decrease manual handling risk associated with these

For further information, please refer to the following:

• Guidance Sheet 1: Chemical Storage (DOCX)
• Guidance Sheet 2: Dangerous Goods Classification System (DOCX)

3.2 Water safety management

The principal and/or their delegate must ensure that water risks are in accordance with the Swimming Instruction and Water Safety Policy as well as ensure that all fences and gates are in good working order.

3.3 Plant and equipment management

The principal and/or their delegate must ensure that plant and equipment associated with the swimming pool are maintained and managed in accordance with the Plant and Equipment Management Policy and the OHS Risk Management Policy. This includes the following:

• plant rooms that store hazardous chemicals, dangerous goods mechanical pumps, electrical equipment etc., are locked at all times and only accessible by trained personnel
• plant rooms display signage on the plant room door highlighting danger chemicals
• ensure that no fittings are broken or missing
• ensure that all suction fittings, grates or covers are secure and in good condition
• all electrical sources and equipment should be sheltered from water, as a result of weather, over splash or cleaning processes
• residual Current Device (i.e. Safety Switches) should be installed on all circuits supplying power to the pool or associated equipment
• risk controls should be regularly reviewed to ensure appropriateness

3.4 Gates and fences management

The principal and/or their delegate must ensure that safety barriers surrounding the pool are managed in accordance with the OHS Risk Management Policy. This includes the following:

• ensure all fences and gates are maintained in good working order
• ensure there are no objects that could be used to climb into the pool area
• ensure that fences and gates have no sharp edges and projections

3.5 Slips, trips and falls

The principal and/or their delegate must ensure that the risks of slipping, tripping and falling are managed in accordance with the OHS Risk Management Policy. This includes the following:

• ensure that non-slip mats are placed in areas which are high risk
• ensure that equipment (e.g. flotation aids) can be stored in suitable receptacles
• contrast the edge of the pool in a different colour
• ensure slippery steps have non-slip surface protection
• ensure broken tiles are replaced (if applicable)
• ensure areas are kept clean and tidy

4 Water Quality Risk Management Plan

Under the Public Health and Wellbeing Regulations 2019 (Vic), swimming pools, spa pools or interactive water features on school grounds are classified as a category 1 aquatic facility requiring principals or their delegate to take the following actions to keep pool users safe:

• register the swimming pool, spa pool or interactive water features with the local council by 14 December 2020
• manage the risks to human health arising from pathogenic microorganisms in the water in the aquatic facility in accordance with the regulations and the Water Quality Guidelines
• ensure adequate training and competency of aquatic facility operators. Facility managers should ensure they have adequately trained staff who understand the treatment processes and know how to maintain water quality. The level of operator training should be proportionate to the risk of the facility. The minimum standard for aquatic facilities would be for staff to undertake a short course offered by an industry body or registered training organisation (recommendations for training are provided in the Health and Safety Training and Short Course Guide (DOCX)).
• have a water quality risk management plan that includes:
  • staff roles and responsibilities, competencies and training requirements
  • a description of the facility, its source water, and its treatment systems
  • water quality targets and treatment objectives
  • hazard identification, risk assessment and control measures
  • operational and verification monitoring
  • incident management and response procedures, and
  • data recording and reporting
• undertake a manual daily key pool water parameter check before the pool opens and operational checks every 4 hours, and to close the pool if the key pool water parameters are not met
• undertake periodic verification and monitoring of the microbiological quality of water at the aquatic facility and take action where the required parameters are not met. Refer to tables below.
• keep records of testing for 12 months from the date the record was made.

For further information please refer to the following:

• Developing a water quality risk management plan for public aquatic facilities
• Department of Health and Human Services aquatic facilities webpage

Support

For support in registering your school aquatic facility and customising and implementing a school’s water quality risk management plan contact Marsh on:

• OHS Advisory Line: 1300 074 715
• Email: safety@education.vic.gov.au

5 Risk Management

5.1 Risk assessment

The principal and/or their delegate should in consultation with the HSR and employees must ensure that:

• record identified hazards in the ‘Hazard Description’ column of the OHS risk register (XLSX)
• identified hazards are risk-assessed using the Risk Assessment Template (DOCX) or equivalent template
• the risk management methodology as outlined in the OHS Risk Management Procedure is followed to assess the level of risk of the identified hazard.

5.2 Implement controls

The principal and/or their delegate in consultation with the HSR and employees must ensure that controls to manage swimming pool risks are identified and implemented using the order of the hierarchy of controls.

5.3 Record risk controls

The principal and/or their delegate in consultation with the HSR and employees must ensure that controls to manage swimming pool risks are recorded on the OHS Risk Register.

5.4 Monitor and review risk controls

The principal and/or their delegate in consultation with the HSR and employees must review the controls implemented to ensure their effectiveness in managing the risk, and incorporate any changes to controls on the OHS Risk Register.

6 Legislation, Codes of Practice, Standards and Guidance

• Dangerous Goods Act 1985 (Vic)
• Dangerous Goods (Storage and Handling) Regulations 2022 (Vic)
• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)

Resources

Templates relevant to this policy and procedure

• Chemical Register (XLSX) – for recording all hazardous substances and dangerous good (such as pool chemicals)
• OHS risk register (XLSX) – for recording of hazards identified during the swimming pool inspection
• Risk Assessment Template (DOCX) – to rate the risks associated with chemical management and identify ways to eliminate / reduce the risks to all users of the pool
• Swimming Pool Inspection Checklist (DOCX) – a department pre-populated checklist which schools need to amend for relevancy to the area being inspected (swimming pools)
• Safe Work Procedure Template (DOCX) – for development of a Safe Work Procedure

Guidance sheets for chemical management (such as pool chemicals)

• Guidance Sheet 1: Chemical Storage (DOCX)
• Guidance Sheet 2: Dangerous Goods Classification System (DOCX)
• Guidance Sheet 3: Prohibited and Restricted Chemicals (DOCX)
• Guidance Sheet 4: Chemical Spill Management (DOCX)
• Guidance Sheet 5: Major Chemical Spill Management (DOCX)
• Guidance Sheet 6: Hazardous Chemical Disposal (DOCX)

Frequently asked questions – swimming pools regulation changes 2021

Frequently asked questions – swimming pools regulation changes 2021 (DOCX) – provides further guidance to schools regarding registration requirements, including information on completing a water quality risk management plan.