FTA Guide to the MAHC

As many of you know, the Model Aquatic Health Code is about to start its voting process to decide whether or not float tank language should be included in the next version of the MAHC. If all of this is new to you, scroll down to the end of this document to read about what the MAHC is and what this is all about.

For those of you who have been following along with this, there have been some big changes that have taken place very recently, and we highly recommend you read through the information here before casting your vote.

Some background on what’s happened so far

Before we get to the actual code language itself, we want to provide a little context. On February 3rd, 2017, the original proposed float tank language was submitted to the Model Aquatic Health Code (they call these submissions change requests). The MAHC then had a six month window of public comment where anyone who paid a $40 membership fee could hop on and leave a comment about the change request (the code language).

There is also a group of people at the MAHC called the Technical Review Committee. This committee is made up of around 10-12 people , some of which are health regulators, some of which represent health organizations (like the CDC or the UL), and some of which are from the recreational water industry (like people who manufacture pool equipment).

The Technical Review Committee reviews every change request that gets submitted, as well as the comments people leave about those change requests, and decides whether there need to be any edits made before the change request goes out to vote. They also make their recommendation to the voting members for whether they think the change request should be voted in or not. Anyone who is a paying member can listen to the phone calls where they have these discussions (but can’t actively participate in them).

During the comment period a handful of people within the float industry left comments detailing their concerns and objections to the language that was being considered. The Technical Review Committee then had their discussion about the float tank change request, and in the opinion of many of the float industry people who left those comments, they did not adequately consider or address the concerns that the float industry had submitted.

We vocalized our concern and dissatisfaction with this process to the MAHC, and as a result the Technical Review Committee allowed the change request to be opened back up for a period of language revision. Members of the FTA were then asked to participate in an editing process of the language to address the concerns members of the industry had raised.

This revision process happened very recently, and very quickly. It started on September 26th and lasted until October 11th. As a result of this revision process the code language in the change request being proposed has some significant changes in it, and this new version is what will be on the table for voting starting on October 17th.

What’s different in the new float tank proposal

You can read the new change request language by going to this website and typing “floatation” into the search box.

Here is a list of what has changed:

  • One of the biggest things that changed is that UV is now an acceptable form of disinfection by itself (previously ozone was required). Hydrogen peroxide is also allowed as an oxidizer or water conditioner.
    • The UV unit does have to meet certain criteria:
      • It must pass the disinfection testing requirement in NSF 50. This doesn’t mean it has to be NSF certified, nor does it mean it has to be tested at the NSF lab, it just means it needs to be tested in a lab to show that it can pass the test (which requires showing a 3-log reduction of pseudomonas and enterococcus).
      • It must have a calibrated sensor. This is a sensor that goes inside the UV unit that detects how much UV light makes it through the solution. These sensors then give you a continuous live readout of the UV’s performance.
      • It must have an alarm system that alerts the staff if the sensor ever detects that the UV’s output has fallen below the correct level. This doesn’t have to be an auditory alarm, nor does it have to be in the float room, so it shouldn’t affect customer’s floats.
  • The other big change is that the reference to NSF CCS 12804 has been removed from this document. CCS 12804 is the NSF’s certification for float tanks. Previously, parts of the CCS were referenced in this change request as requirements that float tanks must meet. Those sections have been removed, and more generalized language has replaced them (eg, it used to require that a manufacturer send in their float tank material to be tested for durability, now it just states that the float tank “shall be constructed of impervious and structurally sound material(s)”)
  • You may notice that this change request is much longer than it was before. That is because the previous version had a section at the top that listed all of the other sections of the MAHC that would apply to float tanks. It was requested by the FTA that the language from these sections be included in the actual float tank change request instead of referenced. The reasoning is that those referenced changes in the rest of the MAHC could change as the MAHC develops over the years, and there is a possibility that those changes may be reasonable for a pool or a spa, but adversely affect float tanks. To prevent that from happening, the language was copied into the change request, which means it can only be changed in the future if it is specifically changed in the float tank section.
  • The requirement for UL certification of the entire float tank has been removed.
  • The requirement for only a single person being allowed in a float tank at a time has been removed.
  • The requirement for 5 turnovers between floats has been reduced to 3.
  • All mentions of the word “water” in the code have been changed to “solution.”
  • A handful of smaller changes were made as well, things like reducing some of the paperwork required when submitting for plans for permitting, removing some unnecessary/inapplicable language about decks and such, and putting in language to prevent health inspectors from interrupting a customer’s float to do an inspection.

Considerations for Voting

The following is an information guide to help you navigate the language that is being proposed here. We believe the language is in a place where there are parts of it that could be viewed as helpful to the industry and parts that can be viewed as burdensome. Whether the ultimate impact of a this language passing will be beneficial or harmful can be a matter of opinion, and the following explanations will attempt to give a breakdown of the various pros and cons.

Do float tanks belong in the MAHC

Before delving into the specifics, it’s important to take a step back and think about the presence of float tanks in this document to begin with. The MAHC describes itself as a document that covers all recreational water. Some would see float tanks as a form of recreational water, while others would argue that float tanks are substantially different than the other items covered in the MAHC (which mainly focuses on pools and spas). Being included in this document has the potential effect of putting float tanks into the pool and spa category in the eyes of many health departments, which can generally come with some assumptions placed upon float tanks that are perhaps inappropriate or impractical. The benefit of being in this document is that it is backed by the CDC, and as such has both an inherent sense of credibility and a wide reach.

Ozone and UV

What many people may find as welcome news is that this language would allow for float tanks to operate without the use of chlorine or bromine. Both ozone and UV are acceptable forms of disinfection, and hydrogen peroxide is allowable as long as you don’t claim it’s a disinfectant, but rather call it an oxidizer or conditioner.

There are some specific requirements on the UV and ozone units, as mentioned earlier, that are likely to be the biggest potential impacts this code could have on new and exiting float centers.

Both UV and ozone units must be tested to show that they can achieve a certain level of disinfection (the testing protocol in Annex H of NSF 50). This test is done on all units that areNSF 50 certified, but those units are not typically found on float tanks. Ozone or UV units that have undergone this testing are typically more expensive than many of the units currently found on float tanks.

For UV specifically, there is also a requirement to have a calibrated sensor and alarm system on the unit. The sensor is built into the UV unit and detects the amount of UV light that passes through the solution. These sensors typically come with an actual live readout of the mj/cm 2 that is passing through the solution. The alarm system will indicate if the levels ever drop below the appropriate operating range. This alarm system does not have to be an auditory alarm, so it shouldn’t mean your customers will be disturbed if it goes off.

The MAHC has a requirement for sensors on all UV units throughout their entire code, and the reason they require them is because it is a continuous validation that your UV system is working properly. UV bulbs can weaken or burn out, oils can build up on the quartz tubes, and turbidity or cloudiness in the float solution can prevent UV from transmitting properly. If any of these things caused the UV light to drop below its appropriate effectiveness, the sensor would alert you. Some of these things (like the UV bulb weakening) can be indicated by other methods, and other things (like oils on the quartz tube) can be less likely if you’re doing proper maintenance on your UV systems.

The difficulty with the requirement for calibrated sensors and alarm systems comes in the cost. UV manufacturers typically only build units that include those for large commercial operations, and as such, the equipment can be much more expensive than the UV units currently found on many float tanks. We’ve talked to a few UV companies, and from those quick conversations it seems the units they have that meet these requirements typically start in the $6,000 – $10,000 range.

There is a possibility that more reasonably priced units could be made if they were made with the size and volume of float tanks in mind, and if this does go through, there may be some incentive for UV manufacturers to produce those units for the float industry.

VGB compliance

The Virginia Graeme Baker Pool and Spa Safety Act which was passed as a result of the death of a 7-year old who became entrapped on a spa drain due to the power of the suction. It calls for anti-entrapment drain covers and applies to “all swimming pools or spas that are (1) open to the public or (2) open exclusively to members of an organization and their guests whether for free or for charge.

This language does include a requirement that float tanks meet the VGB code. The most typical way float tanks meet this requirement is by having 2 suction pipes at least 3 feet apart. Some float tanks already meet this requirement, and some don’t. It’s important to note that this only applies to new centers or to significant renovations (which would include buying a new float tank), so it would not be something you would need to retrofit your existing tanks to meet.

A rushed process

Another thing to consider is the speed at which this code was developed. There was very little time given to the development of this code overall, and as you can see, huge changes were made in the 11th hour. Some people will argue that no matter the outcome, that’s not an appropriate code writing process.

As a result of the tight timeline for the recent revision process, we as the FTA were not given the opportunity to fully engage and solicit feedback from the industry at large on the details of the language changes we were asking for. We did our best to listen to the feedback we did receive, and to be as representative towards the industry as we could, but ideally this would have been a longer process that could have involved more people from within the industry.

This code compared to other existing float regulations

The other thing to consider is the fact that certain health departments already have written or are beginning to write rules for float tanks in their jurisdictions. In many cases, these rules are not seen as ideal by the centers that fall under them. There are many sections of this MAHC language that most people would see as better for their centers than the regulations currently seen in many jurisdictions. Some examples include:

  • The language allows for 3 turnovers of the solution between clients. There are certain health departments out there that are starting to require higher turnover numbers (4 or  5), and that can add time onto transitions between customers.
  • There is no requirement for NSF certified pumps. This means that magnetically driven pumps can be used on float tanks.
  • There is no requirement for NSF certified filters, which means bag filters can be used.
  • There is no requirement for health advisory signage to be posted up in the center.
  • And as mentioned before, there is no requirement for chlorine or bromine.

While this code may not be perfect, there is a perspective where this could be a welcome relief to many centers that are currently dealing with their local regulations. As new health departments begin to write float tank regulations, this document could be shown to them as a model to follow, and it comes with the backing of the CDC.

For centers that are not currently regulated, an adoption of this code would likely lead to some changes in operation and some increased paperwork and documentation (things like having a written response protocol for a bacterial contamination in your float tank), as well as some potentially increased cost to meet the UV/ozone requirements listed above.

In conclusion

There are some clear up sides and down sides to this code passing, although it’s important to remember that ultimately the MAHC is just a recommendation from the CDC that local health departments will have to choose to adopt and implement as they wish.

We would strongly encourage you to read through the actual code language yourself to help fuel your decision. If you don’t feel strongly one way or another, you can also choose to forego voting, and save the $40 membership fee.

If you have any questions, or would like some clarification on specific parts of the code language, please feel free to contact us at fta@floatation.org.

How to cast your vote

The voting takes place online at cmahc.org . Voting opens on October 17th and continues for a month, closing on November 19th (at midnight EST). You must sign up as a CMAHC member for vote ($40). Any person can sign up and vote, even multiple people from the same organization. The voting is weighted so that 50% of the vote is from health regulators and 50% is from everyone else.You can get a breakdown of their voting structure here .

Read this if all of this is new to you

What is the MAHC

The MAHC stands for the Model Aquatic Health Code. This is a document that is created by the Center for Disease Control that is a set of guidelines for recreational water sanitation and operations. The MAHC is what is called a “model code,” which means it is not a regulation in and of itself. Instead, the CDC puts out the MAHC as a document which they consider to be a really nice set of code language for recreational water facilities (mostly pools and spas). They then hope that states or other local jurisdictions will look at this model code and decide that it is nicer than their current regulations, and that they want to adopt it to replace their pool/spa code(either in part, or in whole). The more states that do this, the more uniformity is created across the country’s various recreational water regulations.

The MAHC is fairly new; the first version of it only came out in 2014. Only one state in the US has fully adopted it as their regulation (New Mexico), although a few more jurisdictions are on the path towards adoption, either in part or in full. There are also many jurisdictions that look towards the MAHC as a source of credible information for inspiration in their own code.

The MAHC goes through a process every two years where it gets updated, and this is one of those years. In this update they are proposing to add in language about float tanks.

How the MAHC update process works

Here is the main website that is focused on how the MAHC is updated, which is through what is called CMAHC, or the Council for the Model Aquatic Health Code. On it you can find information about how commenting works, a timeline of the process between now and when this code goes live, and the voting structure .

We are currently in the stage where voting for whether this code should be adopted or not has begun. Anyone who becomes a CMAHC member ($40) can have a vote (even multiple people from the same organization). Voting starts on October 17th and is open until November 19th.

How could this impact my float center

There are a lot of things that would need to happen for you to feel any impact from this. First off, enough people would need to vote yes for this to be adopted into the MAHC. If it does get vote in, the MAHC will release their next version of the code with the float tank language included in the summer of 2018. If/When it comes out in the Summer of 2018, it doesn’t have any impact unless your health department actually adopts the language into their own code. (Again, adoption of the MAHC as a whole is still not currently super widespread.) Local health departments can choose to adopt the float tank language verbatim, or just choose parts of it they want to adopt, or take inspiration from it to write their own code, or ignore it entirely. The MAHC will then have another update process in two years where people can submit to change the float tank language.