It is our stance as the Floatation Tank Association to vote “no” on the float tank language being proposed for the Model Aquatic Health Code.
The reasoning for our “no” vote is detailed below, but we encourage everyone in the industry to take the time to understand the language being proposed and make their own informed decision on how to cast their vote.
We have put together this informational document that provides a breakdown of the most relevant details of what is in the proposed code language, as well as some analysis on the various pros and cons of the language being voted in. It also contains details on how to actually cast your vote, and some background on the MAHC and this whole process.
The Reasons We Are Supporting a “No” Vote
It should be noted that this proposed code language has some merit. As you can see from the details in our informational document, there are many parts of the proposed language that people within the industry will likely see as a positive. It is because there are both notable benefits and downsides to this language being voted in that we put together that informational document and recommend everyone read it to make their own decision. However, as an organization, we believe the downsides of this code outweigh the benefits for the following reasons:
This Was a Rushed Process
As we all know, developing reasonable language to regulate float tanks can be a big task. Many states and organizations have taken years to develop their language because it can take time to consider and answer the many unique questions that arise, and it can take time to properly receive feedback from all interested parties.
The process of code development for the MAHC happened very quickly. The initial Ad Hoc Committee that was put together to create the original language only had a month to work before the language was due for submission. After the change request was submitted, the time allowed for discussion of the language in the internal MAHC process was delayed multiple times. There was a second period of code revision allowed, but even that only took place over the course of about two weeks leading right up to the beginning of the voting period.
As a result of the pace of this process, we are concerned that we did not have the chance as an industry to properly review and analyze all the parts of this language. Ideally there would have been time for more manufacturers and key players in the float industry to be involved and to provide feedback.
This is also a long code with many small and detailed points. There is a possibility that this fast process has led to the oversight of some substantial unintended consequences that could arise from these small details.
Because there is currently no substantial population of the general public becoming sick from floating in commercial float facilities, we see no reason to rush through the process of pushing float regulations forward without the proper development time.
UV Light Calibrated Sensors
Right now, if UV light is used as the primary means of disinfection, the language in the change request requires a calibrated sensor to be included with the unit (in addition to meeting some other disinfection criteria detailed in the FTA Guide to the MAHC). This is an understandable requirement from the point of view of having some way for both center owners and health inspectors to verify that UV lights are actually doing the disinfecting that they should.
The problem with this requirement is that the cheapest UV lights meeting these requirements currently come with a cost of $6,000 – $10,000.
These units are more heavy duty and more expensive than most float tank manufacturers currently use. Mandating them will result in raised costs for manufacturing, and will result in float tanks utilizing calibrated UV sensors going up in price from anywhere between $5,000 – $9,000. This increase in the price of float tanks would ultimately get passed on to float customers and will have an impact on the ability to raise enough funds to start up a float center (which is already a very expensive proposition).
There is a possibility that UV manufacturers will develop more affordable units over the following years, especially if this requirement gets adopted and they see the potential for ongoing future sales. However, the float industry is so small that we don’t have the buying power to truly influence manufacturing decisions – the release of cheaper units is a possibility and a hope, but certainly not a guarantee.
With this in mind, and because of the low risks associated with floating (high salt content, no fecal to oral route of infection, no kids, a single bather load, showering before and after floating, etc.) the FTA feels that requiring a calibrated UV sensor is overkill. We believe that using a unit that has passed the appropriate disinfection tests, along with following manufacturer’s recommendations for cleaning and changing bulbs, along with regular bacteriological tests from a 3rd party lab, should satisfy the need to ensure public safety without a calibrated UV sensor.
Comment Period Open until November 19, 2017
The comment period for change requests is still open, and you can post up your thoughts on the change request and attempt to sway other’s votes. If you’re deciding to vote against the float tank change request, the content below is a great basis for crafting your own comments. We strongly encourage you to write your comments in your own words, as opposed to simply copying and pasting in language from this document.
- This was a rushed process
- initial ad-hoc committee was rushed
- technical review committee discussion was delayed several times and rushed
- many large changes went in less than a week before the vote
- (Although these changes were more favorable to the industry, it speaks to the rushed process)
- Because of the length of the change request, it’s hard to know what burden every little part will be without further industry discussion
- Mandating a UV Calibrated Sensor is overkill
- UV lights with calibrated sensors are in the $6,000-10,000 range on the low side
- The increased price would be passed from manufacturer, to center owner, to consumer
- Because of the low risk associated with floating, it’s likely a calibrated sensor is overkill
- Initial testing and following manufacturer’s recommendations for cleaning and bulb replacement should be enough for now