Something in the world of floating have you stumped?
The Model Aquatic Health Code is a major change to how the float industry is likely going to be regulated in the future. It has been the subject of lots of whispers and rumors throughout the industry, making it almost like a bogeyman for float centers. Ashkahn has worked closely and advocated for the industry along with members of the Float Tank Association and several others.
He helps explain where it’s at in the process now that the version has been finalized, what that means for float centers, and what to expect after it becomes implemented.
The 2018 Model Aquatic Health Code (relevant float tank sections are 4.12.10A – 4.12.11A(pg.101-107) and 5.12.10A – 184.108.40.206.2.1 (pg. 138-147))
- View Change Requests here (type in “float” in the search bar to bring it right up. You’re looking for “4.12.11 and 5.12.11-001” )
The CDC’s Previous drafts of the MAHC
Listen to Just the Audio
Transcription of this episode… (in case you prefer reading)
Graham: Today’s question is, “I’ve been hearing a lot about the Model Aquatic Health Code. What is it, and should I be worried?“
Ashkahn: Yeah. So, this is definitely one of the kind of bigger new developments in the world of float tank regulations that you probably have been hearing a lot about in the last year-ish, that-
Graham: Unless you’ve been hiding under a little salt rock somewhere.
Ashkahn: So, I guess let’s break it down a little bit, before we get into any of the float tank stuff. What is the Model Aquatic Health Code?
So, the Model Aquatic Health Code is what’s called a Model code, and it’s kind of formed by the CDC, Center for Disease Control, and it’s basically kind of the answer to what they define as the problem of there being a huge variety of pool and spa, or “recreational water”, as they define it, kind of codes around the United States, and even around Canada and other parts of the world. But right now, every state has their own pool code and sometimes counties have their own pool codes, and there can be differences from state to state and city to city, and every place has to update their code and keep it up to date with new information, and that can kind of fall behind, and they have so many different organizations, so many different health departments, some of whom are for small areas that don’t have a ton of budgeting and stuff like that to be constantly researching stuff and keeping their code up to date.
The results are that for one thing, you do find different codes for place to place, and also sometimes health codes or pool requirements haven’t been updated in areas for 20 years, 25 years, as a result of it just being kind of an expensive and difficult process to go through. So, in an attempt to solve this problem or kind of make everything a little bit easier on everybody, there’s been this push to create Model codes.
So, it’s kind of an interesting thing to think about because in your head, you think, maybe we could just create a federal pool code that just happened on the national level, but-
Graham: And that is totally, absolutely not how things are done here in the United States.
Ashkahn: No. So, it’s not like the federal government is making a pool and spa code that every state has to follow.
Instead, what’s happening is that some organization, and this not the only Model code that exists. There are other ones from pool and spa associations and stuff like that, but this does seem to be the one that’s actually kind of gaining the most traction and people are looking at.
So, the CDC has created this Model code that they call the Model Aquatic Health Code, and basically they take that document they’ve written up that they think is basically just a really awesome pool code. It’s up to date, kind of based on modern research, it has a lot of thought throughout it, it’s kind of relying on a bunch of expertise and all this stuff. So, they put this document together that they think is super awesome, and they put it on the internet, on a website. That’s as much authority, actual legal authority, as it actually has. It is literally just a PDF on a website.
Graham: Kind of like this podcast, it’s just one big suggestion, you know?
Ashkahn: So, that’s as far as it goes. The CDC can’t actually enforce it as a document, as themselves an organization. What they’re hoping happens it that different states will look at this PDF on a website and they’ll read through it, and they’ll be like, “Wow, that’s some freakin’ awesome pool code. It’s way better than our pool code, it’s up to date”-
Graham: Bring it over here.
Ashkahn: Yeah, and they’ll be like, “What we should do is we should ditch our pool code and replace it with this, the Model Aquatic Health Code.” The more states or counties or health departments that look at this and go, “Yeah, give me some of that Model Aquatic Health Code” and replace their language with it, the more you have created that uniformity you’re looking for, right? Now there’s all these different places that are pulling their information from one source.
And as the Model Aquatic Health Code updates, hopefully they’ll keep their stuff updated as well, and they don’t have to rely on kind of internally making sure they’re responding to new information or new data that’s coming out. They can kind of rely on a single source that’s doing a bit more vetting of information.
So, that’s kind of the logic behind why this exists, and I think what they’re going for as a document.
Graham: Yeah, but it should be noted too that when the states adopt them, they can adopt it in whole. It still has to go through kind of this whole process of what you’d put pool and spa into effect with as the state, so there’s a big internal process that just goes into that adoption.
Even when they adopt it, they can decide, again, to take everything in whole, or they can just take parts of it and say, “These parts make sense. Some other stuff we want to do like we’ve always done it. We’re not going to include these sections.” So, they can take it and just totally piecemeal, except parts or sections of it.
Ashkahn: Or just take inspiration from it. Not take any of the actual language, but be like, “Hey, this is a good idea. We’re gonna implement it, but we’re gonna kind of implement it in our own way.” So, there’s really any level of influence, or they could completely ignore it. That’s the other thing to consider. States might look at this, be like, “Nah. We’re just gonna, we got a good thing going.”
Graham: “We got it.”
Ashkahn: Yeah. So, when you talk about the impact this could have or how fast this could roll out or who it would apply to or these kind of much more concrete questions that I think people have, especially with this float tank stuff we’re starting getting into, it can kind of be hard to answer them because you really, we don’t know. We don’t know how much people are going to look this language, adopt it, take inspiration from it, ignore it, implement it but implement it 10 years from now, implement it from grandfather people in, there’s so many different scenarios in terms of the kind of reach that something in the Model Aquatic Health Code has.
Graham: Just to take a time-out right now, I should say, too, that Ashkahn played a pretty large role dialoguing back and forth with people in the CMAHC, the Council for the Model Aquatic Health Code, about lots of the float tank code that has now been voted to be included in there, which we’ll get to a little later. So, if I seem to be sitting on the sideline and mainly cracking jokes during this process, it’s because Ashkahn is much more officially educated on this than I am, so I apologize, listeners, but-
Ashkahn: The jokes add some spice.
Graham: Thanks, buddy. I appreciate it. Anyway, I’ll let Ashkahn go back to monologuing now, and you’ll hear me chiming in occasionally.
Ashkahn: Okay. So, still before we jump into the actual float tank stuff, the other thing to consider is just a little bit about where the Model Aquatic Health Code itself is as a document, in terms of how widespread it is, and it’s actually kind of interesting to look at. There’s actually so far only one state in the United States that has fully adopted the Model Aquatic Health Code, which is New Mexico, and it took them three years or something, three and a half years, I think, to actually do it from the part to get it through their legislative process and all the things they have to do to make it kind of official regulations.
There’s a few other states that are kind of on the path there, and there’s certain districts or counties that are working on it, and there’s other places that have adopted parts of it, or again, like I said, just taking inspiration from it, but it’s not like half the states in the country have fully adopted the Model Aquatic Health Code and this language is currently already very uniform.
Another one of the reasons for that is this is pretty new. Not just the float tank stuff, the whole thing is a relatively new concept. Version one of the Model Aquatic Health Code came out I think in 2014, so not that long ago, and we’re currently on version two and version three is coming out this summer. So, just as a concept in the pool and spa world, this is amongst the kind of newest developments that happening.
Graham: Even when we go out to these conferences, there’s a fair amount of talks about the Model Aquatic Health Code and oftentimes they even start how we do when we’re talking about float tanks. How many people are very familiar with this, or have read through it, and there’s people just who are health regulators who aren’t very familiar with the Model Aquatic Health Code at all.
Graham: So, even within the pool world, there’s still a large amount of education and adoption still to go from their standpoint.
Ashkahn: Sure. So, okay. Now we can actually talk about the float tank stuff. How do float tanks fit any of this? Well, what happens is the Model Aquatic Health Code goes through a routine update process. It used to be every two years. They just switched it to every three years, and in this update process, people can submit new changes, or edits, or things they want to see either added to or changed in the current Model Aquatic Health Code language. This last round of updates, which happened last year, 2017, basically had a huge new section that was aiming to include float tanks into this document with regulation written about them. That was the process Graham was mentioning that I played a big part in, and other people in the industry played a big part in, and the process… wrote up the language they thought would be good rules for float tanks, and then the whole thing went up for vote, and people who were members of the Model Aquatic Health Code or the council for the Model Aquatic Health Code got to discuss it and vote it in or vote it out.
We just found out not too long ago that it got voted in. So, this thing has actually been voted in. It wasn’t that huge of a landslide or anything. It was, I think, around 60-40 of it being voted in, which is, a lot of the stuff if you see the changes in there, got voted in at 90% or above, or voted out 90% or above.
I will say, too, there’s one final step that actually needs to happen. The CDC itself needs to actually give a final approval for everything, so there’s a chance, I’d probably say a smaller chance, that the whole thing gets rejected before we ever see it actually implemented.
But it is voted in now, and that basically means that again, as long as the CDC approves it, they’re gonna write it into their next version of the Model Aquatic Health Code, which will be released in July of this year, 2018. Again, that’s the point where it just becomes a PDF on a website, right? So, now we have to, from that point before this has any impact on anybody, a health department has to look at that document and decide they want to either adopt it as regulation, they want to adopt it as a guideline, which is usually a faster process than regulation, but slightly less enforceable. They want to just take inspiration from it. They read it and say, “Oh, this is great float tank language. I’m gonna write my float tank language kind of based off this logic.” Or they decide to completely ignore it. All of those things are options, or they decide to adopt it and grandfather existing people in. There’s all these different directions that it can go.
Graham: It’s interesting to me specifically the float tank side, how that plays out. I have no idea how it will, but the fact that float tanks are so weird and new and that a lot of people don’t have any preexisting float tank code in their state or county pool codes means maybe that whole inspiration side of things plays a much bigger role in this one, even in just inspiring them to pay more attention to float tanks or something like that. Anyway, I think that we’re in a weirder position in that divide between adoption and inspiration and all of that being float tanks than a lot of pool code where it’s likely, again, that people already have this certain way they’re doing it or something like that.
Ashkahn: Yeah, there’s definitely a certain kind of filling the vacuum thing that might happen. We might see the float tank section specifically get adopted much faster than the other stuff in the Model Aquatic Health Code because it’s not replacing their existing practices. It’s just filling a gap. I could totally see a health department representative finding out float tanks are opening in their area, having no idea what to do about it, finding that the Center for Disease Control has officially made a set of rules to keep float tanks safe and think, “Great. Done. I don’t have to worry about this. I can just grab this language.” I could totally see the reality of something like that happening.
So, what’s in there? What is the float tank language? So, before they actually release their language in version three, you can still read what got voted in and what will end up in the Model Aquatic Health Code language. If you go to the CMAHC’s website, which is just cmahc.org, you should see in the left column something called “Change requests,” which is what all of the edits are, and something where you can hit “View change requests,” or you can type into Google, “CMAHC view change request,” and it’ll give you a direct link to it. Then in that search box, if you type in “floatation,” you’ll actually see the little change request about all the float tank language. You can click on that, and you can actually read what the language is.
It’s a bit lengthy. It’s 15 pages or something like that, and one of the reasons is because we kind of fought hard for everything that they wanted to apply to float tanks to be written in specifically in the float tanks section. Because what we didn’t want to happen is them to just reference other sections in the Model Aquatic Health Code, like, “Float tanks also have to follow this section,” because what can happen then is in the future, they could update those sections, and their updates might make sense for pools and spas, but might not make sense for float tanks, but because it’s by default applying to all that stuff, we could end up in some weird situations.
Graham: I’m gonna take that for a second and unpack into layman’s terms, because in this case I think I’m closer to a layman myself. Which is just, so it started with just the relatively short document, but then that document, as does much of the Model Aquatic Health Code, referenced other big parts of the Model Aquatic Health Code, saying, “When you include skimmers, pay attention to the skimmer section.” But then it would say things, but only these sections have the skimmer section because some of this stuff obviously only applies to pools, so take these three parts of the skimmer section and include that, and then the skimmer section would reference other things, and at some point, we’re just like, we can’t even pay attention to the interdependencies here.
So, that’s why it turned into this argument to actually take that language from other parts of the Model Aquatic Health Code and include it directly in what now turned out to be a relatively lengthy 15 page addition. So, again, just a little non-technical summary of that.
Ashkahn: Yeah, some of that stuff is just copy and pasted of other sections of the Model Aquatic Health Code, and some of it is copy and pasted with kind of some minor changes to it.
Graham: And then there’s that one fart joke that we managed to sneak in it.
Ashkahn: Section 220.127.116.11. So, there’s a lot in there, and a lot of it is probably not that crazy. Some of it’s just like, “Health departments are allowed to permit you,” and “You need to get a permit from your health department,” real kind of basic language.
But then there’s other things in there that are decently impactful on float centers, and some of them are things that I think a lot of people in the industry would look favorably upon. Some of the biggest ones are the fact that chlorine and bromine are not required. In fact, not really recommended in the language. It specifically says that you can use either a UV system, or an ozone system, or a combination of the two to be able to keep your float tanks clean.
Graham: Which is-
Ashkahn: Which is huge, right?
Graham: That’s a giant, as far as the number one thing that I’ve heard centers that are just opening complain about and butt heads with their health departments the most about, that’s pretty much it. They don’t want to use chlorine or bromine, and the health department absolutely is not going to let them open unless they do. So, having it written in that people are allowed to not only allowed to use alternative methods, but are recommended to use something like UV or ozone is humongous.
Ashkahn: Yeah, and it might mean that those states that are sticking by chlorine won’t adopt the Model Aquatic Health Code-
Graham: Or just won’t adopt that portion.
Graham: Again, they could adopt every other part of it and just say, “And, you know what? Chlorine Is also required,” again, because they can do in part or in whole or whatever they want.
Ashkahn: But the very fact that the Model Aquatic Health Code came out with that language is a lot stronger of an argument that you as a float center trying to convince your health department. So, that part I think a lot of people would look favorably upon.
There is some confusion about hydrogen peroxide. You’re not supposed to use hydrogen peroxide as a disinfectant, which makes sense, right?
Ashkahn: So, that means you’re not just putting hydrogen peroxide into the float tank and relying on that to keep everything safe.
But you can use hydrogen peroxide, as long as you call it an oxidizer or a water clarifier, and so as long as you’re going about this the right way and saying the right terms, that means a UV/hydrogen peroxide kind of system is actually allowable in this Model Aquatic Health Code language.
Graham: And the UV in this case, of course, is the actual disinfector, the sanitizer.
Ashkahn: Yeah, that’s the thing that’s doing the disinfecting, or the ozone.
Other things that I think people would probably look favorably upon, there’s a requirement for three turnovers. That can be less than what some health departments are going for nowadays – four or five turnovers. Stuff like that can have a big impact on your equipment.
There’s not a requirement for NSF certified pumps. I know some people hit that problem, where they can’t have a magnetically-driven pump because it’s supposed to be NSF certified, and NSF certified magnetic pumps don’t really-
Ashkahn: Appear on the market. Exist.
There’s not a requirement for an NSF-certified filter, so that leaves rooms for bag filters and stuff like that that some manufacturers use. There’s definitely kind of some leeway in there on things that some people don’t get leeway on when they’re working with their health departments.
Probably the biggest thing of kind of impact that people might notice if this were actually to be adopted and kind of enforced on you in terms of your center is the actual requirements for ozone and UV, and what they’re looking for out of an ozone and a UV system.
With UV specifically, the requirements are a few things that may not make exact sense to you right away.
Graham: It’s all very complicated.
Ashkahn: The big ones really in there are a requirement for a calibrated sensor, and that the UV light passes the NSF-50’s disinfection efficacy testing. So, those two are things that most likely your UV system in your float tank has not done, or does not have. Most manufacturers are selling equipment that does not/will not meet those requirements, and part of the problem is that the UV systems that do meet those requirements tend to be in the $10,000 range, and that’s kind of the biggest hurdle that I think you’ve heard a lot of people talking about the Model Aquatic Health Code. Once the language got really kind of edited to its final form, that’s really one of the biggest things in there, is that the, to get a UV light that would actually meets the requirements is currently a pretty expensive proposition.
That’s for a few reasons.
Graham: Just to back up really quickly. So, you mentioned right there that there’s this requirement that it meet the NSF-50 disinfection efficacy testing, but there’s not actually a requirement that it be NSF-50 certified itself, or the UV lamp. Do you want to, just for people who aren’t as familiar, you want to break it down a little further?
Ashkahn: So, yeah. You can take your UV light you take it to this organization, the NSF, and they would certify it. They put it through this whole testing process, and a lot of commercial UV systems have gone through that and are NSF certified. The problem is that that can be a really expensive process.
So, usually the systems you see certified, NSF-50 certified, are pretty expensive, big, serious commercial UV systems. When you see kind of the smaller residential units that these companies sell, they usually don’t go through the trouble of paying to have it NSF 50 certified because it’s not worth the expense for them.
So, this language is a little more flexible than that, you don’t have to actually have your UV system certified to all the requirements that are in NSF-50. You just have to have the testing part of it, the part where they actually test that your UV light can kill the certain bacteria. Their disinfection efficacy testing, that’s the test they want to see passed, and you don’t actually have to have it tested at NSF or anything. You just need any kind of ANCE accredited lab-
Graham: Send it to the Daily Solutions Podcast, throw it through the ringer.
Ashkahn: We can have it.
Ashkahn: To show that it’s passed that test. So, there is flexibility in the language there, and in some cases, that does come in useful. In reality, a lot of times if you’re gonna find a unit that’s passed that test, it’s probably the units that have been certified, so usually those things kind of go hand in hand, and it still kind of pegs you into that corner a little bit.
The other part of it, the calibrated sensor, is another interesting one. So, that’s an actual sensor that will be able to detect the UV waves that are going through the solution in your UV system, and it measures them on the other side of that. So, the idea of having a sensor in your UV system is so that if your light bulb starts to diminish in terms of its power that it’s putting out, or if there’s cloudiness in your water, turbidity or anything, or if there’s something built up on the quartz sleeve or whatever other encasing you have for your UV bulb, all those things can lower the amount of UV, the effective UV, that’s actually influencing in your system, and can actually lower the amount of disinfection you’re doing. So, the sensor is there to be able to pick up on all that, and say, yes, the light bulb is working fine, and your sleeve is clean enough that the UV waves are getting through it, and the liquid itself has a high enough transmission that the UV waves are getting through that effectively as well.
So, that’s giving you a live readout confidence that the system’s working correctly, and there’s other ways to deal with some of that stuff. The UV bulbs usually can have control systems in the UV unit itself called a ballast that’ll be able to detect if the UV bulb’s not getting enough power, and you can also do routine cleaning of your UV sleeves and stuff like that to make sure that you’re following all the best practices and these problems that could lower the amount of effectiveness that the UV is having, you’re avoiding by doing proper maintenance.
Graham: One of the suggestions that we had as we were going through this process, and that we actually tried to get some of the language in there changed to was some of those preventative maintenance protocols and also just taking samples of your water in for regular lab testing, bacteriological testing to make sure they’re staying clean and that your tanks are not getting people sick, basically.
The interesting part, I guess, too, is the calibrated sensor stuff, all of this stuff about the UV, wasn’t just added in because of extra concern about float tanks specifically. This is kind of language that they’re trying to add into the Model Aquatic Health Code wherever UV lights are used.
Ashkahn: Yeah. They’re trying to get everybody on this.
Graham: This is a Model Aquatic Health Code thing-
Graham: That they want to have those sensors on all the UV lights because in their mind, it’s the easiest, best guarantee that the lights are working properly and actually doing the disinfecting that they should be.
Ashkahn: Yeah, and really, the unfortunate thing is just the cost, in my mind. If it wasn’t for the cost, it kind of makes sense to me. I understand why you’d want to have sensors. There’s all sorts of maintenance and testing and stuff like that that can give you confidence, but there’s definitely another level of confidence that comes from continuously monitoring something and always having a readout telling you that it’s fine.
Graham: Oh, yeah. If there were a $100 part that we could attach to a UV unit, we would have them on all of ours, too.
Ashkahn: Because there’s other factors with UV, too, that you’re hoping your manufacturer did their research into, but UV lights sometimes don’t get … they take 10, 15 minutes to warm up before they’re actually hitting their kind of effective output. So, if you have a UV unit like that and you’re just running it for 15 minutes between every person, you might never actually be getting to the point where it’s putting out the proper amount of millijoules.
So, that can be prevented by your manufacturer making sure they purchased the right part, and having tested that themselves, but there is something nice about having a quantifiable readout.
The problem is these, just the sensors, tend to be $1,000 in terms of having a part, and the units they build those expensive parts into are again, these big commercial units. Sometimes, and part of the expense comes from having these extra sensors, having it go through some sort of certification, but another part of the expense comes from the fact that these units are usually built for things much bigger than float tanks. They’re built for 100-500,000 gallon pools, and they’re built for flow rates of 100-150 gallons per minute, and as a result, they’re much bigger than we probably need on float tanks. So, there is also a possibility that we might see some UV units that meet these requirements, that someone builds more appropriately sized for float tanks, that might come at a lower cost than this $10,000 range. If someone really tries to specifically make one for the right flow rate we’re doing and stuff like that, the price could come down. I doubt it’s gonna come down to the cost of what UV systems I see a lot of float tanks using-
Ashkahn: $800, $900 systems.
Graham: Yeah, $1,200, $2,000, kind of that range.
Ashkahn: So, that’s just a tricky one. Again, we’ll see if states actually decided that this is important, or if they decided that this is kind of overkill and float tanks just aren’t really risky enough of an environment to warrant having that expensive equipment on there. That would just be kind of to be determined, but that’s definitely the biggest, most impactful thing that I think that’s kind of in this language.
I’d say the other one is that they have, for new centers, so this only applies to new construction in the Model Aquatic Health Code, they do want to see float tanks being kind of VGB compliant. So, that usually means having two separate inlets rather than just one, that some float tanks come with. So, that’s another one that you may see, but in their language, it specifically just applies to new centers, as opposed to the UV thing, which if someone just adopted the Model Aquatic Health Code word for word, would actually apply to existing centers as well, meaning existing centers would have to go buy new UV equipment and install it in their tanks.
Graham: Yeah, you’d need some kind of written exception or variance to get by that if it just got adopted.
Ashkahn: Mm-hmm. So, there’s a lot. That’s a lot about the Model Aquatic Health Code. Again, the language is fully available and is worth kind of looking through. There’s a few other things in there that are interesting to read, and we’ll really just see what ends up happening with this. If it’s adopted, if when it’s adopted float centers are able to convince their health departments to not follow parts of it or change the language or … there’s so many different ways that this could go down from place to place, so something to keep your eye on.
Graham: If you want to get even deeper into it, too, the entire process kind of took place between about January, February-
Graham: Of 2017, up through-
Graham: October, when it got voted on. As a result of that, there is a bunch of changes that have been made. There’s a bunch of comments on the potential, on the change request before it got voted on. You can actually go back and look at those comments online, too. You can see things from us posted up there for things we wanted to have changed, stuff from the Float Tank Association, from Jason McDonald, health regulator up in Canada. So, there’s this whole deeper process that happened getting to where we are now, and I guess just to review, going forward, too, this won’t be adopted until, or the new code won’t actually go into effect until the summer, and from there it could be years before we actually see it adopted by states, or it could be a much quicker process is they’re just putting it into guidelines.
Graham: So, what from happens from here is actually just a giant question mark.
Ashkahn: Like I mentioned before, the Model Aquatic Health Code has its now update process. So, in three years, in 2020, they’ll be going through another update cycle, and anybody who wants to be a member, which includes anybody who pays their membership fee, you don’t have to have any requirements, can submit their changes. If they want to see something edited in this float tank language, you can submit an edit for it and that’ll go through the process of being discussed and voted on and all that stuff for the next version of the code.
Graham: And …
Ashkahn: I think we did kind of a decent little break down of the Model Aquatic Health Code.
Graham: Yeah, could probably go into more depth, but let’s leave it there. If you have any more questions about it though, definitely send them in to floattanksolutions.com/podcast and it’ll give me a nice little break episode while I let Ashkahn ramble on about code language some more.
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