There has been a big development in the world of float regulations recently. You may be hearing people talking about something called the MAHC, and you may have no idea what those crazy little letters mean, but that’s ok. We’re going to take you on a little journey here, and on that journey we’re going to attempt to answer three main questions: What is the MAHC? What does it have to do with float tanks? And what impact will this have on your float center?
What is the MAHC?
The MAHC stands for the Model Aquatic Health Code. This is a document put out by the Centers 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). The MAHC includes everything from the process of getting permits to the specifics of facility construction to the types of disinfection and filtration equipment that are allowed to the frequency of health inspections. 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 regulations (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, including jurisdictions internationally.
The MAHC goes through a process every few years where it gets updated, and 2017 was one of those years. It’s this last update that is of particular interest to us here in the float industry.
What does the MAHC have to do with float tanks?
In 2017 the Model Aquatic Health Code decided to include a section on float tanks in the new version of their code language. The process of including new language in the MAHC involves many steps, and can often take one to two years (or longer) to complete. The MAHC has an organization called the CMAHC (the Council for the Model Aquatic Health Code) that oversees and facilitates the development of the MAHC.
In the case of language involving complex topics, like float tanks, the CMAHC will often put together an ad hoc committee to help develop the suggested code language. Once the language is discussed and written it is then submitted to the CMAHC as what they call a Change Request. These Change Requests then go through a process of review by the CMAHC’s Technical Review Committee, and they are also up online for people to comment on what issues they may see with the language. Some minor changes can sometimes be made during this process, but often it is more of a place for discussion. This discussion can be important because the actual decision to adopt or reject the proposed language is determined by a vote of the CMAHC members.
Anyone can become a CMAHC member by paying a membership fee (although health regulators have a more heavily weighted vote). Being a CMAHC member also means you can submit your own Change Requests during these update cycles.
The proposed language on float tanks went up for vote in October of 2017 and passed 58.8% in favor to 41.2% against (a relatively small margin compared to the rest of the Change Requests which were typically over 90% in favor or against). From there, the CDC itself actually looks at all the passing Change Requests and gives them final approval. About 90%-95% of the Change Requests that were voted in typically get approved by the CDC. The CDC approved Change Requests are then edited into the existing MAHC document, and the new version with all the changes and additions is released in the summer at the start of the swim season. This means the 3rd Edition of the Model Aquatic Health Code, which includes the new float tank language, is scheduled to be released in July of 2018.
So, that leads to the big question, what’s in the actual float tank code language?
The entire float tank language being adopted into the MAHC can be read here. (type in floatation into the search bar and it will be the only result)
(Update: Version 3 of the MAHC has now been released. You can find the document here, and read the float tank parts, which are sections 4.12.10 and 5.12.10)
It’s a decent length document, and a lot of it has to do with pretty run-of-the-mill-stuff (eg, you need to get a permit through your health department before you open, or you need to keep a copy of the plans you submit, etc), but there are also some pretty significant things in there.
The biggest point of discussion between float centers and their health department typically revolves around how the float solution itself is actually cleaned. Many people in the float industry may be happy to know that this code does not recommend the use of chlorine or bromine, and instead states that UV and/or Ozone can be used as the primary source of disinfection (there’s a little bit more nuance to this which we’ll get into).
A few other notable things include the requirement for 3 turnovers between floaters (as opposed to 4 or 5 turnovers we see in a few states), allowing the use of hydrogen peroxide (as long as you call it an oxidizer or water clarifier and not a disinfectant), and no requirements for NSF certified pumps or filters, which allows for the magnetically driven pumps and bag filters that are commonly found on float tanks.
There are also a few things in there that are a bit more rigorous than what many float tanks currently come built with. One of them is that new float centers will need to have their float tanks comply with VGB code, which usually means the float tank has two pipes sucking water into the filtration equipment rather than one. There are a good number of float tanks that already come like this, but not all of them. There is also likely a lot more paperwork and general protocol in this code than many float centers are used to doing, things like record keeping on your HVAC system, or having written out response plans to contamination incidents.
One of the biggest changes in here to the requirements that many float tanks are used to meeting comes in the details of the UV and Ozone equipment that is allowed. All UV and Ozone equipment must pass certain performance testing, specifically the microorganism testing that the NSF does when certifying UV and Ozone equipment for use in commercial pools. This doesn’t mean that the units actually have to be NSF certified, nor does it mean they need to be tested by the NSF, it just means an accredited lab needs to test it to that protocol. (In reality though, most of the time that a UV or Ozone manufacturer goes through this testing process they generally take the extra step and go through the full NSF certification process.)
The other big disinfection requirement is specific only to UV. Under this code language, all UV lights must come equipped with a calibrated sensor. This sensor is something that sits in the UV chamber and actually detects the amount of UV energy that goes through float solution. There are lots of reasons that your UV light could not be reaching its designed performance: your UV light bulb could be getting old and not able to produce as much UV, the protective sleeve around your UV bulb could have a build up of oils or other deposits on it that could be blocking the UV rays from getting to the float solution, your float solution might have a level of cloudiness or particulate in it (sometimes relatively undetectable to the human eye) that doesn’t allow the UV to penetrate as well through the solution, or your UV light could take time to warm up to actual operating capacity and might not actually be providing its full UV output for the first 10-20 minutes of running (which for most float tanks is the entire filtration cycle). If your UV light has a sensor, it can detect when any of these situations is happening and alert you to it.
So far this all sounds pretty nice and dandy, right? Having a UV light that has been tested to show that it can kill harmful microorganisms effectively with an alert system that tells you if it’s ever not performing to that level is a reliable way of running a clean float tank. The downside here really comes from the price of these systems. While most float tanks are currently using a UV system that costs between $600-$1200, an NSF tested UV light with a calibrated sensor typically costs $5,000-$15,000. Part of the higher price comes from the extra equipment in these units (just the sensors seem to cost about $1000), part of it comes from the cost the manufacturers have to pay for the independent testing, but part of it is because UV and Ozone units that come with these sorts of features and independent lab testing are typically only manufactured for large commercial applications. The pools and spas that use them only need to install one or two systems for their whole facility, and they’re typically pumping water at a much higher flow rate than float tanks, making much of the equipment you find out there that can meet this code oversized for float tanks.
While a calibrated sensor does get you continuous real time verification that your UV light is performing correctly, there are good operational practices you can employ that help reduce the risk of a poorly performing UV unit. You can clean your UV sleeves on a routine schedule to prevent any build up of oil or deposits. You can replace your UV bulbs on a conservative schedule before they risk weakening, or some systems come with indicator lights that can detect when the bulb needs replacing. You can purchase a UV light from a reputable company that has done internal performance testing on their units. You can make sure to maintain good clarity in your float solution (although this can be the hardest one to quantify on your own). And you can ask the UV company for information on how long it takes the UV light to warm up to full operational capacity.
Float tanks are generally considered to be less risky environments for the transmission of disease than pools or spas, and there is an argument to be made that this lower risk profile justifies less stringent equipment requirements and a heavier reliance on good operational practice. There is also a possibility that float centers and manufacturers being required to purchase UV units with sensors and independent testing will create a market demand that will lead to UV manufacturers building systems tailored to the float industry, systems that meet these requirements but come in at a much cheaper price point.
All in all this has the potential of having a big impact on the industry. Some will say this is a good thing for the industry, and will lead to better and more consistent sanitation practices that are based on continuous quantifiable information. Others will say this is overly burdensome and unnecessary for an industry that currently hasn’t had a single case of illness reported from any commercial float center. Whether good or bad, the actual impact of the MAHC code and how many float centers will be required to follow it is not as clear cut as you may think.
What impact will this have on my float center?
This, unfortunately, is not a question that has a clear answer right now. Like we mentioned before, this is a model code. That means it by itself does not have any authority, and is not a legal requirement for anyone. In fact, it’s really nothing more than a nice pdf that the CDC put up on a website.
It’s only when a local health jurisdiction (a state, county, city, etc) decides to take this code language and adopt it as their code language that this becomes enforceable. And whether any jurisdiction decides to do that is up to them. Even if they do decide to adopt it, they can decide to adopt it in full, or only in part, or edit it as they see fit, or simply take inspiration from it while writing their own float tank code. Or they may choose to ignore it completely. The actual process of a jurisdiction adopting this can happen relatively quickly or it can take years (it took New Mexico over 3 years to fully adopt the MAHC), and even after that point they can decide to grandfather in existing float centers, or give centers something like 10 years to comply with the new requirements, or they could require everyone to update their centers right away.
All of this is to say, there are a whole lot of different directions this can go, and it’s very early to determine how health departments will respond. There is a possibility that it takes a while for the information to spread or that it’s generally ignored. There is also a possibility that this float language is adopted much faster than other sections of the MAHC. Unlike the other sections of the MAHC that mostly deal with pools and spas, health jurisdictions don’t currently have any language on the books for float tanks. Replacing existing rules and regulations with new ones is a much more difficult process than simply adding new rules, and we could see health departments adopt this float code much faster because it can be seen as “filling a vacuum.”
Whether you think this code being adopted by your health department is a good thing or a bad thing probably depends on the context of your current situation. There are some float centers that are either currently unregulated or under relatively light regulation. Adoption of this float language might seem like a new burden to them or a significant economic blow due to the required equipment changes. There are other float centers that are currently under heavy regulation – or regulation they don’t agree with (like a requirement for chlorine and bromine) – and this MAHC language could lead to their health department removing some of those requirements. This code could also influence health departments as they are approaching writing float regulations for the first time, convincing them to allow UV or Ozone as a primary form of disinfection when wouldn’t have otherwise, or leading them to write more robust requirements than they would have on their own. It will be up to float centers and the float industry to work with health departments as they start to look at the MAHC to make sure things develop as best as they can.
It’s also important to know that this is an ongoing process. Like we mentioned before, the Model Aquatic Health Code has an update cycle that happens every three years. As an industry we can participate in these updates cycles, and even submit changes we would like to see made to the code. We can continue to generate sanitation research and best practices to help inform code processes like this. We can continue working with health departments to have a say when they are making decisions on how to implement float regulations. Most importantly, we can continue to run safe, clean float centers so that our industry can continue to grow with the good track record it has now.
We also covered this whole topic pretty heavily in episode 63 of the Daily Solutions Podcast.