HSE Spa Pool

Health and Safety
Executive
The control of legionella and other

infectious agents in spa-pool
systems
Spa-pool systems are a recognised source of diseases caused by
infectious agents including the organism that causes legionnaires’
disease, primarily Legionella pneumophila. There have been a number of
outbreaks linked to spa pools in leisure centres, hotels, holiday homes,
on cruise ships and on display.
This guidance is primarily for those who manage or operate spa-pool
systems and explains how to manage and control the risks from
legionella and other infectious agents. It will also help service suppliers,
designers, manufacturers, importers, suppliers and installers of spa-pool
systems meet their legal responsibilities.
As well as guidance on operating and maintaining commercial-type
HSG282
systems, there is specific advice on domestic-type spa pools or hot tubs
Published 2017
used as part of a business activity, for example in holiday park rental
units, hotel bedrooms with a dedicated spa and systems on display or at
exhibitions. The guide includes advice on effective ways to safely
manage and control spa-pool systems through:
design, commissioning, operation and maintenance;
testing and monitoring spa-pool water quality;
quality and frequency of inspections.
The control of legionella and other infectious agents in spa-pool systems Page 1 of 62
Health and Safety
Executive
© Crown copyright 2017

First published 2017
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This guidance is issued by the Health and Safety Executive. Following the
guidance is not compulsory, unless specifically stated, and you are free to
take other action. But if you do follow the guidance you will normally be
doing enough to comply with the law. Health and safety inspectors seek to
secure compliance with the law and may refer to this guidance.
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Contents
Introduction 4
Section 1: Legislative requirements 6
Section 2: Types and settings 20
Section 3: Design and commissioning 24
Section 4: Operation and maintenance 32
Section 5: Testing and monitoring water quality 44
Appendix: Spa-pool checklists 52
Glossary 54
References 58
Sources of information 60
Acknowledgements 61
Further information 62
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Introduction
Scope and application
1 This guidance is aimed at dutyholders, including employers and

those who manage and/or operate spa-pool systems, to help them
comply with their legal duties under health and safety legislation. It also
sets out the responsibilities of service suppliers and designers,
manufacturers, importers, suppliers and installers of spa-pool systems,
including contractors. There is practical guidance on how to assess and
control the risks of exposure to legionella and other infectious agents to
staff, users, and anyone else potentially exposed to the spa-pool water
or aerosols from it.
2 There is guidance for maintenance staff, consultants, environmental
health officers, cruise-ship operators, tour operators, rental companies,
holiday lets and organisers of events where spa pools are used, hired
or displayed.
3 Other water systems, including evaporative cooling systems, hot and
cold water systems and other risk systems, also need to be managed
under health and safety legislation. Further information is provided in
HSE’s Legionnaires’ disease: Technical guidance (HSG274).1
Background
4 A spa pool is a self-contained body of warm, agitated water

designed for sitting or lying in and not for swimming or total body
immersion. Spa pools contain water heated usually between 30–40 °C,
which is filtered and chemically disinfected. They have air-jet circulation
with or without air-induction bubbles and can be sited indoors or
outdoors. Such systems have the ability to produce aerosols by means
of air jets or similar devices. A spa pool is usually drained, cleaned or
refilled after a number of bathers or a maximum period of time rather
than after each bather.
5 Spa-pool systems are increasingly popular and can be found in a
variety of sizes and settings ranging from sports complexes, health
clubs, hotels and holiday complexes to cruise ships, private houses, and
on display in showrooms or exhibitions. Spa pools have a much higher
ratio of bathers to water volume than in swimming pools, so their water
has a higher concentration of organic material from bathers.
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6 There have been a number of outbreaks, including fatalities, linked to

spa-pool systems in leisure centres, hotels, holiday homes, on cruise ships
and on display. These systems pose a reasonably foreseeable risk as they
have environmental conditions that could potentially allow and support
growth and dispersion of legionella and other infectious agents where:
water is stored or recirculated;
water temperature in all or part of the system is between 20–45 °C;
these systems can support microbial growth;
water droplets are produced and dispersed as aerosols;
there is the potential for exposure to any contaminated aerosols.
7 The organism that causes legionnaires’ disease, primarily Legionella
pneumophila, frequently grows in poorly designed and managed spa-
pool systems. Other bacteria including other legionella species,
Pseudomonas aeruginosa and environmental mycobacteria, are also
commonly found in spa pools and can cause infection. These can be
introduced into a spa pool from the wider environment or the water
source itself, and Pseudomonas aeruginosa may also be introduced from
the bathers themselves.
8 Spa pools are designed to contain water that is vigorously agitated,
which leads to the formation of aerosols that can be inhaled. The water is
usually maintained within the temperature range where legionellae and
other infectious microorganisms can rapidly grow (20–45 °C) and the high
organic content of spa-pool water makes it difficult to maintain effective
disinfection. Spa-pool systems must therefore be managed carefully to
ensure water quality does not encourage microbial growth and pose risks
to users, people in the vicinity or passing near the spa pool.
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Section 1: Legislative
requirements
Health and safety law
9 This guidance provides specific information on the health and safety

law that applies. General duties under the Health and Safety at Work etc
Act 1974 (HSW Act)2 extend to risks from legionella bacteria and other
infectious agents which may arise from work activities, and dutyholders
must ensure the health and safety of their employees or others who may
be affected by their undertaking.
10 The Management of Health and Safety at Work Regulations 1999
(MHSWR)3 and the Control of Substances Hazardous to Health
Regulations 2002 (COSHH)4 impose certain statutory duties on those
who manage spa-pool systems.
11 The MHSWR provide a broad framework for controlling health and
safety at work and these regulations require that dutyholders:
assess the risks in their workplace;
have access to competent help and advice to apply health and safety
legislation;
establish procedures for employees if there are situations presenting
serious and imminent danger;
cooperate and coordinate health and safety where two or more
employers share a workplace.
12 More specifically, COSHH provides a framework of duties designed to
assess, prevent or control the risks from hazardous substances, including
chemicals and biological agents such as legionella and other infectious
agents, and take suitable precautions. The essential elements are:
risk assessment;
prevent exposure or substitute with a less hazardous substance or
process/method, where reasonably practicable;
control exposure if prevention or substitution are not reasonably
practicable;
maintain, examine and test the control measures;
provide information, instruction and training for their employees;
provide health surveillance of employees, where appropriate.
13 The HSE publication Legionnaires’ disease: The control of legionella
bacteria in water systems (L8)5 contains the Approved Code of Practice
(ACOP) and guidance on regulations. HSG274 Legionnaires’ disease:
Technical guidance gives further practical advice on the requirements of
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the HSW Act, MHSWR and COSHH concerning the risk from exposure to
legionella bacteria. The ACOP applies to employers and those in control
of premises where there is a risk of exposure to legionella. It also:
sets out the responsibilities of those supplying services such as water
treatment, as well as those of manufacturers, importers, suppliers
and installers;
gives guidance on identifying, assessing and managing the risk in
water systems, as well as record keeping.
14 Although only a court can give an authoritative interpretation of the
law when considering the application of health and safety legislation,
HSE and local authority (LA) inspectors expect employers to follow the
guidance in the ACOP or be able to demonstrate compliance with the
law in some other way. This document gives specific guidance, in the
context of spa-pool systems, to help dutyholders comply with the health
and safety legislation set out in the ACOP.
Enforcement
15 HSE and LAs enforce health and safety legislation. HSE is responsible
for enforcement with respect to designers, manufacturers and installers
and for spa pools in premises where HSE is the enforcing authority, eg
factories as well as national and local government buildings. LAs are
responsible for enforcement in hotels, retail outlets, and private sports and
fitness clubs. The majority of spa pools in a business setting will be under
the enforcement of LAs. Further guidance on enforcement allocation can
be found at www.hse.gov.uk/lau/enforcement-allocation.htm.
Other relevant health and safety legislation
16 Other health and safety legislation the dutyholder may need to

comply with includes:
Reporting of Injuries, Diseases and Dangerous Occurrences
Regulations 2013 (RIDDOR);
Safety Representatives and Safety Committees Regulations 1977;
Health and Safety (Consultation with Employees) Regulations 1996.
Reporting of Injuries, Diseases and Dangerous Occurrences 2013

(RIDDOR)
17 These regulations require employers and others to report to HSE
accidents and some diseases arising out of or in connection with work.
Cases of legionellosis are reportable under RIDDOR if a medical practitioner
notifies the employer and the employee’s current job involves working on
water systems located in the workplace, which are likely to be a source of
contamination. For more information see www.hse.gov.uk/riddor.
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The Safety Representatives and Safety Committees Regulations

1977 and the Health and Safety (Consultation with Employees)
Regulations 1996
18 These regulations6 require employers to consult trade union safety
representatives, other employee representatives, or employees where
there are no representatives, about health and safety matters. These
include changes to work that may affect their health and safety at work,
arrangements for getting competent help, information on the risks and
controls, and planning of health and safety training.
Microbiological and other hazards
19 Water in spa pools should be free from irritant substances,

chemicals and infectious microbiological agents at levels which may be
harmful to health.
Microbiological hazards
20 These are generally introduced from bathers or external sources, ie

the source water, atmosphere, and surface surrounds. The risk of
microbial growth increases with the introduction of nutrients (for example
mucus, saliva, perspiration, dead skin, suntan lotion, spray tans,
cosmetics, shampoo and soap residues, urine and faecal matter, and
hair). Poorly designed or poorly managed spa-pool systems can provide
the conditions to create the risk of acquiring an infectious disease.
Legionella species
21 Legionellosis is a collective term for diseases caused by the legionella
organism including the most serious legionnaires’ disease, as well as the
similar but less serious condition of Pontiac fever. There have been a
number of outbreaks linked to spa pools, including those in leisure
centres, hotels, holiday homes, cruise ships and those on display.
Everyone is susceptible to infection but there is a heightened risk with:
increasing age, particularly those over 45;
smokers and heavy drinkers;
those with existing respiratory diseases or certain illnesses and
conditions such as cancer, diabetes, heart and kidney disease;
those with an impaired immune system.
Coliforms and Escherichia coli

22 The presence of E coli in spa-pool water is an indication that faecal
material has either entered the water from contaminated skin, or has
been accidentally or deliberately introduced. Coliforms occur on
vegetation and in soil as well as faeces, so their presence alone indicates
external contamination. The presence of coliforms and/or E coli also
confirms that the treatment has failed to control this contamination.
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Pseudomonas aeruginosa
23 Numerous outbreaks of folliculitis caused by P aeruginosa are
associated with spa pools and hot tubs. Folliculitis presents as a red
rash caused by infection of the hair follicles, usually about 48 hours
(range 8 hours–5 days) after immersion in pool water, and is related to
the duration of immersion as well as the degree of contamination of the
water. Children are generally more susceptible than adults.
Mycobacterium avium and Mycobacterium species

24 Respiratory disease has been associated with non-tuberculous
mycobacteria, particularly Mycobacterium avium, in association with spa
pools and hot tubs.
Other potential infections

25 Other infections such as amoebal, parasitic and other gastrointestinal
infections, furunculosis (caused by Staphylococcus aureus) and
Molluscum contagiosum (a viral skin infection producing papillomas)
have also been associated with using spa pools.
Other hazards
26 The most immediate danger to users is from accidental drowning,

resulting from slipping or tripping, or getting caught in fittings such as
the outlets. This guidance is not intended to give detailed advice on non-
microbiological hazards in the workplace, but the main hazards are
summarised below and managers should be aware of these and manage
the risks associated with them.
Chemical
27 COSHH covers substances that are hazardous to health, including
chemicals and products containing chemicals. Risks associated with
working with chemicals used in a spa pool, overdosing and disinfection
byproducts and inadvertent mixing of incompatible chemicals must be
managed. Further guidance is at www.hse.gov.uk/coshh/basics/
substance.htm.
Temperature
28 Prolonged immersion in water above body temperature can lead to
delayed shock. The warm temperature of spa pools could pose a risk of ill
health to users who are pregnant, have cardiovascular problems, or are
subject to fits. People taking medication for cardiovascular and nervous
system conditions, and those with physical disabilities, should seek medical
advice before using a spa pool. Shortening exposure time and using notices
to warn users can help control the risk. While temperature mainly affects
users, particularly young children, the high temperature and humidity around
the spa pool could also affect people working for long periods close to it.
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Electrical
29 Spa-pool systems should comply with the Electricity at Work
Regulations 1989. More guidance on the risk of working with electrical
equipment is available at www.hse.gov.uk/electricity/information/law.htm
and further information on the standards covers wiring for electrical
installations in swimming pools and spa pools can be found in BS 7671.7
Slips and trips

30 Water in and around the spa pool presents a slip hazard for users
and those walking close to the equipment, and obstructions around the
spa pool could present a trip hazard. There is a legal requirement to
assess the risk from both hazards and guidance is available at www.hse.
gov.uk/slips. Additional information on designing spa pools to minimise
slip and trip hazards has been produced by the Swimming Pool and
Allied Trades Association (SPATA): www.spata.co.uk.
Confined spaces
31 A confined space can be any space of an enclosed nature where
there is a risk of death or serious injury from hazardous substances or
dangerous conditions (eg lack of oxygen). The risk of working in a
confined space, for example in and around the balance tank, must be
assessed under the Management of Health and Safety at Work
Regulations 1999. If the assessment identifies risks of serious injury
associated with confined spaces from work in and around the spa-pool
system, the Confined Spaces Regulations 1997 apply. Further guidance
can be found at www.hse.gov.uk/confinedspace.
Manual handling
32 Take care to avoid injuries when handling the spa pool and any heavy
and/or awkward loads such as chemical drums, as these can lead to
cumulative damage that can be severe and debilitating. If manual
handling is required, an assessment must be carried out in accordance
with the Manual Handling Operations Regulations (www.hse.gov.uk/msd/
manualhandling.htm).
Entrapment
33 There is a risk of suction entanglement and trapping hair or body parts
in the spa-pool inlets, outlets and grilles. The risk should be assessed and
appropriate control measures used to reduce it, for example by using
design features and clearly displayed information to users.
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Identifying and assessing the risk
34 Before any formal health and safety management system is

implemented, the dutyholder is responsible for ensuring a risk
assessment is carried out to identify the possible risks. The purpose of
the assessment is to enable a decision on:
the risk to health, ie whether the potential for harm to health from
exposure is reasonably foreseeable, unless adequate precautionary
measures are taken;
the necessary measures to prevent, or adequately control, the risk
from exposure to legionella and other infectious agents.
35 There are a number of factors that create a risk of someone acquiring
an infectious disease from a spa pool:
presence of infectious agents (eg legionellae) in the spa pool;
suitable conditions for growth of the infectious agents, eg a
temperature of 20–45 °C;
a source of nutrients (eg organic matter from bathers and from the
environment);
a means of creating and spreading breathable droplets, eg the
aerosol created by agitated water;
presence of people who could be exposed to the infectious agents,
eg users, those working on or near the vicinity of the spa pool, or
passing near one.
36 If the dutyholder is competent and understands the risks associated
with operating a spa pool, they may choose to do the risk assessment
themselves. They may need access to competent help and advice, and if
this is not available internally it may be sourced externally, ie from a
consultant or person experienced in carrying out risk assessments. It is
important that they are satisfied that any contractors employed are
competent to carry out the tasks to the required standard.
37 The risk assessment enables the dutyholder to show that they have
considered all the relevant factors, and the steps needed to prevent or
control the risk. The Appendix provides information on the key
requirements when assessing the risks associated with spa-pool
systems and further information is also available in BS 8580 Water
quality. Risk assessments for Legionella control.8 The assessment
should consider:
the source and quality of the supply water, eg from the mains supply
or an alternative;
description of the water system, its component parts and any
associated equipment, including an up-to-date schematic diagram
and the material used in its construction;
possible sources of contamination of the supply and pool water, eg
biofilms within the pipework, bathers, soil, grass, leaves for outdoor
spa pools;
the normal operating characteristics of the spa pool;
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unusual operating conditions, eg dosing pump breakdowns, dosing

pipework blockages or power cuts;
those working on or near the spa pool and susceptibility of users;
clear allocation of management responsibilities;
competence and training of key personnel;
an evaluation of the microbiological and other risks associated with
operation, eg infectious agents, slips and trips, manual handling,
confined spaces etc;
safe operating procedures and controls in place to manage and
control the risk;
monitoring, inspection and maintenance procedures;
results of monitoring, inspection and any checks carried out;
remedial action to be taken if the scheme and control measures are
found to be ineffective;
arrangements to review the assessment regularly and particularly
when there is a reason to suspect it is no longer valid;
arrangements to deal with accidents, incidents and emergencies.
38 The risk assessment should be linked to other relevant health and
safety records, and specifically the written scheme of control.
39 In conducting the assessment, the dutyholder should appoint a
competent person (known as the responsible person), to help them meet
their health and safety duties and take day-to-day responsibility for
controlling the risk identified from infectious agents in the spa pool, ie
managing the control scheme. The appointed responsible person should
have a clear understanding of their role and the overall health and safety
management structure and policy in the organisation. If the necessary
competence, knowledge and expertise are not available, the dutyholder
may need to appoint someone externally. Further guidance is available in
HSE’s Managing for health and safety at work (HSG65).
40 It is important that the responsible person(s) have sufficient authority,
competence and knowledge of the system to ensure all operational
procedures are carried out in a timely and effective manner. Those
appointed to implement the control measures should be suitably informed,
instructed and trained, and their suitability must be assessed. They must
be properly trained to ensure duties are carried out in a safe, technically
competent manner, and receive regular refresher training. Records of all
training, including initial and refresher training, must be kept.
Competence
41 Inadequate management, lack of training and poor communication
can be contributory factors in outbreaks of diseases, including
legionnaires’ disease. It is important that everyone involved in the risk
assessment and operation of the spa pool must be competent,
trained and aware of their responsibilities. The dutyholder must
ensure that suitable and sufficient information, instruction and training
are provided. Competence will be a product of sufficient training,
experience, knowledge and other personal qualities. Training,
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including refresher training, is an essential element of an employee’s

capability to carry out work safely.
42 Employers must consult their employees or their safety
representatives on the identified risks of exposure and the measures and
actions taken to control the risks. Employees should be given an
opportunity to comment on the assessment and control measures.
Employers may wish to involve employees and/or safety representatives
when carrying out or reviewing the assessment as a way to manage
health and safety.
43 The risk assessment is a living document that must be reviewed
regularly to ensure it remains up to date and specifically when there is
reason to suspect it is no longer valid. An indication of when to review
the assessment, and what to consider, should be recorded. This may
result from, for example:
changes to the spa pool, the way it is operated and used;
changes to the treatment regime;
changes to the building water system and any impact on the spa
pool;
availability of new information about the risks or control measures;
the results of microbiological and/or chemical tests indicating control
measures are not effective;
changes to key personnel;
a case of disease (eg legionnaires’ disease) associated with the spa
pool.
Controlling the risk
44 To control the risk, a course of action should be devised to manage

the system by implementing effective control measures. A written
scheme of control should be specific and tailored to the spa-pool system
and any associated facilities, plant and equipment covered by the risk
assessment (see the Appendix, checklist 2). This could be included in, or
part of, the normal operating plan (NOP) which, together with the
emergency action plan (EAP), constitutes the pool safety operating
procedure (PSOP).
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Information box 1 Pool safety operating procedure (PSOP)
Normal operating plan (NOP)
The NOP should set out the way the system operates on a daily basis
and should include details of the layout, equipment, manner of use, user-
group characteristics and any hazards or activity-related risks.
Emergency action plan (EAP)
The EAP should give specific instructions on the action to be taken, by

all staff, in the event of any emergency.
How the plans can be kept
The plans can be kept as written documents or stored electronically,

provided that employees have access to them and that they are available
for inspection by the enforcing authority, if required.
45 The written scheme should specify:

the spa pool and associated plant, ie up-to-date schematic diagram;
the description of the correct and safe operation of the spa pool;
the control methods and other precautions when operating the spa
pool;
the checks required to ensure the spa pool is operating safely and
the frequency of such checks;
remedial action required when monitoring shows that control
measures are ineffective;
information for users.
46 The following factors should also be considered:
type, design, size, approximate water capacity and designed bather
load of the spa pool;
source and quality of water supply;
type of dosing equipment, including the use of any automatic
controls, timers, pumps, balance tank(s), air blowers etc;
pipework and construction materials;
type of filtration system;
backwash schedule, if applicable;
heat source and design temperature;
chemical dosing equipment, including chemical separation, personal
protective equipment (PPE), chemical storage arrangements;
type of treatment to control microbiological activity, eg chlorine;
a method used to control pH;
cleaning regime – accessibility and ease of cleaning, what is cleaned,
how and when;
chemical and microbiological testing regime, including frequency,
operating parameters, and actions when the results are outside
parameters;
susceptibility of users;
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intended use;
water replacement frequency other than via backwashing;
actions for repeated adverse monitoring results or contamination
incidents and criteria for the closure and reopening of the spa pool.
47 Communication and management procedures are particularly
important where several people are responsible for different aspects of
the spa pool’s operation. Responsibilities and lines of communication
should be clearly defined, reviewed and documented to ensure they are
effective, and documentary evidence made available for inclusion in
internal and external audits. This also applies to external contractors who
may be responsible for certain aspects of the control regime.
48 Arrangements should be in place to ensure staffing levels are
appropriate while the spa pool is being operated and the responsible
person(s) or an authorised deputy are contactable at all times when the
spa pool is in use.
49 It is important to ensure that control measures are implemented
effectively and this can be achieved by:
ensuring the design bather load and recommended bather duration is
not exceeded;
encouraging showering before entering the pool;
regular checks and observations at appropriate intervals;
ensuring PPE is being used correctly;
adequate supervision of staff to ensure defined procedures are
understood and being followed;
providing appropriate signage;
taking prompt remedial action when required.
50 For precautions to remain effective, the condition and performance of
the spa pool must be monitored and reviewed. The responsible person
should oversee and manage this, although it is acceptable for competent
consultants or contractors to provide assistance and advice. The review
should include:
checking the performance of the spa pool and its component parts;
inspecting the accessible parts for damage and signs of
contamination, eg biofilms, the condition of the jets/overflows/grilles
etc;
monitoring to ensure the treatment regime is controlling the growth of
infectious agents;
checking that any modifications are included in the review.
Record keeping
51 Where there are five or more employees, the law requires that the
significant findings of the risk assessment must be recorded. If there
are fewer than five employees there is no legal requirement to
record anything.
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52 Records must be kept when managing a spa-pool system and should

include the following:
names of those responsible for conducting the risk assessment, and
managing and implementing control measures;
significant findings of the risk assessment;
written control scheme and details of its implementation (the normal
operating plan or NOP – Information box 1);
details of the state of operation of the spa-pool system, ie in use/not
in use;
results of any monitoring, inspection, test or check carried out on the
spa pool, along with dates such as:
results of chemical and microbiological analysis of the spa-pool
water;
water treatment chemical usage;
inspections, checks and records of maintenance on the water
system, components and water treatment equipment to confirm

correct and safe operation;
cleaning and disinfection procedures and associated reports and
certificates;
information on other hazards, eg chemical, slips and trips;
training records of those who work on the spa pool.
53 Record of the risk assessment must be retained for the period it
remains current and for at least two years afterwards, and records kept
for monitoring, inspections, testing or checks, should be kept for at least
five years.
54 Records, written or electronic, should contain accurate information
about who did the work and when it was carried out. All records should be
signed, verified or authenticated by a signature or other appropriate means.
Dealing with accidents, incidents and emergencies
55 The dutyholder must establish procedures to deal with situations

involving serious and imminent danger where an employee, user or
visitor is, or could be, exposed to a hazardous substance beyond that
associated with normal day-to-day activity. This could be exposure to a
chemical used to treat the water following a significant spillage,
inappropriate mixing of chemicals or exposure to infectious agents from
the spa pool.
56 The emergency procedures are often referred to as the emergency
action plan (EAP), and form part of the pool safety operating procedure
(PSOP) – see Information box 1.
57 The response to an emergency should be proportionate to the risk,
for example a small chemical spillage may not require full evacuation of
the whole premises but detecting certain levels of bacteria in the spa-
pool water could require it to be closed down.
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58 The emergency procedures should provide sufficient information to:

mitigate the effects of the incident;
limit the extent of any risks to health of the people working on or near
and using the spa pool;
restore the situation to normal as soon as possible;
verify that remedial action has been effective;
review factors which led to the incident and implement actions to
prevent recurrence.
59 The EAP should include the following details:
the identity of the relevant hazardous substances present, where they
are stored and used, and the estimated amount in the workplace on
an average day – this would be relevant for the water treatment
chemicals;
foreseeable types of accidents, incidents or emergencies that might
occur with the hazardous substances on the premises including
chemical and microbiological ones, eg spills or microbial growth in
the spa-pool water;
special arrangements to deal with the emergency situations not
covered by general procedures;
safety equipment and PPE required when dealing with an emergency;
first-aid facilities sufficient to deal with an incident until the
emergency services arrive, and location of the facilities;
the role, responsibilities and authority of the people nominated to
manage the accident, incident or emergency, eg person(s)
responsible for shutting the spa pool down;
procedures for employees to follow, such as clearing up and safely
disposing of any hazardous substances or contaminated cleaning
equipment;
regular safety drills;
special needs of all employees, visitors or spa pool users, eg
procedures to ensure safe evacuation.
60 The EAP should be regularly reviewed and updated, specifically when
circumstances change, for example where a new disinfectant is used. A
record of procedures must be kept and be readily accessible. If
appropriate, emergency procedures should be displayed in prominent
positions in the workplace for employees or spa-pool users to read.
Responsibilities of designers, manufacturers, importers,

suppliers and installers
61 Designers, manufacturers, importers, suppliers (including hirers) and

installers must ensure the spa pool is designed, constructed, tested,
installed and commissioned so that it will be safe and any risks to health
are controlled when it’s used. They must also provide adequate
information for the user about the risks of the product. This should be
updated if any new information about significant risks to health and
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safety becomes available. Plumbing fittings and pipework etc must

comply with the requirements of the Water Supply (Water Fittings)
Regulations 19999 and, in Scotland, the Water Supply (Water Fittings)
(Scotland) Byelaws 2014.10
62 Suppliers of spa pools and services, including consultancy and water
treatment services, should, so far as reasonably practicable, ensure that
measures intended to control the risk of exposure to infectious agents
are designed and implemented so that they are safe and any risks to
health are controlled.
Information box 2 Relevant legislation
HSW Act, Sections 3 and 6
This places a duty on any person who designs, manufactures, imports

or supplies articles or substances for use at work, to ensure that they
are safe and without risks to health at work and that any information
related to the article or substance is provided.
It also places general duties on employers and the self-employed to

conduct their undertakings in such a way as to ensure, so far as is
reasonably practicable, that people other than themselves or their
employees are not exposed to risks to their health or safety. They
should also provide adequate information regarding any aspects of
their products or services that might affect their health and safety.
Consumer Protection Act (CPA) 198711
Consumers have the right to expect their purchased spa pool to:
be of satisfactory quality, that a person would reasonably expect

given the description, price and other relevant circumstances;
be fit for purpose, ie it can be used for the purpose expected;
match its description (verbal or written), and if the spa pool is chosen
after seeing a sample it must match this.
It is a criminal offence for a trader to put a false description on goods.
General Product Safety Regulations 199412
These regulations have replaced Section 10 of the CPA and apply to

products supplied to consumers for their private use and to all those
in the business supply chain who are established and supply
consumer goods in the UK. Suppliers include ‘producers’ or
‘distributors’.
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Producers are required to:
only place on the market safe products within the limits of their
activities;
provide relevant information to customers;
take measures to keep themselves informed of the risks that products
may present and take appropriate action, eg withdraw products from
the market if necessary.
Distributors are required to act with due care to help ensure that
products supplied by them are safe. A ‘safe product’ under the
regulations presents either no risk or only minimum risk compatible
with the product’s use.
Health and safety law – holiday parks and lets
Holiday parks – privately owned units

63 The HSW Act does not apply to the private owners of spa pools and
hot tubs installed in a holiday park unit where there is no financial gain
and they are for the exclusive use of the owner, family and occasional
guests. To ensure its safe use, the spa pool or hot tub should be used
and maintained in accordance with the manufacturers’ instructions.
Holiday parks – site owners’ duties

64 Section 3 of the HSW Act imposes a duty on an employer (or self-
employed person) to avoid exposing people who are not their employees
to health and safety risks. So the site owner of the holiday park should:
for private owners – liaise with the owner to ensure the safe use and
maintenance of the hot tub and direct them to relevant information
and guidance, including the manufacturers’ instructions, on its safe
use and the risks posed to both themselves and to others from
legionella (see paragraph 75);
for the sale and rental of spa pools and hot tubs on site – take
reasonable steps to ensure the risk of exposure from infectious agents,
including legionella, is understood, managed and controlled. This
would be considered part of the site owner’s business undertaking.
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Section 2: Types and settings
65 This section is intended to provide definitions for the variety of spa-

pool systems or spa-pool-like units and the various settings in which
they may be installed and used. The type, design and intended use of
the spa pool in relation to the setting in which it is being used should be
considered as part of the risk assessment process. Further information
on the factors that should be considered as part of the risk assessment
process can be found in Section 1 Legislative requirements and the
checklists in the Appendix.
Types of spa-pool systems
66 Common terms associated with spa pools are hot spa, hot tub,
whirlpool spa and portable spa. Jacuzzi® is the registered trade name of
a specific manufacturer and should not be mistaken for a generic name
for spa pools.
67 There are other installations such as:
compact spa-pool installations that have been designed often with air
induction and a counter-current exercise unit;
joined swimming pool and spa pool compartments to enable
swimming in a confined area; or
larger volume spa-pool installations with air induction, often in
conjunction with a variety of water features.
68 Where domestic-type spa pools are used as a business activity, the
bather load is restricted to a discrete group of users.
Bespoke spas
69 A bespoke spa pool is built in situ using standard, factory-built parts
which may be modified or added to on site. Bather loads, water
temperature and the size of the pool may vary greatly but usually they
have a higher bather load and are in a commercial setting (defined below).
These pools typically have either an overflow or deck-level spa with a
separate filter and continuous chemical feeder system (see Figure 1 on
page 26). The design includes a separate balance tank generally located in
the plant room. The complexity of the design features, any associated
equipment and the aerosol exposure must be considered during the risk
assessment and will require enhanced levels of control and monitoring.
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Hot tubs
70 A hot tub is a self-contained factory-built unit for indoor or outdoor
use and is designed for sitting in. They are typically filled with treated
water, maintained at a temperature above 30 °C, fitted with air jets and
aerated (see Figure 2 on page 27). They are generally designed for a
small number of discrete bathers where the water is not changed,
drained or cleaned after every use. Hot tubs are not for swimming in and
do not have a balance tank. These are likely to be small units but with
regular daily usage and the above factors, along with the turnover of
water, must be considered as part of the risk assessment.
Whirlpool baths
71 Whirlpool baths are designed for one or two bathers where the water
is not treated, and are intended to be filled and emptied after each use.
Whirlpool baths are usually fitted with water jets, which can be angled in
use. In addition, there is usually an air track in the floor of the bath,
powered by an air-blower system and/or air may be introduced to the
water jets.
72 Whirlpool baths have the potential for similar problems to spa pools,
such as the formation of biofilms within the pipework system associated
with the air and/or water booster jets, and should be regularly
disinfected. Such factors must be considered as part of the risk
assessment process.
Natural spa pools

73 In these spa pools the water is untreated, but this in itself can pose
potential health and safety implications. The water for natural spas
should be shown to be of satisfactory microbiological quality before their
construction. They must be managed to control the risk of exposure of
bathers and others to infectious agents. This will usually require the
natural spa pool to be managed in the same manner as any other
commercial spa pool. Managers of natural spa pools should, therefore,
follow the guidance on control measures provided in this guidance
document, but alternative control strategies may also be used if proven
to be effective.
Spa-pool settings
74 Spa-pool systems are fundamentally used in the following settings:

domestic – privately owned;
domestic – installed and used as part of a business activity;
commercial – installed in a commercial establishment or public
building.
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Domestic-type spa pools – privately owned

75 Spa pools or hot tubs installed in domestic homes or privately-owned
properties (for example, in a private holiday home) for which there is no
financial gain, ie they are not available for rent or let and are for the
exclusive use of the owner, family and occasional guests, and are not
subject to the HSW Act. The operational use of such systems does not
therefore fall within the scope of this guidance.
Domestic-type spa pools – used as a business activity

76 Domestic-type spa pools or hot tubs used as part of a business
activity (eg in a holiday park rental unit or hotel bedroom(s) with their own
dedicated spa, or as part of a rental agreement for a single family or
group use) are subject to the general duties under the HSW Act. There is
a legal requirement for these systems to be managed and controlled in
proportion to the risk and the risk assessment should consider the type
of pool and its use. Domestic-type spa pools are for use by a small,
discrete group of people at any one time and are typically:
of either a rigid or inflatable/foam-filled structure with freeboard and
skimmer;
systems where the water should be changed after each rental/week,
whichever is the shorter;
disinfected using bromine or chlorine through the use of an inline
disinfectant feeder.
77 These spa pools are not suitable for medium or large-scale business
use (ie large numbers of casual bathers and/or unrelated groups), or for
commercial activity, as design features and systems for control are
unlikely to be sufficient to cope with user demand.
78 Design bather load is a key characteristic and should be considered
as part of the risk assessment to achieve effective control. There are
circumstances in which a domestic-type hot tub would be unsuitable,
and a commercial-type spa pool should be used. These include any
settings where there is potential for a higher bather load and/or there is
continuous bather use, for example party spas, entertainment spas, or
similar – or where several accommodation units have shared access to a
spa pool, eg at a holiday park or large hotel.
79 Where the use of a commercial-type spa pool is not possible or
practicable (eg hot tubs used for cinema screenings), the risk
assessment must consider the bather load and take into account the
characteristics of the spa pool and the control measures required to
effectively manage the risk in this setting. After each period of hire, the
spa pool should be completely drained, cleaned, refilled, disinfected and
drained again. When stored, the spa pool should be dry, including the
insides of the pipework, as far as practicable.
80 There have been significant outbreaks associated with spa pools on
display. Where a domestic-type pool is on display at a showroom or
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exhibition, the design bather load would not apply to the risk assessment
as the pool should be displayed empty of water and there would be no
intended bather use. However, if it is filled, the risks posed to individuals
who work with or pass in close proximity to the spa pool must be
considered and must be treated and controlled.
Commercial-type spa pools

81 These are designed for higher bather loads and are subject to the
general duties under the HSW Act. They are generally installed in a
commercial establishment or public building. Typical commercial
settings, where there is a higher number of users than for domestic-type
spa pools and the number of bathers cannot be clearly anticipated or
recorded, include hotels and holiday accommodation (where the pool is
a shared facility), health clubs, beauty salons, sports centres and clubs,
and swimming-pool complexes. Spa-pool systems for commercial use
are generally characterised by the following:
a deck-level overflow;
greater numbers of users exposed for longer periods of time requiring
increased levels of control and monitoring;
a separate filter and continuous chemical feeder system;
a balance tank and plant room.
Healthcare
82 Healthcare premises, residential or care homes can feature spa
pools, including whirlpool baths, used for medical or therapeutic
purposes. Special consideration should be given to patients or
occupants in a healthcare setting (healthcare premises, residential or
care homes), where they may be exposed to a spa-pool system and a
potential source of waterborne infectious agents. This document should
therefore be read in conjunction with HSE’s HSG274 Part 2 Special
considerations for healthcare and the Department of Health’s specific
guidance for healthcare premises: www.gov.uk/government/publications/
hot-and-cold-water-supply-storage-and-distribution-systems-for-
healthcare-premises.
83 A local risk assessment should consider the number and nature of
any ‘at risk’ patients or residents, as there may be factors which increase
their susceptibility to legionnaires’ disease. Such factors include
increasing age, those with existing respiratory diseases or certain
illnesses such as cancer, diabetes, kidney disease, and those with
impaired immune systems. The risk assessment should inform the
overarching water safety plan, and it is important that the Water Safety
Group has access to expert advice on any risks posed by spa pools and
how to operate and maintain them safely.
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Section 3: Design and

commissioning
84 This section gives a description of the characteristics, design,

construction and commissioning of spa pools. They are designed in
different shapes, sizes and with different configurations of plant and
equipment, and the setting in which they are intended to be used should
be taken into account in the risk assessment. Spa pools, and any
modifications made to them, should be designed with safe operation and
maintenance in mind. In particular, all parts should be easily and safely
accessible for all essential maintenance tasks and in a way that readily
allows for cleaning and disinfection of all wet surfaces. Where spa pools
with a higher bather load are sited indoors, consider the
dehumidification/ventilation of the area around the spa pool.
Design
85 Spa-pool systems should be designed and constructed to be safe,

and minimise risks to health and should comply with:
Classification, Labelling and Packaging Regulations 2015;13
Construction (Design and Management) Regulations 2015;14
European Biocidal Products Regulation (EU) 528/2012;
Water Supply (Water Fittings) Regulations 1999 and, for Scotland, the
Water Supply (Water Fittings) (Scotland) Byelaws 2014;
The Private Water Supplies Regulations 2009,15 in England, the Private
Water Supplies (Wales) Regulations 2010;16 or the Private Water
Supplies (Scotland) Regulations 2006;17
BS EN 806 (Parts 1-5) Specifications for installations inside buildings
conveying water for human consumption;18
BS 8558 Guide to the design, installation, testing and maintenance
of services supplying water for domestic use within buildings and
their curtilages.19
86 The design of the spa pool should take into account:
location;
design bather load;
source water quality;
drainage and water replacement;
access for cleaning, operation and maintenance;
balance tank (if appropriate);
plant location;
filtration;
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chemical treatment and storage areas;

circulation rate and circulation hydraulics;
turnover period;
materials of construction;
prevention of deadlegs.
Construction
87 Spa pools and associated pipework and equipment should be
constructed from materials appropriate for their intended use. They
should be supported to ensure minimal movement or flexing of the shell
to prevent damage and facilitate effective drainage. Surfaces should be
smooth and free from defects that would otherwise support microbial
growth. All water fittings used in the construction of systems must
comply with the requirements of Water Supply (Water Fittings)
Regulations 1999 and, for Scotland, the Water Supply (Water Fittings)
(Scotland) Byelaws 2014. All non-metallic materials used in the
construction of the spa-pool system must comply with the appropriate
parts of BS 6920.20
88 The design of spa-pool shells normally conform to one of two designs:
deck-level overflow system (see Figure 1) – maintains the water level
at a constant height while the excess water flows to a balance tank to
be replaced as the bathers leave the spa pool;
freeboard and skimmer system (see Figure 2) – where the water level is
below the top of the system to accommodate bather immersion.
Circulation
89 Spa pools and plant should be designed to achieve circulation and
mixing of all the treated pool water with no stagnant areas and effective
removal of water from the surface (where the bulk of the pollutants are).
Spa pools should be designed with a surface draw-off of approximately
80% of the circulation volume. To maintain microbiological quality of the
spa-pool water, the filter and pumps should be sized to provide a
turnover of pool water that is suitable for the pool layout and operation at
the limit of the anticipated bather load, which will typically be 6 minutes
for commercial-type spa pools where bather load is high and 15 minutes
for lower bather loads.
90 For deck-level overflow systems, surface water spills into perimeter
channels forming part of the recirculation system, and is drawn from the
balance tank and pumped through the filters and circulated back to the
spa pool. All suction outlets should be duplicated and connected to
more than one fitting, and the fittings should be of an anti-vortex design
to reduce the risk of entrapment. Where suction pipes are run from a
plant room, all suction valves should be left open while the pump is
running to avoid deadlegs.
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91 Figure 1 is an illustration showing a design for a deck-level overflow

spa pool and its associated water system. It shows how the water is
continuously circulated, filtered, chemically treated and heated before
being returned to the spa pool via the inlets. Water within the spa pool
should continually overflow into the deck channel, which then returns to
the balance tank. There may also be a secondary circuit that draws
water from the spa-pool footwell and reinjects it into the spa pool. The
heater and chemical dosing units should be adequately interlocked to
‘fail-safe’ if the water stops circulating.
ANTI-SYPHON LOOP
SURFACE WATER
REMOVAL CHANNEL
AIRLINE
WATER MASSAGE JET
AIR JET MAIN SUPPLY

STRAINER
INCORPORATING
BACKFLOW
PROTECTION
AIR
BLOWER
OVER
FLOW
BALANCE
pH CORRECTION POINT TANK
3 WAY
PUMP STRAINER VALVE
DRAIN
HEATER
FILTER
FILTRATION
WATER BOOST
DISINFECTANT
AIR SYSTEM ADDITION POINT
HEATING
3 WAY 3 WAY PUMP STRAINER

VALVE VALVE
Figure 1 Design of a typical deck-level overflow spa pool and associated

water system
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92 Figure 2 illustrates a typical freeboard and skimmer system – it shows

how the water is drawn directly from the spa pool via the surface level
skimmer to the filter. Water within the spa pool should be continually
pumped through the filter and returned to the pool tank. There may also
be a secondary circuit that draws water from the spa-pool footwell and
pumps it back into the spa pool.
Air
Jet
Light
Power
Pump
Drain Heater
Figure 2 Design of a typical freeboard and skimmer spa pool and associated
water system
Pipework
93 Pipework should be designed to be readily accessible and removable
for inspection and cleaning, with minimum length of pipe runs to avoid
deadlegs and reduce the surface area for microbial biofilm growth. As
plastic pipework may readily support microbial growth, the materials
chosen should minimise the risk. Flexible, internally-corrugated piping
should not be used as it increases the surface area for growth and can
create areas that are difficult to clean.
94 All non-metallic materials used in the construction of the spa pool
should comply with the Water Regulations Advisory Scheme (WRAS)
approval scheme which lists products that have been tested and comply
with BS 6920.
Filtration
95 Filtration is necessary to ensure adequate water clarity can be
maintained through the removal of suspended particulate matter/debris
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in the water. Filtration is a means of entrapping particles mechanically

and/or through absorption onto a filter medium. There are several types
of system in common use and the choice of system type and size should
reflect the anticipated type of use, circulation rate and bather load. Spa
pools will typically only require one filtration system but multiple units
and types in sequence may be appropriate, depending upon the local
circumstances.
Sand filtration – Sand filters are vessels containing 16/30 graded
sand (or glass) as a filter medium through which a pressurised water
supply is fed. They are recommended for use where bather load is
anticipated to be high due to their size and reliability. The flow rate, in
addition to the size and depth of the vessel and choice of medium,
will affect the efficiency of the system. Higher filtration rates (such as
25–50 m3/m2/h) are suitable for lower bather loads and lower rates
(such as 10–25 m3/m2/h) for higher bathing loads. The design and
installation should allow for effective operational procedures such as
checks on sand quality, regular backwashing and periodic media
replacement. The system water volume should be based on the flow
rate and time period recommended by the filter manufacturer to allow
for backwashing.
Cartridge filters – Cartridge filters are systems of tightly packed filter
media such as fibreglass or paper in a demountable unit. They are small
units and typically would only be used in domestic-type spa pools where
the bather load and anticipated level of particulate matter was low. The
design and installation should allow for removal of the cartridge for
regular chemical cleaning, drying and periodic replacement.
Pre-coat filters (including diatomaceous earth) – These filter vessels
contain internal septum coated with a filter medium such as
diatomaceous earth. The design and installation should allow for
effective operational procedures such as backwashing and periodic
media replacement.
96 Alternative types of filtration and filtration media exist and, where
used, should be verified as suitable for the type of spa pool and the
setting in which it is to be used.
Balance tank
97 Deck-level overflow systems should have a balance tank designed to
take up the water displaced from bathers and should be:
appropriately sized for the bather load;
easily and safely accessible for inspection, cleaning and maintenance;
constructed from materials which minimise the potential for
microbial growth;
smooth to facilitate inspection, cleaning and disinfection and free
from defects that support microbial growth;
easy to drain completely;
designed to limit ingress of dirt and other potential nutrients but with
a removable lid or inspection hatch to facilitate access while
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maintaining the appropriate backflow protection with an air gap which

is unrestricted;
designed with sufficient water capacity when unoccupied for a filter
backwash, where necessary.
Water treatment and control systems

98 Water treatment is essential to inhibit microbial growth in the spa-
pool water and associated plant. The programme of treatment should be
designed to control microbial growth, pH and include appropriate dosing
control systems. The control system should be designed to be
compatible with the proposed water treatment programme.
99 Where key risk factors are greater, such as high bather load, chemical
dosage and control should be automated to ensure the correct treatment
levels are consistently applied. Various automatic control systems are
available incorporating redox, amperometric or photo ionisation
detectors (PIDs), with pH control. Both amperometric and PID controllers
are more specific for chlorine and bromine and are considered to provide
better control than redox. Take care when considering the use of an
automatic controller with trichloroisocyanuric acid (Trichlor) to ensure its
suitability and compatibility with cyanuric acid.
100 Chemicals added to the spa-pool water as a solution are normally
added by positive displacement metering pumps which can be adjusted
to vary the volume of the chemical dosed. Dosing pumps should be
designed to shut off if the circulation system fails, but automatic water
quality monitors should remain in operation. Where chemicals are added,
eg Trichlor, calcium hypochlorite or bromochlorodimethylhydantoin
(BCDMH), they should be introduced using a sidestream dispenser.
101 Domestic-type systems used as part of a business activity are
typically disinfected using bromine or chlorine through the use of an
inline disinfectant feeder.
Heating
102 The typical operating temperature of spa pools is 30–40 °C.
The heat exchanger should be sized to ensure that a rise in water
temperature will not cause damage to the shell or any tiling but should be
capable of heating the pool water within a suitable timeframe according to
pool design. Specific details are given for tiled pools in BS 5385-4 Wall
and floor tiling. Design and installation of ceramic and mosaic tiling in
specific conditions. Code of practice.21
Booster jets
103 Booster jets are inlet fittings that blend air and water creating a high
velocity turbulent mix. The booster jets and pipework should be
designed to discourage biofilm formation and to facilitate inspection,
cleaning and treatment programmes. This should include preventing
areas where water might become stagnant in addition to enabling the
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use of biodispersant compounds, eg chlorine dioxide, where

circumstances require it for removing biofilm, slime, fouling etc.
Air-blower system
104 An air-blower system consists of a series of air holes or injector nozzles
in the floor and seats which deliver air to these outlets and operated in a
similar manner to booster jets. These can be difficult to disinfect and may
support microbial growth, so the pipework should be designed to be
demountable and accessible for inspection, cleaning and disinfection.
Spa-pool water make-up supply

105 The make-up water supply to the spa pool should comply with the
Water Supply (Water Fittings) Regulations 1999 and, for Scotland, the
Water Supply (Water Fittings) Byelaws 2014. The supply pipework
should be sized to ensure the spa pool can be filled quickly after it is
drained and cleaned.
Plant location
106 The pool plant and equipment should be located as near as
possible to the spa pool with suction and delivery pipe runs and
chemical dosing lines, where used, kept as short as practicable.
107 To ensure all routine and maintenance functions can be carried out
adequately there should be sufficient space, easy access and a separate
area close by for safe storage of chemicals. Further information on plant
space and chemical storage can be found in the Chartered Institute of
Building Services Engineers (CIBSE) Guide G Public Health and Plumbing
Engineering,22 and Swimming Pool Water: Treatment and Quality
Standards for Pools and Spas published by the Pool Water Treatment
Advisory Group (PWTAG)23 and the PWTAG website: www.pwtag.org.
Commissioning
108 Commissioning is an essential step in ensuring that spa-pool
systems operate safely from the outset. They should be commissioned
to ensure they operate correctly and safely in accordance with the
design parameters. It is essential that the commissioning process is
carried out by competent people in a logical and defined manner and in
full compliance with the supplier’s or installer’s instructions. It should
include both the spa pool and any associated pipework and water
treatment plant, where relevant.
109 The responsibilities of the staff carrying out the commissioning
process should be clearly defined, with adequate time and resources
allocated to allow the integrated parts of the installation to be
commissioned correctly. The precautions taken to prevent or control the
risk of exposure to legionella and other infectious agents during normal
operation also apply to the commissioning process. It is important to
note that a spa-pool system may harbour residual water and microbial
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contamination from pressure testing before leaving the manufacturer or

supplier; this risk must be assessed and all components cleaned and
disinfected as part of the commissioning process.
110 The spa pool should be fully tested to confirm its functional safety
and fitness for its intended purpose before being brought into use, and
the procedure and results should be fully documented. Commissioning
should include:
water disinfection to reduce microbial growth, typically with 50 mg/l
chlorine for at least one hour, with the pH kept as near to 7.0 as
possible during this period;
evidence that safety standards have been met;
a comprehensive functional water test to ensure the spa pool
system operates correctly;
chemical and bacteriological analysis of the water to ensure
operating parameters are achievable and being maintained.
111 Once commissioned, the spa pool should be treated as if in

normal use.
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Section 4: Operation and

maintenance
112 This section provides guidance on the operation, cleaning and

disinfection of spa-pool systems. Water in spa pools should not contain
significant levels of irritants or infectious microbiological agents, which
generally come from the atmosphere, water source and surface
surrounds or bathers.
113 The volume of water, operating temperature, location of the pool
(eg outside) and bather loads all contribute significantly to risk, which
means that disinfection, microbial control strategies and filtration are
essential for maintaining standards in spa pools. As with any water
system, routine maintenance is essential to ensure the system works as
intended. Maintenance requirements should follow manufacturers’
instructions, and additional guidance on maintaining water systems is
provided in BS EN 806-5 Operation and maintenance.
114 An appropriate water treatment programme must be capable of
controlling not only legionella and other microbial activity, but also pH. It
should include appropriate measures, such as regular physical cleaning
and shock disinfection, to maintain the system’s cleanliness. As these
aspects are often interrelated, failure to control one aspect will often lead
to other problems and increase the microbial risk. The water treatment
programme should be capable of delivering certain chemical and
microbiological criteria (see Tables 3 and 4 in Section 5), which will
depend on the nature of the water and the treatment system.
Bather load
115 Each type of spa pool is designed to contain a maximum number of
bathers at any one time and this is an important determinant of
satisfactory water quality during typical use of the spa pool. The risk
assessment should consider the bather load to ensure satisfactory water
quality and determine the operational actions. The number of bathers in
the spa pool at any time should never exceed the number of seats or
loungers provided in it.
116 The design bather load is the maximum number of bathers using the
spa per hour (ie each hour is three periods of 15-minute bathing followed
by a 5-minute rest period) and this should be stated and not exceeded.
The design bather load should be approximately 10 times the capacity of
water in the spa-pool system when measured in cubic metres, with a
minimum of 250 litres per bather (for example a 5 m3 pool would have a
design bather load of 50 bathers per hour).
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Water replacement
117 In a commercial setting, as a minimum the total water volume should
be replaced with fresh water when the bather load equals 100 x the water
capacity measured in cubic metres since the last water replacement.
Where a spa-pool area is incorporated within the swimming-pool water-
treatment system, the dilution of pollutants is much greater and water
replacement should be up to 30 litres per bather per day in accordance
with the recognised standard for swimming pools. Where a stand-alone
spa pool is situated adjacent to a swimming pool, the swimming-pool
water may be used to fill the spa pool but the spa-pool water must be
emptied to waste and not drained into the swimming pool.
118 Where a hot tub or spa pool is used as a business activity, the total
water volume should be replaced each week, or after each group of
users, if earlier.
119 It is expected that water will be completely drained and replaced in
a typical spa-pool system. However, where this is not practicable, eg due
to a large pool size, there should be additional control measures and
enhanced monitoring to ensure that the physical, microbiological and
chemical quality of the spa-pool water is maintained.
Water quality
120 Effective water treatment relies on filtration working in conjunction
with chemical disinfection. Filtration that is working effectively and
efficiently contributes to maintaining the cleanliness, clarity and safety of
the water. Chemical disinfection is required to prevent microbial growth
and reduce the risk of infection.
121 The spa-pool maintenance programme should ensure appropriate
physical operation of the spa pool and provide a suitable chemical
balance to achieve microbiological control. To ensure optimum water
quality, the turnover time of the spa pool and the design bathing loads
should not exceed recommended limits.
122 The turnover time is the time taken for the entire spa-pool water
volume to pass through the filters and treatment plant and back to the
spa pool. The maximum design water turnover time for lower bather
loads is 15 minutes, and 6 minutes for commercial-type spa pools (where
there are higher bather loads).
123 Backwashing is the process of reversing the flow of water
through the filter to clean the filter media. Where sand filters are used,
backwashing will be necessary. The frequency of backwashing should
be informed by the risk assessment and manufacturers’ instructions
and it should not be done when the spa pool is in use. There should
be sufficient capacity in the spa pool and balance tank for
backwashing the filter efficiently and enough time must be factored
into the process to enable the filter medium to settle before reopening
the spa pool. For this reason, backwashing should be done after the
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last user of the day, or before the site is closed overnight, but with the
spa pool left running.
124 Sand filters should always be backwashed before the pressure rises
above normal clean operating pressure by 0.35 bar. Precoat filters
should be recharged according to manufacturers’ instructions. Where
cartridge filters are used, at least two sets should be retained to ensure
there is one set in use while the other is being chemically cleaned and
dried. Filters should be replaced as appropriate in accordance with risk
assessment and manufacturers’ instructions.
125 The frequency of inspection and monitoring of the spa-pool system
will depend on the operating characteristics of the pool, its complexity,
design bather load and setting, eg healthcare. The risk assessment
should define the frequency of inspection and monitoring, depending on
the type of use and user (particularly where there are adjustments made
by the assessor to take account of local needs). Table 1 provides a
checklist of operational actions and the typical recommended
frequencies. Table 2 (page 38) provides guidance on the spa-pool
inspection and recommended actions.
Table 1 Operational actions and typical frequencies
Operational actions Typical frequencies
Commercial-type spa Domestic-type spa

pools (high bather load) pools and hot tubs
Check water clarity Daily at opening and At least twice daily
every two hours depending on risk
thereafter assessment and usage
Check if dosing system Daily at opening Daily
is working
Check chemical Daily at opening Daily where appropriate
reservoir level
Determine pH value, and Daily at opening and At least twice daily
residual disinfectant every two hours depending on risk
thereafter assessment and usage
Determine TDS Daily -
Clean the water-line Daily – at end of the day/ Check daily and clean
user period with a fresh as appropriate but as a
damp cloth using minimum at water
sodium bicarbonate replacement
(sodium hydrogen
carbonate)
Clean overflow channels Daily – at end of the day/ Check daily and clean
and skimmers user period as appropriate but as a
minimum at water
replacement
Clean spa-pool surround Daily – at end of the day/ Check daily and clean
user period as appropriate but as a
minimum at water
replacement
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Operational actions Typical frequencies
Commercial-type spa Domestic-type spa

pools (high bather load) pools and hot tubs
Backwash filter Daily – at the end of the -
day/user period
Replace cartridge filter - At water replacement
with a cleaned cartridge
Inspect strainers and Daily At water replacement
grilles
Record incidents Daily As appropriate
Check any automatic Daily Daily, where fitted
systems are operating
correctly
Drain spa pool, clean Daily to weekly based Between each group of
whole system including on risk assessment users or at least weekly,
strainers and refill whichever is shorter
Drain and clean balance At least twice per year -
tank based on risk
assessment and weekly
visual checks
Inspect accessible Weekly Weekly
pipework and jets and
clean as necessary
Disinfect flexible hoses Monthly Monthly
Microbiological testing Monthly for ACC, Monthly for ACC,
coliforms, E coli, coliforms, E coli,
P aeruginosa and P aeruginosa and
quarterly for legionella quarterly for legionella
Clean input air filter Monthly Monthly
Full chemical test Monthly or as As determined by risk
dependent on water determined by risk assessment
quality assessment
Disinfectant/pH Monthly or according to Monthly, where fitted,
controller – clean manufacturers’ or according to
electrode and check instructions manufacturers’
calibration instructions
Check effectiveness of Quarterly -
filtration
Check, clean, disinfect - Between each group of
and dry filter cartridge users or weekly,
whichever is shorter
Clean and disinfect Quarterly Weekly where
airlines appropriate
Check sand filter Quarterly check and -
annual sand
replacement
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Dehumidification
126 Where spa pools with a higher bather load are sited indoors,
consider the dehumidification/ventilation of the area around the spa pool.
The level of evaporation from the surface of the spa pool is increased
when the airblower/jets are operated and equipment should be in place
to lower the humidity, for example:
control timers to limit prolonged operation of the jets/airblower when
the pool is not being used (limited to no more than 15 minutes’
continuous operation);
an air temperature of 1 degree C above the water temperature to a
maximum of 30 °C and a maximum relative humidity of 60–70% is
typically required. Ventilation should be set at a rate of 10–15 litres
per second per square metre of wetted area;
central plant incorporating heat recovery and/or heat pump
dehumidification can be used to recirculate the air. However,
recirculatory systems can operate under conditions that cause severe
corrosion and loss of performance;
using a cover when the spa pool is not in use;
a wall-mounted dehumidifier can also be provided and can contribute
to the space heating to reduce condensation.
User information
127 Risk assessments should identify the information to be provided for
users, including good standards of hygiene, recommended bathing time,
bather load and the appropriate procedures when using the spa pool.
They are typically provided in a form of notice.
Information box 3 Example information for bathers
This is not an exhaustive list but, as an example, bathers should:
use the toilet and shower before entering the spa pool;
not wear sun tan lotions, spray tans or skin creams;
not use the spa pool after a heavy meal or under the influence of
alcohol or sedatives;
keep their head above the water;
not exceed 15 minutes’ immersion at a time;
not exceed the maximum number of bathers (one per seat);
seek medical advice if pregnant, have health problems or
immunosuppressed;
supervise all children in and around the spa pool and not allow
children under 4 years of age, or those unable to keep their head
above the water level when sitting, in the spa pool.
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Water treatment programmes

128 An appropriate water treatment programme must be capable of
controlling microbial activity, pH and include appropriate measures, such
as regular physical cleaning and disinfection. Where fitted, spa
equipment should turn itself on automatically twice a day to ensure water
treatment to all parts.
129 The pH, total alkalinity, total dissolved solids (TDS), temperature and
calcium hardness of water are the main factors in determining the
balance of the water. Balanced water is neither scale forming nor
corrosive and may be measured using a number of indices (such as the
Langelier Saturation Index or Ryznar Stability Index). Water balancing
may not be required in spa pools with a higher bather load due to the
frequency of water replacement and draining of the spa pool.
130 The most important factor in water balance is pH which should be
maintained between pH 7.0–7.6. Depending on the nature of incoming
mains water and the disinfectant used, the pH of the water may need to
be adjusted by the use of chemical treatment to ensure the disinfectant
remains effective (see Information box 4 Adjusting the pH).
Information box 4 Adjusting the pH
The nature of the incoming mains water supply tends to determine the pH
adjustment required. Bromine products (eg 1-bromo-3-chloro-5,5-
dimethylhydantoin) as well as some chlorine products (eg sodium
dichloroisocyanurate dihydrate) tend to be relatively neutral when
dissolved in spa-pool water and have little effect on the pH. Heating
water drives off acidic carbon dioxide so the natural tendency is for the
pH to rise in spa pools.
Products such as trichloroisocyanuric acid form an acidic solution (pH 3)

in some but not all water supplies and an alkaline pH adjuster will be
required to increase the pH to within the maximum range (pH 7.0–7.6), eg
soda ash (sodium carbonate).
Sodium and calcium hypochlorite will result in an alkaline pH so an acid

pH adjuster will be required. Acidic pH adjusters include sodium
hydrogen sulphate (sodium bisulphate) and for commercial spas,
hydrochloric acid.
131 The TDS are the measure of the concentration of dissolved materials
present in the water from the water treatment chemicals and bathers.
The TDS of the spa-pool water should be no more than 1000 mg/l higher
than the incoming fill water, above which corrosion of the water
distribution system may become more apparent. Planned regular water
replacement will normally prevent such occurrences.
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Cleaning and disinfection
132 The risk from exposure to legionella and other infectious agents
should be controlled by maintaining the cleanliness of all parts of the
system and the water within it to ensure the pool remains free from
nutrient sources arising from contamination and corrosion. This may be
achieved by routine inspection, cleaning and ongoing disinfection.
Table 2 provides guidance on inspection and the recommended actions.
The concentration of disinfectant used should be checked at the end of
the disinfection period to ensure that it has been maintained for the
duration of contact time.
133 In addition to the spa pool, balance tank and its associated
components, cleaning should take account of other areas where
contamination may occur, for example the ingress of dirt into the spa
pool from the surrounding walkways. Cleaning products should be
compatible with the materials used in the construction of the spa pool
and with other chemicals used for treatment.
Table 2 Guidance on inspection and recommended actions
What to inspect Purpose Recommended action

Spa-pool waterline Prevent ingress from Clean with a fresh,
surface contamination damp cloth using
sodium bicarbonate
(sodium hydrogen
carbonate)
Overflow channels, Prevent ingress from Clean with a
skimmers, strainers and surfaces contamination concentration of
grilles, and the 100 mg/l free chlorine
surrounding area
Balance tank, if any Control microbial Drain and clean with
contamination particular attention to
the waterline and the
underside of the lid
Spa-pool covers Control microbial Clean inside and out
contamination with a concentration of
100 mg/l free chlorine.
Dry and store covers in
a clean area when not in
use. A cover lifter will
keep the cover off the
ground when not in use
Headrest Control microbial Remove and clean
contamination
Jets and any accessible Control microbial Inspect and clean as
pipework contamination necessary
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What to inspect Purpose Recommended action

Water clarity Check effectiveness of Review control
control measures strategies as cloudiness
may indicate:
the spa pool has been
left unused
failure of the
circulation pump
incorrect dosing of
water treatment
chemicals
presence of
undissolved
chemicals
incorrect filter
cleansing procedures
and/or
algal/bacterial growth
Routine disinfection
134 A variety of disinfectants are used in spa-pool systems to control
microbial growth (see Information box 5 Disinfectants). The quality of the
incoming mains water supply should be taken into consideration before a
disinfectant can be selected.
135 Various factors may influence the maintenance of disinfectant levels,
for example bather numbers, temperatures, sunlight, turbulence, organic
loading and/or aeration. At pH 7, free chlorine residual measured by
DPD1 should be 3–5 mg/l, or total active bromine 4–6 mg/l. The
effectiveness of the disinfectant is directly related to the pH of the water.
Spa-pool water treatment chemicals should be continuously dosed and
dosing of high-bather-load spa pools should be automatically controlled.
Hand-dosing should only be used in emergencies such as plant failure or
for shock treatment.
136 The process of disinfection using a chlorinating agent results in the
formation of free and bound (combined) chlorine. Combined chlorine,
which has slow and little disinfectant effect, is formed by the reaction of
free chlorine with organic materials arising from bather pollution, eg urine
and perspiration. The efficiency of the disinfection system to cope with
the bather load is reflected by the concentration of combined chlorine.
The ideal combined chlorine concentration is 0 mg/l, but a concentration
of less than 1 mg/l is normally considered acceptable (although the
combined chlorine should not exceed half of the free chlorine). Above
this concentration, irritation to the mucous membranes of the eyes and
throat may occur.
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137 Disinfection using a brominated chemical results in combined

bromine being formed as the predominant and effective disinfectant.
Free and combined bromines are not usually differentiated between
when monitoring the spa-pool water disinfectant concentration, since
combined bromine is still an effective disinfectant and so the
measurement is recorded as total active bromine (DPD1).
138 For spa pools that form an integral part of a leisure-pool system,
where chlorinating disinfectants are used in conjunction with ozone, the
residual disinfectant concentration required in the spa-pool water will be
dependent on spa-pool design and attaining satisfactory microbiological
results.
139 It is important to ensure that a satisfactory residual disinfectant
concentration is achieved so that it does not permit microbial growth in
the spa-pool water or the filter media.
Information box 5 Disinfectants

Sodium hypochlorite Sodium hypochlorite is usually
supplied as a solution (10–15%
available chlorine) which should be
stored under cool conditions and
used within its expiry date
(a maximum of 3 months). Using
sodium hypochlorite will raise the pH
of the spa-pool water and requires
subsequent pH reduction
Calcium hypochlorite Calcium hypochlorite is supplied in
powder, granular or tablet form, and
must be dissolved in a suitable
reservoir or feeder before being
injected into the spa-pool water. In
hard-water areas more frequent
cleaning and backwashing of the
filters may be required to minimise the
occurrence of blockages in the
filtration and distribution pipework
due to the deposition of calcium salts.
There are quick-dissolving granular
calcium hypochlorites designed for
shock dosing by hand. Using calcium
hypochlorite will raise the pH of the
spa-pool water and requires
subsequent pH reduction
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Chloroisocyanurates Chloroisocyanurates are commonly
used in domestic-type spa pools and
are available as slowly dissolving
tablets (trichloroisocyanuric acid) or
rapidly soluble granules (sodium
dichloroisocyanurate dihydrate).
Trichloroisocyanuric acid should be
delivered via a dosing unit. Ensure
that any automatic controller is
compatible with cyanuric acid at
concentrations in excess of 20 mg/l.
Sodium dichloroisocyanurate
dihydrate is only suitable for dosing
directly into the spa-pool water and
normally should only be applied in
this way as an emergency measure.
Using dichloroisocyanurates will
usually have little or no effect on the
pH of the spa-pool water, although
this can depend on the source of the
water. Using trichloroisocyanuric acid
will tend to lower the pH
The use of chloroisocyanurates
results in the addition of cyanuric acid
to the spa-pool water and its
concentration should be maintained
below 100 mg/l by dilution with fresh
water. Cyanuric acid concentrations
above this level can encourage algal
growth and may prevent the release
of free chlorine into the spa-pool
water
Solid bromine-based disinfectants Bromochlorodimethylhydantoin-
1,bromo-3-chloro-5,5-dimethyl
hydantoin (BCDMH) is a slow-
dissolving tablet used in a soaker
feeder, where a portion of the
circulating water is bypassed through
the brominator (feeder). BCDMH can
also be used in a pre-filled granular
feeder device, which may float (with
or without additional minerals) or be
plumbed into the circulation system. It
must be added from a suitable dosing
unit and ideally automatically injected
before the filter
Other formulations of brominated
hydantoins are used which are more
acidic and dissolve faster than pure
BCDMH
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Silver stabilised hydrogen peroxide SSHP is a broad spectrum
(SSHP) disinfectant usually supplied as a
solution to be dosed or added to the
spa-pool system. It comprises a
solution of hydrogen peroxide,
stabilised using proprietary ionic
silver-based chemistry. The usual
recommendation is a shock dose of
the water to remove any existing
biofilm or biofouling from the system,
normally carried out at 100 ppm for a
minimum of 12 hours. Higher
concentrations may be required
depending on the condition of the
facility. The spa or hot tub can then
be operated with a hydrogen peroxide
residual of 50 ppm (30 ppm to
70 ppm hydrogen peroxide). No pH
adjustment is required
Ozone with residual disinfection Ozone may be used but it must be in
conjunction with residual disinfection.
The type of ozonisation used depends
on the spa-pool installation. Where
spa pools are installed as an integral
part of a leisure-pool water treatment
system, the treatment is sometimes
combined with that of the main leisure
pool. Ozone treatment would normally
be followed by deozonisation before
residual disinfection. Free chlorine
residuals will still need to be
maintained between 3–5 mg/l,
bromine at 4–6 mg/l, and
isocyanurates at 3–5 mg/l to ensure
adequate disinfection
Alternatively, trickle stream ozonisation
is sometimes used where the ozone is
not removed by a deozonisation bed
prior to the addition of the residual
disinfectant. The ozone should be at
such a concentration to ensure that
0.01 ppm ozone is not exceeded in the
atmosphere above the spa-pool water.
The residual disinfectant may be any
of those mentioned earlier in this table.
The ozone generator should be
checked daily to ensure it is operating
correctly. The system must be
maintained and cleaned as specified in
the manufacturer’s instructions
Where ozone generation plant is
installed, mechanical ventilation may
be necessary to achieve 10 air
changes per hour. Extract should be at
low level and in accordance with HSE
publication EH38 Ozone: Health
hazards and control measures,24 and
CIBSE guide TM21 Minimising
pollution at air intakes25
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Ultraviolet light Ultraviolet (UV) light only has a
bactericidal action at the point of use
and therefore additional disinfection is
required (eg residual chlorine).
BCDMH is not suitable for use in
conjunction with UV as bromate will
be formed. The system must be
maintained and cleaned as specified
in the manufacturer’s instructions
Other disinfectants
140 There are other types of disinfectant available but it is important that
the disinfectant used has been independently shown to be capable of
providing satisfactory chemical and microbiological water quality.
Emergency disinfection
141 The EAP must take account of situations where the spa pool has
become grossly contaminated. This may be identified by repeated
failures of microbiological results or visual inspection. The EAP should
include removing bulk contaminants by cleaning and super chlorination,
and the use of a flocculent.
Chemical storage
142 Acids, alkalis and disinfectants should be stored appropriately in a
secure, well-ventilated, dry storage area, preferably separate to the plant
room, with each area having provision for heat and frost protection and
marked with an appropriate warning sign. These should be bunded (the
bund should be able to contain at least 110% of the maximum volume of
liquid stored) and separated to contain any spillage of liquid chemicals
and prevent any subsequent mixing of acids and alkalis, where highly
toxic chlorine gas may be produced. Storage information is provided in
the safety data sheets.
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Section 5: Testing and

monitoring water quality
143 The risk from exposure to legionella and other infectious agents
should be prevented or controlled and the precautions taken monitored
to ensure they remain effective. This section gives guidance on
monitoring the water quality in spa-pool systems, routine sampling and
testing for the presence of bacteria. These combined factors will help to
give an indication of whether control is being achieved.
144 Spa-pool water should be routinely analysed to ensure the continued
effectiveness and suitability of the treatment programme. The frequency
and extent of any analysis will depend on the operating characteristics of
the system and will typically include daily, monthly and/or quarterly actions
to ensure that chemical dosage and system water quality are appropriate –
see Table 1 Operational actions and typical frequencies (page 34).
145 The identification of changes in the water chemistry such as pH,
disinfectant concentrations and water balance should allow for
necessary corrective actions to be taken to the treatment programme or
system operating conditions.
146 The microbiological monitoring programme should include the
routine sampling and testing for the presence of bacteria to assess the
effectiveness of the water treatment.
147 Testing of water quality, using chemical and microbiological
monitoring, is an essential part of the spa-pool treatment regime and
may be carried out by the operator where they are suitably trained to do
so, or by an external service provider.
148 Testing and recording of the chemical and microbiological
parameters associated with the spa pool should be carried out and
appropriate actions taken according to the results (see Tables 3 and 4).
The test results should be provided in the form of a report which will
form part of the record-keeping requirements.
Chemical
149 The frequency and extent of the chemical testing should be

determined by the risk assessment. Most testing can be done at
poolside but some specialist tests will require laboratory analysis.
150 Testing of spa-pool water should capture normal variation of operating
conditions, for example it should be carried out when the features are not
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operating as spa-pool water chemistry alters during activation of the

booster jets, and ideally should also be carried out just after maximum use
to ensure the treatment regime is working appropriately.
Table 3 Chemical parameters and actions required
Test Typical range Recommended action

pH 7.0–7.6 None
<7.0 or >7.6 Close spa pool and
check the operation and
calibration of acid/alkali
dosing units
Recheck pH once any
faults have been
rectified. If pH is still out
of limits, the spa pool
will need to be emptied
and refilled with mains
water to reach the
typical pH range and
additional treatment may
need to be added to
achieve this pH
Disinfectant Chlorine 3–5 mg/l None
Bromine 4–6 mg/l
Chlorine <1 mg/l or Close the spa pool,
>10 mg/l apply corrective actions
and retest
Bromine <2 mg/l or
>12 mg/l
Chlorine 1–2 or 6–10 mg/l Check dosing units are
operating correctly
Bromine 2–3 or 7–12 mg/l
High levels of
disinfectant can be
lowered by partial
replacement of spa-pool
water, once the
underlying fault has
been rectified
Low levels of
disinfectant can be
increased by shock
dosing of spa pool
water, once the
been rectified
Combined chlorine 0<1 mg/l None
>1 mg/l Review control
measures
High levels can be
lowered by partial
replacement of spa-pool
water, once the
been rectified
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Test Typical range Recommended action

Total dissolved solids No more than 1000 mg/l None
(TDS) higher than the incoming
fill water
>1000 mg/l higher than Review control
the incoming fill water measures
Spa pool will need to be
emptied and refilled to
lower concentration
151 Information obtained from regular monitoring can indicate whether:

water replacement and backwashing are being done at sufficient
frequency;
disinfectant residuals are adequate;
operation of the water treatment plant is effective for the bather
load;
there is overdosing of water treatment chemicals (indicated by high
biocide levels);
the filter remains effective;
there is advanced warning of failure of filters, valves etc.
152 The test results should be recorded and should state the acceptable
limits for parameters tested, together with any remedial action to be
taken in the event of a test result being out of specification (both upper
and lower limits).
Microbiological monitoring
153 The frequency and extent of the microbiological sampling strategy

should be determined by the risk assessment but at least monthly for
ACC, coliforms, E coli and P aeruginosa and quarterly for legionella.
Sampling should be done when the spa pool is in use, preferably when
heavily loaded or immediately afterwards, and sampling for legionella
should be carried out in accordance with BS 759226 (Information box 6
Microbiological sampling procedure). The laboratory performing the tests
should be accredited by the United Kingdom Accreditation Service
(UKAS) to EN ISO 17025 General requirements for the competence of
testing and calibration laboratories.27 Additional microbiological sampling
should also be taken:
when a spa pool is first used or recommissioned;
after a report of ill health following spa-pool use;
where there is doubt about the effectiveness of the control regime;
where there has been a contamination incident;
where alterations are made to the treatment or maintenance
regimes.
154 Reports of illness associated with use of a spa pool should be

discussed with the local environmental health officer (EHO), who will
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liaise with local public health services, as necessary. In the event of an

outbreak, where there are two or more cases of illness associated with a
spa pool, additional microbiological samples will be taken by the
appropriate agency, following discussion between the EHO and local
public health service Health Protection Team, or Health Board.
155 Sampling frequency can be altered, depending on the risk
assessment, including previous adverse results or any adverse health
effects reported by the bathers. Spa pools situated outdoors will have
additional demands placed on the disinfection and filtration systems
from environmental contamination by dust, debris etc, so it is important
that these factors are taken into account when determining a monitoring
schedule.
Information box 6 Microbiological sampling procedure
Sample bottles for microbiological testing should be either individually

wrapped or the outer surface disinfected by wiping with, for example, an
alcohol swab and allowing the bottle to dry before use. Plastic (not glass)
sampling bottles can be supplied by the testing laboratory for this
purpose – they must be sterile and contain a validated neutralising agent
for the disinfectant.
The testing laboratory must be informed of the disinfectant used before

the sample is taken, to ensure that the appropriate validated neutraliser
is supplied. If an appropriate neutraliser is not available then the sample
must be tested as soon as possible as the testing laboratory will need to
take into account the time delay before testing is carried out when
interpreting results.
For routine monitoring, a sample bottle of 500 ml should be used and, for
legionella, a sample bottle of a size specified by the laboratory.
Microbiological sample bottles should not be rinsed with the water to be
tested as this will remove the neutraliser. To take the sample:
remove the stopper or cap first with one gloved hand, making sure
that nothing touches the inside of the bottle or cap;
when the bottle is being plunged into the water, keep the long axis
approximately horizontal but with the neck pointing slightly upwards
to avoid loss of the neutralising agent;
immerse the bottle about 200–400 mm below the pool surface and
then tilted upwards to allow it to fill;
when removed from the water, replace the cap immediately and invert
the bottle repeatedly to disperse the neutraliser;
send to the laboratory without delay to enable analysis ideally within
24 hours of sampling but no longer than 48 hours.
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In transit, any samples should be protected from light and placed in

insulated containers maintained at the following approximate
temperatures for the duration of the journey:
samples for legionella testing – ambient temperature;

samples for non-legionella testing – 2–8 °C (use freezer or ice packs
but do not let the sample container come in direct contact with the
freezer packs).
A record should be made of the pH value and the disinfectant residuals

determined at the time of sampling.
156 Regular microbiological testing should be carried out by a laboratory

with the required tests within its scope of accreditation and recorded
together with any remedial actions and follow-up samples after an
adverse result.
Microbiological tests
157 The monitoring programme should include the routine monthly

sampling and testing for the presence of bacteria and should include an
ACC (or total viable or total colony count), coliforms, E coli, and P
aeruginosa, in addition to quarterly tests for legionella.
158 The ACC will give an indication of the overall microbiological quality
of the spa pool and whether microbiological control is being achieved.
This should be carried out in accordance with BS EN ISO 622228 with
incubation at 37 °C for 24 hours.
159 The presence of E coli and/or coliforms is an indication of the
presence of serious contamination and a failure in the water treatment
system to remove the contamination.
160 The presence of P aeruginosa is an indication of water treatment
failure with likely colonisation of and biofilm formation on the spa-pool
filter and within other parts of the system.
161 Where health problems associated with the use of the spa pool are
identified, it may be necessary to test the water for other relevant
organisms, based on epidemiological evidence. First seek advice from
the local Health Protection Team.
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Recommended actions based on the microbiological

results
162 The dutyholder should cease operation of, and close the spa pool
immediately where, following a routine microbiological test, there is
evidence of gross contamination if there is:
>10 cfu E coli per 100 ml in combination with
>10 cfu ACC per ml and/or
>10 cfu P aeruginosa per 100 ml;
>50 cfu P aeruginosa per 100 ml:

>1000 cfu legionella spp per litre;
other chemical or physical evidence that the spa-pool disinfection
system is not operating correctly.
163 If the microbiological results are unsatisfactory but do not indicate

immediate closure as above, a review of the records should be carried
out and the sampling and microbiological tests repeated immediately.
Repeat failures could indicate significant microbiological contamination
problems that may require more focused monitoring. This may include
water samples or swabs from suspect components such as the balance
tank or the overflow channels (see Table 4).
164 If the results are still unsatisfactory after the repeat samples and
investigation, immediate remedial action is required that may necessitate
the spa pool being closed.
Table 4 Microbiological results and appropriate actions
Microbiological result Action

Aerobic colony count (or total viable count)
Aerobic or total colony count at 37 °C If the colony count is >10 cfu/ml and
>10 cfu/ml is the only unsatisfactory
microbiological result, and residual
disinfectant and pH values are within
recommended ranges, the water
should be resampled and retested
Aerobic or total colony count at 37 °C Check treatment system and
>100 cfu/ml manual testing results records
immediately
Implement any remedial action as
required
Resample and retest
Coliforms and E coli
Coliforms and E coli present Occasional positive samples may
>1 cfu/100 ml occur if the spa pool has been
sampled immediately after a
contamination event before the
disinfection system had time to be
effective. A repeat sample should be
taken whenever coliforms have been
detected
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Coliforms ≤10 cfu/100 ml A coliform count of up to
10 cfu/100 ml is acceptable provided
that the residual disinfectant and pH
values are within recommended
ranges, there are no E coli present and
the aerobic colony count is <10 ml
Coliforms present on repeat test or if Indicates that disinfectant regime is
>10 cfu/100 ml at any time ineffective
Close spa pool
Shock dose the spa pool with
50 mg/l free chlorine circulating for
1 hour or equivalent
Drain, clean and disinfect
Review control measures and risk
assessment
Carry out remedial actions
identified
Refill, disinfect and adjust pH to
recommended range; and retest
next day and 2-4 weeks later
Pseudomonas aeruginosa
P aeruginosa present 10–50 cfu/100 Take a repeat sample for testing
ml with or without raised coliform, Scrub walls of balance tank, if any,
E coli or colony count and cleanse the filter
Chlorinate to 10 mg/l free chlorine,
circulate and flush
If repeat sample contains
P aeruginosa the filtration and
disinfection processes should be
examined to determine where the
organism has been multiplying
P aeruginosa present >50 cfu/100 ml Close spa pool
with or without raised coliform, E coli Shock dose the spa pool and
or colony count balance tank, if any, with 50 mg/l
free chlorine circulating for 1 hour
or equivalent and flush through
assessment
identified
Refill, disinfect and adjust pH to
recommended range; retest next
day and 2–4 weeks later
Legionella
<100 cfu/l Under control but maintain control
measures
>100 cfu/l and up to 1000 cfu/l Resample and keep under review
assessment
identified as necessary
Health and Safety
Executive

>1000 cfu/l Immediate closure of pool and
exclude public from pool area
Shut down spa pool
Shock dose the spa pool with
50 mg/l free chlorine circulating for
1 hour or equivalent
assessment
identified
Refill and retest next day and 2–4
weeks later
165 Alternative techniques for determining microbial activity may be used

as long as they are suitably validated and accredited. It is important that
the data from such tests can be properly interpreted, so that appropriate
action levels can be set to enable informed decisions on the control
measures needed. This may be achieved by running the tests in parallel
with traditional culture-based methods for a period.
Health and Safety
Executive
Appendix: Spa-pool checklists
It is a legal duty to carry out an assessment to identify and assess

whether there is a risk posed by exposure to legionella and other
infectious agents from the spa-pool system or any work associated with
it. Once the risk is identified and assessed, a written control scheme
should be prepared, implemented and properly managed. The following
checklists will help to ensure the appropriate arrangements are in place
to manage and control any risk of infection from the spa-pool system.
This will include a physical inspection of the system, and an examination
of the management procedures and appropriate records.
In addition to the spa-pool system, the dutyholder will also need to
assess whether there are any other sources of risk and ensure
appropriate control measures are put in place.
Checklist 1 Risk assessment
1 Clear allocation of management responsibilities including name, job

titles and contact information for:
dutyholder;
responsible person and nominated deputies;
service providers.
2 Clear identification of roles and responsibilities including employees

and contractors.
3 Competence, training and instruction of key personnel, employees
and contractors including training records.
4 Check to confirm that consideration was given to preventing the risk
by elimination or substitution before implementing control measures.
5 Description of the spa-pool system (including make, model, year of
manufacture, and type), component parts and associated equipment
including an up-to-date schematic diagram to include:
system plant, eg filters, strainers, pumps, non-return valves;
standby equipment, eg spare pumps;
associated pipework and piping routes;
associated storage/balance tanks;
chemical dosing/injection points;
water supply;
parts that may be temporarily out of use.
Health and Safety
Executive
6 Evaluation of the risk which should include the potential for microbial
growth, other health and safety issues (eg chemicals, working in confined
spaces, electrical safety, ease of access to parts of the system etc) and
compliance with the water safety elements of the water fittings regulations.
7 Assessing the potential for the system to become contaminated with
micro-organisms (including legionella) and other material, including
considering:
the source and quality of the make-up water;
the likelihood for airborne contamination;
the effectiveness of the biocide treatment.
8 Arrangements to review the risk assessment regularly and particularly

when there is reason to suspect it is no longer valid.
Checklist 2 Written control scheme
1 Purpose.
2 Scope.
3 Risk assessment.
4 Management structure.
5 Instructions for correct and safe operation of the system.
6 Safe operating procedures for the spa-pool system including
appropriate control measures.
7 Precautions in place to prevent or minimise risks associated with
the system.
8 Effectiveness of control measures including chemical and physical
water treatment, disinfection and cleaning regimes and remedial work
and maintenance.
9 Monitoring, inspection and maintenance procedures.
10 Results of monitoring, inspection and any checks carried out.
11 Tests, checks and inspections to be carried out, their frequency and
resulting corrective actions.
12 Remedial action to be taken in the event that the scheme and control
measures are found to be not effective.
13 Health and safety information, including details on storage, handling,
use, and disposal of any disinfectant used in both the treatment of the
system and testing of the water.
14 Emergency plan to deal with situations involving serious or
imminent danger.
15 Audit of contractors upon completion of any contracted work (eg
plumbing work or biocide installation).
Health and Safety
Executive
Glossary
Acid A chemical which lowers pH value (increases the acidity) when

added to pool water
Acidity A measure of the acid content of water
Active bromine This is readily available for killing bacteria and algae. It
includes free bromine and some bromamines
Aerobic colony count (ACC) The total number of culturable bacteria
(per volume or area) in a given sample (does not include legionella)
Aerosol A suspension in a gaseous medium of solid particles, liquid
particles or solid and liquid particles having negligible falling velocity. In
the context of this document, it is a suspension of particles which may
contain legionella with a typical droplet size of <5 μm that can be inhaled
deep into the lungs
Air blower Mechanical device for inducing air into ducting in the spa
Air induction A system whereby air is induced into ducting and released
into the water through small orifices or where it is induced from the side
of the spa into hydrotherapy jets
Algae simple organisms similar to plants that require light for growth,
typically found in aquatic environments
Algicide A chemical compound which destroys algal growth
Alkali A chemical which raises the pH value (reduces the acidity) in pool
water – also called a base
Alkalinity A measure of the alkaline content of water
Amperometric An electronic device for measuring the current produced
in water due to the presence of oxidising agents such as bromine,
chlorine or ozone
Automatic controller An electronic system to maintain correct
disinfectant and/or pH value. A chart recorder may be incorporated to
give a permanent and continuous record of these parameters. Manual
back-up is required
Backwash The process of reversing the flow of water through the filter
to clean the filter media and discharge the waste to drain
Health and Safety
Executive
Balance tank A tank fitted in circulation system of overflow spas to

balance water displaced by bathers and to provide additional water
volume in heavy-use situations, to maintain a constant level in a
commercial-type spa
BCDMH Abbreviation for the dry organic compound 1-bromo-3-chloro-5,
5-dimethylhydantoin-bromine-based spa and pool water disinfectant.
Biocide A substance that kills microorganisms
Biofilm A community of microorganisms of different types growing
together on a surface so that they form a slime layer
Booster jets For pumping water at high pressure, normally sized for
maximum performance through hydrotherapy jets and also to provide
high-pressure jets of water within the body of the spa for body massage
Brominator A dispensing device for dosing bromine into a spa or pool
recirculating system
Bromine An element very similar to chlorine used as a biocide and
sometimes as a disinfectant. The main practical difference between
bromine and chlorine when used as a biocide is that bromine remains
effective at higher pH values
Cartridge filter A replaceable filter used in domestic-type spa pools and
constructed from pleated paper or wound fibres, through which water is
passed for filtration
Chlorination The process of treating pool or spa water with chlorine.
Chlorine can be added to pool and spa water in a variety of commercially
available forms as gas, solutions or solids (granules or tablets)
Chlorine An element used as a biocide and for disinfection (see
bromine, combined chlorine and free chlorine)
Chlorine residual The amount of chlorine remaining in the spa-pool
water after satisfying the chlorine demand. The chlorine residual can be
expressed as free chlorine residual, combined chlorine residual or total
chlorine residual
Combined bromine Bromine which has reacted with nitrogen to
form bromamines
Combined chlorine The amount of chlorine that has reacted with
nitrogenous or organic materials to form chlorine compounds. If the
materials are nitrogenous then the compounds formed are chloramines
Coliform A bacterium belonging to the enterobacteriaceae
Deadleg A length of water system pipework leading to a fitting through
which water only passes when there is draw off from the fitting, thereby
providing the potential for stagnation
Health and Safety
Executive
Deck-level overflow system A system with perimeter overflow channels

for the removal of surface water forming a part of the recirculation
system which are typically used in commercial-type spa pools
Decks and surrounds Areas surrounding spas, which are specifically
constructed and installed for use by bathers
Diatomaceous earth (DE) filter A filter using diatomaceous earth as a
filtering medium
Disinfection The reduction of the number of microorganisms to safe levels
by either chemical or non-chemical means (eg biocides, heat or radiation)
DPD1 A chemical reagent used to measure the bromine, chlorine and
ozone residuals in the water
Filter A device that separates particulate matter from water by circulation
through a porous medium
Filtration rate The rate of filtration of water in a given time, ie cubic
metres per square metre of effective filter area per hour (or gallons per
square foot of effective filter area per hour)
Flocculent A chemical used to aggregate particles suspended in water,
for example contaminants, to aid their removal by filtration
Free chlorine Chlorine dissolved in water to form hypochlorous acid and
Hypochlorite ion
Hypochlorite Inorganic chlorine compounds used for pool-water
disinfection. Commercially available forms are sodium hypochlorite
solution, calcium hypochlorite granules and tablets (lithium hypochlorite
is not permitted)
Langelier saturation index This is applied to pool water to assess
whether it has corrosive or scale-forming tendencies. The equation used
to calculate the index takes into account the pH, alkalinity, calcium
hardness, total dissolved solids and temperature of the water
Oxidising biocide A chemical agent which kills microorganisms by
oxidising organic matter, eg cell material, enzymes or proteins
Ozone A tri-atomic form of oxygen with powerful oxidising properties,
used as a water disinfectant and purifying agent in conjunction with
another residual disinfectant
Parts per million (ppm) A ratio for expressing chemical
concentration. In water, parts per million has the same numerical
value as milligrams/litre (mg/l)
pH A logarithmic scale of units, 0–14, which measures the balance
between acidic and alkaline (basic) compounds in water. Values below 7
are increasingly acidic, 7 is neutral, and values higher than 7 are
progressively alkaline. However, acidity and alkalinity are not proportional
to pH (see acidity and alkalinity)
Health and Safety
Executive
Ryznar stability index This is used to assess the scale-forming

tendency of water by using pH and calcium carbonate saturation to
correlate to a database of scale-thickness measurements observed in
municipal water systems
Scale Hard deposits, which can block pool pipework and form on pool
water surfaces. Generally caused by the precipitation of calcium and
magnesium carbonate from hard water
Shock dose A term usually applied to the process of adding a higher
than normal dose of disinfectant, sometimes called ‘shot’ dose or
super chlorination, to pool water to control microbial growth or
destroy bather impurities
Skimmer A device designed to remove surface water, forming part of
the recirculation system
Super chlorination see shock dose
Total alkalinity The quantitative analysis of the mix of bicarbonates,
carbonates and hydroxides in water. While too high total alkalinity causes
pH to resist adjustment, too low total alkalinity makes it difficult to maintain
Total chlorine The total sum of the free and combined chlorine in the water
Total dissolved solids (TDS) The quantity of soluble material in water
expressed as mg/l. These solids will typically include calcium and
magnesium (sodium in softened water), bicarbonate, chloride, sulphate
and traces of other materials. High levels cause turbidity
Total viable counts see aerobic colony count
Turnover time The period of time required to circulate a volume of water
equal to the total volume of water in the system. In spas this is usually
expressed in minutes
Water displacement The volume of water displaced by each bather
entering the spa. The water displacement is approximately 0.06 m3
(13 gallons) per bather
Health and Safety
Executive
References
1 Legionnaires’ disease: Technical guidance HSG274 HSE 2013

www.hse.gov.uk/pubns/books/hsg274.htm
2 Health and Safety at Work etc Act 1974 (c37) The Stationery Office
1974 www.legislation.gov.uk
3 Managing for health and safety HSG65 (Third edition) HSE 2013
www.hse.gov.uk/pubns/books/hsg65.htm
4 Control of substances hazardous to health (6th edition). The Control
of Substances Hazardous to Health Regulations 2002 (as amended).
Approved Code of Practice and guidance L5 (Sixth edition) HSE 2013
www.hse.gov.uk/pubns/books/l5.htm
5 Legionnaires’ disease: The control of legionella bacteria in water
systems. Approved Code of Practice and guidance on regulations L8
(Fourth edition) HSE 2013 www.hse.gov.uk/pubns/books/l8.htm
6 Consulting workers on health and safety. Safety Representatives and
Safety Committees Regulations 1977 (as amended) and Health and
Safety (Consultation with Employees) Regulations 1996 (as amended).
Approved Codes of Practice and guidance L146 (Second edition) HSE
2012 www.hse.gov.uk/pubns/books/l146.htm
7 BS 7671 Requirements for Electrical Installations. IET Wiring
Regulations British Standards Institution
8 BS 8580 Water quality. Risk assessments for Legionella control. Code
of Practice British Standards Institution
9 Water Supply (Water Fittings) Regulations 1999 SI 1148/1999
The Stationery Office www.legislation.gov.uk
10 Water Supply (Water Fittings) Scotland Byelaws 2014 Scottish Water
www.scottishwater.co.uk
11 Consumer Protection Act 1987 (c43) The Stationery Office 1987
www.legislation.gov.uk
12 General Product Safety Regulations 1994 SI 2328/1994
13 The Classification, Labelling and Packaging of Chemicals
(Amendments to Secondary Legislation) Regulations 2015 SI 21/2015
Health and Safety
Executive
14 Managing health and safety in construction. Construction (Design and

Management) Regulations 2015. Guidance on regulations L153 HSE 2015
www.hse.gov.uk/pubns/books/l153.htm
15 The Private Water Supplies Regulations 2009 SI 3101/2009
16 The Private Water Supplies (Wales) Regulations 2010 Wales
SI 66/2010 The Stationery Office www.legislation.gov.uk
17 The Private Water Supplies (Scotland) Regulations 2006 SSI 209/2006
18 BS EN 806 (Parts 1–5) Specifications for installations inside buildings
conveying water for human consumption British Standards Institution
19 BS 8558 Guide to the design, installation, testing and maintenance of
services supplying water for domestic use within buildings and their
curtilages British Standards Institution
20 BS 6920 Suitability of non-metallic materials and products for use in
contact with water intended for human consumption with regard to their
effect on the quality of the water British Standards Institution
21 BS 5385-4 Wall and floor tiling. Design and installation of ceramic
and mosaic tiling in specific conditions. Code of practice
British Standards Institution
22 Public Health and Plumbing Engineering Chartered Institute of
Building Services Engineers (CIBSE) Guide G 2014 www.cibse.org
23 Swimming Pool Water: Treatment and quality standards for pools and
spas Pool Water Treatment Advisory Group (PWTAG) www.pwtag.org
24 Ozone: Health hazards and control measures Environmental Hygiene
Guidance Note EH38 HSE 2014 www.hse.gov.uk/pubns/eh38.htm
25 Minimising pollution at air intakes TM21 CIBSE 1999 www.cibse.org
26 BS 7592 Sampling for Legionella bacteria in water systems. Code of
practice British Standards Institution
27 EN ISO 17025 General requirements for the competence of testing
and calibration laboratories British Standards Institution
28 BS EN ISO 6222 Water quality. Enumeration of culturable micro-
organisms. Colony count by inoculation in a nutrient agar culture medium
British Standards Institution
Health and Safety
Executive
Sources of information
Manufacturers should provide detailed advice and instructions on the

management of their spa pool. General advice on this can also be
obtained from:
Pool Water Treatment Advisory Group (PWTAG) pwtag.org
Swimming Pool and Allied Trades Association (SPATA) www.spata.co.uk
British and Irish Spa and Hot Tub Association (BISHTA)
www.bishta.co.uk
Chartered Institute for the Management of Sport and Physical Activity
(CIMSPA) www.cimspa.co.uk
SPATA publish detailed guidance on constructing and installing
commercial-type spa pools, and BISHTA publish guidance on domestic-
type, self-contained spa pools.
Health and Safety
Executive
Acknowledgements
HSE thanks the following organisations for providing representatives with

policy and technical expertise used when preparing the guidance that
appears in this publication:
Public Health England (Nick Phin, Gavin Dabrera, Sandra Lai, Jimmy
Walker, Harsh Duggal, Elaine Stanford)
City of London (Toby Thorp)
Public Health Wales (Robert Smith)
Health Protection Scotland (Eleanor Anderson)
Public Health Agency, Northern Ireland (Michael Devine)
Independent legionella consultant (John Newbold)
Pool and Water Treatment Advisory Group (John V Lee)
Royal Society of Public Health (Susanne Lee)
Swimming Pool and Allied Trades Association (Howard Gosling)
British and Irish Spa and Hot Tub Association (Chris Hayes)
Amateur Swimming Association (Richard Lamburn)
British Holiday and Home Parks Association (Jackie Gawen)
Health and Safety
Executive
Further information
For information about health and safety, or to report inconsistencies or

inaccuracies in this guidance, visit www.hse.gov.uk/. You can view HSE
guidance online and order priced publications from the website. HSE
priced publications are also available from bookshops.
British Standards can be obtained in PDF or hard copy formats from BSI:
http://shop.bsigroup.com or by contacting BSI Customer Services for
hard copies only Tel: 020 8996 9001 email: [email protected].
The Stationery Office publications are available from The Stationery
Office, PO Box 29, Norwich NR3 1GN Tel: 0870 600 5522 Fax: 0870 600
5533 email: [email protected] Website: www.tsoshop.co.uk/
(They are also available from bookshops.) Statutory Instruments can be
viewed free of charge at www.legislation.gov.uk/.
This document is available at: www.hse.gov.uk/pubns/books/hsg282.htm
Published by the Health and Safety Executive HSG282 05/17

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Health and Safety

The control of legionella and other

© Crown copyright 2017

Section 1: Legislative requirements 6

Section 2: Types and settings 20

Section 3: Design and commissioning 24

Section 4: Operation and maintenance 32

Section 5: Testing and monitoring water quality 44

Appendix: Spa-pool checklists 52

Scope and application

1 This guidance is aimed at dutyholders, including employers and

4 A spa pool is a self-contained body of warm, agitated water

6 There have been a number of outbreaks, including fatalities, linked to

Health and safety law

9 This guidance provides specific information on the health and safety

Other relevant health and safety legislation

16 Other health and safety legislation the dutyholder may need to

Reporting of Injuries, Diseases and Dangerous Occurrences 2013

The Safety Representatives and Safety Committees Regulations

Microbiological and other hazards

19 Water in spa pools should be free from irritant substances,

20 These are generally introduced from bathers or external sources, ie

Coliforms and Escherichia coli

Mycobacterium avium and Mycobacterium species

Other potential infections

26 The most immediate danger to users is from accidental drowning,

Slips and trips

Identifying and assessing the risk

34 Before any formal health and safety management system is

 unusual operating conditions, eg dosing pump breakdowns, dosing

including refresher training, is an essential element of an employee’s

Controlling the risk

44 To control the risk, a course of action should be devised to manage

Information box 1 Pool safety operating procedure (PSOP)

Normal operating plan (NOP)

Emergency action plan (EAP)

The EAP should give specific instructions on the action to be taken, by

How the plans can be kept

The plans can be kept as written documents or stored electronically,

45 The written scheme should specify:

52 Records must be kept when managing a spa-pool system and should

 inspections, checks and records of maintenance on the water

system, components and water treatment equipment to confirm

Dealing with accidents, incidents and emergencies

55 The dutyholder must establish procedures to deal with situations

58 The emergency procedures should provide sufficient information to:

Responsibilities of designers, manufacturers, importers,

61 Designers, manufacturers, importers, suppliers (including hirers) and

safety becomes available. Plumbing fittings and pipework etc must

Information box 2 Relevant legislation

HSW Act, Sections 3 and 6

This places a duty on any person who designs, manufactures, imports

It also places general duties on employers and the self-employed to

Consumer Protection Act (CPA) 198711

 be of satisfactory quality, that a person would reasonably expect

It is a criminal offence for a trader to put a false description on goods.

General Product Safety Regulations 199412

These regulations have replaced Section 10 of the CPA and apply to

Producers are required to:

Health and safety law – holiday parks and lets

unusual operating conditions, eg dosing pump breakdowns, dosing

inspections, checks and records of maintenance on the water

be of satisfactory quality, that a person would reasonably expect

chemical treatment and storage areas;

samples for legionella testing – ambient temperature;

>10 cfu P aeruginosa per 100 ml;

>50 cfu P aeruginosa per 100 ml: