By Lizzie Ward, Managing Director of SAS Water Ltd, legionella control specialists, based in Leek.
Many holiday complexes, leisure facilities and sports clubs are emerging cautiously from lockdown.
If facilities include spas and hot tubs, there’s lots to consider as seen in new guidance from the UK Pool Water Treatment Advisory Group (PWTAG).
Operators should seek specialist support and carry-out a full risk assessment before recommissioning spas and hot tubs.
PWTAG, a respected independent advisory body, states: “Spa pool and hot tubs have always presented particular infection challenges, so it is crucial that their operation during the pandemic is preceded and governed by a rigorous audit, including formal risk assessment.
“Each manager, or person in overall charge of health and safety for the spa pools and hot tubs, must ensure there is a Covid-19 risk assessment in addition to those already in place in accordance with the Health and Safety at Work Act and associated legislation. (ACoP L8 Legionnaires’ disease: the control of legionella bacteria in water systems and HSG 282 Control of legionella and other infectious agents in spa-pool systems.)
“Coronavirus is likely to be with us for some time, so the risk assessment will need to be reviewed regularly, in response to changes and growing knowledge.”
Public Health England advice is that hot tubs and spas should only be used in ‘social bubbles’ and should be emptied and cleaned after each rental as per best practice in health and safety guidance (HSG 282).
When used in a family group, the hot tub/spa pool should be avoided if any member of the social bubble has Covid-19 symptoms. From 4 July, two households (i.e two social bubbles) can interact, although hot tubs may have a limited capacity for the number of individuals that can use it while maintaining safe distancing.
For example, two families sharing a lodge could both use its hot tub – but not another visitor. One family in a lodge could invite another person to stay and use the hot tub. Only those hot tubs and spa pools that can be used by such a social bubble can be used; thus public integrated spa pools attached to a swimming pool should not be used, even after 4 July. Commercial standalone spa pools can be used by up to two households forming a single social bubble with draining between use.
Hot tubs are, by design, relatively confined spaces, users should be reminded that thy are likely to be sitting closely together and facing each other. While not part of a legionella risk assessment, it is important to remember that Covid-19 can be spread by people talking, laughing, sneezing and coughing.
Now that outdoor spas and hot tubs are permitted to open in England on 11 July and indoor spas and hot tubs from 25 July, there is a need to have robust practices in place before opening.
Spa pool and hot tubs have always presented particular infection challenges. It is crucial that their operation during the pandemic is preceded and governed by a rigorous audit, including formal risk assessment.
Each manager, or person in overall charge of health and safety for the spa pools and hot tubs, must ensure there is a Covid-19 risk assessment in addition to those already in place in accordance with the Health and Safety at Work Act and associated legislation. (ACoP L8 Legionnaires’ disease: the control of legionella bacteria in water systems and HSG 282 Control of legionella and other infectious agents in spa-pool systems.)
Coronavirus is likely to be with us for some time, so the risk assessment will need to be reviewed regularly, in response to changes and growing knowledge.
Reopening following lockdown
Because the spa or hot tub may have been unused for a few months, it should be thoroughly cleaned and disinfected prior to reopening. If they have been left running, they should now be super-chlorinated then emptied. Treatment prior to reopening should include:
- Emptying and flushing out any existing water including from any balance tank
- Procedures for flushing out the pipework (not be confused with biofilm removal through the use of chlorine dioxide)
- Cleaning the internal and user-facing surfaces and removable jets with a cleaning solution of 1000mg/l of disinfection solution; chlorine dioxide-based products may be used (equivalent dosage concentrations should be recommended by the manufacturer). Any scale should be removed before disinfection
- Filling with fresh water and super-chlorinating to 50mg/l and pH as near to 7.0 as possible
- Maintaining these levels of disinfection and pH for at least one hour (or equivalent, eg 10mg/l for five hours); the circulation should be fully operating during this time, including filters, all associated pipework, jets and blowers
- At the end of this period, all water thoroughly sluiced out, including the filter and all pipework
- Operation restarting as routine, ensuring target disinfectant and pH values are maintained.
When refilling a spa or hot tub, rapid dissolving calcium hypochlorite or sodium hypochlorite solution at 5mg/l free chlorine per 1000 litre capacity should be added at the start. This will ensure that there is no pipework which is not chlorinated as the water level rises.
Microbiological testing (including for Legionella) will be even more important than usual to demonstrate there are no infectious agents present in the spa pool or hot tub water system.
This is important and is highlighted in HSG 282. A commercial spa’s water should be replaced when the number of bathers has reached 100 times the volume in m3 (cubic metres). Where a hot tub is used as a business activity, the total water volume should be replaced each week, or after each rental, if that is sooner.
Operation of booster and air jets are another potential source of contamination by bathers. It is therefore important to ensure the booster jets are regularly circulated with water chlorinated to at least 3mg/l. Air jets should be disinfected at least weekly with a solution of 50mg/l free chlorine.
Lizzie Ward, Managing Director of SAS Water Ltd said: “Spa pools and hot tubs have an inherent risk of causing Legionnaires’ Disease and other infections, unless managed appropriately. The coronavirus pandemic has not gone away, there are currently no specific treatments available for it, and it is known to lead to lasting lung scarring for some people. Legionnaires’ Disease is also a form of pneumonia and we must be incredibly vigilant at this time to ensure legionella bacteria growth is kept to a minimum.
“It is a legal requirement that every spa pool or hot tub used in a business setting has a risk assessment for the control of Legionella and other infectious hazards
“PWTAG states that before reopening a spa pool or hot tub during the continuing pandemic, the risk assessment must be reviewed and operators should update their written scheme of control and emergency action plan.
“It has always been the case that spa and hot tub operators have a duty to mitigate the risk of legionella growth. They must also have access to competent advice and to inform, guide and train employees working around water facilities.
“If you need further information, or support with safety matters concerning your spa or hot tubs, we can support you. SAS Water Ltd has a team of qualified, experienced legionella consultants and we are members of the Legionella Control Association.
To learn more about SAS Water’s service, please go online to www.saswater.co.uk.