Automating Title 22 Compliance

PoolWarden Reporter September 15, 2017

Having been involved with swimming pools since 1984 and chemical automation since 1991, I have seen many benefits in automating chemistry. No, it is not perfect like everything and everyone in our world but I have witnessed pools and spas with chemicals being maintained by an automation system to be much more likely to have clean, clear and safe water at any given time.

Having started in this business adjusting dials on chlorine feeders and doing my best to maintain water at parameters defined by a County Health Department, one of the first things I noticed on automated pools was the water looked much more polished with little to no algae.

The debate on Title 22 compliance goes on with or without automation. Many counties throughout California are approving automation with human interaction intervals not to exceed a maximum of 7 days depending on the type of facility and some are not. The code allows for automation as stated here.

Section 65523 – Operation Records.
(a)Except as provided in Health and Safety Code, section 116048, the pool operator of every public pool open for use at a public pool site shall test the disinfectant residual and pH of the public pool water a minimum of once per day. The pool operator shall also test heated pools’ water temperature a minimum of once per day. The pool operator may perform these daily tests using a properly calibrated automatic chemical monitoring and control system if approved by the enforcing agent and in accordance with the manufacturer’s equipment specifications for calibration and directions for proper use. The pool operator shall maintain a written daily record of all test results, equipment readings, calibrations, and corrective action taken at the public pool site.
Having spoken to a number of health officials from counties in Northern and Southern California, I have gotten a lot of information both for and against automating Title 22 compliance. Let’s discuss the reasons against first.
Two of the main reasons against automation are people will automate, then forget it, leaving the automation to itself and all other aspects of pool safety such as identifying broken drain covers and insecure gates unmonitored. First I will address set and forget. The code requires operating in accordance with the manufacturer’s equipment specifications for calibration and directions for proper use. This can easily be done on routine service visits on a weekly basis.
No, we cannot guarantee 100% compliance all the time but then this cannot be accomplished with a manual visit either. Responsibility is required at all levels. Pool owners, operators, service companies and users need to be responsible to ensure the health and welfare of any aquatic facility. I know this doesn’t always happen which is why we have the need for public health officials. Human beings have been taking short cuts since the beginning of time.
With our automation systems it can be verified that human interaction has occurred at a specific day and time, making it more difficult to “game” the system. There have been numerous times over the years when I have seen inaccurate information manually entered into a pool log. Sometimes, especially during the swim season, service companies can be stretched beyond capacity making it difficult to always make a daily stop. One of my customers had been working 7 days a week for several months doing manual readings himself so his employees could have a day off. The burnout was obvious. For a lot of pool owners, 7 day a week manual visits can bust budgets and cause problems between customers and service providers.
Even with a daily visit, we know we can guarantee water chemistry compliance for a brief window of time. A spa can go out of compliance in just a few minutes and just about every one of them will be out of compliance before the next daily visit even with no use during that day.
Automation can help ensure 24/7 compliance especially with remote communication which makes it possible for notification when the chemistry levels get to user defined levels based on code requirements. With this level of communication, pool operators can be proactive and correct a situation before it becomes a problem with compliance as well as the health and welfare of bathers.
In regards to monitoring broken drain covers, skimmer lids, gate issues, etc. has always been a requirement to ensure these things are in good repair. Some counties allow for a community member to walk by daily for a visual inspection, some allow for these components to be inspected at regular service intervals. This should also be the responsibility of pool and spa users that upon seeing something broken or a gate not closing to report immediately and have the ability to close a facility before someone gets hurt. It is impossible for a service company or pool operator to monitor these issues 24/7.
I have yet to see a pool log that has entries for drains, skimmers, gates, etc.
The reasons for automating the daily recording of sanitizer residual, pH and temperature are not limited to the following.
We live in a world where many things that were done manually are now automated. Automation makes processes more efficient and reliable. Properly maintained automation will provide better results than manual operation. We are now on the cusp of having automated cars which will reduce accidents. We have had automated temperature controls for decades. Who would have a heater or AC with a manual on off switch?
Automation does not take days off, call in sick, falsify records and works 24/7. It is also able to provide chemically compliant water all the time, not just a moment in time. Obviously no system is failsafe. Even a circulation pump can fail after a pool is serviced. Some automation systems with or without remote communication can be set up to have audible and visual alerts in the event chemistry and temperatures going out of range along with loss of flow.
Automation can also reduce traffic, fuel consumption and emissions by eliminating the need for trucks driving around 7 days a week just to check chemical levels. This saves time and money allowing for resources to be available for other components of a pool system. It also makes it much more likely a pools health with be maintained, providing for the welfare of the public.
Again, I do not advocate a set it and forget it mentality which is much like a dial on a chlorine/bromine feeder which cannot take into consideration bather load and does nothing to compensate for pH in which an operator adjusts the pH when they are there and typically comes back to it needing adjustment again.
It is my belief that chemical automation can be highly effective in helping pools and spas to be Health Department compliant. By allowing automated Title 22 compliance, departments will be participating in an industry improvement. Especially since manual daily testing has not typically been done outside of hotels and fitness facilities until the automation was employed. Inspectors often have very difficult work loads, departments sometimes have high turnover and the end goal of improved water quality and safety is not happening in the real world.
Resistance to emerging technologies is human nature for most but technology can be our friend in improving compliance if the industry embraces automated Title 22 systems by embracing 21st century water management.

Lance Fitzsimmons

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