ISRM NATIONAL GUIDANCE NOTE
RISK ASSESSMENT ADVICE TO HELP POOL OPERATORS ESTABLISH AN APPROPRIATE SWIMMING POOL CHILD ADMISSION POLICY for UNPROGRAMMED SWIMMING


The Health and Safety Executive’s publication HSG 179 Managing Health and Safety in Swimming Pools states:
“Pool Operators will need to consider the number of children (under the age of 8 years) allowed into a pool, during unprogrammed sessions under the supervision one parent or adult. The decision on whether or not to admit adults with parties of children should be made having followed the principles of risk assessment, taking into account the physical attributes of the pool, the pool environment, staffing levels, and where possible, the swimming capabilities of the children.”
This means pool operators putting in place measures that will ensure the safety of young children, so far as is reasonably practicable. It will include establishing policies to determine the age at which children are deemed safe to swim without an accompanying adult and also the number of children that one adult can safely supervise.”
ISRM are the leading national professional body for the management and development of sport in the UK and our expertise suggests that the principles included in this guidance note should be considered when undertaking a risk assessment.
This guidance seeks to draw a fine line between the level of risk children face when they swim and the clear benefits of swimming. There is no doubt that the absence of parental attention has been a key factor in many accidental pool drownings but there is a further risk from too restrictive a control on children’s admissions. We do not wish to either deny children the opportunity to learn to swim and to develop swimming skills or to drive them to swim in unsafe water areas as a result of being turned away from their local pool. The level of risk has to be manageable and appropriate to each particular pool, based upon an assessment of the risks present and the control of those risks.
Guidance issued in 2002 has therefore been redrafted in 2005 to make it clearer to pool operators that they need to:
a) risk assess pools and different types of pool use by children
b) seek to find ways to help children come to pools rather than turning them away


SPECIFIC RISK ASSESSMENT FOR EACH POOL

In order to determine the appropriate number of children that can safely be supervised by one adult at each individual pool and for each type of pool activity, management should undertake a risk assessment. The purpose of this guidance is therefore to help inform the assessment of risks and to help management formulate a policy that will be specific and relevant to each pool. The risk assessment should take into account the full range of risks at each individual pool, together with the accident record for the pool.

When undertaking the process of risk assessment, each pool will follow a similar, generalised format, aiming to cover all eventualities for each type of use. This will involve looking carefully at:
• the physical environment
• the activities being undertaken
• the participants: age, maturity and swimming ability
• any equipment in use
An assessment needs to be undertaken of the level of seriousness of any possible hazards identified, alongside the likelihood or frequency of an incident actually happening. The pool operator should then consult with those closely affected or informed and decide what action could be taken to control or eliminate the risk. This will include adopting a policy in relation to child admissions. The policy arrived at should be kept under constant review. This should include monitoring the accident and incident records for the pool and a review of the risk assessment when any changes are introduced, such as alterations to staffing levels, introducing new activities or alterations made to the structure of the pool.


KEY FACTORS TO BE CONSIDERED IN THE RISK ASSESSMENT
a) Design, Layout and Type of Pool
Pools vary in size, shape and depth. Some pools are part of a complex of pools, with shallow water pools either segregated from or adjacent to deep water; some will have a range of features including moving water (waves, geysers and rapid rivers, etc.) and there may be physical hazards such as high freeboards (for wave pools), sudden changes in depth or hidden areas. All of this will need to be taken into account in assessing the risks to children and determining how many children, of what age, one adult can safely supervise in a particular pool.
b) Type of Session and Activities
Pools are increasingly programming different sessions to attract different user groups to the pool. This may be special family sessions, parent and toddler sessions, lane swimming, inflatable sessions or other fun sessions. The level of risk will vary with the degree of excitement, interruptions to lifeguard sight lines, water movement, access to shallow water and the general busy-ness of the session. Different sessions may need different levels of control.
c) The age and maturity of the children
“Under eight” is a very wide age band; ranging from babies and toddlers through to children first going to school and then about to embark upon junior school education. Age also has a link to height (relevant to water depth) and maturity (recognising and responding to hazards). These need to be considered in relation to the environment and the sessions in which the children are engaged.
d) The Number, Qualifications and Experience of the Staff
HSG 179 “Managing Health & Safety in Swimming Pools” gives guidance on the number of lifeguard staff required to safely supervise a variety of different types of pools. Pool operators will need to ensure that in any case this guidance is followed.

The number of lifeguards on the poolside, their qualifications and level of experience in supervising young children is an additional factor to take into account when undertaking a risk assessment. If a greater number of well-qualified and experienced staff are employed when children are using the pool, this may help management to introduce more flexibility in terms of the numbers of children with responsible persons admitted. This extra resource would however need to be backed up by other controls, for example, designated sessions for particular activities, as an extra lifeguard cannot alone replace the close and constant supervision of a parent.
The lifeguard has responsibility for the safety of all swimmers. The role of the lifeguard is very much in supporting and not replacing parents or carers. In this respect, the principal function of a lifeguard is to pre-empt dangerous situations from ever arising but should an incident occur, they must be able to make a rescue, give appropriate first aid and effect the emergency procedure. Child admission polices are part of a raft of management action that can be taken to help prevent accidents occurring.
e) Application in a lightly used local community pool
Local knowledge and local experience (for instance in a lightly used, small community pool in which most users and their swimming ability are well known) may enable operators to know which children and which parents are safe to use the pool, and to determine numbers and ages on a case by case basis.
Alternatively the pool operator may operate a scheme by which “licences” to swim or “swim passes” are issued following attendance at a training session or as part of a screened membership system (see ‘f’ below.) In this way the operator can assure themselves of the ability of the responsible people to safeguard identified children.
Where pools are not busy it is also often easier for lifeguards to see when swimmers are at risk in the pool as a result of their own behaviour and to warn or keep a special eye on such swimmers (see ‘g’ below). By restricting or controlling admissions, even a busy pool can create special sessions that replicate these conditions.
f) Good swimming ability
Just as all pools are different, so too are children! The swimming ability of children will significantly affect the level of risk different children will experience in swimming pools and therefore the measures required for their safety. Children with good swimming ability may be considered outside the scope of a pool’s usual child admission policy .
A good swimming ability, to a standard in excess of the bare minimum set by the National Curriculum key stage 2 requirements, may be sufficient to provide reasonable safety for children in their use of pools.
The swimming ability of the children should be certified by an appropriate authority, to demonstrate that in a continuous test, they can swim sufficiently well, to be reasonably safe. ASA and ISRM approve a “Swimming Standard” at which, in our joint opinion, children can be deemed to be reasonably water safe. This is a certificated award with an integral photograph option and can be considered a “passport” to swimming admission.
The criteria to achieve this is as follows:

Kelloggs Frosties ASA/ISRM Pool Swimming Standard Award:
• Jump from the side of the pool into water of a depth of 1.5m or more so that the head fully submerges, alternatively where there is only shallow water, hold a submerged mushroom float position for 10 seconds, then,
• tread water for 1 minute and finally,
• swim 50 metres under 2 minutes.
Swimming ability is an important factor which needs to be taken into account in the risk assessment. Where children meet the criteria for the ASA/ISRM Pool Standard Award, this helps reduce risk and increases the number of children who could safely be supervised by a single adult. The precise number will depend upon the full range of circumstances.
g) Children wearing armbands in designated non-swimmer areas
If children are non-swimmers, wearing approved armbands and they are restricted to designated non-swimmer areas, (meeting the criteria below), safety is enhanced, risk factors lowered and pool operators can reflect this in their policy on the number of children who may be accompanied into these areas by a responsible person.
Designated non-swimmer area criteria:
• Suitable and sufficient area of shallow water that is clearly defined
• Restricted access to any adjacent deep water
• Unobstructed lifeguard vision to all the pool surface area and the pool tank
• No moving water features
• No steep slopes where people can quickly or inadvertently get out of their depth

The following outlines ISRM’s recommendations for pool operators to consider using when drafting Child Admission Policies. This is not an easy task and should not be undertaken without due consideration to all the factors in play. Policies should reflect risk rather than corporate policy and should be specific to individual pools and sessions. An important element of setting policies is to ensure they are fully understood by and explained to all who are affected.

ISRM RECOMMENDATIONS

1. THE AGE AT WHICH CHILDREN NEED TO BE ACCOMPANIED

We strongly believe that all children under the age of eight years should always be accompanied in the water for unprogrammed swimming sessions.

2. THE PERSON ACCOMPANYING CHILDREN

A responsible person, should accompany all children under eight into swimming pools. They will need to go into the water with the children they are accompanying. Whilst in the pool they must maintain a constant watch over the children for whom they are responsible and be in close contact with those of their children who are weak or non-swimmers. Children should never be left on the poolside or in the pool without an accompanying responsible person.

The age at which a person is deemed responsible is likely to be at least 16 years although we recognise that some parents may be younger than this and that some persons, irrespective of their age, may not have the required competency to look after the children in their care. Consideration should be given to these issues in determining the appropriate policy.

3. THE NUMBER OF CHILDREN ONE RESPONSIBLE PERSON CAN SAFEGUARD

The number of children that one responsible person can safeguard in a swimming pool will depend upon a variety of circumstances:

• the design, layout and type of pool, type of session and activities,

• the swimming ability and maturity of the children and whether approved armbands are being worn by non-swimmers,

• the number, qualifications and experience of the staff on lifeguard duty.

4. CIRCUMSTANCES WHICH MAY INFLUENCE CHILD ADMISSIONS POLICIES

a) A pool with an especially safe “Designated Non-Swimmers Area” (teaching pools, shallow water pools and designated areas of shallow water in a traditional pool)
We would recommend that in such an area, as long as the children involved are either swimmers or non-swimmers who are wearing armbands, one responsible person may be able to safeguard, either up to:
• Three children aged 4-7 OR
• Two children under the age of eight, where any one of them is under the age of 4
N.B. Most children under the age of 4 will be out of their depth in a 900mm deep pool.

Not all armbands are as safe as those manufactured to approved standards. Managers should advise customers only to use armbands that are kite marked or carry a BS EN number and may perhaps even offer a range for sale or loan.


b) A traditional 25m swimming pool with deep and shallow water (no designated non-swimmer area)
Where it is not possible to designate a non-swimmer area, and if the children cannot swim and are not wearing armbands, the responsible person with them would need to support them much more actively. Children who cannot stand up in the water would have to be held, whilst children who can stand up would need to be carefully watched to make sure they did not slip, fall or go out of their depth. In these circumstances we would recommend that one adult might safely be able to look after either:
• One child under the age of four (unable to stand) OR
• Up to two children aged 4 to seven
NB. In our opinion it is unlikely that these circumstances should apply unless parents wish to take their children into deep water or wish them not to wear armbands - for instance when encouraging them to develop their swimming skills. Under normal circumstances children who cannot swim should wear armbands and be restricted to shallow water areas.

Reasoning:
• Inability to to swim and keep afloat will put children at a serious risk of drowning if they go out of their depth and if no one is at hand on a one to one basis to keep an eye on them. In wearing approved armbands this will change the situation, as at least they will not go under the water but if children are not familiar with wearing armbands, they may not be able to keep their faces out of the water.
• Some swimming ability, but overconfidence, may cause children to put themselves in danger of getting out of their depth and of then being unable to return to a safe area, however they should be reasonably safe if the accompanying responsible person ensures that they stay in their own depth.
c) Leisure pools with a combination of exciting and challenging features present
Pool operators will be aware if they operate a leisure pool of the increased risks to children and weak swimmers where there are wave machines and other exciting and challenging features. It may even be necessary to increase the minimum age or introduce height restrictions below which it is not advisable for children to swim unaccompanied by an responsible person or it may be advisable for all children under the age of eight to be accompanied on a one to one basis.
d) Special consideration
Special consideration needs to be given to individual policies for:
i. Groups of children e.g. children’s birthday parties, play groups, cub groups, brownies etc
ii. Children and/or parents or carers with a disability or special needs.
Factors that might be taken into account could include, for example, restricting such groups to designated non-swimmer areas, providing exclusive use, increasing the number of lifeguards and specifying the number of children to responsible accompanying persons. Ideally each group should be risk assessed individually, alternatively pool operators may prepare model risks assessments based on prior experience.

5. CHILDREN’S USE OF CHANGING ROOMS

Associated with child admissions is the issue of children of the opposite sex using the same changing room as the responsible person who is accompanying them and issues of child protection.

ISRM advocate that all pools should be designed with village changing accommodation, or equipped with group or family changing rooms as the most satisfactory way to eliminate this problem. Where this is not practicable then an alternative solution is necessary.

Responsible persons accompanying children to a pool should be able to take under eights into an “opposite sex” changing room where there is no other responsible person to take the child into a “same sex” changing room, as it is reasonable to assume that a child deemed too young to swim unaccompanied is also too young to fend for him or herself in a changing room or to change unaccompanied. There is also a serious risk that if a young child under the age of eight is allowed into a changing room unattended, then the child might also enter the pool area and even the pool, on their own without the protection of an accompanying carer, and so be at risk of drowning.

Young children of the opposite sex in an open changing or showering area may cause embarrassment, hence discretion should be exercised and due consideration shown by both the accompanying person and other adult users in the presence of a child. The overwhelming consideration in these circumstances has to be the welfare and safety of the child.

Ensuring that a responsible person accompanies young children under eight is one way of providing some protection for children from inappropriate adult attention. Pool operators should have a child protection policy in place and should train their staff to make them aware of what to do if they have any concerns relating to child protection.

6. PUBLIC INFORMATION AND AWARENESS

In writing a policy which will affect customers and potentially restrict access or change the opening hours at which they can attend, it will be important for pool operators to consult with members of the public who are likely to be affected and to take their views into account. Management may be challenged to tread the fine line between wanting to satisfy customer requirements and ensuring child safety. Management should at all times endeavour to encourage increased swimming attendances rather than limiting access, in the knowledge that children are at far lesser risk in the comparative safety of a swimming pool than they would be in a river, lake or sea.

The policy adopted for child admissions should be clearly displayed in the appropriate language/s or format at points where the public enter the building.

Parents should be encouraged to act in a safe manner when they bring children to swim and action should be taken to get safety messages across to parents and carers. It would be helpful to publish parental guides to help parents make the best possible use of the pool, its programmes and of the time spent in the pool with their children.

7. WRITTEN POLICY

The policy once established, and the reasons for its adoption and the decisions taken in arriving at the policy, including the specific hazards or lack of hazards and their means of control, should be included in the Normal Operating Procedures for the pool.

All staff engaged at the pool should be made fully aware of the policy and the reasoning behind it. It should be part of the ongoing training programme for relevant staff. Receptionists as much as duty management and lifeguard staff need to implement the policy consistently.

8. PROGRAMMED SWIMMING INSTRUCTION

Procedures for children under instruction during programmed swimming time are dealt with in the document entitled “Safe Supervision” available from ISRM.

9. PLAY AND PADDLING POOLS EXEMPT

ISRM make a clear distinction between swimming pools used for swimming and paddling pools that are a play experience. The issues in relation to paddling pools are dealt with in the document entitled “Paddling Pool Operation” available from ISRM.