little bit about some of the things that are going on we wanted to seek some feedback uh we want to talk about
0:30
disinfectant science while we can read the screen disinfectant cyanurates and this and the cmhc but we also wanted to talk
0:38
about again how this is going to impact us going forward where it's going to impact us
0:44
and i wanted your feedback i want to see what you think of what we're looking at
0:50
and i also wanted to see um
0:57
i also wanted to see what we could do going forward to have more of a say in what happens in
1:03
the industry as a whole um pool professionals aquatics professionals um and
1:11
and folks from those facets just simply because i i don't think we have very good representation there now so if everybody
1:18
can go into this open-minded if you want to take notes as we go along if there's
1:24
some topic um as jen said she would like people to be able to interject
1:30
with feedback or ex with questions with feedback on different things that we're speaking
1:35
up about so definitely please do that that's the purpose of this we want your feedback
1:43
we need cohesion between science and what happens in the field in this industry and unless we work together unless we
1:50
have that type of feedback decisions are going to be one-sided and that's not going to work for anybody so
1:56
so with that you guys know me i'm rudy stanquist we have with us roy of war tom keegler and
2:02
jen wang wong sorry jen i knew i was going to screw it up chen huang and i guess we're just going
2:09
to go ahead and get that rolling and i'll keep an eye on what we have going on here on the side jennifer jennifer take it away
2:18
okay okay so we're going to do introductions really quick rudy do you wanna i'm rudy you guys know
2:25
me like i said just a second ago i've been in the industry for 30 years i've
2:31
done retail manufacturing uh ran my own service company up in north
2:37
central florida for a little while i've bounced around the us and since i've been consulting i've bounced around
2:42
the world just a little bit i've actually got to teach on five different continents i'm shooting for
2:48
two more but i can't figure out a way to get into antarctica apparently there's some problem with
2:54
getting to the water unless there's a base there that i can get to which would be awesome but in either case um
3:02
that's me so from there roy yeah i'm roy many of you know me if you
3:09
don't i've been in the industry since 91 uh i've worked with the bachelor cell arch dupont
3:16
recently bio lab and now i'm out on my own running my own little service business i'm the germ guy i mean if you you open
3:23
your cpo manual you see my name in the front of that i wrote the rwi manual for nspf uh so it's like
3:31
probably heard more nasty stories about germs and pools from me than anybody else so it's like
3:38
[Music] 20 of my time for the last 30 years has been running pools and i've run them in
3:43
like nine different states now and right now about a half residential
3:49
half commercial uh sitting in my office right now i'm just an old cool boy with a degree
3:55
in microbiology tom take it away okay i've been 30 years
4:01
in the industry as well um research technical service uh run a lot of field trials with uh
4:08
chlorine and bromine biocides uh so i've worked for industry chemical
4:13
suppliers for for most most of that time monsanto and occidental chemical i currently work
4:22
as a consultant for the isis cyanurate industry ad hoc committee which is a consortium
4:29
of manufacturers and i am a member of the the cmac chlorine stabilizer ad hoc committee
4:36
which we'll talk about a lot in a
4:41
i want minute add to that tom's participation in that ad hoc committee is not a sponsored is pro bono volunteer work that he does
4:48
out of his passion um i am i am a chemist i have a my bachelor's of science in chemistry from
4:54
truman state university um i currently am a technical and regulatory consultant
4:59
for the water treatment industry i have more than 15 years of experience in biotechnology academia
5:05
biopharmaceuticals manufacturing and immunology research and over about five years of that has
5:13
been spent in the water treatment industry including um you know
5:19
industrial water treatments drinking water pool water and other sanitizer uses um so i
5:26
i'm affiliated with or have been affiliated with at some point in time alphaquest sigma which is professional chemistry fraternity
5:32
association of water technologies american water works association um the phta rwqc
5:39
i'm involved with i'm not a member but looking to become one um and i've been involved with the cmec
5:44
chlorine stabilizer on hot committee as well i am a scientist first and foremost i am
5:50
an independent consultant second um and i also um provide consulting services for the
5:56
consortium of isocyanary manufacturers okay so like rudy said
6:04
um this this meeting was very last minute for us as well so we have thrown these slides together so
6:10
um forgive us for a lack of a smoothness throughout but um we really
6:16
wanted to open the conversation with you all and hear what you guys say i feel that you know
6:24
um the the voice of you know poolside professionals um and operators is severely lacking
6:32
in um some of these groups that address codes for pools and
6:39
we really need your intel and your feedback and your voice um so we're gonna focus on two key pool
6:46
codes well we're going to mention two because they're sort of competing codes
6:51
um and we're going to focus on one just because this particular month is um and weak is very interesting for
6:58
that code so we're going to talk about that um we're going to base some of the the
7:03
information we want to share with you we're going to look at outbreak data we're going to talk about what the difference is between you know
7:10
different types of free chlorine that are mentioned total chlorine free chlorine um what you
7:15
measure as free chlorine versus what what that's really telling us uh because that's really important to understanding
7:21
proper sanitation and we want to talk about current risk proposals that are out there um for some
7:28
of these codes and then um we're also going to talk about real world scenarios and data and
7:34
we really want to hear from you all so please interrupt us with questions as you have them um and let's
7:41
we'll get started um so like i said there's two codes of
7:47
interest um that we are going to point out to you today one is phtas ansi standard 11.
7:53
this code is driven predominantly by the phta recreational water quality
7:58
committee roy has served on that committee for a long time um and now he consults
8:05
um serves as a consultant for that committee tom and i have been actively involved and
8:12
participating but not as members um as guests with that committee um for the last year and a half or two
8:19
years i guess now um it's probably more like two years right tom
8:26
i guess he's needed almost almost two yeah um so and they there's also the standard 11
8:32
is also driven by recently added component structure to phda which is the standard writing
8:38
committees that they have for the various standards um but a lot of the people that are serving on that committee are also rwqc
8:45
members um then there's the cdc's model aquatic health code um if you haven't heard of that this
8:52
code is free um it's accessible online it is driven by the council
8:58
for the model aquatic health code um you can join anybody can join and become a member of
9:04
the cmac and that membership is a three-year membership because the cycle of the mac
9:10
gets edited every three years and we're going to talk about that both of these now have a what's called a change
9:16
request process and the ability for the public to um provide feedback there's mechanisms
9:23
for that but we're going to focus today on the mac and the cmaq
9:29
so um just want to add that the cmaq is a non-profit
9:35
organization the intent of it is to be the be the ones that contribute to the code
9:42
that is owned by the cdc um to put together a science-based code
9:49
and best practices tool for everybody to utilize um it is very very
9:56
exhaustive code i will say that compared to other pool codes that are out there um for us most of our focus is basically
10:04
on operations and water quality um for the purpose of this talk that's
10:11
you know we're going to focus on that in sanitization disinfection but there's a lot
10:17
more involved in that code um just in general um cmac
10:24
members you it's a very cheap membership i want to say it's anywhere between like 90 and 200
10:30
per individual not per company um and they allow being a member you get to
10:38
be involved you can provide public comments that are taken
10:44
into consideration um on different change request proposals that have been made
10:50
and a couple of recent changes this is going to come up again later from the last c-max cycle till now is
10:56
that they've increased the vote so the cmac body will vote on different change requests that have
11:02
been submitted and the vote has to be 61 or higher in order
11:08
to pass and this was a change that was made out of um necessity by the cdc they decided that
11:15
if there's any change requests that have been put forth that are very controversial and maybe not necessarily justified or
11:23
clearly that's what should be happening or they don't have issues with being adopted um they were getting
11:29
a vote that was below 61 and so that's why that was changed from 51
11:34
to 61 as a minimum it's important to note also that the vote from the cmaq body is weighted
11:40
50 public health officials and 50 industry since you guys are um a new category
11:47
thank you rudy who has worked with the um cmac board to get a category added to you guy for
11:55
you all um for membership there what is it called rudy is that the
12:00
pool service professionals i believe it's aquatic uh service professionals
12:08
the chunk that we were able to get but we do have we do have our own niche now so we are in there
12:13
i think you're in your own niche however i think you would get lumped in with the 50 percent industry vote weight
12:19
um where included in the aquatic sector the other half would be the
12:24
health department so we are definitely on the aquatic side okay so this is a health based code like
12:31
i said it's owned by the cdc and that is partially why it's um it's divided that way um
12:38
but that doesn't mean that you know it'll be that way forever and i i have heard from various folks
12:44
that 50 50 public health and industry split may not make sense and if you guys feel
12:50
you know differently you know you should be um sharing that and communicating that
12:56
because it's important you know and and they do want to hear from us in all of you so that is that is
13:03
the purpose of the council for the model called a kelp code um so some of these changes i'll just
13:10
tell you that tom and roy and i were all personally involved in the conversations that led to
13:17
multiple com public comment periods when there was previously only one that led to a minimum passing vote of 61
13:26
um those are changes since the last cmac cycle and they were they were spurred by some
13:32
change requests um that were very controversial that there was extra conversation that went
13:38
on and extra meetings that happened we were involved and so some changes can be made if you have a voice i just want to
13:45
emphasize that um present changes to the
13:50
cdc um are necessary to remain current with the latest
13:56
science so the cmac tries to coordinate that and prioritizes you know change requests
14:02
that are based on um science and data and and preferably peer-reviewed publications and best
14:09
practices um and then this is just this is just a code so it has to be adopted by your
14:16
local authorities having jurisdiction and by states and different inspectors
14:27
okay so um c-mac um and i'm now going to talk about
14:34
they have they also have in the c-mac special ad hoc committees um one of those
14:39
is a chlorine stabilizer or ad-hoc committee it's the only one i'm going to talk about today but there are different ones out there
14:46
um it was originally organized by michael beach of the cdc and previous cmac director doug sackett
14:53
in late 2005 early 2006 and it was the goal was to have a group
14:59
of experts come together to analyze existing data on cyanuric acid and make different recommendations
15:05
for the code um 2016 not 2006. oh i'm sorry
15:13
2016. i apologize um late 2015 early 2016 that's the typo
15:18
um and the original members um were like i said hand-picked by
15:25
michael and doug um and they were designed that was by design to provide the right
15:31
balance of expertise and balance in terms of interest and um you know favors
15:39
in terms of you know potential bias on these issues so those members include dr ellen meyer of
15:45
um now segura formerly archlangela and innovative watercare and dr sam pickens who is retired from
15:52
axio westlake um tom one of our speakers today dr tom keegler he is retired from montana
15:59
oxychem at the time he was still working for oxy with intent to entire retire again he is a volunteer on this
16:06
committee and he's not a sponsored member for the work that he does um dr roy voor was um
16:13
previously bio lab and also a previous member of this committee richard fox um he often notes himself as
16:20
a private citizen but he has other affiliations for other companies
16:26
that are listed there and then dr chip blatchley of purdue university and he is the one that
16:31
was assigned to be the chair by michael for this ad hoc committee um
16:36
some changes that have been made since the original membership so those are the original members um dr
16:42
laura supps um of university of wisconsin who has um some health care or health um
16:49
official background um she joined in uh fall of 2016. um
16:57
roy stopped participating and officially left um in late summer 2018 and
17:05
i um joined and sort of actively participated um over
17:10
the last year and i'm no longer actively participating and i'll get back to that in a little bit but
17:16
that's mostly because of all the controversy that's gone on okay roy take it over
17:26
okay many of you have seen this slide before this is based upon cdc information about
17:32
what kind of germs we're actually seeing in outbreaks in public pools and so we're talking about public pools
17:38
because there's almost no data on residential pools but in about 89
17:44
of the people that get sick in public pools it's crypto and we all know that you cannot control
17:50
crypto with chlorine but that wedge up there at the top are the other ones that are considered
17:56
readily controllable by free chlorine if there is more than one ppm
18:03
uh measured by a test kit you know and that includes pseudomonas legionella e coli shigella norovirus and giardia
18:12
so this is the numbers that we're facing and and the numbers haven't changed that
18:17
much for the last uh 15 years uh there is additional information that's come out since then but it is not
18:24
significantly different than this next slide jim
18:30
all right a lot of the conversation over the last three years with the ad hoc committee
18:36
uh and it came down to talking about giardia so what do we know about giardia in
18:42
swimming pool well the last data that we have from the united states
18:48
is the summary that came out from the years 2011 2012 and probably the data's a
18:55
little bit older than we like but if you stop and you think about it since then the cdc's been involved in ebola
19:03
and now they're involved in uh uh covet 19. so it's like so the data is not exactly
19:11
as current as we would like but it's still probably exactly the same trend so if we look at what data we have
19:17
there's about 32 000 cases of reported grt in the united states less than seven
19:24
hundredths of one percent is from treated swimming pools
19:29
turns out those 21 cases were all from the exact same pool and so there has never been a
19:36
documented case of giardia according to the cdc data when there was at least one ppm of
19:44
chlorine as measured by dpd in the pool so what do we have on
19:49
giardia and pools well we do not know how much giardia there is in a pool
19:55
we do not know how fast charity is killed in a swimming pool and we'll get into
20:01
this in a minute but there's no real data on
20:06
kill rates of free chlorine with or without cyanuric acid there is some data that's
20:14
privately held by one of the manufacturers in here but this is the
20:20
entire data set that we have available today that is solid and defensible
20:28
on giardia are you guys comfortable making decisions on that
20:34
kind of data that's really the question i want you to think about i mean
20:40
we one outbreak 21 cases and that's the best data that we've got
20:47
and the entire concept that of changing cyanuric acid
20:52
relies on a data set like this okay next slide i just want to point out
21:00
that the kill rates that we do have on giardia are for drinking water and not pools and that's all we have
21:08
next slide jim okay uh after you heard jim talk about the ad
21:15
hoc committee well after five years of digging and you know i mean you saw all the academic adventures on there
21:21
uh you know everybody on that original committee except for one had a phd
21:27
we know how to dig for data if it exists couldn't find the data on grdnpools
21:34
and so the group could not come up with a reasonable worst case
21:40
scenario that everybody could agree on and so to develop this model that you've
21:46
heard about you took one study and multiplied it by another study and multiplied it by
21:52
another study but that also multiplies the errors
21:59
and so it came up with a model and when you actually looked at it
22:06
and you take this mathematical model and you put in there and if you plug in the current
22:12
parameters that are in the model aquatic health code that is 90 ppm of cyanuric acid
22:18
2 ppm free chlorine as measured by dpd the risk from giardia is not significant
22:28
that's where the written you know i heard this talk about all these ratios and everything that's where the 45 to 1 comes in so the
22:36
the model that everybody talks about says if you do it the way you're doing right now with the limited data we've got it's not
22:44
an issue but if you go back
22:49
and you say well we could use one bather per 15 square feet
22:55
instead of one per 20 square feet and we could turn the filter off and we
23:01
could keep the pool occupied at one bather for 15 square
23:07
feet 24 hours a day seven days a week
23:12
52 weeks a year 365 or 66 days per year then there is a
23:19
slight change in the risk and if you put those assumptions in
23:25
there you calculate how much cyanuric and acid you have in there and you have to lower the ratio to 20 to
23:32
1. my argument with this is there is not a
23:37
pool in the world that is occupied at 100 capacity 365 days a year
23:46
and if any of us is running a pool that's it that crowded we had one
23:51
bathroom for 15 square feet with the filter turned off
23:56
the health department's gonna close us down anyway it's illegal to run a pool that way and so i
24:04
you know why i'm pissed off about the whole thing and i'll be honest i'm pissed about this it's
24:11
to get to that number you are running illegal an illogical conditions
24:19
it doesn't make sense i've been looking at the microbiology for 25 years
24:26
this is not the biggest threat but the model says it's the biggest threat the two threats
24:33
are crypto and not keeping one ppm of rechlorine in the
24:38
in the water that's what the data says the model is not reflective of what i see in the
24:45
real world that's my background jim
24:50
or tom europe let's be one thing the mac
24:58
is a is is lacking in and and the ad hoc committee has introduced change
25:04
requests for is is properly defining uh some of the terms around
25:10
measuring chlorine and and so the mac defines free
25:17
available chlorine uh or fac as the sum of hocl
25:22
and ocl minus and and that's fine and dandy or is properly defined
25:29
but then they go and use that everywhere in the mac as though that's
25:34
the number that you measure which is incorrect so the ad hoc committee is introducing this
25:42
term dpdfc to find the available chlorine that you
25:48
measure with a test kit as free chlorine you know a test kit based on dpdf
25:55
dpd uh and this is then the the free available
26:02
chlorine hocl and ocl minus plus the available chlorine that's bound to the cyanuric
26:08
acid ring and if you're looking at an outdoor pool
26:13
that's stabilized running one two three parts per million
26:18
available chlorine and 20 to 50 or 90 parts per million
26:25
cyanuric acid only a small fraction of the dpdfc that you measure
26:31
is really fac and so those are two very different values
26:38
and the mac just completely seems to equate the two so uh the mac really needs to be
26:45
changed to reflect that the mac also didn't define total
26:50
chlorine and combine chlorine uh adequately and we introduced uh definitions for those you know what
26:57
those things are next slide i just want to add that from
27:02
this point on you're going to hear us reference dpd fc or measured free chlorine
27:08
so from this point forward okay is there any questions on that what that term means that's that's the reading that you
27:14
actually get from your test kit uh we also define cyanurate bound
27:21
chlorine as the available chlorine which is bound to the cyanurate ring that actually exists in solution of
27:28
several different compounds which are in rapid equilibrium and and
27:35
so the chlorine-bound cyanuric bound chlorine actually dissociates to release
27:42
avail hocl when some free chlorine is depleted by reaction with demand so i i see the
27:50
cyanurate bound chlorine as a reserve of chlorine which allows you to release the free
27:56
chlorine when it's needed so you you know you've seen the equilibrium with with
28:02
hypochlorous acid uh the hypochlorite ion is in uh rapid equilibrium and and
28:10
with hocl and hocl is your active bicycle agent so that's
28:16
that that's the thing that really does your kill the same in the same way the the core
28:21
cyanurate bound chlorine uh is in rapid equilibrium with hocl
28:28
and can rapidly dissociate in a matter of seconds when more hocl is needed now there
28:36
are several like i said there's several different compounds in solution
28:41
and it takes several different equilibrium constants to
28:48
determine actually what's in solution to characterize that equilibria
28:54
but those determine what the concentration is for all the different compounds in solution including what the
29:00
concentration of hocl is o'brien and co-workers measured that in
29:06
1974. woman and alexander came in a couple years ago and
29:12
published the temperature dependence for two of the equilibrium constants that are important so
29:18
we now have some idea of how those equilibrium constants vary with temperature
29:23
[Music] next roy you're up well before we do that is
29:31
we've been seeing it flash up on my screen that we've got chats rudy are we are we not giving people the
29:37
opportunity to ask questions here no i think they're just being very polite at this time and
29:43
not wanting to interrupt so um i don't know who any of these people are
29:50
please please interrupt us we don't want to be blowing through information with you all and you guys
29:56
feel like we're just talking at you we don't want any of that we want to hear um that we're making the information
30:04
um you know relatable to you all and relevant so if you guys have questions we we
30:09
definitely want to hear it feel free to please interject it's not a formal this is not a formal event well that's the whole
30:15
that's the whole point of it that's the idea behind it the goal in getting everybody together and
30:21
getting this group together and luckily these folks having some
30:26
availability for us is to um
30:31
get your feedback really um you know we can only take it so far without
30:36
information from the field and all of you have such a tremendous wealth of knowledge whether
30:42
you're watching uh whether you're you know attending right here you're gonna watch the video later or you're
30:47
checking us out on facebook as we roll along you all have a tremendous wealth of knowledge and that's extremely
30:53
valuable to um what we're working on and also with that
30:58
as i stated at the beginning we want to create more involvement in this as well um tom mentioned an area
31:06
where the cmac or the model aquatic health code was lacking i can tell you another area where it's
31:12
lacking is in his involvement from the
31:17
pool industry sector i know aquatics is a little bit better but as far as the
31:24
pool industry goes we don't have a great presence there but
31:29
we could so please definitely chime in ask questions
31:34
and i'll let jen get back to it just to clarify something rudy said
31:40
there is a good pool industry presence on the cmac but it's lacking in pool service professionals
31:47
that's where we're really lacking so there's there's other um involvement from other sectors of the
31:52
pool industry like manufacturers and builders that sort of thing but we
31:57
but we need to hear from service professionals so we're missing information from the field which is that's right
32:04
which is where the greatest intel comes from the front line and that's you guys at
32:10
one point there rudy i mean if you i sat in on most of the trc
32:16
uh discussions as they evaluated to change requests
32:22
and you could you could see that in a lot of the discussions the you know some many of the trc members
32:28
understood certain things about pools and and the discussion was intelligent
32:34
and then they got into other areas where it was clear they just didn't know what they were talking about and a couple of
32:40
experienced pool operators would have helped that discussion a lot so just to clarify for everybody what
32:45
tom's talking about the trc is what is called the technical review committee
32:50
these are people that have been selected to review all of the change requests
32:56
that have been submitted for the model aquatic health code in any given cycle um and they change for cycle they're not
33:04
always the same people but they have a huge influence on how we
33:09
see the cmac people vote um so the technical review committee
33:16
will are supposedly have the resources to review change requests and then they provide a
33:22
recommendation on what they're telling counsel for a model aquatic health code members how to
33:28
vote and we usually see the vote results are usually very similar to those trc
33:34
recommendations that's what tom's talking about yep okay roy take it away
33:42
okay so what do we know about kill data on giardia because that's the one that keeps popping out on on you know after five years of work
33:49
well uh the only data that's publicly available was done by the u.s epa water
33:55
division out of cincinnati and they developed what's called a ct table on there it was done in drinking
34:01
water did not contain cyanuric acid and they do it over a range of temperatures
34:07
in there and so the value that we normally use in pools is
34:13
at the ct value for giardia and that gives you a 99.9
34:19
kill so it's uh one ppm of chlorine will kill uh 99.9 of the giardia in 45 minutes
34:27
so you've been through a cpo course if you increase it to 3 ppm then your kill
34:32
rate 15 minutes if you increase it to 10 ppm it's in 4.5 minutes
34:38
so this was the data that was then used and incorporated back into the
34:44
mathematical model that came out of it like we want to point out it's drinking
34:49
water not poor water and there is not data from the epa
34:55
that involves cyanuric acid so it is an estimated calculation at best
35:05
and as a microbiologist uh i probably run as many kill studies
35:12
in the lab as anybody alive today on swimming pools and i can tell you kill data in the lab
35:19
is kind of like a two-year-old with a bad attitude it works some days and some days you're
35:26
in for a screaming fit i'm not very satisfied with relying upon
35:33
estimated data if we're making uh serious changes so this is another reason why i'm not
35:40
very happy with this whole approach right now yeah and roy i'm not real happy with the ct tables
35:45
i i don't think they took care of the ph effect very well at all i i think
35:52
epa's uh treatment of the data was was flawed too yeah so it's like
36:00
you got no data in one area and you've got marginal or poor data in another one
36:05
you're putting mathematical model on it and you're trying to predict what your two-year-old is going to do on a bad day
36:13
that's where we are i just want to add to that too that um
36:18
vince hill gave a talk this past week at the world aquatic health conference and one of the things
36:24
that he reviewed was some of the models that have been developed including the one that we are um discussing here and you know models
36:31
are only as good as the amount of data that we have to put into them and they are a good tool but they are certainly
36:37
not a replacement for additional research and um they like i said they're only as good as
36:44
the as the data that we have by which you know we we make them and design them by so um
36:52
you know like i said the model is a good tool it's a good resource it helps give us an idea but it is an estimate and we
36:58
will never no matter how much data we have we will never ever be able to have
37:04
no uncertainty or zero um uncertainty in any kind of estimation that's why it's
37:09
an estimate but there is a large amount of uncertainty which is the point that we
37:15
are making when we talk about giardia kill data because all these proposals are being predominantly based on giardia where we
37:23
are severely lacking data and we have marty kelly right now
37:28
stating that the ct tables do not account for ph or the effect of
37:34
cyanuric or percent of cyanuric acid if anybody wants to address that
37:44
or not we can just agree the ct tables that epa publishes
37:51
cover a range of phs and temperatures the temperature range is shown there
37:59
33 to 77 degrees fahrenheit they don't go any higher temperatures than that they do cover a
38:05
range of ph
38:11
and those are in the tables and when you actually look it's not exactly certain how many of
38:17
those were actually solid experiments versus estimated values because yeah the entire set of ct
38:26
tables is is basically epa's fit to a bunch of literature data uh it
38:33
it it's really their mathematical fit to a bunch of data that they put together what you're
38:39
really saying is we've got a mathematically modeled table that now we're sticking in
38:45
an another mathematical formula so now we're multiplying the errors every time
38:51
we get in another formula good question marty and then we're using that to justify the
38:57
need to reduce risk just thought i'd add that okay are we ready to move on
39:06
my screen's blinking with another comment rudy is that for us uh that's craig saying good point roy
39:13
okay so i'll keep you posted as they come up if um you'd all like kudos as we go
39:18
along i'll let you know when those pop up as well okay so part of the recent i guess
39:25
um spur in in sort of reigniting the controversy with respect to cyanuric
39:31
acid has been this model that we've been talking to you about um which like we said is based
39:37
off of giardia um and there has been a lot of risk
39:42
reduction proposals that have been made have been made um based on this um a lot of
39:49
misinterpreting in the paper as well but i'm gonna focus on the original proposal because these are
39:55
your experts in pool industry and i know everybody in the pool industry thinks of themselves as an expert
40:00
but the cmac chlorine stabilizer ad hoc committee members are very influential um
40:06
based on this rudy is everything under control i just
40:12
heard my voice talking to myself you're fine okay great don't welcome but get you psychiatric helplessness
40:19
thank you for that
40:24
um the original proposal which was published in the paper um was based on trying to develop
40:32
a set of assumptions or worst case of worst case scenarios to the point where
40:37
in our opinion the worst case of the worst case of the worst case is no longer
40:42
um realistic or reasonable um and here are some of the worst case
40:48
assumptions that were made um it was based on a pool depth of only three feet
40:54
shallow pool um the ingestion rate and the frequency and exposure was based off of children
41:00
um we obviously would assume children are probably ingesting more pool water than most adults i would say um there
41:07
was a couple set of equilibrium constants um that there are available at the time we only had o'brien's
41:14
that's what was chosen for the paper they are different and that needs to be addressed because
41:20
they shouldn't be different um in addition to that um a couple other assumptions that were made as roy
41:26
mentioned was the 15 square feet high bather load which i will point out
41:31
is higher than what is allowed for what's called flat water in pools um per the current monophotic
41:39
health code requirement um in addition they also assumed no pool
41:44
filtration um i can't imagine a pool that doesn't have a filter
41:49
and i can't imagine why you would have that filter turned off if you're running the pool um the mac does require pool filtration
41:57
and does require a minimum amount of filtration um in addition to that the original proposal
42:03
um had the pool being open 24 hours a day 365 days a year a pool that never ever closes there is
42:10
no such pool and this led to saying that oh we
42:15
estimate our risk means we need to not exceed an operational ratio of cya to
42:21
dpdfc of 20 to 1. another aspect of this which we're going to talk some more about too
42:28
is the giardia introduction rate parameters part of the reason why they have some error
42:33
is they are based off of a fecal matter shedding rate from e coli data because we don't have any for giardia in
42:40
addition to that that introduction rate of giardia is um utilizes how much giardia concentration there is
42:47
in that fecal matter which we're going to talk about that because that's very vague we'll talk about that coming up really
42:53
quick jen um i have uh coming from the facebook side we have uh wayne ivey sich is now
43:01
um watching from facebook he says a pool welcome wayne he says a pool with no filter is a pond
43:08
uh rob matthews wants to know he's asking selected by who and what
43:14
qualifications do they have so i'm assuming he's referring to the ad hoc um
43:22
committee uh patricia carr says we're here and josh mall says that he's here and watching but i did not mention
43:30
my book yet and i should do that that i have a book and that everybody should read it pretty
43:35
much i mean i ad-libbed some of it but he said i should mention it so there you go okay so to
43:42
i can't remember now who asked which question but uh yes wayne i agree with you and uh part of the reason why there was
43:49
no filtration um done for that proposal is because they assumed that the effects of minimum filtration
43:57
would be negligible at best and that's not really the whole story i don't think there was enough digging done on that
44:03
um with regards to the members of the chlorine stabilizer ad hoc committee for the cmac um they were hand-picked um
44:11
i mentioned earlier they were hand-picked by michael beach of the cdc and doug sackett which is the former director
44:17
former director of the c-mac um and that was basically to have a balance and
44:22
expertise and opinion honestly in terms of you know uh biased experience um based on
44:28
background of you know a pro-cya versus an anti-cya um perspective um but also like i said
44:36
expertise was really part of that conversation and then consider some parties that were
44:41
considered to be neutral as well so that was the membership composition
44:47
and you will hear me call them the experts because i sometimes get tired of saying
44:52
the cmaq chlorine stabilizer ad-hoc committee members because it's a mouthful so um just know
44:58
when i say that that's what i'm talking about i know that we are all in a lot of ways experts but
45:04
that's what i mean it's not just for just for the purpose of being short um okay so i mentioned to you all that
45:11
the original proposal had those unreasonable assumptions um and if you make some adjustments again
45:18
this is a model which is an estimate which is based off of thinking that she already has the highest risk pathogen we have that's chlorine
45:24
sensitive in pools um but all those assumptions being had if we modify the bather load to be at least
45:31
consistent with the maximum bather load allowed per the current mac that's appropriate for this model you'd
45:38
be looking at 20 square feet for bather instead of 15 if you modify your pool to actually have
45:45
your filter on um we estimate that you will have a very very ultra conservative estimate of
45:51
30 percent grd assist being removed per pass with a six hour turnover which is your maximum allowable um
46:00
and that is based off of because we've gotten some criticism from that minimum
46:05
pool filtration assist removal adjustment that is based off of uh
46:11
filtration removal that james ambergee has done of cryptosporidium
46:17
cysts showing an average of 25 um cryptosporidium usus being removed
46:23
uh by a slow or sorry a fast fan fast sand pool filter um
46:31
and which is the least efficient pool filter that is out there and giardia cysts are about
46:36
twice the size um of a cryptosporidium cyst you would
46:42
really be pretty safe assuming that you're removing substantially more giardiasis per pass than you are
46:47
cryptosporidium cysts um and there is some giardia um
46:52
you know filtration removal data but that's associated with drinking water did i get that right tom
46:59
yes there is some data on drinking water filters but drinking water filters are
47:04
very different from a typical sand filter on a pool but yes that data does show better
47:11
removal of giardia so another adjustment that we made and this was not part of the model
47:17
originally when the paper was published is we accounted to say the pool does close
47:22
it's not open 24 hours so we adjusted it to say okay fine it can be open every day but it's going to close every night
47:29
so we um did hours of operation at 12 hours per day and that accounts for diurnal recovery that you
47:37
see um and we assumed that you know in that diurnal a recovery
47:43
assumption we utilize the worst time of day um as part of the calculation in the
47:50
model um for potential pathogen concentration the last two hours that the pools opened
47:57
per day in any given day and with these modifications that that led to a new estimate in risk
48:04
associated with a maximum operational ratio of 45 to 1
48:09
rather than 20 to 1. so that's a huge difference and those were these were the only changes we made for
48:14
that so we didn't account for like i mentioned in the previous slide the issues that i alluded to with
48:21
giardia introduction rate um which has a big impact on estimating your risk of infection
48:27
there is a very high amount of uncertainty it's it's significant which is basically
48:34
an error associated with the estimate there is a factor of about plus or minus 5.85
48:41
times um and that was based on a statistical log normality done by the
48:47
lead author on that richard um this estimate is probably due to the
48:53
fecal shedding rate which i mentioned is based off of e coli data not giardia data um also the model the giardia
49:01
concentration in fecal matter does not account for what percent of that giardia um in the fecal matter
49:09
is viable versus what is not and then even from what percent of giardia is viable does not
49:16
mean that it will result in infectivity so percent infectivity is another area
49:21
where data is lacking so these lead to overestimates um potentially over
49:27
estimates of of giardia introduction rate in the model let's stop right there and look at that air factor
49:33
all right everybody out here has got a test kit and everybody out here runs calcium
49:39
here's the math if you run your test kit and you get 206 ppm on your test kit
49:46
that error factor means your your test could give you a reading as 44
49:52
or a reading of 1521 ppm of calcium
49:58
so that air factor that they're using to change the standard says your pool is somewhere between 44
50:06
ppm of calcium and 1521 ppm of calcium
50:12
that's the kind of variability in the numbers that we're talking about here
50:17
really really i have rob matthews on facebook wanting
50:23
to know um why there are so many assumptions being used and why not just use
50:31
scientific fact great question great question because nobody has gone
50:39
out and done the basic research we don't know how much giardia is in a swimming
50:45
pool so we had to take three different studies that were totally unrelated
50:51
that had a whole bunch of air in them variability that's a better terminology and multiply
50:57
them together and that multiplies your error and then we had to make assumptions on cyanuric
51:04
acid we had to make assumptions on temperature what are the first three letters in the word assumption
51:13
that's where we are yeah you love being a free agent um and be happy if your reading is
51:21
somewhere between 44 and 1521
51:27
that's the numbers you're dealing with guys i mean we we tried to do as good of a job as we
51:32
could to get data out of the literature and use data in the model that that was
51:38
was reasonable but particularly roy on the giardia data that isn't so
51:43
you know some of that is error in the measurements but a lot of this is this variability from person to person
51:50
too we're looking at a person that's infected getting into the pool
51:56
well it looks like we have wendy purser um suggesting that we draw our samples from the spas
52:03
on cruise ships before they're drained except
52:08
wendy giardia is not a pathogen in spots there are no fecal born
52:16
pathogen outbreaks in spas even on cruise ships well she did give another example but she
52:22
mentioned a brand so i'm leaving it out
52:27
but but roy i am not right as as when a person's infected as they get
52:33
through their disease they're shedding different amounts of giardia day to day
52:38
too and so there's there's just there's a very small amount of data and when you're taking a
52:46
small amount of data there's a very large variability into it and a lot of the data is not directly applicable
52:53
and so one of the slides we're going to get to in a couple of minutes is if you want to do this kind
52:58
of you know analysis you have to do a serious serious serious
53:05
big study and nobody's done it and so we don't know
53:13
i mean we do not know how much giardia is in a swimming pool today with or without cyanuric acid yep but
53:21
the only data that we've got is the outbreak data and the outbreak data says
53:26
it doesn't happen but it may be there it may be at such a small level that
53:34
it's not significant so we're trying to match up
53:39
70 years of feeding studies but done back in the 1950s on prisoners that's
53:44
how they calculated how much giardia people required to get and trying to match it up to the way we
53:50
run pools today and there's a lot of holes in our data and
53:55
you're seeing why i'm very frustrated because it's like you it's the numbers just aren't there
54:03
can't do it guys just can't do it so all these are really good points i'm
54:08
going to keep us moving along we're going to run out of time and i really want to hear from you all so um i just want to just kind of back us
54:15
up a little bit a few feet higher and say that this initial proposal is really what spurred and
54:22
reignited and then sort of sent the message that's now the perception of many now
54:30
very very wide perception that we need to reduce risk because they now think um there's a
54:37
problem with risk of infection particularly as proteins together just in general now that we need to reduce
54:43
risk so the 20 to 1 ratio that was proposed that was based on these
54:48
um you know unreasonable assumptions that we've now reviewed and the the
54:55
factor error that i said of 5.85 x plus or minus was not done at the time
55:01
but they did note they did do a sensitivity analysis and they did assess that you know any assumption that you change
55:07
in the model any input parameter that you modify can shift the curve of risk estimation and therefore the
55:14
recommended ratio around um and they did know that and they knew that there was a high
55:20
uncertainty but yet these risk reduction proposals are still being made and
55:26
trying they're attempting to justify at the cost and impact to you all so right roy
55:35
take it and take it fast okay all right you're on you've all run pools
55:41
we run pools every bit of chlorine out there's got it's good aspects and there's bad ass backs on there
55:47
and it's like you have to know what you're using at the right time you work with it you manage it
55:55
after five years to select a committee hand-picked by cdc
56:02
and c-mac in there couldn't come up with definitive information on giardia
56:08
and so you're seeing the frustration what we need is real-world data and the
56:16
cdc the only data that we've got does not show giardia to be an issue 21
56:22
cases in the one period on there that's the total number of cases all
56:29
right to show a problem with giardia the model has to use illegal conditions
56:36
that would immediately get the pool closed by the department of health and run a cool 24 7 365.
56:44
it makes more sense just to slow the whole thing down go out and do what we call science
56:52
do actual studies in the lab to find out what the kill rates really are
56:57
and then go out to pools and collect water samples
57:02
that's the logical approach we need to be doing not running off on some mathematical model
57:09
that has got an error that's unbelievably big
57:18
all right tell you roy all right measure the giardia in the pool today
57:23
we've only got to guess resolve the discrepancy in the equilibrium models because it's like the
57:30
science shouldn't be there and these mathematical equilibrium this is chemistry this biology is all over the map
57:36
chemistry should be pretty clear-cut and which one of these two mathematical equilibrium you pick
57:42
makes a big difference we've got to resolve that mathematically while we're doing these cool studies we
57:50
need to look at lazy rivers versus wave pools versus hotel pools hotel pools on a saturday
57:58
night versus a monday morning in there so we need to get data
58:04
particularly as it relates to the impact of bather load when we're looking at those different types of venues that is a huge impact on
58:13
um you know risk and you know originally we started
58:19
talking about only e coli and enterococcus in the in the 1960s now we talk about a whole bunch of other
58:25
organisms in here we don't have much data on these other organisms maybe we need to do some basic research on that
58:32
and once we've got the data then we sit down do the whole thing again and say now we've got a mathematical
58:38
model now we could actually put numbers in and come up with a
58:44
good estimation because in science that's what you do you come out with a hypothesis that's what this model is it's a
58:50
hypothesis you go out to the field you collect the data you compare it back
58:55
did the model predict what it said it was if it does you keep the model if it
59:02
doesn't you change it that's what you do in science you don't run off and just
59:10
launch something because you've got some idea on paper and that's what's being asked to done
59:15
right now that's what they're trying to do at mac is just launch this idea with no science behind
59:21
it i think the next one's you jen okay
59:28
before we move on from this slide i'm just gonna add this is gonna come up here in a minute but most of the focus so far has been
59:34
given to a max operational ratio that is for routine operation um you know what you would set your
59:41
limits at if you will but then there's a different section in the model aquatic health code that talks about um
59:47
what warrants an imminent health hazard um that would result in either immediate
59:53
correction or closure of the pool um and there are currently no like
1:00:00
criteria um requirements that speak to efficacy for imminent health hazard
1:00:08
or the closure or immediate correction section and we need to look at minimum
1:00:14
disinfection levels as a ratio for that and and determine where to go from there because we don't have
1:00:21
any good science to guide us right now for that criteria as well
1:00:29
okay so i'm just gonna preface saying i i'm throwing up a big table at you guys i'm sorry um we're just gonna we're just
1:00:37
gonna try and get through it together these are the issues we wanted to make sure you had this information
1:00:43
um for you know the understanding the different proposals that have been
1:00:49
thrown out there that could impact you particularly as it pertains to cyanurates and i know this is a lot and actually there's three
1:00:56
slides this is only the first one um so like i said when i talk about the
1:01:01
experts i'm referring to the chlorine c mach chlorine stabilizer i thought committee members um we have over on the
1:01:06
left our vote recommendation um the second column was added for roy's benefit which
1:01:12
i'm going to get to in a moment each change request that has been submitted to the mac
1:01:17
has a change request number um the those numbers correspond to what
1:01:22
area of the code that it is a change change request for um i also have on there what says
1:01:28
current proposal and i put current proposal because some of these change requests have been changed and
1:01:35
the proposal that you might see on the cmaq website might not be reflective of what you see written here
1:01:41
in my table exactly um this has to do with how you find the information in the cmaq website so i
1:01:48
wanted to make sure that i differentiated between current what's current um and then in the next
1:01:54
column noting for you guys certain change requests that have been revised
1:02:00
um that might not be reflective in the description on the cmac website the only way to look
1:02:06
at these revisions is to go into the technical review committee's evaluation form
1:02:13
and you can find out what you're voting on so if you vote on basically the description itself um
1:02:19
and you don't click into it you might think you're voting on one thing and you're actually voting on another
1:02:24
because um that revision is what you're voting on so um the next column is talking about
1:02:32
whether the experts agree on a particular item and then the trc recommendation
1:02:40
for how they recommend cmac members vote based on their evaluation and the
1:02:46
rationale that's being utilized just kind of a quick summary or my paraphrasing of the rationale for any given current
1:02:53
proposal whether or not the proposal has additional cost or impact to pool
1:03:00
operations um for justifying a risk reduction based on large uncertainty um
1:03:08
and i feel like these are areas to highlight for you for consideration in your vote and then there's an additional comment section so we're just going to
1:03:14
quickly go through them and i just want to practice by saying ellen meyer did an hour and ten minute presentation on most
1:03:22
if not all of these change requests um and i'm going to try and do it in like hopefully
1:03:28
five minutes so bear with me here um so before we get started i just want
1:03:35
to point out that you should pay attention to column number two which is on each one of the following three slides
1:03:40
um roy has something he wants to point out to you about that what i'm
1:03:47
going to say on that is when you look at the uh change requests that are put in by segura
1:03:52
they're all over the map i mean the ratios are different the limits are different
1:03:59
is this a scientific proposal they're putting out here or are they just throwing out ideas to
1:04:04
confuse the issue and you know figure out what they can get i mean it's like they're the ideas are
1:04:12
vastly conflicting with each other but they've all got their company name on them what the hell is going on
1:04:21
you figured that one out i'll just say this that i the that column notes not only just ones
1:04:28
that various employees of segura have submitted but also ones where they are um through ellen
1:04:35
meyer she is a member of the c-mac chlorine stabilizer ad hoc committee so that means that segura is involved in
1:04:43
that cr so and so i just kind of did that because it's important to note that because in
1:04:48
some scenarios because of ellen's involvement in that group she is supporting a change request that
1:04:55
might be conflicting with another exchange request that she has submitted as an individual so just want to point that out um so
1:05:03
we do recommend adopting um some of these changes um the first one is about the
1:05:09
definitions which we've already reviewed the next two are about increasing the
1:05:14
testing frequency of cyanuric acid concentration in pools if you utilize stabilized chlorine
1:05:20
one proposal was to do it every single day the other proposal was to do it once a week that once a week proposal was
1:05:26
made by the committee um and they are in agreement on that
1:05:31
um then there is the secondary disinfection systems being
1:05:36
required for all aquatic venues and not just high risk venues this was submitted by roy himself
1:05:42
i think this is an important piece although it does have a cost impact to you all
1:05:49
um the definition for agitated water is important because it is inconsistent and it impacts how
1:05:56
people are interpreting bather load in the mac so tom submitted that one
1:06:02
the change request for a minimum disinfection residual of one part per million dpd fc
1:06:10
as opposed to one part per million fac and for that one part per million dpdfc to be the
1:06:16
same regardless of cyanuric acid concentration this is important because you can adopt this
1:06:21
if you're going to adopt a max operational ratio to align the concept you wouldn't
1:06:27
necessarily need to have a minimum of two parts per million measured free chlorine with one part per
1:06:33
million cyanuric acid so the this is that was where this change came from
1:06:39
um there is a max operational several max operational ratios that have been
1:06:44
proposed i'm going to start at the bottom of the page um bottom of the page is a max ratio of
1:06:50
two and a half to one cyanuric acid to dpdfc this was put in by john kelly
1:06:55
it's based on a 0.32 part per million hypochlorous acid concentration
1:07:01
uh this is ridiculously high we don't recommend that one ellen meyer submitted a 15 to one max
1:07:07
operational ratio based on the her arbitrary assignment of one part per
1:07:12
million monochlorine efficacy equivalence um
1:07:18
the next i'm going to skip kind of to the middle where you see the no in the middle of the page on the left
1:07:25
the cya group the expert submitted an original well some of them submitted
1:07:30
an original 20 to one that has now been revised to a max operational ratio of 30 to one
1:07:35
so you'd be voting on a 30 to one and we do not recommend that because that is again a risk reduction proposal all the
1:07:42
ones i've said for max operational ratios are risk reduction proposals that are based on a huge
1:07:47
amount of uncertainty insufficient data um large amount of error and that would be
1:07:54
fine if it didn't have a impact on pool operation and cost
1:08:01
so if there was no trade-off then sure if if there's if we can reduce risk and
1:08:08
make our pools healthier with no negative impact let's do it that makes sense
1:08:13
but they all have negative impact and their the uncertainty is just significant so
1:08:19
the science is insufficient to back that up um we need to reduce the error another
1:08:25
cr right below that is the max operational 50 to 1. that was submitted on behalf of some
1:08:31
members of the chlorine stabilizer at hot committee at that time that referred to tom
1:08:36
roy and myself for a max ratio of 50 to 1. this 50 to 1 is based off of the
1:08:42
previous mac addition limit of 100 parts per million for cyanuric acid which was reduced to 90
1:08:47
based off of the inability for you all to perform um dilutions
1:08:54
which we all know is kind of bogus so that's where the 50 to 1 came from it
1:08:59
came from equating the previous mac um limits of two parts from only dpdfc and one hundred parts
1:09:05
with cyanuric acid this is basically the same risk that we currently have of 45 to 1.
1:09:10
so we're basically saying we don't need to reduce risk and our previous limits were fine and that's where the ratio is that is
1:09:17
the max operational ratio that we are recommending to you um so
1:09:24
okay what did i leave out the next um one near the end of the page with the
1:09:29
last yes on the left there that we're recommending is an adjustment for the current
1:09:34
planaric acid limit of 90 parts per million to be exceeded up to 180 parts per
1:09:42
million if you are able to demonstrate the ability to accurately test
1:09:47
such a high such a higher concentration in pools this was a joint effort change request
1:09:54
it's been revised it originally was to eliminate the 90 now it's been revised to have the ability to go up to 180 and
1:10:01
that was jointly done with the experts as well
1:10:06
any questions so far
1:10:13
okay so this next one is a little bit more complicated um
1:10:19
there is a closure cr that has been submitted that has four components to it
1:10:25
um those four components can include the one part per million minimum dpdfc regardless of cyanuric acid which
1:10:32
we've already talked about but we're saying that should be operational as well as closure um there is currently not a maximum
1:10:39
cyanuric acid concentration for closure we have proposed that that be 300 that's
1:10:45
based off of the epa swim model of 305 parts per million
1:10:51
um toxicity uh which has a built-in safety factor of a hundred just
1:10:57
thought i'd throw that out there um the other part that we recommend that
1:11:03
was recommended to change was uh the fourth part i should i'm gonna skip to the fourth question
1:11:09
bless you was spas have a minimum uh three part per million dpdfc as
1:11:15
opposed to fac um basically fac is equivalent to saying we know we
1:11:22
want higher minimum disinfection levels in spas than pools but if you translate three parts per
1:11:28
million fac um at the lowest it can possibly go in terms of ph and temperature within a
1:11:35
spa you're talking about having basically roughly over 100 104 times more hypochlorous acid
1:11:42
in your spa for truly free chlorine fac um as three parts per million than you
1:11:48
would in a pool i don't think we're saying we need 104 times more so but so we're saying change though to
1:11:55
dpdfc but harmonize it with allowing cyanuric acid in spas which makes sense um
1:12:02
because you already have a higher minimum disinfection and that information can be found on the next yes cr which says to
1:12:09
eliminate the ban of cyanuric acid in spots the third component of the closure cr at the top
1:12:15
this is one cr that has four different criteria so the last one is the third one i'm going to talk about
1:12:20
that is for a max ratio of 45 to 1. so if we're saying that you should have
1:12:26
a max operational ratio of 50 to 1 certainly a lower ratio for closure doesn't make
1:12:31
sense um this proposal was kind of pushed through within the experts when they
1:12:37
were discussing it back when lower ratios were being looked at
1:12:42
and there was no actual formal vote taken on this after all the other changes that were made so
1:12:49
they just didn't revisit this conversation and it needs to be revisited um we are proposing because of the issue
1:12:56
within the current model aquatic health code this cr because it's a package of four different criteria
1:13:03
does need to be adopted uh because if you don't then your max operational ratio
1:13:09
will become a closure minimum disinfection requirement so we would want to see this we would
1:13:17
want to say yes we should vote yes on this cr because it's a package but we really need to change and this is
1:13:24
how you can make a difference by putting a comment in saying this 45 to 1 for closure needs to
1:13:29
be changed to 150 to one and more work needs to be done there to refine the efficacy requirements for
1:13:36
closure as well but certainly 150 to 1 would be the equivalent of having 300 parts per million of cyanuric acid
1:13:44
and two parts per million dpd fc we certainly don't want to see us going up to probably 301 that's likely too high
1:13:50
that's where the 150 to one comes from um ellen also submitted the next change
1:13:57
request is ellen's submission for a max closure ratio of 45 to 1. again she submitted this cr
1:14:04
this is where you can vote for a closure of 45 to 1 without having to allow your pools to get up to 300 parts
1:14:11
per million of cyanuric acid um it's just kind of separating out the one criteria
1:14:16
uh we do not recommend that um also segura submitted another
1:14:23
um i'm sorry john kelly submitted another cr saying we need to eliminate the possibility of immediate correction
1:14:29
as opposed to just closing the pool so everybody has to close no matter what when you don't meet any of those requirements um
1:14:36
we talked about the next one for the elimination of the ban on cyanuric acid and spas there's also a cr that's been been
1:14:42
submitted to banned cyanuric acid in indoor pools this cr
1:14:47
um i don't know who has submitted it but it is um not there's insufficient science
1:14:54
that justifies any kind of need to ban um cyanuric acid and indoor pools
1:15:01
and it doesn't really address uh potential impact of cyanuric acid in indoor pools
1:15:06
from windows sunlight exposure um so we do not recommend that one there
1:15:13
is a requirement there's another cr that's been submitted um by segura again that requires
1:15:20
immediate correction or closure for any exceedance of cyanuric acid anywhere in the code
1:15:25
um very arbitrary and not really justified with the science at
1:15:31
this time and then there's another cr that ellen submitted that says we should add
1:15:37
theoretical peak occupancy to the closure section because it's already stated elsewhere in the code that you
1:15:42
can close based on that exceedance so it's just a matter of also including it in the relevant section
1:15:49
any questions about this before i move on
1:15:54
okay and the last set of change requests that are related to um to cyanuric acid that have been
1:16:03
submitted for the code are various the first three are all related two of which by the way have been
1:16:09
submitted by segura but the first three are all about reducing the cya limit of 90 the current
1:16:14
limit of 90 down to 25 40 or 60 um and
1:16:20
we do not agree with any of these and the last one is to add cyanuric acid effect
1:16:26
to training information and that does affect you all but the information that they put in
1:16:32
that change request is only talking about pools that have cyanuric acid concentration between one and ten parts per million
1:16:37
there aren't any real pools that do that so that's really not really relevant and if they want to add cyanuric acid
1:16:43
effective training they need to reconsider how they're putting together that information it needs to include the ratio concept
1:16:50
that you've heard us talking about um and that's it i think that's the end
1:16:57
oh okay not the end so we've reviewed and thrown a lot of information at you all and i'm
1:17:03
really grateful for you guys attending at the very very late notice um if it wasn't obvious from all these
1:17:11
different changes that are extremely controversial that are out there right now on the table um they're they're all
1:17:19
going to impact all of us and and you guys are included in that and you should have a voice
1:17:25
so we're really looking for your help um to have this balance
1:17:31
with your voice included to talk about how these changes impact you all what you guys see um that
1:17:37
could be incorporated to improving our aquatics industry and making sure that any changes that
1:17:43
are proposed make sense that they um include the impact that you guys see
1:17:49
and that they're that they're adopted smoothly um and that the right things get passed so
1:17:55
we're encouraging you to join the cmac and get involved and we
1:18:00
we re you should really also consider providing feedback for phda standard 11 as well
1:18:05
um but we've thrown a lot of information at you we want to spend the rest of the time hearing from you all what you guys think jen what was the
1:18:12
cost again to join um the cmac so cmac membership cost varies depending
1:18:19
on at what point in the cycle the current cycle that you join um right now i believe the cost is 190
1:18:27
per individual um starting i believe sometime next year i believe it will go
1:18:34
back down and then you pay for that for three years so if you join late in the cycle which
1:18:41
is right now because it's late in the cycle then it costs more than if you join at the beginning of a three year cycle
1:18:46
um so that three year cycle will start over i think sometime next year and then it'll cost less than that
1:18:55
by a good margin and it will be a three year membership so i know um this has been quite a bit
1:19:02
of information and for a lot of folks um you know
1:19:07
the first time they're hearing of some of it and i think if we have a means if not right now
1:19:12
that's fine we can add it as a as a comment later a means for post
1:19:19
uh presentation feedback um an email something along those lines i have got
1:19:25
received a couple of messages stating um that right now they're just trying to
1:19:30
digest and we don't know exactly what to ask we'd love to ask questions but this is a lot
1:19:36
so um if we can come up with something like that like i said it doesn't have to
1:19:42
be right this second because i can always add it later on but for an avenue for that i think that
1:19:47
everybody here would um appreciate that although if you do have a question right now i don't
1:19:53
want that to um make you hesitate i'd like to get
1:19:58
that out there and give everybody a shot to answer while we're all here live and in person as well um
1:20:05
so i think that's where we're at now in asking for additional questions same thing for those of you following
1:20:11
along on facebook i can see those so i am a little i'm a little bit slower in getting to them but if you guys post
1:20:17
questions if you're watching along live on facebook i can make sure that i um as we have done throughout this get
1:20:24
those asked um again the whole goal of this is to encourage participation uh jen
1:20:31
roy and tom um were kind enough to bring their presentation to us
1:20:38
um and present the facts and give you guys an idea of what's going on um we definitely would like
1:20:46
um ideas from you guys you you're you know you're
1:20:52
the you're the missing link um the folks in the field uh the intel that we don't have um so
1:21:00
that's where i'm at i'm gonna shut up now if anybody wants to ask questions please definitely do so i
1:21:06
don't know if any of the uh rest of the three had anything they'd like to add to that rudy i want to add
1:21:11
one more thing so part of the reason why this was scheduled at such late notice because tomorrow
1:21:16
is a very important day tomorrow marks the beginning of the triennial cmac conference um and so if
1:21:24
you feel uh moved by the information that we've shared with you today and you want to get involved i'd
1:21:30
strongly encourage it um registration for the conference is free
1:21:36
if you have a current cmaq membership and we've already talked about that cost and how that works as well
1:21:41
so if you are currently a cmac member or you want to join and become a cmaq member
1:21:46
you get to go to the conference for free registration is free um and the reason why the conference is
1:21:52
so important is because currently based on the the policies of how the cmac
1:21:57
is being handled and how changes the code can be impacted is there there is some sort of mechanism
1:22:04
that allows conference feedback to be incorporated into the right path forward so if you do join
1:22:11
and you speak up at the conference and or you submit public comments um all of that can be taken into account
1:22:18
and can impact the vote and impact these changes that are currently on the table that
1:22:24
affect us all so that's why i wanted to try and meet with you guys at such late notice and
1:22:30
i apologize uh rudy has talked to me about joining you all and getting in front of you all
1:22:35
um for many months and i we should have done this sooner but i'm glad we're here today and i'm glad we're having the
1:22:41
conversation so again the cmac conference starts this week it's the rest of the week wednesday thursday
1:22:47
and friday we're going to be reviewing all these change requests there's going to be um there's going to be a public open
1:22:52
forum as well during that schedule and you'll get to hear a little bit more about some of these change requests from
1:22:58
various trc members um and also there'll be some caucuses
1:23:03
which is like subgroups that will be um where we can have more conversation with our different categories of
1:23:09
membership so now i'd like to open it for questions
1:23:16
and feedback we want to hear your guys's thoughts what do you guys think about all of this may not have a question but you just have things you want to share
1:23:22
most of you are muted right now so if you do want to ask a question make sure to unmute your mic and then just go for
1:23:32
it
1:23:39
i think we've got chat flashing at us rudy great to see you all i have to leave oh
1:23:48
wendy's building a house congratulations wendy um adam hold adam holbrook he is um he's a cmac
1:23:54
member he's encouraging folks to get out there and vote um scrolling along here we pop over onto
1:24:02
rob

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