Swimming pools are at the heart of communities, offering a safe, affordable, and fun environment for people to exercise, spend time with friends and family, and learn life skills. As a swimming pool owner or operator, you have a duty of care to those who use and help run the facility. Outlined here is the key paperwork you need to comply with regulatory requirements and safeguard the health and safety of visitors and employees. 

Pool Safety Operating Procedure (PSOP)

Every pool operator is responsible for the health and safety of employees, pool users and other people on the premises.

Swimming pool operators commonly put procedures in place to enable them to comply with their legal obligations. This is to ensure staff and pool users are kept safe from injury or ill health.

The PSOP is usually made up of two documents: 

  • Normal Operating Procedure (NOP)
    This sets out how the pool operates daily.
  • Emergency Action Plan (EAP)
    This provides specific instructions on the action to be taken by all staff if there is an emergency.
REMEMBER! Those completing documentation relating to Regulations 3, 5, and 7 of the MHSWR 1999 should be deemed competent.

This means that they should have the following:

  • Appropriate skills
  • Appropriate knowledge
  • Technical proficiency
  • Suitable experience

These are working documents, meaning that they should be continuously reviewed and updated.

Normal Operating Procedure (NOP)

The Managing Health and Safety at Work Regulations 1999 (MHSWR 1999), Regulation 5 states:

‘Every employer shall make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventative and protective measures.’

This translates to our Normal Operating Procedures (NOPs) in the swimming pool world. Whilst the contents of these policies and procedures vary, they should be specific to the swimming pool/facility and will differ from site to site.

Content of an NOP could include:

  • An organisation staff chart: Line of authority within the staff team so staff know who to go to for support.
  • A plan of the building: A clear plan showing the whole building - public and staff areas.
  • Details of the pool(s): Key information such as dimensions, depth, and location of safety signage.

The list goes on…

Emergency Action Plan (EAP)

MHSWR 1999, Regulation 8 requires employers to ‘establish and give effect to appropriate procedures to be followed in the event of serious and imminent danger’. This is known as the Emergency Action Plan (EAP) for swimming pools.

In the same way, NOPs need to be specific to the swimming pool/facility, and EAPs need to be specific and not copied and pasted from the internet or across sites.

Content of an EAP could include:

  • Overcrowding
  • Broken glass in the pool
  • Electrical failure
  • Etc.

You can read more guidance on PSOPs here.

Water Safety Risk Assessment

A water safety risk assessment is needed for several reasons:

  1. Legal compliance: Regulation 3 of MHSWR 1999 places a legal duty on employers to conduct risk assessments. This includes identifying and managing risks associated with swimming pools on their premises. Non-compliance can lead to legal consequences, including fines and even prison time. Demonstrating due diligence by conducting a Water Safety Risk Assessment can help reduce liability in the event of an accident or incident, demonstrating that you have taken all reasonably practicable steps to prevent harm.
  2. Preventing accidents: Water can pose a serious risk, including drowning. A water safety risk assessment helps to identify potential hazards and implement control measures to prevent accidents.
  3. Protecting lives: Ensuring the safety of employees, visitors, or the public is not only a legal requirement but an ethical one. Conducting risk assessments is essential for safeguarding lives.
  4. Understand what control measures will mitigate risk: Creating a suitable and sufficient Water Safety Risk Assessment will inform what control measures need to be implemented to mitigate the risk posed by the water.

Have you tried our Water Safety - Am I Doing Enough' Quiz 

A Risk Assessment is a process of identifying things that could cause harm (hazard) and identifying a way (control measure(s)) to reduce the likelihood (risk) of an accident happening.

    • A Hazard – something with the potential to cause harm.
    • A Risk – how likely it is that harm will actually be caused.
    • Control Measure is put in place to prevent the hazard from causing harm.

Defining something as high, medium, or low risk is done by considering the likelihood and consequence of each risk. This can be done by utilising a risk assessment matrix. By rating risk levels from high to low, you can focus attention on the most significant and urgent threats.

A table to show the impact and likelihood of risks from low to high.

The contents of your Water Safety Risk Assessment will depend on the site-specific hazards. A risk assessment at one site will not be suitable for a different site (don’t copy and paste!). As an example, this could look like:

Water Drowning  Install Rescue Equipment as recommended

Section 3 of the Management of Health and Safety at Work Regulations 1999 states that risk assessments should be reviewed if:

  1. There is reason to suspect that it is no longer valid, or
  2. There has been a significant change in the matters to which it relates.

    Using RLSS UK to Carry Out Your Water Safety Risk Assessment

    You might want to consider using an external, expert consultancy service for a few reasons:

      1. Specialised Knowledge: RLSS UK possesses specialised knowledge and experience that has developed over our 130+ year history, ensuring a robust and accurate assessment of water safety risks. Swimming pools have specific risks that a general health and safety professional might not be competent in assessing.
      2. Objective Assessment: We will provide an objective and impartial assessment, free from internal biases, leading to a more accurate risk assessment.
      3. In-the-know: RLSS UK is partnered and works closely with other industry experts and regulatory bodies, such as RoSPA, the RNLI, The Institute of Swimming, and the National Water Safety Forum, keeping us at the forefront of water safety innovations and knowledge.
      4. Regulatory Compliance: Our advice is UK law and legislation-driven, backed up by industry guidance and knowledge of best practices.
      5. Commercially aware: We will recommend control measures that are reasonably practicable; this involves balancing the risk against the trouble, time and money needed to control it.

    Click here to make an enquiry.

    Disclaimer: The content on this webpage is limited and should not be considered exhaustive. Users are reminded that additional safety documents may be required depending on their nature of business. This resource is not a substitute for comprehensive safety planning, and users are encouraged to consult with relevant experts and authorities to ensure full compliance with safety regulations and requirements. The webpage and its authors do not assume liability for decisions made or actions taken based on the information presented herein.