Swimming Pool Technical Advisory Committee /
Electrical – Comments
7th Edition (2020) Florida Building Code, Building
SW-FBC -B- Ch. 4- Comment #1
From: Vincent, Bob
G [mailto:Bob.Vincent@flhealth.gov]
Sent: Friday, February 28, 2020 7:45 PM
To: Madani, Mo
Subject: Public pools TAC
For
the final Pool TAC meeting, please consider the two following edits to recent
revisions, and one suggested definition change for a term in the building code:
1) This last sentence HIGHLIGHTED was left out of the 2020 code draft
but was in the supplement.
454.1.2.8.1 Sun shelf dimensional
requirements. Sun
shelf areas must be a minimum of 20 inches (508 mm) wide and provide a minimum
of 10 square feet (0.93 m2) of horizontal surface adjoining on the edge of the
pool (three sides of shelf must be surrounded by pool deck) over a
distance of not less than 3 feet (914 mm). The sun shelf edge that
adjoins the pool edge must be continuous. The sun shelf floor shall be
horizontal or shall a have uniform slope from a zero depth entry, and its
maximum depth shall be between 8 inches (203 mm) to 12 inches (254 mm) below
the water surface. In
pools utilizing automatic recessed surface skimmers, there shall be at least
one skimmer in each sun shelf area.
(SW8341 A1 only/SW7903)
2) This revision may
contradict the DOH pool code. DOH has a code requirement for a
Safety/Lifeguard plan that we must approve for pools with climbable structures
and for all water theme parks; in that plan, lifeguards typically cannot be
replaced by non-lifeguard-certified attendants at a slide run out. Added language suggested is
highlighted.
454.1.9.2.2.4
Attendants or lifeguards Water park personnel shall be provided at the top of the
slides and at the run out in
accordance with a safety/ lifeguard plan approved by DOH.
(SW7917)
3)
The following definition of Swimming Pool in the FBC-Building code definitely
contradicts for public pool Interactive Water Features where there is no water
depth, and for the Epsom salt float pools with
only 10”-12” of water. I suggest the definition be changed to better
reflect one or both of the statutes’ definitions listed below. I have
added Under Lined phrases that may help with snips from the statutory and FBC
definitions below:
SWIMMING POOL. Any structure, basin, chamber or tank containing an artificial body of
water for swimming, diving or recreational bathing located in a residential
area serving four or fewer living units having a depth of 2 feet (610 mm)
or more at any point as defined in s. 515.25, FS, or the body of water is a
public pool as defined in s. 514.011, FS.
The following are definitions in the Florida Statutes 514 and
515, and in the Building Code Chapter 4 at 454:
514.011 Definitions.—As
used in this chapter:
(2) “Public
swimming pool” or “public pool” means a watertight structure of concrete,
masonry, or other approved materials which is located either indoors or
outdoors, used for bathing or swimming by humans, and filled with a filtered
and disinfected water supply, together with buildings, appurtenances, and
equipment used in connection therewith. A public swimming pool or public pool
shall mean a conventional pool, spa-type pool, wading pool, special purpose
pool, or water recreation attraction, to which admission may be gained with or
without payment of a fee and includes, but is not limited to, pools operated by
or serving camps, churches, cities, counties, day care centers, group home
facilities for eight or more clients, health spas, institutions, parks, state
agencies, schools, subdivisions, or the cooperative living-type projects of
five or more living units, such as apartments, boardinghouses, hotels, mobile
home parks, motels, recreational vehicle parks, and townhouses.
(3) “Private pool” means a
facility used only by an individual, family, or living unit members and their
guests which does not serve any type of cooperative housing or joint tenancy of
five or more living units.
515.25 Definitions.—As used in this chapter, the term:
(9) “Public swimming pool” means a swimming pool, as
defined in s. 514.011(2), which is operated,
with or without charge, for the use of the general public; however, the term
does not include a swimming pool located on the grounds of a private residence.
(10) “Residential” means situated on the premises of a
detached one-family or two-family dwelling or a one-family townhouse not more
than three stories high.
(11) “Swimming
pool” means any structure, located in a residential area, that is intended for
swimming or recreational bathing and contains water over 24 inches deep,
including, but not limited to, in-ground, aboveground, and on-ground swimming
pools; hot tubs; and nonportable spas.
Snipped From FBC
454.2:
Bob Vincent, R.S., M.P.A., Environmental Administrator, Water
Programs, Bureau of Environmental Health, Division of Disease Control and
Health Protection, Florida Dept. of Health, Office phone 850.245.4578,
Fax 850.487.0864, 4052 Bald Cypress Way, Bin A-08, Tallahassee, FL
32399-1710 Email: Bob.Vincent@flhealth.gov Webpage: http://www.floridahealth.gov/healthy-environments/index.html
Vision:
To Be the Healthiest State in the Nation Mission:
To protect, promote and improve the health of all people in Florida through
integrated state, county and community efforts. Florida
has a broad public records law which includes written communications.
How are we doing? http://adminappsdoh35.doh.state.fl.us/ContactUs/DOHFeedback.aspx?Email=EnvironmentalHealth@doh.state.fl.us&Office=BureauOfEnvironmentalHealth
TAC Recommendation:
Commission
Action:
Commission
Action:
SW-FBC-B-Ch. 4- Comment #2
From: Dallas Thiesen
[mailto:Dallas@floridapoolpro.com]
Sent: Friday, February 28, 2020 6:13 PM
To: Madani, Mo
Cc: Bob Vincent (Bob.Vincent@flhealth.gov); Michael Weinbaum;
KHebrank@carltonfields.com
Subject: FSPA Comments 1st Integration Draft 2.28.2020
Good evening Mo,
The below
comments and edits represent the work of FSPA and the Florida Public Pool
Coalition with specific participation by Bob Vincent from the Florida
Department of Health and Aquatic engineer Michael Weinbaum
(both cc’d on this e-mail).
454.1.1.1 Sizing
Explanation: To clarify the new sizing requirements
language adopted by the Commission, the clauses of 454.1.1.1 have been
rearranged to establish a base line minimum bathing load depending on the
facility capacity, then providing the sizing formula. Additionally, language
requiring the addition of automated controllers has been added to ensure proper
sanitation for pools with high turnover rates under the sizing formula. The
blow edits reflect the proposed edits.
454.1.1.1 Sizing
The pools provided at a
transient facility shall be able to accommodate one bather per five living units, while the
bathing load at a non-transient facility shall be at least one bather
per seven living units. Recreational vehicle sites, campsites and boat
slips designated for live-aboards shall be considered
a transient living unit. For properties with multiple pools, this requirement
includes the cumulative total gpm bathing
load of all swimming pools, excluding spas, wading pools and
interactive water features. The
bathing load for conventional swimming pools, wading pools, interactive water
features, water activity pools less than 24 inches (610 mm) deep and
special purpose pools shall be computed either on the basis of one
person per 5 gpm (0.32 L/s) of recirculation flow,
or one person per each 20 square feet (0.9
1.9 m2)
of surface area, whichever is less. The bathing load for spa type pools
shall be based on one person per each 10 square feet (0.9 m2) of surface
area. The filtration system for swimming pools shall be capable of meeting
all other requirements of these rules while providing a flow rate of at
least 1 gpm (0.06 L/s) for each living unit at
transient facilities and 3/4 gpm
(0.04 L/s) at nontransient facilities. The pools provided at a transient facility
shall be able to accommodate one bather per five living units, while the
bathing load at a non-transient facility shall be at least one bather
per seven living units. Recreational vehicle sites, campsites and boat
slips designated for live-aboards shall be considered
a transient living unit. For properties with multiple pools, this requirement
includes the cumulative total gpm bathing load of
all swimming pools, excluding spas, wading pools and interactive water
features. All other types of projects shall be sized according to the
anticipated bathing load and proposed uses.,
For the
purpose of determining minimum pool size only, the pool turnover period used
cannot be less than 3 hours. except pools serving non-transient
residential developments of 1,000 units or more can be sized based on 2.5
hours. Where a pool’s
turnover rate is calculated to be less than 3 hours, that pool shall comply
with Section 454.1.7.9 for automated controllers.
454.1.9.2.6.2 Filter Performance /
454.1.1 “Plunge Pools” / 454.1.9.2.6.1 Recirculation Rates
Explanation: The language of 454.1.9.2.6.2 has been
edited to clarify the section and accomplish the goals of the adopted
modifications. Furthermore, edits to the “Plunge Pool” definition (454.1.1) and
the recirculation rate for waterslides (454.1.9.2.6.1) have been edited to
ensure that the filter performance requirements can be meet and proper water
sanitation can be maintained where are waterslide is present at a swimming
pool.
454.1.9.2.6.2
Filter
areas
performance
. Minimum filter
area requirements shall be twice the filter areas specified for the
recirculation rates stipulated in Section 454.1.6.5.5.1. This exception is
only applicable to conventional pool recreational slides. The filtration system shall be capable
of returning the pool water turbidity to 5/10ths (0.50) NTU within 8
hours or less after peak bather load. A continuous readout/electronic
recording in-line turbidity meter shall be installed and used to determine
compliance with this NTU criteria whenever the
filter area size is optionally not doubled in size. , otherwise the turnover rate in the plunge pool’s total water volume, as
defined in 454.1.9.2.6.1, must be 1 hour or less.
454.1.1
“Plunge pool” means the receiving body
of water located at the terminus of a recreational water slide and is
dedicated solely for that purpose. Conventional public sSwimming
pools that are not dedicated as plunge pools that include a recreational water
slide as part of the design shall meet the requirements of Sections 454.1.9.2 454.1.1
through 454.1.6.5 and 454.1.9.2 with the exception of Sections
454.1.9.2.1.6.1, 454.1.9.2.3, and a portion of 454.1.9.2.6.2, which are
deemed optional only for conventional pool recreational slides.
454.1.9.2.6.1 Recirculation rate. The recirculation-filtration system of
water slides shall recirculate and filter a water volume equal to the total
water volume of the facility in a period of 2 hours or less. For swimming pools that are not dedicated as plunge pools,
but include a recreational water slide as part of the design, Tthe
total water volume shall include the water in the plunge pool dimensions
stipulated by code, plus the slide water.
Best,
--
Dallas J. Thiesen
Government Affairs Manager
Florida Swimming Pool Association
2555 Porter Lake Drive, Suite 106
Sarasota, FL 34240
(941) 952-9293 Ext 113
(941) 404-8327 Cell
(941) 366-7433 Fax
TAC Recommendation:
Commission
Action:
SW-FBC-B-Ch. 4 - Comment #3
From: Jennifer Hatfield [mailto:jhatfield@phta.org]
Sent: Friday, February 28, 2020 5:07 PM
To: Madani, Mo
Subject: written comments
Mo – in reviewing the latest action by the Pool TAC and Commission,
found on the Post-Workshop February 11, 2020 documents, we understand that the
language as it stands now for the following section would read as follows:
454.1.9.8.6.3
In lieu of Section 454.1.9.8.6.1, the recirculation system
must be designed to continuously return 100 percent of the water to the
collector tank after all (100 percent) of the water is first filtered and
treated with disinfectant and pH adjustment chemicals; the final treatment
shall be provided by a validated UV disinfectant unit described in Section
454.1.6.5.16.6, on each feature pump, before any of this treated water is piped
to the water features.(Note: UV flow capacity must meet the feature pump(s)
flow capacity).
We believe there may have been an error in that the
disinfectant treatment is done prior to the UV treatment, which is opposite of
the order in 454.1.9.8.6.1. The final language on that code change we
understand reads as follows:
454.1.9.8.6.1
All (100 percent) of the water from the collector tank must be first
filtered, treated with by an NSF Standard 50 certified UV
disinfection unit with a minimum 40 mJ/cm2 dose, and
then final treatment provided by disinfectant and pH adjustment
chemicals, and then final treatment provided by an NSF Standard 50 certified
UV disinfection unit with a minimum 40 mJ/cm2 dose before
any of this treated water is piped to the water features.
If the above language is not how these sections would currently read
in the 7th edition, please provide the correct language as it may
make this comment for the Commission’s consideration a moot point. But to
ensure the opportunity to provide what we see as a correction in order, the
Pool & Hot Tub Alliance provides the following for consideration by the
Commission:
454.1.9.8.6.3
In lieu of Section 454.1.9.8.6.1, the recirculation system
must be designed to continuously return 100 percent of the water to the
collector tank after all (100 percent) of the water is first filtered, treated by a NSF Standard 50 certified UV disinfection unit with
a minimum 40mJ/cm2 dose described in Section 454.1.6.5.16.6, on each feature
pump, and then final treatment treated with disinfectant and pH adjustment chemicals; the
final treatment shall be provided by a validated UV disinfectant unit described
in Section 454.1.6.5.16.6, on each feature pump, before any of this
treated water is piped to the water features. (Note: UV flow capacity must meet the feature pump(s) flow
capacity).
Reasoning for the proposed change: If you treat
with disinfectant and then UV, the question is do you have sufficient residuals
in the tank for the water feature. It is safer to require the UV first and
chemicals/disinfectant last. This is the order required in Section
454.1.9.8.6.1 of the Code.
Please let me know if you need anything further and thank you for the
opportunity to comment.
Best,
Jen
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TAC Recommendation:
Commission
Action:
SW/E-FBC-B- Ch. 4 - Comment #4
From: Hall, John (RER) [mailto:John.Hall2@miamidade.gov]
Sent: Friday, February 14, 2020 12:20 PM
To: Madani, Mo
Cc: Goolsby, Michael L. (RER)
Subject: Comment on the draft 7th Edition (2021) Florida Building Code
Good morning Mo,
Following the January 28, 2020 Swimming Pool TAC meeting and
discussions with FSPA representatives, I am respectfully submitting the
following comment to the 6th Edition (2017) Florida Building Code,
Building Section 454.1.4.2.5 for inclusion in the 7th Edition (2021)
Florida Building Code, Building as follows.
454.1.4.2.5 Voltage
limitation. Underwater lighting, or lighting that may be exposed to
nozzle-directed pool water, shall not exceed 30 volts DC or 15 volts AC.
Such lights shall be installed in accordance with manufacturer’s installation
instructions specifications and be listed by a Nationally
Recognized Testing Laboratory approved for such use by UL or NSF.
The rational for the comment is:
·
The section was lacking a
title.
·
Equipment is to be installed in
accordance with manufacturer’s “installation instructions” not specifications.
·
Approval is a function of the
Authority Having Jurisdiction, not third-party testing laboratories.
·
Both UL and NSF are among
nineteen Nationally Recognized Testing Laboratories. The Code should not
be usurping OSHA’s role of recognizing appropriate laboratories for product
testing and evaluation.
Thank you for your consideration in this matter.
Sincerely,
John T. Hall
Board and Code Administration Division
Senior Code Officer (Electrical)
Miami-Dade County Department of Regulatory and Economic
Resources
11805 SW 26 Street, 2nd Floor
Miami, Florida 33175-2474
(786) 315- 2557 Phone
(786) 315-2907 Fax
From: Holland, Bryan [mailto:Bryan.Holland@nema.org]
Sent: Friday, February 14, 2020 3:08 PM
To: Hall, John (RER); Madani, Mo
Cc: Goolsby, Michael L. (RER)
Subject: RE: Comment on the draft 7th Edition (2021) Florida Building
Code
Thank Mr. Hall,
I fully support this comment to further revise/correct the language used
in Section 454.1.4.2.5 of the FBC-B…
TAKE CARE,
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Bryan |
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TAC/SW Recommendation/SW:
TAC/E Recommendation:
Commission
Action: