Management of Water Quality in

Licensable Aquatic Facilities

Legislation Course for Managing Agents

BCA Academy

Environmental Hygiene & Compliance Team

Sanitation and Compliance Division
Environmental Public Health Operation Group
National Environmental Agency
Topics

1. Diseases associated with aquatic facilities

2. Manage public health risk in aquatic facilities (Legislative and Design Requirements)
3. Penalty for offences related to licensable aquatic facilities regulations
4. Responsibilities of a MA for maintaining acceptable water quality
a. Management of water quality in aquatic facilities
b. Causes of poor water quality parameters
c. Remedial measures
d. Record Maintenance
5. Response to complaints and feedback
6. Response to incidents involving faeces and vomitus contamination

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 Diseases Associated with Aquatic

1 Facilities

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Microbial Hazards Associated with Aquatic Facilities

• Causative agents:
• Viral – Enterovirus, Norovirus, Hepatitis A
• Bacterial – Shigella, Escherichia coli (E. coli) O157
• Parasites – Giardia, Cryptosporidium

• Common symptoms:
• Diarrhea
• Fever
• Vomiting
E. coli O157 can cause renal (kidney) failure

• Sources
• Primarily from faeces released by infected swimmers (e.g., young children or
swimmers with diarrhea) into the water.

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Acquired Recreational Water Illnesses (RWIs)
▪ Acquired Recreational Water Illnesses when contaminated water is:
• swallowed
• gets in contact with cuts/wounds
• inhaled
• allowed to remain in contact with sensitive tissues/skin for prolonged time

▪ Users with lower Immunity

• Young children
• Pregnant women
• Elderly
• Immuno- compromised individual- AIDS, chemotherapy patient or those who
are already ill

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Pathogenic Organisms in Chlorinated Aquatic Venues

Organism Illness Route of Infection

Enteric Bacteria • Gastroenteritis • Fecal/Oral

• Conjunctivitis • Eyes
• Pneumonia • Inhalation
Legionella • Legionnaires’ Disease • Inhalation
(pneumonia), Pontiac Fever
(flu-like)
Pseudomonas • Hot Tub Folliculitis • Skin
aeruginosa • Conjunctivitis • Eyes
• Pneumonia • Inhalation
• Swimmer’s Ear • Ears
Cryptosporidium and • Gastroenteritis • Fecal/Oral
Giardia
Adenoviruses • Conjunctivitis • Eyes
• Gastroenteritis • Fecal/Oral
Enteroviruses • Gastroenteritis • Fecal/Oral
• Viral meningitis
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Outbreaks Reported Worldwide
• In the last 5 years, Singapore has not reported any confirmed outbreak of waterborne
diseases arising from aquatic facilities (AFs).
• There is a risk of an outbreak from AFs as the AF water is often used multiple times
without exchange of water and if the water is inadequately treated.
Places
Date Case Death Possible source
reported
Bournemouth Jun 39 0 Outbreak caused by Legionella.Unhygienic condition.
UK 2019 https://www.bbc.com/news/uk-england-dorset-48892538. Bournemouth health
spa probed after Legionella outbreak. BBC News, 6 Jul 2019
York, UK Aug 160 0 Outbreak caused by Giardia.Insufficient filtration system and failure to put
2015 necessary chemicals to clean the water in the swimming pool.
https://orw.telegraph.co.uk/news/2019/01/16/swimming-school-set-
businessman-led-uks-largest-ever-outbreak/
Trafford, UK Sep 8 0 Outbreak caused by E. coli O157.Contaminated water in the swimming pool
2004 due to a blockage to the chlorine dosing system.
A. Verma, F.J. Bolton, et al. An outbreak of E. coli O157 associated with a
swimming pool: an unusual vehicle of transmission. 2008.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2870659.
Miyazaki Jul 295 7 Outbreak caused by Legionella.1,500,000 CFU/100 ml bacteria from the hot
Prefecture, 2002 water circulating within the spa facilities
Japan Mika Okada, Kimiko Kawano, Fumiaki Kura, Junko Maekawa-Amemura, Haruo
Watanabe, Kenji Yagita, Takuro Endo, Sen Suzuki. Largest outbreak of
legionellosis associated with spa baths: comparison of diagnostic tests
Kansenshogaku Zasshi 2005, Vol 79, Issue 6; Pg 365-374.
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 Manage Public Health Risk In

2 Aquatic Facilities
(Legislative and Design Requirements)

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Hygiene Standards of Higher Risk AFs

Enacted on 31 Aug 2021

• Amendments to Environmental Public Health Act to license spa pools and water
playgrounds to enhance hygiene standards and monitoring, and better address
potential risk of water-borne disease outbreaks

• Environmental Public Health (Swimming Pools) Regulations is replaced with

Environmental Public Health (Licensable Aquatic Facilities) Regulations

• A valid licence is required to operate swimming pools, water playgrounds

(including interactive water fountains) and multi-use spa pools

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Licensable Aquatic Facilities

Swimming pool means any artificial pool, device or facility that —

• is designed to operate with a water recirculation system that does not utilize
hydrojet circulation or air induction bubbles;
• is not completely drained of water after every use of the pool, device or facility;
and
• is, or is intended to be, primarily used for people to swim, dip, dive or wade in

Water playground means any facility that —

• has one or more artificial water features;
• is designed to operate with a water recirculation system that does
not utilise hydrojet circulation or air induction bubbles;
• is not completely drained of water after every use of the facility; and
• is, or is intended to be, primarily used for people to play or interact
in.

Multi use spa pool means any artificial pool that —

• is designed to operate with a water recirculation system that utilises hydrojet
circulation or air induction bubbles; and
• is not completely drained of water after every use of the pool;

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Legislative and Upstream Requirements

Code of Practice on Environmental Health (COPEH, Section 5)

• Provide minimum design criteria that minimizes the chance of contamination
Design and water stagnancy at licensing/building plan stage

Environmental Public Health Act (Sections 63-66)

• Licence is required to operate an aquatic facility
• Powers to close pool in the event of non-compliance or outbreak of
infectious disease

Operation & Environmental Public Health (Licensable Aquatic Facilities) Regulations

Maintenance • Use of potable water source or any water source approved by Director-General
of Public Health (DGPH)
• Use of non-gaseous chlorine-based or bromine-based disinfectants or any
disinfectants approved by the DGPH
• Conduct water quality monitoring
• Conduct prompt mitigation

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 Penalty for Offences Related to

3 Licensable Aquatic Facilities

Regulations

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Maximum Penalty for Non-compliance

Non-compliance of water
Unlicensed aquatic quality, Non-submission of
facility water quality test results

• First offence: a fine not • First offence: a fine not

exceeding $5,000
• Second or subsequent offence: a
fine not exceeding $10,000 or to
imprisonment for a term not
exceeding 3 months or to both.
exceeding $5,000
• Second or subsequent offence: a
fine not exceeding $10,000

It is an offence for not

renewing your licence
yearly!

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4 Responsibilities of a Managing
Agent

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Responsibilities of a Managing Agent (Overview)

Put up sign for

public health
reason & display
test result

Respond to
Renew licence
feedback on AF
timely
water quality
Managing agent’s
responsibilities

Rectify pool Maintain

contamination acceptable water
promptly quality

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 Maintain Acceptable Water Quality
Understand How Swimming Pool Works

Water
Balancing/surge
circulation
tank pump(s)

Strainer
Return inlets

Chemical
injection
Backwash
tank

Filter
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Maintaining Acceptable Water Quality
Performing Water Quality Test

▪ Ensure the water circulation and water purification systems of AFs are maintained in good working
condition and operated to keep the water in the AF clean, clear, disinfected and free of any scum,
debris or floating material.

▪ Ensure AF is maintained in good working condition and kept clean and free of algae, dirt, litter,
slime and vermin.

▪ Ensure the pool water quality complies with the parameter limits stipulated in the Environmental
Public Health (Licensable Aquatic Facilities) Regulations

▪ Test and record pH and free chlorine residue/total bromine level of water on-site at least once a
day
• The testing kit on-site must be provided and maintained in good working condition (e.g.:
calibrated)
• Test to ensure that there is sufficient disinfectant in AFs at all times when open for use

DGPH has the power to request the licensee to test the water at more intervals
when necessary.

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Maintaining Acceptable Water Quality
Steps to Test for pH and Residual Chlorine Daily

• Scoop water with the test kit

• 30 to 40cm deep in the swimming pool

• Perform the test using the test kit

• Record the reading and make it readily available for our officers’ check upon

request.

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Maintaining Acceptable Water Quality
Submission of Monthly/Quarterly Water Quality Test Result Electronically
Engage a Singapore
Accreditation Council (SAC) - List of accredited labs: https://sac-
accredited laboratories for accreditations.gov.sg/Pages/Homepage.aspx
monthly/quarterly tests

Licensees or Labs to submit the Website for submission of water quality test result:
water quality test results to NEA https://licence1.business.gov.sg/web/frontier/home

• Sampling for a particular month shall be done within the same

month
e.g. sampling for Mar 2022 shall be done within Mar 2022
• Water quality test result for a particular month is to be
submitted no later than the 14th of the subsequent month
e.g. Mar 2022 should be submitted latest by 14 Apr 2022

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Maintaining Acceptable Water Quality
Test Parameters to Assess Water Quality of Aquatic Facilities

Frequency Testing Water quality test Swimming Swimming Water Multi-

by who parameter Pool without Pool with AG Playground use Spa
AG* feature(s) feature(s) Pool
Daily & Daily on- pH 7.2-7.8
Monthly site by
licensees Free Residual Chlorine 1-3 3-5
(mg/L)
Monthly
pH 7.2-8.0
by SAC
labs
Total Bromine (mg/L) 2-4 4-6
(indoor only)
Monthly SAC labs Turbidity (NTU) ≤ 0.5 NA

Heterotrophic Plate Count ≤200

(HPC) (cfu per ml) at 48h,
35ºC
E. coli (cfu per 100 ml) <1

Quarterly SAC labs Legionella Bacteria Count NA <1

(cfu per 100 ml)
Pseudomonas aeruginosa NA <10
Count (cfu per 100 ml)
*AG: Aerosol-generating

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 Licence’s Validity

• NEA licenses all aquatic facilities (AFs) in non-residential premises in Singapore, which
include but not limited to AFs located within Sport Singapore/People Association
complexes, common property of condominiums, hotels, clubs and educations
institutions.
Set up MCST Make payment (NEA Inform NEA in writing

Renew Licence
Apply licence

Cancel licence
CorpPass & apply via sends reminder (via email/signed
GoBusiness when before the licence letter*) to cancel.
developer transfers expiry date) & receive
management to an electronic licence
MCST in PDF format copy NEA proceed to
($200/yr) cancel. No further
notice to MCST

* Email: NEA_VC_Licences@nea.gov.sg.
Signed Letter sent to Environment Building, 40 Scotts Road, Central Licensing
Branch, #12-00, Singapore 228231
Put up Notice/Display for Public Health Reason

Do not contaminate
Display test results
pool water

Display AF water
Provide a clear sign to quality result in a
direct every swimmer
to use a pre-swim conspicuous &
shower accessible
position

Licensees shall ensure that no person who suffers from

any cut, wound or sore shall be permitted to use the AF. 22
Maintaining Acceptable Water Quality
Performing Water Quality Test

• Ensure the pool water quality complies with the standards stipulated
in the Environmental Public Health (Swimming Pools) Regulations
• Test and record pH and chlorine residue of water at least once a
day
• The testing kit on-site must be provided and maintained in good working
condition (e.g.: calibrated)

DGPH has the power to request the licensee to test the

water at more intervals when necessary.

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Maintaining Acceptable Water Quality
Steps to Test for pH and Residual Chlorine Daily

• Scoop water with the test kit

• At least 30cm deep in the swimming pool
• Perform the test using the test kit

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Maintaining Acceptable Water Quality
Submission of Monthly Water Quality Test Result Electronically
Engage a Singapore List of accredited labs: https://www.sac-
Accreditation Council (SAC) - accreditation.gov.sg/cab/acab/Pages/ACTL-
accredited laboratories for Overview.aspx?f=All&a=LAF012&ss=ALL
monthly test
Website for submission of water quality test result:
Labs to submit the water quality https://eservices.nea.gov.sg/essp/spw/controller?e
test results to NEA vent=AUTHENTICATE

• Sampling for a particular month should be done within the

same month
e.g. sampling for Aug 2019 should be done within Aug 2019
itself
• Water quality test result for a particular month is to be
submitted no later than the 14th of the subsequent month
e.g. Aug 2019 should be submitted latest by 14 Sep 2019

AF closure
• Inform NEA as earlier as possible on closure period with supporting documents
(eg: notice to guests or confirmation of works to be carried out) 25
Maintaining Acceptable Water Quality
Understand How Water is Collected by Accredited Lab

• Microbiological test sample

• Use sterile bottle with an agent that neutralizes the disinfectant (e.g., sodium
thiosulfate)
• Select a representative spot in the swimming pool
(Do not sample at the return inlets where treated water is returning pool)
• Tilt and fill the sample bottle
• Avoid contamination by not touching the bottle opening and the inner cap

• Physio-chemical sample

• Use clean bottle(s), eg: those received from the lab

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Maintaining Acceptable Water Quality
pH and Free Residual Chlorine to be Monitored Concurrently

At pH between 7.2-7.8, the free residual chlorine^ is able to be

maintained between 1-3 mg/L with maximum disinfectant efficiency.

pH issue
>8 Limited
effectiveness
<6 Corrosive,
compatibility
issue

^ Free residual chlorine such as hypochlorous acid (HOCl), hypochlorite ion (OCl-).
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Rectify AF Contamination Promptly
Understand the Cause of Failed Results and Act Promptly

Rectify failed results promptly!

Parameter Condition Likely cause

Turbidity > 0.5 NTU Filtration may be ineffective.

pH < 7.2 Water has low alkalinity. May irritate eyes.

>8 Water is more alkaline. Chlorine/bromine

will not be effective.

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Rectify AF Contamination Promptly
Understand the Cause of Failed Results and Act Promptly

Parameter Condition Likely cause

Residual <1.0 ppm Low dosage. Disinfection will not

chlorine be sufficient.
>5.0 ppm High dosage / level - may irritate
eyes/skin.
Total Bromine <2.0 ppm Low dosage. Disinfection will not
be sufficient.
>6.0 ppm High dosage / level - may irritate
eyes/skin.
Heterotrophic > 200 Disinfection not adequate, or pool
Plate Count CFU/ml may be heavily used.

E. coli Present

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Rectify AF Contamination Promptly
Understand the Cause of Failed Results and Act Promptly

Parameter Condition Likely cause

Legionella >1 CFU/100ml Ineffective disinfection, water

Bacteria Count stagnancy, biofilm accumulation

Pseudomonas >10 CFU/100ml Ineffective disinfection, water

aeruginosa Count stagnancy, biofilm accumulation

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Maintain Record for Traceability

• Both daily (on-site) and monthly lab water quality test records are
required to be kept in proper records (soft or hard copy) for at least
1 year for inspection by NEA

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5 Response to Complaints/Feedback
on AF Water Quality

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Response to Complaints/Feedback on Pool Water Quality

Managing Agent is the first-line of response to feedback and should take

prompt action to mitigate it to minimise public health risk

Feedback Likely cause

Algae or fungus Chlorine/bromine level and/or water circulation

Irritating smell
Cloudy, coloured and/or foaming water
Presence of worms or insects
may not be sufficient. Review water testing
results and inspect pool areas.
Chlorine level not within the permitted limits.
Various factors may give rise to this condition
– corrosion of metals, inadequate filtration,
inadequate chemical treatment, etc.
Find the source, e.g., possible surface run-off
from landscaping nearby (eg: soil, nearby
plants) or mischief by swimmers.

Seek professional advice (eg: pool contractor) when necessary.

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Maintaining Acceptable Water Quality
Conduct Remedial Measures Promptly & Submit Test Results to NEA

• Licensee is aware, or has reason to suspect

• the AF’s water does not conform to any regulated limit
• the AF’s water is contaminated by any substance which is likely
to endanger the health of any person

• must take the following remedial measures:

Inform DG within 24 hrs

and Collect sample for Submit the test results
Clean & disinfect AFs within 3 regulated tests 24 hr to NEA via
calendar days after cleaning & GoBusiness within 7
disinfection calendar days after
(once licensee aware of the completion of test
failed results) (date of test results).

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6 Response to Incidents Involving
Faeces and Vomitus Contamination

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Response to Incidents Involving Faeces and Vomitus
Contamination
Risk of Faeces and Vomitus in Pool

• Faeces and vomitus are likely to contain

bacteria, viruses and parasites.

WHO Guidelines (2006)

• Accidental faecal releases may occur

relatively frequently, although it is likely
that most go undetected.
• The risk of illness with faecally-derived
pathogens

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How to Respond to Faeces -Contaminated Pool
Incidents (formed stools)
Licensee should take prompt action to rectify pool contamination
Discourage people to
transfer to another
Close the pool Shut down power for
pool with separate
immediately* circulatory system
system until proper
shower

* If other pools share the same

circulation and filtration system,
close them all.

Quickly remove the

Maintain free chlorine faeces and dispose of
Turn on power for them appropriately,
level to 1.0-3.0 mg/L, circulatory system
at pH 7.2 to 7.8 e.g. in a toilet bowl

According to World Health Organisation's

(WHO) guidelines for swimming pool
management

Conduct tests to
Backwash water
confirm the levels of Reopen pool
filtration system
chlorine and pH
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How to Respond to Faeces- & Vomitus-Contaminated
Pool Incidents (Running Stools/Vomitus)
Licensee should take prompt action to rectify pool contamination

Close the pool Shut down power for Pool cleared of

immediately* circulatory system people immediately

* If other pools share the same

circulation and filtration system,
close them all.

Backwash water
filtration system
Shock dose
Turn on power for
circulatory system, Raise free chlorine
residual to 20 mg/l for
filter for 6 turnover
cycles; 8 hr

According to World Health Organisation's

Conduct tests to (WHO) guidelines for swimming pool
confirm the levels of
Reopen pool management
chlorine and pH within
regulatory limits
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Response to Incidents Involving Faeces and Vomitus
Contamination

Licensee should always try to determine if the person who

defecates or vomits has or recently had gastrointestinal
disease.

When in doubt, or when there is a

widespread distribution of faeces, always
take tighter precautionary measures!

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Safeguard • Nurture • Cherish

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