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STATE OF CONNECTICUT
DEPARTMENT OF PUBLIC HEALTH
< ENVIRONMENTAL HEALTH SECTION
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EHS Circular Letter#2008-91
DATE: December 1,2008
TO: Directors of Health/Districts
Chief Sanitarians
Building Officials
Pool Contractors
FROM: Pamela E. Scully,Sanitary Engineer 3
Recreation Program,Environmental Health Section
RE: Guidance on the Virginia Graeme Baker Pool&Spa Safety Act for All Public Pools
The Virginia Graeme Baker Pool and Spa Safety Act(Act)was signed into federal law in December 2007.The Act
is being administered by the U.S.Consumer Product Safety Commission(CPSC)and goes into effect December 19,
2008. The Act imposes mandatory requirements for suction entrapment avoidance,to promote the safety of pools,
spas and hot tubs.The Act requires:
• Safety Drain Covers.Each swimming pool or spa drain cover manufactured,distributed,or entered
into commerce in the United States shall conform to the American National Standard ASME A112.19.8
-2007 Suction Fittings for Use in Swimming Pools,Wading Pools,Spas,and Hot Tubs published by
the American Society of Mechanical Engineers(ASME).Compliance with this Standard will be
enforced by the CPSC as a consumer product safety rule.
• Public Pool Drain Covers.Every public pool and spa,both new and existing,must change out the
existing main drain covers and install main drain covers that conform to the ASME/ANSI Al 12.19.8-
2007 Standard.("Main Drain"as defined in the Act is"a submersible suction outlet typically located at
the bottom of a pool or spa to conduct water to a circulating pump")
• Public Pool Drain Systems.Every public pool and spa,both new and existing,-v th a single maid
Aglip,other than an unblockable drain,or with multiple main drains that are less than three(3)feet
ate,shall be equipped with one or more additional devices or systdms designed to prevent suction
entrapment that meet the requirements of any applicable ASME/ANSI Standard. Such additional
devices or systems include a safety vacuum release system(SVRS),or suction limitin vents stem or
gravi _drainage system,or automatic um shuto tem.
SUMMARY TABLE:
TYPE OF POOL Change Drain Covers Install Auxiliary Drain System
One(1)Main Drain Yes Yes-if blockable
No—if unblockable(larger than 18"x23"
Two(2)or More Drains -drains Yes No
more than 3 feet apart
Two(2)or More Drains—drains Yes Yes—if blockable
less than 3 feet apart No—if unblockable(larger than 18"x23")
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EHS Circular Letter 2008-91
Page 2
EXISTING PUBLIC POOLS:
Public Health Code(PHC) Section 19-13-B33b(g)states that the Director of Health,if there exists a condition that
constitutes a"safety hazard","may order such public pool closed until the correction is made".The Act is a federal
law,which the State of Connecticut has not adopted it into regulation,however it is the exngctation of the DPH
that the Directors of Health,under the authority of PHC Section 19-13-B33b
take action to ensure
that the public pools are safe with regards to the entrapment issues addressed in the Act.Therefore the DPH-
Recreation Program recommends and will support local health directors on the following course of action
pertaining to recognizing the issues that arise from the Act:
1. All public pools,as defined in PHC Section 19-13-B33b,with the exception of gravity drain pools,that
have not complied with the requirements of the Act by December 19,2008 for pools that are open,or b
the date they re-open for seasonal pools,where products for compliance are commercially currently y
available or not,should be ordered closed until such time as they are in compliance.These pools present a
safety hazard since they are not in compliance with the Act.Pools used by children pose the greatest risk.
Therefore the local health directors should exercise their own judgment and enforce the PHC by closing the
pool under PHC Section 19-13-B33b(g).
2. Gravity drain public pools,as defined in PHC Section 19-13-1333b,that have not complied with the
requirements of the Act by December 19,2008 for pools that are open,or by the date they re-open for
seasonal pools,where products for compliance are NOT commercially available,may file a letter with the
local health officials and the DPH Recreation Program that documents their efforts to comply with the Act
and stating their intent to fully comply once the products needed for compliance are commercially available
to them.These pools should be allowed to remain open for use up to three months after products are
commercially available.Gravity drains,due to their design,pose a much lower risk for entrapment.
(Gravity drain pools are pools with a gutter system,having a surge tank or balancing tank. For these types
of pools the main drains are not directly connected to a circulating pum including recognition of gravity drain pools,in the first quarter of 2009p) DPH will offer training;
3. All public pools,as defined in PHC Section 19-13-1333b,that have complied with the requirements of the
Act may send a written statement to the local health officials stating that they are or will be incompliance
either by December 19,2008 or the date in which they re-open for use.Please note that this letter is not a
legal requirement,but a suggested method to help track compliance.
4. Splash pads/Spray parks,with no standing water,by definition are exempted from the Act.They do not
need to make any changes to their main drains and can remain open and continue to operate as usual.
5. A licensed professional(Consumer Protection License SP-1 for contractors and SP-2 for
journeymen/workers)should do all the work necessary for compliance to ensure that correct flows are
maintained across the drain and that the correct connection of the main drain cover to the sump is achieved.
6. As in the past,any public pool that is missing a main drain cover or has a broken main drain cover should
be ordered closed until a repair is made. These pools present a high safety hazard and should be closed
immediately under PHC Section 19-13-B33b(g).
NEW PUBLIC POOLS:
PHC Section 19-13-1333b(1)requires that new pools be built in compliance with the Connecticut Public Swimming
Pool Design Guide as it is amended from time to time. The Design Guide was amended to require drain covers as
set forth in the Act. Therefore no plans will be approved after December 19,2008 without the necessary covers.
Public Pools that have already received approval from the DPH on their plans and specifications and are presently
under construction will be treated as "existing"public pools for compliance with the Act at the time when they seek
approval to open for use.