Pool water microbiological

testing – further update

1. Previous guidance and sources
In addition to the subject being included in its training manuals, ISRM has
issued two previous information notes on the subject of microbiological testing of
swimming pool water:
• Information note 151: The responsibility of pool managers for the safe
bacteriological quality of pool water.
• Information note 284: Pool water microbiological testing – update.

This information note summarises, updates and supersedes the advice previously
given in the previous notes, with particular reference to who has responsibility for
testing.

ISRM’s guidance on this subject has been informed by both its own expertise and
body of knowledge, and the following:
• The work of the independent Pool Water Treatment Advisory Group, of which
ISRM is a founder member. Specifically, their definitive guide ‘Swimming Pool
INFORMATION

Water’ plus their BSI publically available specification PAS 39.

• The guidance of HSG 179 ‘Managing Health and Safety in Swimming Pools’,
plus the Health and Safety at Work Act and other relevant legislation.

2. Testing responsibility
Introduction
As with most health and safety issues, there is no legislation specifically detailing
the responsibility for microbiological testing of swimming pool water.

Instead, it is the responsibility of the pool operator to carry out their business within
the requirements of general health and safety law and other available guidance. In
this case, the context is:

• Health and Safety at Work Act 1974.

• Environmental Protection Act 1990.
• The Control of Substances Hazardous to Health Regulations (COSHH) 2002.
• Health and Safety (Enforcing Authorities) Regulations 1998.
• PAS 39: 2003. Management of Public Swimming Pools, Water Treatment
Plant and Heating and Ventilation Plant – Code of Practice.
• HSG 179 - Managing Health and Safety in Swimming Pools.

The responsibility for ensuring compliance with health and safety legislation at
swimming pools falls to either the HSE or the Environmental Health Departments
depending upon the main activity of the premises. Pools owned, managed or
occupied by local authorities and those in educational establishments or schools
are enforced by the Health and Safety Executive (HSE). Privately operated (not
domestic) pools, for example those in hotels, holiday camps and fitness clubs are
the responsibility of Environmental Health Departments (EHDs). The following
extract from HSG 179 outlines this point.

Institute of Sport and Recreation Management

Ref – 320: 01/07 Sir John Beckwith Centre for Sport, Loughborough University, Loughborough LE11 3TU
Tel: 01509 226474 | Fax: 01509 226475 | [email protected] |www.isrm.co.uk
Enforcement of health and safety law The analysis of samples should instead be carried out by
13 Under the Health and Safety (Enforcing a reputable and independent organisation. This will most
Authorities) Regulations 1998 the local authority is likely be either an accredited laboratory or through the
the enforcing authority for all pools unless it is the local Environmental Health Department.
owner and/or occupier who has any extent of control of
the activities or the equipment. HSE is the enforcing
authority in pools occupied by local authorities, in 3. Extract from BSI Code of Practice
educational establishments and at Ministry of Defence
premises. Where there is doubt, seek clarification from PAS39:2003
the local HSE office.
5.5.2 Microbiological
The role of Environmental Health Departments
Remember also that Environmental Health Officers have 5.5.2.1 General
right of entry into all pools under the Environmental
Protection Act 1990 and therefore may undertake Microbiological contamination of the pool water can
bacteriological sampling if they deem it necessary. result in pathogenic (disease producing) microorganisms
causing infections to bathers. These contaminants
Depending on local practice and available resources, can be introduced into pool water from bathers,
your local authority’s Environmental Health Department from the pool filters or occasionally from defects in
may choose to carry out regular routine testing at the pool engineering (e.g. that allow the water to be
pools in its area, including those operated by local contaminated with sewage).
authorities.
Tests should be performed monthly to monitor the
However, the actions of local EHDs do not take away presence of indicator microorganisms. These can
indicate operational problems that could result in
the operator’s responsibility for arranging regular
infections. Additionally, tests should be performed:
microbiological testing by an accredited laboratory.
a) before a pool is used for the first time;
b) before it is put back into use, after having been
This responsibility stems from the general responsibilities shut down for repairs;
under HASAW and COSHH regulations, and is clearly c) if there are difficulties with the treatment system;
outlined in the standard guidance, HSG 179, as the d) if contamination has been noted;
following extract explains: e) as part of any investigation into possible adverse
effects on bathers’ health; and
Disinfectants and bacteriological water quality f) to validate changes made to the pool treatment
359 In order to establish that the pool is without regime, e.g. change in disinfectant, or frequency of
risks to the health of those using it, pool operators will addition, or engineering.
need to ensure, under the COSHH Regulations, that
they have adequately controlled the risks from exposure More frequent sampling will be necessary if there is a
to micro-organisms. To do this, adequate disinfecting problem, or for particularly heavily loaded pools.
of the pool will need to take place and bacteriological Hydrotherapy pools should be tested twice weekly as
sampling will be required. the people using these pools are immersed for longer
periods (as are staff) and may be more vulnerable to
360 Bacteriological sampling will need to be infection.
undertaken monthly in pools in use all year round.
Constant checking of the correct disinfectant level Microbiological sampling should be performed by
trained and competent personnel to prevent sample
and pH value will ensure the bacteriological quality
contamination. Microbiological analysis should be
of a well-run pool. Bacterial levels should be zero (or
carried out in appropriately accredited laboratories, e.g.
near zero) as a ‘baseline’. More frequent samples will
UKAS laboratories. The pH value and the concentration
be necessary where a deterioration in water quality of free and total disinfectant in the pool water should be
occurs. Pools that are less frequently used should be measured when the microbiological sample is collected.
checked before use and then monthly throughout their Microbiological samples should be taken beginning at a
operational period. depth of 200 mm to 400 mm below the surface of the
pool.
In-house analysis of results
In the interests of independently validated, accurate The results of routine microbiological sampling should
and robust record keeping, which may be vital in the always be interpreted in conjunction with:
case of litigation, ISRM recommends that the operators • chemical tests performed on site and/or in the
of swimming pools DO NOT carry out the analysis of laboratory at the time of sample collection; and
microbiological tests themselves. • a review of the maintenance records for the pool,
including records of the pH, residual disinfectant
levels, mechanical failures and water appearance
and other untoward events.
It should be noted that failure to comply with the target NOTE 1 In themselves, coliforms do not usually
levels for one or more of the parameters is often a cause disease.
passing phenomenon.
NOTE 2 The presence of Escherichia coli is a better
Subclauses 5.5.2.2 to 5.5.2.7 give the limits for the indication of faecal contamination (see 5.2.2.4).
various tests, and indicate what action should be taken
if unsatisfactory results are obtained. Samples should be
Coliforms are sensitive to disinfectant and should be
tested for aerobic colony count, coliforms, Escherichia
absent in 100 ml of pool water. A repeat sample should
coli and Pseudomonas aeruginosa.
be taken whenever coliforms have been detected.
If the microbiological results are unsatisfactory the
A coliform count of up to 10 cfu/100 ml is acceptable
microbiological tests should be repeated immediately.
provided that:
If the results of the second microbiological tests are still
a) coliforms are not found in the repeat sample;
unsatisfactory, an investigation into the management
b) the aerobic colony count is less than 10 cfu/ml;
and operating conditions of the pool should be
c) there are no E. coli present;
undertaken and a third series of microbiological tests
d) the residual disinfectant and pH values are within
should be made.
recommended ranges.

NOTE The investigation may require the help of the 5.5.2.4 Escherichia coli
laboratory that does the tests, the district council
Environmental Health Department, or an independent Escherichia coli is normally present in the faeces of most
consultant. humans, mammals and birds. It is widely used as a
specific indicator of faecal contamination as it is unable
If results are still unsatisfactory after the investigation to grow within the environment. The presence of E.
and a third series of tests, immediate remedial action coli in swimming pool water is an indication that faecal
is required that may necessitate the pool is closed (see material has entered the pool water from contaminated
5.5.2.6). skin, or from faecal material that has been accidentally
or deliberately introduced. It also indicates that the
5.5.2.2 Aerobic colony count treatment has failed to remove this contamination.

The aerobic colony count (ACC), sometimes called the E. coli should be absent in a 100 ml sample.
total viable count, colony count, or plate count, is a However, because most bathers will have some faecal
general test that indicates whether the pool disinfectant contamination of their skin, particularly if they have
regime is effective in controlling contamination under not showered before bathing, a single positive sample
operational circumstances. The colony count should be may be the result of recent superficial contamination by
carried out in accordance with BS EN ISO 6222 a bather that has not yet been decontaminated by the
(BS 6068-4.5) but with incubation at 37°C for 24 disinfectant residual. A repeat sample should then be
hours. taken.

NOTE These test conditions are set to isolate the 5.5.2.5 Pseudomonas aeruginosa
range of organisms that can colonize the mouth and
skin of bathers. Pseudomonas aeruginosa can grow within untreated
waters and in biofilms. It can cause skin, ear and eye
The ACC can become increased where there is a higher infections when present in large numbers and outbreaks
bather load, reduced chlorine residual or where there are of skin infections have been linked to swimming pools
defects in water treatment. and spa pools.

The aerobic colony count should normally be 10 or less Well operated pools should not normally contain P.
colony forming units (cfu) per millilitre of pool water. If a aeruginosa. If the count is over 10 P. aeruginosa per
colony count above 10 cfu/ml is the only unsatisfactory 100 ml, repeat testing should be undertaken. Where
microbiological result, and residual chlorine and pH repeated samples contain P. aeruginosa the filtration and
values are within recommended ranges, the water disinfection processes should be examined to determine
should be retested. whether there are areas within the pool circulation
where the organism is able to multiply. Where counts
5.5.2.3 Total coliforms exceed fifty, pool closure should be considered (see
5.5.2.6).
Coliforms within swimming pools can be considered as
an indication of faecal contamination or poor hygiene
(e.g. contamination from shoes or leaves in outdoor
pools). Their presence indicates that the treatment has
failed to remove this contamination.
5.5.2.6 Closing pools

Pools should be closed following a routine

microbiological test if:
a) the result suggests gross contamination (see
below); or
b) there is other chemical or physical evidence that
the pool disinfection system is not operating
correctly (e.g. if the records show that residual
disinfectant levels were inadequate or erratic
and frequently too low, or the pool water is of
unsatisfactory appearance).

Where there is evidence of gross contamination the

pool should be closed to prevent illness in pool users.
The local Consultant for Communicable Disease Control
(CCDC – via health authority) should be contacted.

The following should be considered as gross

contamination:
a) greater than 10 E. coli per 100ml in combination
with:
1) an unsatisfactory aerobic colony count (>10
per ml); and/or
2) an unsatisfactory P. aeruginosa count (>10 per
100ml); and
b) greater than 50 P. aeruginosa per 100ml in
combination with high aerobic colony count (>100
per ml).

5.5.2.7 Additional testing in outbreaks

In the event of an outbreak of illness associated with a

swimming pool, additional microbiological testing may
be considered necessary. This needs to be discussed
with the CCDC and the chairman of the outbreak
control team. If disinfection is adequate then bacterial
and viral tests are unlikely to represent the conditions
at the time of the infectious event. Cryptosporidium or
Giardia contamination may still be detectable through
examination of backwash water and filter material
(routine testing for Cryptosporidium and Giardia is not
considered useful).