Pool Safety Operating Procedures

Also available as PDF file Pool Safety Operating Procedures

 Cottonmill Swimming Pool – Pool Safety Operating Procedures

Key Points

  • Use of the pool is for members and children of members only.
  • Guests are not normally allowed.
  • The pool is run by the members for the members.
  • All members are responsible for safety.
  • Any member can have keys, and may use the pool at any time it is available, subject always to the provisions of this document.
  • There are no lifeguards.
  • There is no filtration system.
  • Children must be supervised – in and around the pool – in accordance with the section of this document relating to children and young people.
  • Solo swimming is not recommended.
  • No glass or bottles on the poolside.
  • No throwing people in.
  • No running poolside.
  • No pushing.
  • No diving – feet first entry only.
  • No bombing.
  • Please respect and take care of our pool safety equipment and know how to use it.
  • Maximum of 100 people in the pool at any time.
  • The pool may only be used if there is a functioning mobile phone on the premises.
  • Don’t lock the main entrance door from the inside.
  • Standards of operation may not be as high as might be expected in a commercial pool.
  • If you consider these limitations to be unacceptable, do not use the pool.
  • Know the emergency procedures which are set out fully below.
  •  In an emergency dial 999 WITHOUT DELAY. The location of the pool is Cottonmill Lane (near the junction with Cottonmill Crescent) in St Albans, Hertfordshire. Postcode AL1 1HJ. Remember you will have to open the front door for the emergency services.


St Albans Sub-Aqua Club Ltd rents the old outdoor public swimming pool on Cottonmill Lane, St Albans, from the local council, along with its ancillary buildings. The pool was built in 1905, although has been altered and deepened since. The old filtration system was no longer functional and was removed by the Club in the early 1980s. More recently, the Club has carried out repair and maintenance work, which has improved safety, but members must nevertheless realise that due to the age of the pool facilities, safety standards will inevitably not be up to modern standards. 

The pool is available for use by Club members and the children of Club members only. Guests may only use the pool with special permission of the directors. Many Club members have keys and have access to the pool at any time it is available subject to the provisions of this document.

This document relies heavily on guidance included in “Managing Health and Safety in Swimming Pools” issued by the Health and Safety Commission, which, although it deals with commercial pools, does still offer a lot of advice relevant to our situation. To quote from the introduction, “Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law.” 

Who is responsible for safety?

As a voluntary organisation with no employees, we are not subject to the same H&S rules as a commercial operator  Our pool is used only by its owners (the members) We do not consider that the responsibilities and relationships between a commercial operator, its employees and their customers can be transposed directly onto a club setting. We therefore fall some way between a domestic and a commercial pool.

Nevertheless, the directors of St Albans Sub-Aqua Club are aware of their responsibility to ensure that the pool is used as safely as possible. However, all individual members, as part owners (of the lease if not the freehold) have a responsibility todo all that is reasonably practicable to take care of their own health and safety and that of others.

This is very different to a commercial setting, where the operator and its employees are absolutely responsible, with only a limited duty of care falling on the customers.

As in any organisation, everybody is responsible for safety.

Under the Club’s rules, members are obliged, not only to comply with the pool safety rules, but also to assist the directors in their enforcement.

Limitations to the provision of safety

The alternative to accepting the following limitations would be to close down the pool. We therefore believe that, in a Club setting, operating a pool under these circumstances is not unreasonable.

It must be accepted that the resources of the club are limited and the pool is over one hundred years old. It is therefore not possible to operate the pool to modern day standards.

There are no lifeguards to supervise swimming in the pool. To ensure safe use of the pool, we rely on a combination of

  • awareness of potential safety hazards of using the pool
  • recommendations on good practice in and around the pool
  • Safety Briefings and basic rescue skills (mandatory) and additional training on rescue skills (optional)
  • members taking responsibility for themselves, their children and indeed other members should they get into difficulties.

The old water filtration system has been removed and it is not financially viable to replace it. This may result in an issue with water clarity towards the end of each season.

All members must be made aware of these safety limitations, and must make their own judgement as to whether they wish to use the pool.

Nevertheless, the Club directors acknowledge their obligation to ensure that all possible safety measures are put in place within the above constraints.

Who should be allowed to use the pool?

Use of the pool is for diving, snorkelling and swimming members including members’ spouses and children who have registered with the Membership Secretary or Swimming Representative. Social members are not permitted to use the pool. All members using the pool must have attended the compulsory Safety Briefings, and acknowledged reading these Pool Safety Operating Procedures, in particular the clauses pointing out the risks involved, which are reinforced by appropriate signage.

Members’ guests (as defined in the Club rules) may not use the pool, unless special permission from the directors has been obtained.  In that event the member must remain present for the whole time of the guest’s visit, both must comply with all Club rules, and the guest must be made aware of the risks involved by appropriate signage. The privileges of a guest shall not exceed those of the member.

The pool may only be used if there is a functioning mobile phone available on the premises.

Hours of Operation

The pool is available for both lane and general swimming during daylight hours, i.e. from 30 minutes after sunrise to 30 minutes before sunset. However swimmers are not permitted to use the pool under any circumstances once darkness falls.

There will be no access to the pool at certain specified times, such as on Wednesday and Thursday evenings, when the pool is in use by scuba divers, canoeists or other organised groups.

The pool must not be used in the event of a thunderstorm or lightning. Please vacate the pool and take shelter from the storm until at least 30 minutes has passed after the last thunder or lightning has been heard or seen.

Children and Young People /Vulnerable Pool Users

The pool is not supervised. The Club has no members who are qualified to be Pool Supervisors.

Children and young people may use the lane area for swimming practice provided that no adults are swimming in the lanes at the time. The lanes are not a play area.


Children (who are aged under 8 years old) are at particular risk in and around swimming pools and must never be left unattended in the pool or poolside. No more than two children under the age of 8 years may be supervised by each parent or legal guardian (defined as “parent” in this document).

It is our expectation that supervision of children aged under 8 years old should be by a parent in the water within arm’s reach of their child or children. In the event that this is not possible for any reason, parents must be in close proximity poolside to their child or children and their child or children within their sight at all times. This responsibility must not be delegated to other pool users.

Any member found to have left their child or children unattended in the pool or poolside may have their membership terminated with immediate effect.

Young People

Young people aged 8 to 16, while not requiring the same supervision ratios as children aged under 8, may still be vulnerable in and around the water. Parents should actively supervise young people who are members of their family, both when they are in the pool and poolside. This supervision may take place from the side of the pool. Please make young people aware of the rules set out in this document and encourage them to obey any safety instructions or advice given by an adult.

When there are scuba divers in the pool, all pool users must follow any instructions given by the diving marshal (shore cover).

Other Vulnerable Pool Users

Those swimming after consumption of food or alcohol are particularly at risk and this is discouraged by the Club. If you have consumed alcohol please be mindful of your supervisory responsibilities towards your children and young people in your family.

Be aware of non-swimmers poolside who may not wish to enter the water, or who may wish to enter the water but stay within their depth.

Year Round/Cold Water Swimmers

The pool remains open for swimming – subject to the provisions of this document – year round. However, there are additional risks towards the end of the summer swimming season, when the water may have turned green and cloudy. Any swimmer who has a problem and sinks to the bottom may remain undetected. Always know where your friends are, and tell them if you are leaving the pool for a break.

Swimmers who intend to swim through the seasons should be aware that as the pool is unheated the water temperature will drop quickly and considerably once the summer season is over, and time spent in the water should therefore be limited. Take the time to acclimatise to colder water. Even experienced cold water swimmers can be caught unawares by the dangers. Swimmers should be aware that their core temperature can continue to drop even once they have got out of the water. Showering in hot water after a cold swim can be dangerous and for this reason the showers will be turned off during the autumn and winter. Swimmers are advised to warm up by dressing as quickly as possible in layers, and having a warm drink. Solo swimming in cold water is particularly inadvisable (see below on Solo Swimmers).        

Solo Swimmers                        

Solo swimmers are at additional risk. The absence of anyone to help can turn a minor problem (cramp, cold, accident, health issue) into a fatal incident. For these reasons solo swimming is actively discouraged by the Club and is at the risk of the adult member concerned provided that he or she understands and accepts the risks involved. Children and young people must never swim alone.

Swimmers are strongly encouraged to use a buddy system for arranging their swims. This can be done by using the very active swimming Facebook group.

Solo swimmers must make friends or family aware of their presence at the pool and the time that they expect to be back. They should make arrangements for what actions should be taken in the event that they fail to make contact within the specified time.

As always, the pool may only be used if there is a functioning mobile phone available on the premises.

Scuba Divers

Scuba divers should dive in accordance with their own guidelines – even in a swimming pool.

Other Pool Users

Participants in organised pool games will be more vulnerable to injury, and the organisers of these events must give careful consideration to their safety.

Note that those involved in competitive games should be aware that they might not be covered by the Club’s insurance. Please check before organising or taking part in any competitions, however informal they may be.

Pool Equipment

Adult divers and snorkellers who have been trained may use a mono fin and snorkel equipment in the pool.

Junior snorkellers who have completed their training and are underwater hockey players may practise with a snorkel, mask and fins in the pool provided they are being supervised by a parent in accordance with the section above on supervision generally of children and young people.

Swim fins may be used by both adults and children/young people as a swim training aid; however parents should be aware that they increase power and may give a false sense of security to children and young people who may travel out of their depth without realising it. Parents should therefore supervise the use of swim fins.

“Mermaid tails” are not permitted in the pool under any circumstances. Their use has been linked to fatalities and the RLSS (UK) has cautioned that they should only be used in organised classes by trained professionals.

Only SOFT inflatable beach-type balls and skimmer balls (ie those specifically designed for pool use and not other sports or exercise such as footballs) are allowed poolside and in the pool. Paddles of the type used with inflatable dinghies should not be used at the pool. This is due to the risk of damage to the pool liner and pool surrounds from these items.

Parents should be mindful of the risks of large inflatable toys and lilos as there is a danger that children may become trapped in or hidden from view under them.

Poolside users

Not everyone wants to be in the water. Those on the poolside for a BBQ, a drink in the sun, sunbathing, or just watching the fun, may also be at risk. Falling in is the obvious hazard, but there are also trip hazards, getting splashed by pool users etc.

Take particular care if you have been drinking, or if you can’t swim.

Broken glass is a real danger to those with bare feet. Only cans or plastic glasses are allowed on the poolside – no glass.

Although the pool is now in use throughout the winter, extra care should be taken when there is little or no water in the pool.

Throwing or pushing people in, and running poolside, are strictly forbidden.

Take care around the barbecue area and observe all the usual precautions. BBQ’s can be hot and can cause fires if left unattended. The club will not cook your food for you, so make sure your meat is thoroughly cooked through before eating. If in doubt, there is a microwave indoors.

Control of Admissions

Any adult member may apply for a key and electronic keyfob, which will allow them access to the clubhouse and the poolside. There is a charge of £25.00 for the keys including a deposit of £10 which is reimbursed on return of the keys. These rates are subject to change.

Only members who have attended a compulsory Safety Briefing are allowed to use the pool.

Members who refuse to comply with Club rules or the provisions of this document may have their keys withdrawn – see the section on Conduct.

If a keyholder opens up, he/she has the responsibility of locking up, or handing that responsibility to another keyholder.

No more than 100 people may be in the pool at any one time (excluding divers).

Personal Safety

The front door should latch when closed, denying access from the outside except by keyholders. If it doesn’t please contact a director . In no circumstances should the front door be locked with the key whilst people are inside – this sets off the alarm, and those inside will be unable to get out. If you do set off the alarm please contact a director as it will need to be reset even if the alarm stops.

Unauthorised Access

The pool area is surrounded by a high brick wall, topped with barbed wire, to deter unauthorised access.

Any unauthorised person, entering either through the door or over the wall, should not be confronted. Politely ask them to leave (ask them to come back on a Wednesday evening if they have legitimate business, such as a membership enquiry). Call a friend or another member (preferably a director) and if all else fails, leave quietly and call the police. Do not get involved in any confrontation, especially if you are alone. It might turn violent.

After dark

The pool floodlighting must be switched on when members are poolside after dark; however the pool itself must not be used outside daylight hours. Note that to avoid nuisance to our neighbours, the floodlighting will automatically turn off at midnight, and use of the poolside area is not permitted after this time.


Electricity is available on the poolside and in some of the outbuildings for lighting, fridges etc. Also occasional power tools, pumps etc. All electrical sockets adjacent to the poolside are protected with Residual Current Detection devices. Nevertheless, do not operate any electrical equipment whilst wet.


Pool water treatment

The directors authorise at least one competent member to monitor the condition of the pool water and to treat with chemicals as required to keep the water as safe as reasonably practical.

A notice is fixed to the back of the pool access door, showing the current state of the water, and advising whether it is safe for swimming or not. Members should pay attention to this notice.

Nobody shall attempt to treat the pool water, or handle the chemicals, unless they have received proper training and have been authorised by the directors.

Safety Equipment

Members should familiarise themselves with the Club’s safety equipment and its proper use. This is covered fully in our Emergency Procedures Policy and the mandatory Safety Briefing. Please do not interfere with safety equipment and use it only for its proper purpose. Safety equipment is checked regularly but if you notice a problem please make the Committee aware.

Accident Reporting

Should any accident or injury occur at the pool this should be reported to the Committee by filling in an Accident Report Form and posting it into the Accident Reporting Form Box in the Clubhouse. Copies of the Form can be found pinned to the notice board close to the double doors used to access the pool. Please also inform the Club’s Health and Safety Director (HSD) by telephone of any accident or injury in addition to filling in a form. The Club’s HSD or any Committee member can also be approached with any general comments, concerns or suggestions in relation to safety at the pool.

First Aid Box

A First Aid Box is available in the Clubhouse. Should you use any items please make the HSD aware so that they can be replaced.

General Issues of Conduct and Behaviour at the Pool

We rely entirely on the compliance of members with the provisions of this document to keep the pool open and operational.

In the event of refusal to comply with Club rules or guidelines, refusal to comply with the direction of a Committee member, misuse of or damage to Club property or equipment, or serious or persistent breach of the rules, the directors of the Club may at their discretion and with no refund of any fees paid by any member:

  • immediately terminate any membership; or
  • suspend any membership for a period to be determined by the directors; or
  • require the return of any key fobs held by any member.

Emergency equipment

An emergency telephone is located under the first aid box in the bar area, or use a mobile phone. Dial 999 or 112. The location of the pool is Cottonmill Lane (near the junction with Cottonmill Crescent) in St Albans, Hertfordshire. Postcode AL1 1HJ. Remember you may have to open the front door for them.

Flotation devices, ropes and poles should be located around the poolside.

A first aid box in located in the bar area (see above).

An Automatic External Defibrillator is located in the bar area.  Every member should know where it is and how to use it. If you don’t know, open it up and follow the instructions – it is designed to be used by anybody. You cannot make the situation worse by using it. But DO NOT LET IT DELAY YOU CALLING 999! .

Appendix One – Supervision –

Under clause 187 of Managing health and safety in swimming pools http://www.hse.gov.uk/pUbns/priced/hsg179.pdf ,a risk assessment must be undertaken to decide whether constant poolside supervision is required. As the pool meets the criteria from the list, we note that it is strongly recommended that constant poolside supervision is provided.

However, St Albans Sub-Aqua Club is a club whose members are likely to be strong swimmers, and many of the members are qualified in lifesaving. The Club rules stipulate that the pool may only be used by members who have attended the compulsory Safety Briefing. Although it is noted that this may fall some way short of the recommended supervision requirements (4 to 6 lifeguards), it is considered to be a reasonably practicable alternative.

The highest risk is probably posed by the use of the pool by non-diving members and their children . The rules are probably adequate in these circumstances, but every member must share the responsibility of enforcement. The use of video surveillance has been considered, but the proposal has been rejected by the membership.

A Risk Assessment has been carried out and appears at the end of this document.

Appendix Two – The Pool

The pool is 18m wide by 32m long and varies in depth from 0.9m to 2.5m. The deep area of the pool (9m by 15m) is cordoned off by safety ropes. See diagram overleaf. Swimmers should never use the deep part of the pool unless authorised to do so.

The usable part of the pool includes an area for lane swimming which is 32m long and with one or two lanes, according to the time of day.

The area available for general and lane swimming (excluding the diving area) is approximately 300 sq m. The recommended capacity is 3 sq m per person, equating to a maximum of 100 persons in the pool at any time. This excludes divers, or other authorised users in the deep area of the pool.

St. Albans Sub Aqua Club

Risk Assessment – Cottonmill Pool

Issue 9 – 29.3.19

Hazard Who Frequency Severity Risk evaluation Controls Immediate measures to deal with consequences if risk does occur
Heart attack All Rare Fatal Medium Medical self-declaration / BSAC referral to medical referee CPR training for club members De-Fib & training available Telephone line installed Mobile phone on site at all times Advise no solo swimming Call emergency services (telephone right hand wall by centre door) CPR Use of de-fibrilator ( right hand wall by centre door)
Drowning All Rare Fatal Medium Monitored by buddy / instructors / club members / pool supervisor Familiarisation with pool depths Deep water roped off Training/sessions conducted in depths suitable to skill level Depth and safety signage Rescue equipment available Inductions & safer swimming sessions provided Visibility checked before use Use of all equipment in the pool carefully monitored Use of snorkel and diving equipment restricted to those who have undertaken training Mermaid tails not permitted Balls used in and around the pool designed for pool use Assistance from buddy / instructor / club member / parent / pool supervisor Call emergency services CPR if required
Fire outbreak and burns from use of the BBQ All Rare Moderate injury Low Fire extinguishers BBQ lighting fuels, fire accelerant to be safely stored   Water to hand – pool and running water Call emergency service if necessary Assistance by buddy/instructor/club member/parent/pool supervisor Apply appropriate first aid Seek medical advice
Poisoning  All Rare   Fatal Chemicals, cleaning substances, BBQ lighting fuels, fire accelerant  to be safely stored COSHH Sheets stored with chemicals PPE to be worn by pool dosing team handling chemicals Training given to pool dosing team Follow instructions on COSHH sheet Call emergency services if necessary
Hazard Who Frequency Severity Risk evaluation Controls Immediate measures to deal with consequences if risk does occur
Panic All Rare Moderate injury Low Monitoring by instructor/ buddy / club member /Pool Supervisor Assistance & TLC  from buddy / instructor / club member / parent / pool supervisor
Slipping on pool surrounds All Rare Moderate injury Low New non-slip surface on pool surround No running in pool area Fins removed when walking on pool surrounds Assistance / by buddy / instructor / club member / pool supervisor Apply appropriate first aid (right hand wall by centre door) Seek medical advice Call emergency services if necessary
Slipping on entry to building from pool area All Rare Moderate injury Low No walking into club house with wet feet All to change in outside cubicles not toilets Use outside toilets / showers after using pool Assistance / by buddy / instructor / club member / parent / pool supervisor Apply appropriate first aid Seek medical advice Call emergency services if necessary
Hypothermia   All Rare Moderate injury Medium Limit time in water Training given on use of wetsuits, & warm clothing Hot drinks available Space blankets available in 1st Aid box Summon instructor / club member / parent / pool supervisor Remove casualty from water Apply appropriate first aid Seek medical advice Call emergency services if necessary
Contact with other water users / pool side or bottom All Frequent Moderate injury Medium Good pool planning / control Liaise with other water users Supervise / Referee Games Feet first entry only Summon instructor / club member / parent / pool supervisor Remove casualty from water Apply appropriate first aid Seek medical advice Call emergency services if necessary        
Hazard Who Frequency Severity Risk evaluation Controls Immediate measures to deal with consequences if risk does occur
Skin / eye irritation Ingestion/ Inhalation     All             Pool water testing and dosing team Occasional             Occasional Minor injury           Moderate injury Low             Medium Pool water tested Chlorine/Ph adjusted Signage on entry to pool indicates water quality Recommend use of goggles / masks by pool users   Training given in handling, mixing and dosing pool All Personal Protective Equipment (PPE) must be worn when dosing the pool (Respirator mask, goggles, gloves and apron) Shower / bathe eyes Assistance from Instructor / Key holder / Pool Supervisor Seek medical advice       Shower / bathe eyes Follow instructions on COSHH Sheet Seek medical advice Call emergency services if necessary
Infection from faeces, sickness or blood All Rare Minor injury Low Use of toilets before swimming Swim nappies to be worn by children not toilet trained No swimming with open wounds or if unwell Remove solids and superchlorinate If not solid, vacuum to waste, superchlorinate and close pool for 24hrs    
Cuts from broken glass All Rare Minor Low No glass on poolside Summon instructor / club member / parent / pool supervisor Apply appropriate first aid Seek medical advice Call emergency services if necessary          
Hazard Who Frequency Severity Risk evaluation Controls Immediate measures to deal with consequences if risk does occur
Injury from kit used, tools or  building materials All Rare Moderate injury Low Check all equipment used for safety Store maintenance items and building materials safely in secure areas Instructor / club member / parent / pool supervisor / premises officer to assess and remove kit to quarantine or safe storage areas Summon instructor / club member / parent / pool supervisor Apply appropriate first aid Seek medical advice Call emergency services if necessary

Assessed by: Ali Humphrey

Date: 29.3.19