Risk Management Topic Swim Testing Policy Implementation Nineteen people, mostly children, drowned in YMCA swimming pools between 2002 and 2004. Most did not know how to swim and it appears that none were swim tested. An analysis of the data from these incidents plus the near drowning incidents of the same period reveals some alarming facts. The shallow end of the pool was where five of the thirteen deaths occurred in 2002, three of the four deaths in 2003, and one of the at least two in 2004. Three more nearly drowned there in 2004. Most of the kids involved in these incidents were between four and six years old. All drowning deaths are preventable and constitute a tragic loss, but losing a child in the shallow end is unconscionable. Many YMCAs do not test the swimming capabilities of unknown swimmers, but the above tragic statistics demonstrate the need to develop and implement swim test protocols that will protect all non-swimmers, even those in shallow water. An increasing number of Ys, both independently and working in conjunction with The Redwoods Group, are now successfully testing swimmers of unknown ability, especially participants of special use groups like day camp, rental groups, and birthday parties. The Redwoods Group is advocating the following policy on swim testing: We realize that for some YMCAs this policy may be a significant shift from current operations. Any change in policy and procedure will no doubt encounter difficulties in administration and implementation. This guide is designed to help ease the transition by sharing best practices and practical ideas from YMCAs that have had success with the change. Of course, each YMCA is different and a strategy that works effectively in one location may not be appropriate in another. Although new ideas and innovations regarding this policy are encouraged, the points outlined above and the spirit of the policy should be fully incorporated. Your swim test policy should be enforced at all times without exception. Failure to do so may put your YMCA legally at risk in the event of an incident. More importantly, not enforcing this or a similar policy leaves your swimmers at risk. Some Definitions 1: Children: Legally a child is anyone who has not reached majority...our duty to protect a child is arguably greater than that due an adult because the child may not possess the maturity, judgment, or physical stature necessary for safety in an aquatic environment, especially with the added complication of peer pressure. While teenagers may be tall and physically agile enough to be safe in shallow water, the decision to exclude any child from testing is fraught with danger...both to the child and to the Y...do so very carefully.The TestThe purpose of testing is to ensure the safety of the children. Two separate and distinct sets of skills should be evaluated to determine where a child can go (i.e., deep or shallow water) and what level of supervision the child needs to be safe in your aquatic environment. Deep water access should require testing that is difficult enough to give an accurate account of skill level without endangering the individual. The test should be specific to your aquatic facility and should be easily supervised so it is accessible when needed. All tests should include at least the following aspects (but more extensive testing is of course acceptable): 1: Jumping into water that is over the individual's head and returning to the surfaceThe three described components will demonstrate the child's capability and comfort in deep water. It is critical that the tester carefully analyze the second point...if the child struggles or only completes the test with great difficulty the child should be restricted from the deep water and should be retested at a later date. When the stakes are life or death, almost is not good enough. Children who do not successfully complete the deep water test or who choose not to take it should be restricted to the pool's shallow section. Those who can demonstrate shallow water competency by readily gaining their footing after being held on the water's surface or pulled forward in a prone position and then being released are safe to play in water that is armpit depth or less without an immediate adult caregiver. Those who cannot readily gain their footing should only be allowed in the pool when meeting one of the non-swimmer options. Testing should be done in an area free of obstacles, equipment, or other swimmers that is under the active surveillance of an on-duty lifeguard distinct from the one doing the testing. This may require specific times for testing or additional staffing because of programming or staffing considerations. Sufficient time for testing should be scheduled into the start of each session of outside or special use groups. This will allow the aquatics staff to review the rules and safety with the children and to test them properly. Testing time can be scheduled into open, community, and family or other general swim sessions as well. Appropriate times may be 15 minutes before the session begins, between sessions, or during scheduled safety breaks when the pool is cleared. Leaving 10 minute breaks between programs can also provide times for swim tests to be administered. Any scheduled swim test times should be clearly posted and advertised to provide information about when testing will be available and to eliminate complaints. Lifeguard scheduling may need altering to have sufficient staff to safely run swim tests. One means of doing this it to extend lifeguard shifts so that there is a fifteen minute overlap between shifts. The incoming guard could do any needed testing before taking the stand and relieving the outgoing guard. Probably the largest procedural change arising from this policy will be administrating the test to all the children. It may encounter some initial resistance from both staff and parents. This can be reduced by emphasizing thesafety of the children. With an appropriate system of record keeping, children who have passed the test need not be re-tested each time they use the pool. Their test status can be entered into the computer so that known swimmers' identification is handled at the front desk, not on the pool deck. Options for non-swimmersThe two significant differences in this swim testing policy from all others are that all children are evaluated, not just those who want to go into the deep water, and that every non-swimmer is required to comply with one of three conditions to use even the shallow portion of the pool. The specific option chosen will vary with the individual user, the program, and the availability of equipment and staff at the YMCA. Following is a brief explanation of each condition. Option A allows a non-swimmer to be in the shallow end of the pool, but only when within an arm's length of an actively attentive parent or adult caregiver who is in the water with the non-swimmer. This condition is the most practical during an open or family swim session. If the child does not pass the test (declination of testing is equivalent to not passing), then the parent must be in the water, actively engaged, and within arm's reach of the child at all times that the child is in the pool or pool area. The parent may not leave the child unattended for any reason. The education of parents will be crucial for the success of this condition. Clearly communicate the reason for this policy to your members including the necessity for constant active supervision in any aquatic setting, including residential, apartment, or hotel pools. Your efforts should not only make your policy easier to enforce, but might also save a child's life away from the YMCA. As noted in the section on testing, some children who are not quite capable of passing the swimming test are capable of being safe in water of sufficiently shallow depth. These children can easily get their feet down and stand when they are in shallow enough water. If there is a designated area in the pool where the deepest water in that section is not deeper than that child's armpits, then a child who has demonstrated shallow water competency could swim there without immediate adult supervision. For example, if your pool has a zero-entry section with a maximum depth of three feet, or perhaps a subdivided shallow section with a maximum depth of four feet, any child who has demonstrated shallow water competency and who is tall enough that s/he canstand in deepest water in the section without the water going above her or his armpits could be allowed to play in that section without having an adult within arm's reach. Of course, this assumes that the child is old enough to be in the water without parental supervision. Many YMCAs already have a policy requiring children under a certain age to be accompanied by a parent in the building. This policy should be strictly enforced in all areas of the facility, but is critical in the aquatics setting. A child who has to be accompanied by an adult to be in the building because of age or individual challenges who passes the swim test still needs a parent or adult caregiver in the pool area. Although the parent may not need to be in the water they still have to be present to provide supervision for the child. Neither shallow water competency nor swimming capability confers upon a child the maturity needed to be left without parental supervision. Lifeguards are just that...not babysitters. Option B, described in the testing paragraph above, allows children who are "shallow water competent" (i.e., can readily regain their footing in water that is armpit deep or less) to play without immediate supervision in zones where the maximum depth does not exceed their armpits. These zones can be created using additional lifelines as noted in "the pool" section below. Option C allows a non-swimmer to be actively involved in a swimming class, defined as any swimming program where there is direct in-the-water interaction between the program facilitators and the participants and where direct parental involvement is impractical. Examples include formal swimming lessons, day camp swimming programs, and formal birthday parties. Not included are free swim portions of birthday parties or day camp...the interaction between instructor and participant is what qualifies it as a class. The qualifying operative in this option is participation, not enrollment. The child must be actively engaged in the lesson at the time that s/he is in the pool. During camp or party programs, the definition of lesson may take a broader meaning so that it encompasses any instructor-led activity involving interactive participation between instructor(s) and non-swimmers. Water games and activities that strengthen swimming ability or build water safety skills are lessons that have been infused with fun. A day camp swim program may include a certified swim instructor to actively engage the non-swimmers in a lesson or game in the shallow section. Camp counselors could be certified as water safety instructors and could greatly enhance the value and safety of the children's time in the water. Birthday party options might include the YMCA providing an instructor to facilitate games in the shallow end that engage all the non-swimmers. Those children might have a better time than those just involved in free swim. Option C allows a non-swimmer who does not have an adult within arm's reach and is not actively engaged in a lesson to be in the shallow portion of the pool if s/he is wearing a USCG approved PFD. This option should be considered an accommodation, not a requirement. If your association does not want to allow a PFD in your pool please do not let this option force that decision. The use of a PFD is not failsafe and cannot replace active supervision...the use of a PFD is no guarantee against drowning. This option should not be considered as a means of convenience for the parent...it should be used only if options A or B cannot be met due to a lack of staff or due to unique programming. Even if a PFD is used the parent or caregiver cannot ever leave the child unsupervised in the pool area. A child will often try to remove her or his PFD, sometimes successfully. Some associations do or would like to allow other floatation aids, basically for the convenience of parents. Inflatable devices are categorically unsafe...there are too many ways for them to fail. Non-inflatable units that attach to the body of the child, such as back floats, bubble floats, or swim belts create control issues as there is so much variance in the products that it is difficult to ascertain which are adequate. Many may keep the child afloat without keeping the head out of the water (some may actually position the head in the water by where they attach to the body). However, even some USCG approved units may not keep an unconscious child's face out of the water. IdentificationOnce the children have been tested, there needs to be a means of knowing who is safe in deep water, who is shallow water competent, and who needs to be under constant supervision whenever they are in the pool. All individuals who have been tested should be marked... anyone who is not marked has not yet been tested and should not be allowed in the water. There are many methods of marking a swimmer's ability level including wrist bands, bathing suit badges, evenmarkings on the child's shoulder or back. There are two important points to consider when choosing how to identify swimmers in your pool: how easily the marking can be seen by the lifeguard and the acceptance of the marking by the children. Both are important. Colored bathing caps are probably the easiest way for a guard to identify ability, but since children don't like them it is rarely used. Bathing suit tags and wrist bands are also used...children accept and even embrace them as badges of honor, but as the identifier is normally under the water, recognition by the lifeguard is very difficult. One product that combines the visibility of a bathing cap with the acceptability of a wrist band is the MJ "Safe-T-Band" (Fig. A). It is a break away neck band designed by a YMCA aquatics professional. The bands come in different sizes, colors, and styles and are available at The Lifeguard Store at www.thelifeguardstore.com. The PoolThe first step in implementing a comprehensive swim test plan must be to evaluate the physical aspects of the pool and to divide it into appropriate zones. Many YMCA pools are 25 yard rectangles with shallow ends that start three feet deep and have a constantly sloped bottom to about five feet deep. At this break point the slope increases drastically until it flattens at the deepest point, normally from eight to twelve feet deep (Fig. B). Local and national codes (and item two of this policy) require the presence of a floating safety line at the break point that separates the shallow from the deep section. Its purpose is to make swimmers aware of the depth change and to provide a lifeline for swimmers who find themselves in trouble. Unfortunately, by itself this protocol is only adequate for adults. A shallow end that extends to five feet deep (60 inches) is deeper than the average height of a twelve year old child. Four and a half feet deep (54 inches) is deeper than the average height of a nine year old child, and even a shallow end that is only four feet deep (48 inches) is over the head of the average seven year old child. Part of the reason that nearly one half of YMCA drowning deaths in the past three years have occurred in the shallow end is because shallow is defined as it relates to an adult, not as it relates to a child. Five feet deep is not shallow for most non-swimming children. The significant slope change at the break point creates an additional hazard for a child who is not comfortable in the water, even with the floating safety rope in place. A child who steps over the break point may not have the ability or presence of mind to grasp the lifeline for support. The use of multiple lifelines can reduce both hazards in your pool, either by dividing the shallow end into multiple zones or by restricting access to the area immediately surrounding the break point. The shallow end can be divided into multiple zones according to water depth. A common shallow end ranges at a steady negative slope from 3 feet deep to 5 feet deep for 15 yards. A float rope is normally inserted at the break point of the deep end, creating a single shallow end with a maximum depth of five feet as in figure B, too deep for most non-swimming children. This portion can easily be subdivided with a second float rope creating two zones, one ranging from 3 feet to 4 feet deep and one from 4 feet to 5 feet deep (Fig. C). The children should be allowed in the various depths by a combination of swimming ability and height, e.g., non-swimmers and shallow water competent bathers for whom 48" is at or below their armpits can only go in the shallow section, shallow water competent bathers for whom 60" is at or below their armpits can go in the middle section, and swimmers can go in any zone. Such a policy also eliminates the break-point danger for the shallower section (and younger children). Restriction of the break point danger area can also be accomplished by using multiple floating safety ropes either alone or in conjunction with the multiple zone set-ups. As an alternative to a single rope at the break point, two ropes are utilized. One rope is put in place one half to one meter toward the shallow end of the break point. A second rope is put in place one half to one meter toward the deep end, leaving a one to two meter zone between the two float ropes (Fig. D). No swimming is allowed in the area between the ropes. This prevents access to the break point and leaves the area clear of swimmers, allowing easy visibility to the bottom of the pool for the lifeguards in a high risk area. This configuration also separates the deep from shallow zones by a larger physical space, allowing identification of children who are in an improper zone or who attempt to cross into the other zone more easily and quickly without significantly detracting from more critical scanning activities. The previous examples demonstrate how multiple floating safety ropes can provide better management of swimming zones. While these designs may not exactly fit the layout of your pool, the concepts can be applied in any type or shape of pool. Administration and RecordsThorough record keeping is essential for efficient implementation of this policy. Once a child has been tested (assuming her or his skill level has not changed), there is no need to continue repeating the test each time the child returns to your pool. Since a permanent brand on the child is undesirable, the maintenance of accessible test records is important. As much of the administration of these records as possible should be shifted from the lifeguard staff to other personnel, e.g., front desk or camp staff. The lifeguards should only administer tests, distribute neck bands, or record results when not on active scanning duty. Lifeguards who are responsible for surveillance should not have any other duties distract them from this task. Procedures for open, family, or general swim time for members should follow a standard policy. The specifics of this policy may be unique to each YMCA, but the following practices are currently being used by some associations. After the test is administered the lifeguard who conducts the test records the results and assigns the appropriate color band. The results are added to the master list, preferably by non-aquatic staff, e.g., front desk personnel. When the child returns to swim, the front desk staff looks up the name and gives the child the indicated color band, which is returned as the child leaves the pool. The master list can be kept on paper or electronically, but the latter is easiest if available as many swipe card systems have the ability to maintain such information and display it when the card is swiped. Another method is to issue a sticker to be affixed to the child's membership card that displays the swimming level. The front desk staff sees this and issues the appropriate band. Children may of course re-take the test and swimming level can be upgraded easily by updating the book or system entry, or by issuing a new card sticker. Special use groups such as parties or day camps should have the testing and distribution of bands done right after the safety lecture and prior to any activity in the pool. For a single use occasion there is little need for paperwork as the children may not return to the YMCA. Children that are members and who will return, or have already taken the test can follow normal use procedure. For multiple use groups such as day camp or an after school program, counselors and child care staff can keep the record and distribute appropriate color bands before each swim period. This list can be easily kept up to date with the front desk list either manually or electronically. The effective implementation of the swim test policy will require cooperation and coordination between aquatics and other YMCA staff. The collaboration between aquatics and camp or day care staff both in marking swimmers and through engaging non-swimmers in active lessons and activities will provide a better overall program for the children and will help to provide skills and knowledge the children can use outside the camp program. The visibility of the program from the front desk to the pool will highlight the YMCA's dedication to aquatic safety and the extra effort taken to protect the children in the pool. The implementation of any new policy is difficult and this policy is obviously no exception. It will require regular monitoring, analysis, and revision so that it can be incorporated smoothly into the daily operation of your YMCA. Overall, the policy will better protect all patrons of your aquatic facility and will add value to any program that utilizes the pool. Please call us at 800-463-8546 to discuss this or any other risk management concern, or visit our web site at www.redwoodsgroup.com to learn more about YMCA risk management related issues.
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| Risk Management services are provided by The Redwoods Group to assist the insured in fulfilling its responsibilities for the control of potential loss-producing situations involving their YMCA operations. The information contained is not intended as legal advice; it simply represents trends in the YMCA industry, related industries and/or law. Laws and suggested standards are under constant review by courts, states and trade groups. They can be vastly different in each jurisdiction. For legal advice relating to any subject addressed, YMCAs are advised to seek the services of a local personal attorney. The information is provided "AS IS" without warranty of any kind and The Redwoods Group expressly disclaims all warranties and conditions with regard to any information contained, including all implied warranties of merchantability and fitness for a particular purpose. The Redwoods Group assumes no liability of any kind for information and data contained or for any course of action you may take in reliance thereon. |
| Original 06/28/05 |