What did the MLHU find?
A list of infractions found between 2011 and 2014 was gathered from the software inspectors used to enter inspection data. It was found that while there had been an increase in compliance, there were reoccurring items that still needed to be addressed, including some items which showed decreasing compliance with legislative requirements. Deficiencies in record-keeping (including monthly, weekly, daily, hourly, bi-hourly tests and inspections that need to be conducted by operators), and water chemistry parameters (chlorine/bromine, pH, and/or total alkalinity) were identified among the top non-compliance issues.
The MLHU also found several items gathered during its literature scan which aligned with feedback provided by the focus groups. These included:
- Focusing on the top non-compliance issues found during inspections;
- Providing job-specific and hands-on training;
- Providing the rationale for the training and/or legislative requirements;
- The need for ‘Legislative Compliance Training Programs’ at all employee levels;
- The need for training to be delivered in an interactive way, drawing on a combination of teaching methods; and
- The importance of the location and timing of the training.
So what is being done now?
By engaging facility operators and PHIs and incorporating the feedback with information gathered from the literature, it is hoped the MLHU’s training program will add value to the recreational water landscape in London and Middlesex County. It is expected the program will better reflect the needs and wants of recreational water facility owners and operators, while providing a supportive environment to increase legislative compliance. To be successful, the training program has to adjust and adapt as new evidence and best practices become available. As part of the redevelopment project, the program has been designed to be adaptable so training material and content can be adjusted to focus on the most common non-compliance issues, and modified as new information becomes available, or when regulatory changes are announced.
One of the key findings from the program review was the importance of including adult learning principles and strategies that have been successful in other regulatory compliance programs. As a result, the following activities have been incorporated into the training program:
The revised training provides an overview of the eight components recommended in the Recreational Water Protocol, 2016 under the Ontario Public Health Standards (OPHS) and Protocols. To make the training more relevant, each year’s training will have an overarching theme. The training will focus activities and content on the top two or three non-compliance issues identified from the previous year. For example, in 2015, the top two issues identified from inspection data were: water chemistry parameters outside of regulatory ranges, and incomplete record-keeping. As a result, a significant portion of the 2016 training program focused on these issues. A quick review of participants’ post-training surveys indicated the level of knowledge and importance of these two items has increased. Many of the activities listed in Table 1 aim to address some of the barriers operators face in their efforts to manage facilities in a safe and sanitary manner.