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What is the MAHC, and how can my aquatic facility become compliant?

The Model Aquatic Health Code (MAHC) was developed by the CDC to make aquatic facilities healthier and safer. Compliance is voluntary, although all or parts of it may be adopted on the local or state level to update existing codes. Parts of the MAHC address pool operation and policies intended to prevent drownings.


A 2011 CDC study revealed more than 100 fatal drownings in 9 years at pools with lifeguards on duty. For every fatal drowning, 4 non-fatal drownings requiring medical care also occur.


Lifeguards are often blamed when a drowning victim is not recognized in a timely manner, but management is responsible for the training, staffing, and positioning of lifeguards.


In their Lifeguard Management manual, the American Red Cross states:

Area of Responsibility
The facility manager and lifeguard supervisor establish each lifeguard’s area of responsibility for patron surveillance.

The Model Aquatic Health Code (MAHC), developed by the CDC states:

5.6.1.2.1.1A Lifeguard Positions
If the AQUATIC VENUE requires lifeguards, the AQUATIC FACILITY owner shall ensure that glare conditions are assessed from each lifeguard position as identified in the Zone of Patron Surveillance to determine if the AQUATIC VENUE bottom and objects in the POOL are clearly visible to QUALIFIED LIFEGUARD staff throughout operating hours per MAHC 6.3.3.1.1.

Testing, typically done using manikins, is disturbing to some patrons (adults and children alike), even when informed that the manikins are only training devices.

And because patrons find manikins disturbing, they change their swimming activities, invalidating testing.

Some facilities that don’t want to risk frightening or offending patrons by submerging life-like devices, perform testing after hours, with a dozen lifeguards attempting to replicate the turbulence created by hundreds of patrons. Other facilities forego simulating turbulence altogether and submerge manikins in quiescent pools. Either approach skews testing results and can result in lifeguards being assigned zones that are too large, or positioned in stands that are too low to allow adequate visibility when scanning.


The Model Aquatic Health Code requires:

6.3.3.1.1A Zone of Patron Surveillance
When QUALIFIED LIFEGUARDS are used, the staffing plan shall include diagrammed zones of PATRON surveillance for each AQUATIC VENUE such that: 1) The QUALIFIED LIFEGUARD is capable of viewing the entire area of the assigned zone of PATRON surveillance, 2) The QUALIFIED LIFEGUARD is able to reach the furthest extent of the assigned zone of PATRON surveillance within 20 seconds, 3) Identify whether the QUALIFIED LIFEGUARD is in an elevated stand, walking, in-water and/or other approved position, 4) Identifying any additional responsibilities for each zone, and 5) All areas of each AQUATIC VENUE are assigned a zone of PATRON surveillance.

What are aquatic facility operators—who are committed to the success of their lifeguarding team and dedicated to complying with the MAHC—supposed to do when testing with manikins and/or silhouettes during operating hours upsets patrons?


A simple, scientific solution to this problem exists.


Since refraction causes submerged bodies to break apart, lifeguards are taught to look for blotches at the bottom of the pool while scanning. This means that testing devices do not need to be life-like in shape. They do, however, need to be life-like in size.


The smallest person likely to drown in a public pool is a toddler. Based on investigations of drowning incidents, as some children drown, when they stop struggling, they tuck into a fetal position, decreasing their size at the bottom of a pool. Therefore, the smallest victim a lifeguard must be able to see is the size of a toddler in a fetal position.


Scientific tools were developed that anthropometrically represent a toddler in the fetal position (length, width, and height) without looking like a submerged child.

These scientific tools are known as ANGELS™ devices. Patrons disregard ANGELS™ devices and continue to play and swim as though nothing unusual is on the pool bottom.

When laid out in a grid across the bottom of any pool, ANGELS™ devices demonstrate where glare interferes with a lifeguard’s ability to see a submerged body on the bottom of the pool.

ANGELS devices extend across the entire width of this pool, but are not visible on the far side of the pool due to glare from windows and overhead lighting.

In addition to helping aquatic facility operators comply with the Model Aquatic Health Code, ANGELS™ devices serve as a valuable training tool and help develop muscle memory when used to teach lifeguards to effectively and efficiently scan their entire assigned surveillance zone.


With ANGELS™ devices, aquatic directors are able to run testing and lifeguard training sessions under a variety of conditions, including during swimming lessons, aerobics classes, open swim and even while swim team is in the water, without compromising activity taking place in the pool. Similarly, lifeguard vigilance testing can be easily completed without interfering with patron activity or enjoyment.


Set up of the Lifeguard Positioning and Training Tool (LPTT) takes less than 10 minutes and vigilance testing can be completed at any time of the day, without upsetting patrons.


For more information, explore our website our email ContactUs@aqua-conscience.com

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