The need for a comprehensive Risk Management Program for the Prevention, Recognition & Management of Drowning & Aquatic Injuries

Drowning is a significant health concern within the U.S. and is one of the leading causes of unintentional injury deaths for people of all ages.  Drowning is the 3rd leading cause of unintentional injury death for children 14-years-of age and under; and, it is the 2nd leading cause of death from all causes for children under 4 years of age.  According to the National Swimming Pool Foundation, “water is a foreign environment, and immersion into this environment is potentially dangerous for humans.”  Therefore, it is critical that anyone responsible for any type of aquatic venue must establish, implement and maintain appropriate drowning and aquatic injury prevention strategies as part of their Risk Management Program.

According to the National Drowning Prevention Alliance, the aquatic facility managers and operators must:

  1. Recognize the risks associated with water-related activities and/or venues
  2. Implement strategies to reduce and manage the risks
  3. Responsibly maintain those strategies

Aquatic Facility Managers and Operators must provide a safe environment for swimming and other aquatic activities.  In order to do so, this person must be knowledgeable of safety practices and standards.  All too often, the manager or operator relies solely on state health codes to determine the operational protocols necessary to safeguard the swimming public.  However, health codes are only minimum standards.  And, in the opinion of this author, “minimum is only one small step above inadequate.”

Besides Murphy’s Laws, this author is a firm believer in the Rule of Numbers that states that

the more people who use your aquatic venue increases the probability of a significant incident.  And, each day you operate without a significant incident brings you one day closer to when the incident will occur.

Therefore, the aquatic facility manager or operator must be proactive to identify the potential for any type of conceivable emergency incident.   And, lifeguards, attendants, and other staff must be vigilant in their surveillance duties at all times in order to prevent the incident or to recognize the incident at its onset.

The primary responsibility of any aquatic venue manager or operator is to:

(A) prevent incidents;

(B) recognize incidents at their onset, as well as their potential; and

(C) rapidly and effectively manage the incident, as well as its potential.

Therefore, as part of the facility’s Risk Management Program, a comprehensive Threat Assessment must be conducted of the aquatic venue in order to evaluate the physical hazards that exist and to determine the types of activities that may place patrons at heighted risk.  Hazards must then be removed, or adequate warnings must be posted in order to warn the public of them.  And, those activities that place persons at heighted risk must either be safeguarded, or prohibited.

Another purpose of the Threat Assessment is to determine the Level of Operational Capability required of the facility personnel.  As an example, the location of the aquatic venue must be considered as well as the capability of the local Fire, Rescue, EMS, and Law Enforcement agencies.  If the average response time of Advanced Life Support providers is 6 minutes or more, serious consideration should be given to mandate training of facility personnel in airway management and oxygen administration and oxygen administration and airway management equipment should be readily available as part of the facility’s Emergency Response Plans (ERPs) for the proper and immediate response to respiratory and/or cardiac emergencies, including all submersion cases.  This would be in addition to having personnel trained and equipped in the use of an Automated External Defibrillator (AED) which should be required at all aquatic venues.

Drowning is a hypoxic (lack of oxygen reaching the brain and other vital organs) event.  Drowning victims deteriorate into cardiac arrest because of the initial onset of respiratory arrest.  The best way to manage hypoxia is to administer oxygen during the administration of positive-pressure-ventilation and chest compressions.  All lifeguards are trained to provide positive-pressure-ventilation (PPV) using a Personal Resuscitation Mask (PRM), as well as a Bag-Valve-Mask (BVM) Resuscitator.  They are also trained to administer Basic Life Support (BLS) CPR which includes:

  • A = Airway
  • B = Breathing
  • C = Circulation
  • D = Defibrillation

Therefore, every aquatic venue staffed with lifeguards should be equipped with BVMs, PRMs, and AEDs.  And, as previously mentioned, lifeguards should also be trained in oxygen administration and airway management.  And, they should be equipped with oxygen administration equipment (oxygen tank and regulator) and airway management equipment, including a manual hand-held suction device and oropharyngeal and/or nasopharyngeal airways.

The Threat Assessment should also be used to establish the Operational Criteria required for that facility.  This would include Rules and Regulations for the public, as well as Standard Operating Procedures (SOPs) or Guidelines (SOGs) for staff personnel.

And, finally, once the Operational Criteria has been established and the Operational Capability of personnel determined, the aquatic facility manager or operator must then Plan for the incident; Train for the incident; and, acquire the Resources required to safely and effectively respond to and manage emergency incidents at this facility.

Every aquatic venue needs to develop an Emergency Action Plan (EAP), as well as individual Emergency Response Plans (ERPs)  The aquatic facility manager or operator must develop an ERP for every conceivable emergency.  And, as part of the on-going in-service training program, lifeguards and staff must be continually drilled and evaluated on their ability to recognize an incident and respond rapidly and effectively to that incident.

The Model Aquatic Health Code developed by the Centers for Disease Control (CDC) advocates that “quailed” lifeguards should be required when any of the following conditions exist:

  1. For new construction, any Aquatic Venue deeper than 5 feet at any point;
  2. Any aquatic venue that allows for unsupervised children under the age of 14 years;
  3. Any aquatic venue while it is being used for the recreation of youth groups, including but not limited to childcare usage or school groups
  4. Any aquatic venue while it is being used for group training must have dedicated lifeguards on deck for class surveillance, including but not limited to competitive swimming and/or sports, lifeguard training, exercise programs, and swimming lessons;
  5. Any aquatic venue with a configuration in which any point of the aquatic venue surface exceeds 30 feet from the nearest deck;
  6. Any aquatic venue with an induced current or wave action including but not limited to Wave Pools and Lazy Rivers;
  7. Any aquatic Venue in which bathers enter the water from any height above the deck including but not limited to diving boards, drop slides, starting platforms, climbing walls, and/or Waterslide Landing Pools; and
  8. Any aquatic venue that sells or serves alcohol within the aquatic venue enclosure, during the periods when alcohol is sold or served.

So, what is a “qualified” versus a “certified” lifeguard?  Upon successful completion of a lifeguard training program, the graduate is “certified” as having successfully completed that specific course of training.  However, that individual should not be considered as being qualified to work as a lifeguard at any specific facility until such time as the following requirements have been met:

  • The lifeguard candidate’s knowledge and skills are evaluated by the perspective employer prior to being hired;
  • The lifeguard candidate participates in a comprehensive site-specific pre-service training program;
  • The lifeguard candidate is provided with a comprehensive site-specific SOP or SOG Manual that includes, such things as surveillance protocols; uniform requirements; rotations; hazard identification and mitigation strategies; risk assessment and protocols to safeguard risk; location and use of safety, rescue, and resuscitation equipment; emergency communications; etc.;
  • A review of all safety, rescue, and resuscitation equipment;
  • A compete review of the facility Emergency Action Plan (EAP); and
  • A review of facility Emergency Response Plans (ERPs).

The aquatic facility manager or operator must then schedule and require that all lifeguards participate in regular, on-going in-service training which would include victim recognition drills and the conduct of Emergency Response Plans.  This author advocates that training should be constant and comprehensive and:

Don’t just train until they get it right – train until they can’t get it wrong!

All lifeguard personnel need to be qualified, not just certified.  And, all aquatic facilities need to develop and administer a Risk Management Program, including the conduct of a comprehensive Threat Assessment, in order to prevent incidents; to recognize the potential for an incident, as well as the incident itself at is onset; and to rapidly and effectively respond to and manage incident, as well as its potential.



About the Author

Gerry is a professional Aquatics Safety & Water Rescue Consultant for Lifesaving Resources ( in Kennebunkport, Maine.  He has conducted training throughout the U.S., as well as Internationally, for both the Lifeguard and Aquatic Recreation, as well as the Public Safety and Rescue Sectors.  Gerry has written and published over 40 articles and several instructional guidebooks, and he has consulted as a Forensics Expert in over 500 drowning and/or aquatic injury litigation cases.  He has consulted for and appeared on, as an Aquatics Safety & Water Rescue subject matter expert for, CNN, MSNBC News, CBS’ Early Show, NBC’s Today Show; ABC’s Good Morning America, The Weather Channel, The Discovery Channel, and The History Channel, in addition to numerous radio talk shows and local television news broadcasts in New York, Connecticut, Texas, Virginia, New Hampshire, and Maine.  Gerry is also a licensed Emergency Medical Technician and Firefighter with over 50 years of experience.

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