The following item numbers are being clarified in response to industry questions. Text from the VSP 2011 Operations Manual is printed first, then the clarification.# 6.0
Recreational Water Facilities

# Fill Level and Turnover Rates (10)
For RWF with skim gutters, the fill level of the RWF must be to the skim gutter level. An RWF slide that is combined with a pool must have a TURNOVER rate that matches the rate for the pool.

# Clarification
Use flow rates from flow meters to calculate TURNOVER rates. Do not use the manufacturer's pump rate to calculate TURNOVER rates.
For the statement "An RWF slide that is combined with a pool must have a TURNOVER rate that matches the rate for the pool," pool refers to either WADING or SWIMMING POOLS but not CHILDREN'S POOLS. In addition, the water for the slide must come directly from the basin of the pool and return directly to the basin of the pool.
For facilities that meet the definition of more than one type of RWF, the more protective TURNOVER rate applies. For example, if a CHILDREN'S POOL also has features of an interactive RWF or ACTIVITY POOL, the TURNOVER rate must be 0.5 hours. The only exception is that when a slide is combined with a pool, the TURNOVER rate for the combined system may match the rate for the pool. However, if a pool and slide combination is also combined with another facility, the most protective TURNOVER rate applies. Finally, if a facility is modified, the most protective TURNOVER rate applies.
(See also clarification for 6.2.2.1.1 for HALOGEN residual.)

# Filter Housing Cleaning and Disinfection (10)
The filter housing must be cleaned, rinsed, and disinfected before the new filter media is placed in it. DISINFECTION must be accomplished with an appropriate HALOGEN-based DISINFECTANT. At a minimum, a 50-ppm solution for 1 minute, or equivalent CT VALUE, must be used.
Records must be maintained on all inspection and cleaning procedures.

# Clarification
The filter housing must be cleaned, rinsed, and disinfected each time the filter media-including cartridge filter-is changed.

# Hair and Lint Strainer (10)
The hair and lint strainer and hair and lint strainer housing on all RWFs must be cleaned, rinsed, and disinfected weekly. DISINFECTION must be accomplished with an appropriate HALOGEN-based DISINFECTANT. At a minimum, a 50-ppm solution for 1 minute, or equivalent CT VALUE, must be used. Records must be maintained on all inspection and cleaning procedures.

# Clarification
If there is not a hair and lint strainer but there is a filter before the pump, this filter must be cleaned, rinsed, and sanitized.

# Bather Loads (10)
Documentation must be maintained on the maximum bather load for each RWF.
The maximum bather load must be based on the following factor: One person per five gallons (19 liters) per minute of recirculation flow.

# Clarification
Use flow rates from flow meters to calculate bather loads. Do not use the manufacturer's pump rate to calculate bather loads.

# Water Chemistry (10)
The RWF's flow rates, free and combined HALOGEN levels, PH, total alkalinity, and clarity must be monitored and adjusted as recommended by the manufacturer and to maintain optimum public health protection and water chemistry.
Evaluate bather load and make adjustments to water parameters to maintain optimum water quality.

# Clarification
Install flow meters to monitor flow rates. Only combined chlorine must be monitored.
Combined bromine does not need to be monitored.
"Manufacturer" refers to the RWF manufacturer and also to manufacturers of the pumps, filters, flow meters, and any other associated equipment.

# Fecal and Vomit Accident (10)
A fecal and vomit accident response procedure that meets or exceeds the procedure provided in Annex 13.8 must be available for review during inspections.

# Clarification
CDC recommends a pH range of 7.2 to 7.5 for loose stool accidents for inactivating Cryptosporidium. This clarification also applies to Annex 13.8.

# Residual (09)
A free residual HALOGEN in the ranges detailed in the table below must be maintained in recirculated RWFs.

# Recreational Water Facility
Free

# Clarification
For facilities that meet the definition of more than one type of RWF, the more protective HALOGEN residual applies. For example, if a children's pool also has features of an interactive RWF or ACTIVITY POOL, the HALOGEN range must be 2.0 to 5.0 ppm. Finally, if a facility is modified, the most protective HALOGEN residual applies.
(See also clarification for 6.2.1.1 for TURNOVER rates.) Manual readings must be recorded on a chart or log, retained for at least 12 months, and available for review during inspections.

# Automated Free Halogen
Repairs on malfunctioning HALOGEN analyzer-chart recorders must be completed within 30 days of EQUIPMENT failure.
Provide an audible alarm in a continuously occupied watch station (e.g., the engine control room) to indicate low and high free HALOGEN and PH readings in each RWF.

# Clarification
If two RWFs are combined and the water for one RWF comes from and returns to the basin of the other RWF (not the compensation tank), separate monitoring systems are not required. Monitoring is then only required on the main RWF (e.g., a slide and SWIMMING POOL). Note: During operational inspections, VSP will take manual samples of both RWFs.

# Data Logger (10)
If an electronic data logger is used in lieu of a chart recorder, it must have certified data security features. For RWFs open longer than 24 hours, a manual comparison test must be conducted every 24 hours.

# Clarification
Electronic data logging must be in increments of  15 minutes.

# Shock Halogenation (10)
The free residual HALOGEN must be increased to at least 10.0 MG/L (ppm) and circulated for at least 1 hour every 24 hours.
The free residual HALOGEN must be tested at both the start and completion of shock halogenation.
The water in the entire RWF system must be superhalogenated to 10 ppm to include the WHIRLPOOL SPA/SPA POOL tub, compensation tank, filter housing, and all associated piping before starting the 1-hour timing.
Batch halogenation of the tub and compensation tank may help in reaching the minimum 10 ppm residual quickly.
Facilities filled only with SEAWATER are exempt from this requirement. Clarifications to the VSP 2011 Operations Manual (December 2013 Revision); 7

# Clarification

# Life Saving (10)
A rescue or shepherd's hook and an APPROVED flotation device must be provided at a prominent location (visible from the full perimeter of the pool) at each RWF that has a depth of 1 meter (3 feet) or greater. These devices must be mounted in a manner that allows for easy access during an emergency.  The pole of the rescue or shepherd's hook must be long enough to reach the center of the deepest portion of the pool from the side plus 2 feet (0.6 meters). It must be a light, strong, nontelescoping material with rounded, nonsharp ends.  The APPROVED flotation device must include an attached rope that is at least 2/3 of the maximum pool width.

# Clarification
The rescue or shepherd's hook must be long enough to touch the bottom center of the deepest portion of the RWF plus 2 feet (0.6 meters) as measured from the closest edge without an obstruction. This edge can only be used for measurement if someone could freely walk down both sides without an obstruction such as a waterfall, fountain, statue, etc.
For a rectangular pool, the shorter distance would be from the long side of the rectangle as long as there are no obstructions (Figure 1). The 2 feet (0.6 meters) is measured from where the shepherd's hook crosses the fill line of the RWF.

# Figure 1. Shortest Distance in a Rectangular Pool
For RWFs with a beach level, the measurement can be from the edge of the tub (Figure 2).

# Figure 2. Measurement in RWFs with a Beach Level
Clarifications to the VSP 2011 Operations Manual (December 2013 Revision); 9

# Spas (10)
In addition to the safety sign requirements in section 6.7.1.1.1, install a sign at each WHIRLPOOL SPA and SPA POOL entrance listing precautions and risks associated with the use of these facilities.
Include, at a minimum, cautions against use by the following:  Individuals who are immunocompromised.  Individuals on medication or who have underlying medical conditions such as cardiovascular disease, diabetes, or high or low blood pressure.  Pregnant women, elderly persons, and children.
Additionally, caution against exceeding 15 minutes of exposure.

# Vessels can submit existing signs for review by VSP.
It is advisable to post additional cautions and concerns on signs.

# Clarification
Those under 16 years of age are considered children for the purpose of whirlpool safety sign requirements.

# Antientrapment Drain (10)
ANTIENTRAPMENT/ANTIENTANGLEMENT requirements for drain covers and SUCTION FITTINGS in RWFs are shown in Table 6.7.1.2.2 (below). This does not apply to facilities with zero depth where the drains are not under direct suction.
VSP is aware that the requirements shown in Table 6.7.1.2.2 for existing vessels may not fully meet the letter of the Virginia Graeme Baker Act, but we also recognize the life-safety concerns for rapid dumping of RWFs in conditions of instability at sea. Therefore, it is the owner's decision to meet or exceed the VSP requirements.
Testing of manufactured drain covers must be by a nationally or internationally recognized testing laboratory.
The information below must be stamped on each manufactured ANTIENTRAPMENT drain cover:  Certification standard and year. A letter from the shipyard must accompany each custom/shipyard constructed (field fabricated) drain cover fitting. At a minimum the letter must specify the shipyard, name of the vessel, specifications and dimensions of the drain cover, as detailed above, as well as the exact location of the RWF for which it was designed. The name of and contact information for the REGISTERED DESIGN PROFESSIONAL and signature must be on the letter. Definitions:  Alarm = the audible alarm must sound in a continuously manned space AND at the RWF. This alarm is for all draining: accidental, routine, and emergency.  GDS (GRAVITY DRAINAGE system) = a drainage system that uses a collector tank from which the pump draws water.
Water moves from the RWF to the collector tank due to atmospheric pressure, gravity, and the displacement of water by bathers. There is no direct suction at the RWF.  SVRS (safety vacuum release system) = a system which stops the operation of the pump, reverses the circulation flow, or otherwise provides a vacuum release at a suction outlet when a blockage is detected. System must be tested by an independent third party and found to conform with ASME/ANSI A112.19.17 or ASTM standard F2387.
- APS (automatic pump shut-off system) = a device that detects a blockage and shuts off the pump system. A manual shut-off near the RWF does not qualify as an APS.
- Describe or show the flow of POTENTIALLY HAZARDOUS FOOD from when last in temperature control to placement in time control and discard.

# Clarification
Time control plans must identify all refrigeration and hot holding units on time control, but only cabinets and compartments on time control must be labeled.
EQUIPMENT that does not have cabinets or compartments does not need to be labeled as time control. Such EQUIPMENT includes bains marie, cold tops, and soup wells.
Containers of POTENTIALLY HAZARDOUS FOOD under time control and placed on preparation counters must be labeled with the discard time, even if the outlet is open less than 4 hours.

# Handwashing and Toilet Facilities
This applies to toilet facilities for galley personnel even if ACCESSIBLE to other crew members.

# Clarification
Sections 9. 1.1.1.7 and 9.1.1.1.8  also apply to this section.

# Hands-free Exit (41)
Passenger and crew public toilet facilities must be equipped so that persons exiting the toilet room are not required to touch the door handle with bare hands.
Where toilet stalls include handwashing facilities, the bare-hands-free contact must begin in the toilet stall. Toilet facilities with multiple exits, such as spa dressing rooms, must have bare-hands-free contact at each exit.
This may be accomplished by methods such as locating paper towel dispensers at sinks and waste containers near the room door, installing mechanically operated doors, removing doors, or using other effective means.

# Sign (41)
A sign must be posted advising users of toilet facilities to use hand towel, paper towel, or tissue to open the door unless the exit is hands free.
A pictogram that illustrates the correct use and disposal of paper towels as written in section 9.1.1.1.7 may be used in lieu of a sign.

# Convenient (29C)
Each FOOD PREPARATION AREA, bar, WAREWASHING area, and garbageprocessing area must have at least one handwashing facility in it.
Clarification ASME A112.19.8-2007 has been replaced by ANSI/APSP-16 2011. ANTIENTRAPMENT protection equipment (covers, suction fittings, safety vacuum release system-SVRS, etc.) must comply with ASME A112.19.8-2007-or any successor standards-whether the equipment is manufactured or field fabricated.
Food Safety

# Clarification
This applies to partial beards (such as goatees) and to heavy, pronounced mustaches.

# Food Storage and Protection

# Clarification
This applies to storage of candy and other food items sold in candy shops, including self-service candy shops and shops where the candy is served by a crew member.
Food Display and Service

# Clarification
This applies to self-service candy shops where customers serve themselves from candy displays or dispensers.

# Time Control Plan (16 C)
A written time control plan(s) that ensures compliance with these guidelines must be maintained on the vessel and made available for review during inspections (Annex 13.11). A time control plan must be posted at each outlet where time control is used. The plan(s) must  Include set-up and discard times for each outlet.  List refrigeration and hot holding units (compartments and cabinets) on time control (the physical units must also be labeled as such).

# Clarification
This applies to self-service and served candy shops where employees serve candy, refill self-service containers, etc.

# Decks, Bulkheads, and Deckheads

# Clarification
This applies to self-service and served candy shops where employees serve candy and refill self-service containers and consumers serve themselves.

# Lighting

# Clarification
This applies to self-service and served candy shops where employees serve candy and refill self-service containers and consumers serve themselves.

# Child Activity Centers

# Facilities

# Clarification
Sections 9.1.1.1.6, 9.1.1.1.7, and 9.1.1.1.8 also apply to this section, except that the sign advising users to wash hands (in section 9.1.1.1.6) is not required.

# Public Toilet Facilities (41)
Passenger and crew public toilets (not including food-area toilets) must be provided with a handwashing station that includes the following:  Hot and cold running water.  Soap.  A method to dry hands (e.g., sanitary hand-drying device, paper towels).  A sign advising users to wash hands (pictograms are acceptable).
Hands-free Exit (41) Passenger and crew public toilet facilities must be equipped so that persons exiting the toilet room are not required to touch the door handle with bare hands.
Where toilet stalls include handwashing facilities, the bare-hands-free contact must begin in the toilet stall. Toilet facilities with multiple exits, such as spa dressing rooms, must have bare-hands-free contact at each exit.
This may be accomplished by methods such as locating paper towel dispensers at sinks and waste containers near the room door, installing mechanically operated doors, removing doors, or using other effective means.
Clarifications to the VSP 2011 Operations Manual (December 2013 Revision); 14

# Sign (41)
A sign must be posted advising users of toilet facilities to use hand towel, paper towel, or tissue to open the door unless the exit is hands free.
A pictogram that illustrates the correct use and disposal of paper towels as written in section 9.1.1.1.7 may be used in lieu of a sign.

# Child-size Toilet (42)
If toilet rooms are located in a CHILD ACTIVITY CENTER, child-size toilet(s) or child-accessible toilet(s) (child-size seat and step stool) and handwashing facilities must be provided.
Child-size toilets (to include the toilet seat) must have a maximum height of 280 millimeters (11 inches) and a toilet seat opening no greater than 203 millimeters (8 inches).
Handwashing sinks must have a maximum height of 560 millimeters (22 inches) above the deck or a step stool must be provided.

# Clarification
Sink height does not apply to handwashing stations outside of the toilet room. However, VSP recommends a maximum height of 560 millimeters (22 inches) above the deck for all children's handwashing stations. If the sink is higher than 560 millimeters (22 inches), VSP recommends providing a step stool.

# Ventilation

# Showers (43)
Shower heads must be cleaned and disinfected every 6 months. DISINFECTION must be accomplished with an appropriate HALOGENbased DISINFECTANT at 10 ppm for 60 minutes, or an equivalent CT VALUE.

# Clarification
Shower head cleaning and DISINFECTION must be recorded in a log and maintained on the vessel.
12.0 Administrative Guidelines

# Corrective Actions
Signed corrective-action statements (Annex 13.16) must be submitted to the VSP Chief by the master, owner, or operator. Corrective-action statements must detail each deficiency identified during the inspection and the corrective action taken.

# Clarification
Corrective-action statements (Annex 13.16) must be submitted to the VSP Chief by the master, owner, or operator within 2 weeks of receiving the final inspection report.

# Annex
Baby-only Water Facility

# Safety Sign
A safety sign must be posted by the facility with letters at least 26 millimeters (1 inch) high at each entrance to the BABY-ONLY WATER FACILITY feature that states, at a minimum, the following:  This facility is only for use by children in diapers or who are not completely toilet trained.  Children who have a medical condition that may put them at increased risk for illness should not use these facilities.  Children who are experiencing symptoms such as vomiting, fever, or diarrhea are prohibited from using these facilities.  Children must be accompanied by an adult at all times.  Children must wear a clean swim diaper before using these facilities.
Frequent swim diaper changes are recommended.  Do not change diapers in the area of the BABY-ONLY WATER FACILITY. A diaper changing station has been provided (exact location) for your convenience.

# Clarification
The letters on the sign heading must be at least 26 millimeters (1 inch) high, but all other lettering must be at least 13 millimeters (1/2 inch) high.

# Fecal, Vomit, and Blood Accident Response for RWFs
The clarification in 6.2.1.6.2 also applies to 13.8:

# Fecal and Vomit Accident (10)
A fecal and vomit accident response procedure that meets or exceeds the procedure provided in Annex 13.8 must be available for review during inspections.

# Clarification
CDC recommends a pH range of 7.2 to 7.5 for loose stool accidents for inactivating Cryptosporidium. This clarification also applies to Annex 13.8.