Surf Venue Guidance

Background

Surf venues have emerged as a new and innovative way to enjoy recreational water activities. These large-format aquatic venues (e.g., one quarter- to multiple-acre surface area) pose distinct challenges that cannot be addressed in the same manner as a typical swimming pool. Several of these venues are operating in the United States, with more planned for future construction.

This interim guidance addresses health and safety issues that aquatic sector and environmental public health practitioners should consider when these venues are proposed for their jurisdictions. This guidance is based on current science and best practices and addresses design, construction, operation, and management recommendations that are specific to surf venues. The recommendations ensure proper filtration, disinfection, and management of the water and identify ways to reduce the risk of illness and injury, including drowning. Unless addressed below, please refer to CDC's Model Aquatic Health Code (MAHC) for guidance on the design, construction, operations, and management of public swimming pools and other aquatic venues.

Definitions

Bathymetry means the surf venue basin floor's shape and slope, which are critical components of generating traveling and surfable waves in surf venues.

Night surfing means surfing in a surf venue from 30 minutes before sunset to 30 minutes after sunrise or during periods of low illumination.

Preoperational surfing means surfing — after the first preoperational inspection and before subsequent preoperational inspection(s) and opening to the public — to help designers and builders to adjust waves, etc. before handing the surf venue over to the owner.

Surf venue means a large-format aquatic venue (e.g., one quarter– to multiple-acre surface area) dedicated to surfing on a surfboard or other similar surfing or wave-riding device, with bathymetry and equipment that generate traveling and surfable waves (mimicking those in oceans), and used only by surfers (i.e., not by bathers).

Surfer means a person at a surf venue who has contact with water either through spray or partial or total immersion, surfs on a surfboard or other similar surfing or wave-riding device, and can be exposed to contaminated water or can contaminate the water.

Surf venue design and construction

Surf venues will likely deviate from the required provisions for typical pools. An authority having jurisdiction (AHJ) might require a plan to be submitted and reviewed, or they might require variances. A plan review or variances might also be required for any substantial renovations to a surf venue.

CDC recommends following these surf venue guidelines, where not in conflict with AHJ provisions:

Design and construction

• The AHJ may provide an alternative mechanism for submitting detailed scaled and dimensional surf venue drawings if they include intellectual property.
• The surf venue design report submitted for approval should include a computational fluid dynamics (CFD) model for each surf venue to demonstrate the elimination of dead zones.
• Drawings for each surf venue should include a schematic layout of chemical storage space(s) as delineated in MAHC 4.1.2.2.6.

Technical specifications

• Theoretical peak occupancy may not apply to surf venues.
• For each surf venue, peak surfer occupancy should be calculated by dividing surfer-accessible water surface area by the surf venue density factor.
  • Surf venue density factor = 1,000 ft² (92.8 m²) of surfer-accessible water surface per surfer.

Materials

• Surf venue wave break zones should be exempt from having a slip-resistant finish as delineated in MAHC 4.2.1.8 for water depths <3 feet (0.9m) and in MAHC 4.5.9.1 for zero-depth zones, except in areas designated for access or egress.
• Organic materials as delineated in MAHC 4.2.1.10 should be prohibited as a surf venue interior finish.

Equipment

• Where applicable, all equipment used or proposed for use, including surf venue–specific equipment (e.g., turbidity meter and wave-generating and biofilm-controlling equipment), should comply with MAHC 4.3.1–4.3.3.1.
• All equipment should be designed, installed, operated, and managed so that it does not present a potential for entrapment or injury.

Assessing water quality

• Surf venues should use turbidity meters to assess water clarity throughout and continuously.
• Surf venues may be exempt from MAHC 4.5.1.2.3, assessing water clarity from the deck.
  • If a reference tile or main suction outlet is used to help assess a surf venue's water clarity, then the reference tile or main suction outlets should be visible up to 30 feet (9.2 m) away in direct line of sight from the water surface when the water is in a non-turbulent state and bubbles have been allowed to dissipate.
• Surf venues may be exempt from MAHC 4.5.2.1–4.5.2.2, bottom slope parameters, except in areas designated for access or egress.
• Surf venues may be exempt from the MAHC 4.5.2.3, draining without leaving puddles or trapped standing water.

Surf venue access and egress

• Surf venues may be exempt from MAHC 4.5.3.1–4.5.3.3.1 access and egress parameters.
  • Access to surf venues should be controlled.
  • Each surf venue should have at least one Americans with Disabilities Act (ADA) designated access point.
  • Handrails, as required by the ADA for accessible entry, should be designed in such a way that they do not present a potential for entrapment or injury.

Zero depth (sloped) entries

• If trench drains are used along a surf venue's zero-depth zone, the trench drains should comply with MAHC 4.5.9.3–4.5.9.3.1.
  • A surf venue may be exempted from MAHC 4.5.9.3–4.5.9.3.1 trench drain parameters in zero-depth zones, if the recirculation system otherwise demonstrates sufficient surface skimming.

Color and finish

• Floors and walls below the water line should be white or light pastel in color such that a person is visible on the floor and algal growth, debris, dirt, and cracks in the surface finish can be identified from 30 feet (9.2 m) away in direct line of sight from the water surface when the water is in a non-turbulent state and bubbles have been allowed to dissipate.
  • Surf venues may be exempt from MAHC 4.5.11.1, assessing visibility from the deck.

Underwater benches, ledges, shelves, and swim-up bars

• Underwater benches should be prohibited in surf venues.
• Underwater ledges should be prohibited in surf venues.
• Swim-up bars should be prohibited in surf venues.

Depth markers and markings

• Surf venues should be exempt from MAHC 4.5.19.5–4.5.19.5.3, having depth marking at break in floor slope.
• Surf venues should have a marker with the range of water depths and a no-diving marker on a sign at each controlled access point.
  • These markers should be clearly visible to people accessing the surf venue.
• All lettering and symbols should be as for other types of depth markers.

Lighting

• For preoperational surfing, the minimum surf venue water surface lighting level should be maintained as follows: 4–8 horizontal footcandles (43–86 lux) for shallow water, 6–8 horizontal footcandles (65–86 lux) for medium depth, and 10–12 horizontal footcandles (108–129 lux) for deep water.
• The surf venue–specific minimum water surface and underwater lighting levels should be established during pre-operational surfing such that a person is visible on the floor from 30 feet (9.2 m) away in direct line of sight from the water surface when the water is in a non-turbulent state and bubbles have been allowed to dissipate.

Flow rates/turnover rates

• Surf venues should be exempt from MAHC 4.7.1.10–4.7.1.10.1 and 4.7.1.10.3.1, flow rate and turnover time parameters.

Granular media filters

• Surf venue water should be filtered at least as delineated in MAHC 4.7.2.2.1–4.7.2.2.5.

Decks

• A perimeter deck should not be required around 100% of surf venue perimeter.
  • A perimeter deck should be provided where surfers and aquatics staff access the surf venue.
  • Any surf venue perimeter deck should comply with MAHC 4.8.1.1–4.8.1.5.1.1.2 and 4.8.1.5.1.4–4.8.1.5.3.4.

Wing walls or peninsulas

• Surf venues may have wing walls/peninsulas or islands only to quell waves.
• Wing walls or islands should not present a potential for entrapment or injury or interfere with proper surf venue operation.
• Wing walls/peninsulas or islands should not be used by qualified lifeguards or surfers.
• Wing walls/peninsulas and islands should be exempt from MAHC 4.8.1.6.1.2 and MAHC 4.8.1.7.2, having a slip-resistant finish, respectively.
• Wing walls/peninsulas and islands should be exempt from MAHC 4.8.1.6.6 and MAHC 4.8.1.7.4–4.8.17.5, having depth markers, respectively.

Access

• Surf venue access should be controlled to prevent and deter unauthorized entry.

Hygiene facilities

• A drinking fountain, toilet, and handwashing station should be located no greater than 300 feet (91 m) walking distance from each controlled access point, if the surf venue is used by only surfers ages >5 years.
• A drinking fountain, toilet, handwashing station, and diaper-changing station should be located no greater than 200 feet (61 m) walking distance from each controlled access point, if the surf venue is used by children ages <5 years.
• Surf venues should be exempt from MAHC 4.10.4.2.1–4.10.4.2.1.1, basing the cleansing shower count on aquatic venue surface area.
  • A minimum of 1 cleansing shower per sex or 2 unisex cleansing showers should be provided for every 5 people until exceeding the sum of the surf venue's peak surfer occupancy and maximum number of aquatics staff whose duties include entering the water in a given shift.
• Surf venues should be exempt from MAHC 4.10.4.3.5, providing 4 showerheads for rinse showers per 50 feet (15.2 m) of beach entry.
  • A minimum of 1 rinse shower should be located at each controlled access point.
• Surf venues should be exempt from MAHC 4.10.4.4, allocating percentage of showerheads to cleansing showers and rinse showers.

Rope and float line

• The surf venue should be fitted with a rope and float line to restrict access to the caisson wall if required by the surf venue equipment manufacturer.
  • Rope and float line should not apply to surf venues as indicated in MAHC 4.5.19.5.3.

Safety

• A minimum of two emergency shut-off switches to disable wave action should be provided.
  • These switches should be clearly labeled and readily accessible to qualified lifeguards.
  • The primary shut-off switch should be located at a point constantly staffed by a qualified lifeguard.
  • The secondary switch(es) should be located to maximize effectiveness of the safety plan.

Surf venue operation and management

Operations

Preoperational surfing

• Preoperational surfing in the surf venue should be prohibited until an inspection approved by the AHJ demonstrates the aquatic facility, including the surf venue, complies with requirements.
• Opening the surf venue to the public should be prohibited until
  • Adjustments due to preoperational surfing are completed and,
  • An inspection approved by the AHJ demonstrates the aquatic facility, including the surf venue, complies with requirements.
• If the surf venue is not open to the public and drained as delineated in MAHC 5.4.1.1–5.4.1.1.3, puddling of water or trapping of standing water should be prevented using
  • Permanent measures (e.g., alter the bathymetry) when permanently closed, or
  • Temporary measures (e.g., sump pumps) when temporarily closed.

Surf venue structure

• Depth range markers and no diving markers should be maintained at each controlled access point.
• Lighting systems should be maintained as delineated previously.
• Surf venues may be exempt from MAHC 5.6.1.1.2, lighting for main drain to be visible from waterside.
• The surf venue should not be open if light levels are such that a person on the floor is not visible from 30 feet (9.2 m) away in direct line of sight from the water surface when the water is in a non-turbulent state and bubbles have been allowed to dissipate.
• The surf venue owner or operator should ensure glare conditions are assessed for qualified lifeguards assigned to specific surfers so that these qualified lifeguards can continuously view assigned surfers throughout the surf venue throughout operating hours.
• Night surfing should be prohibited unless light levels are provided as delineated previously.
• Liner integrity should be monitored for compromise.

Recirculation and water treatment

• The wave frequency should not be less than (but can be greater than) the wave frequency in the CFD model used to demonstrate the elimination of dead zones, if wave action is needed to eliminate dead zones.
• Surf venues should be exempt from MAHC 5.7.1.9–5.7.1.9.1 flowrate and turnover rate parameters.
• The turbidity should be maintained at <5 NTUs at all times.
• Combining the surf venue's recirculation and treatment systems with any other aquatic venue's recirculation and treatment systems should be prohibited.
• Surf venue water should be filtered at least as delineated in MAHC 5.7.2.1–5.7.2.2.6.
• The use of dyes should be prohibited in the water.
• Primary disinfectant concentration should be maintained as delineated in MAHC 5.7.3.1–5.7.3.1.2.3.
  • Cyanuric acid concentration should be remain at or below 15 ppm.
  • The AHJ may consider decreasing minimum DPD-FC (concentration of free chlorine as determined by N,N-diethyl-p-phenylenediamine [DPD]–based testing methods) concentration to 0.5 ppm, only when generating waves, all MAHC surf venue parameters are met, and the following parameters are met:
    • Neither cyanuric acid (CYA) nor stabilized chlorine should be used and CYA concentration should remain at 0 ppm;
    • Secondary treatment should be used;
    • Water monitoring frequency should be increased to every 2 hours while open to the public; and
    • MAHC 5.7.2.1–5.7.2.2.6 filtration parameters should exceeded.
    • The AHJ may revert to minimum DPD-FC concentration to 1.0 ppm, if pathogen transmission or other threats to public health occur with minimum DPD-FC concentration of 0.5 ppm.

Water sample collection and testing

• Surf venues should be exempted from MAHC 5.7.4.3.2–5.7.4.3.3, sampling location.
• Water samples should be collected as delineated by the water monitoring plan.

Water quality

• Turbidity readings should be recorded at the same time DPD-FC or total bromine and pH tests are performed.
• Surf venues may be exempt from MAHC 5.7.6.2, assessing water clarity from the deck.
  • If a reference tile or main suction outlet is used to help assess water clarity, then the reference tile or main suction outlets should be visible up to 30 feet (9.2 m) away in direct line of sight from the water surface when the water is in a non-turbulent state and bubbles have been allowed to dissipate.

Lifeguard- and safety-related equipment

• Free U.S. Coast Guard–approved life jackets that are properly sized and fitted should be provided and available at each controlled access point.

Policies and management

Staff training and staffing

• To be recognized as a qualified operator of surf venues by the AHJ, an operator should successfully complete:
  • An operator training course as delineated in MAHC 6.1.1–6.1.3.13, and
  • Training on the following topics:
    • Chemical safety laws and practices specific to storing and handling substantial quantities of chemicals onsite,
    • Biofilm, and why and how it needs to be controlled, and
    • Turbidity meter and wave-generating, biofilm-controlling, or any other equipment and features unique to the surf venue.
• Each surf venue should have at least one qualified operator onsite when open for surfing.
• To be recognized by the AHJ as a qualified lifeguard of surf venues, a lifeguard should:
  • Successfully complete training as delineated in MAHC 6.2.1.1–6.2.1.3.8 or an open water lifeguard course approved by the AHJ,
  • Possess current certificate for such training, and
  • Successfully complete
    • pre-service requirements as delineated in MAHC 6.3.3.3–6.3.3.3.6.2 and in-service requirements as delineated in MAHC 6.3.3.4–6.3.3.4.5, or
    • pre-service and in-service requirements as delineated by open water lifeguard course approved by the AHJ
• Qualified lifeguards should be staffed as delineated in MAHC 6.3.4.3–6.3.4.3.5.
• Additional qualified lifeguards may be assigned to specific surfers so that these qualified lifeguards can continuously view assigned surfers.

Emergency response plans

• Watercraft may be included as part of the safety plan. Watercraft powered by internal combustion engines should be prohibited.
• The accidental chemical release plan should include procedures as delineated in MAHC 6.3.4.5.6.1.

Water monitoring

• A water monitoring plan should be developed and implemented. At a minimum, the plan should
  • Establish water sample collection points throughout the surf venue so that testing results provide representative documentation of water quality,
  • Document water monitoring procedures, including water sample collection and water testing procedures, in writing and include a schematic of where water samples are to be collected (e.g., with global positioning system coordinates),
  • Train aquatics staff assigned water monitoring duties on procedures, and
  • Inform this staff of any updates to the plan.
• The water monitoring plan should be kept on file at the aquatic facility.
• The elements detailed in the water monitoring plan should be implemented and in evidence in surf venue operation and are subject to review for compliance by the AHJ at any time.
• The AHJ may require the submittal of the water monitoring plan for review and approval prior to opening the surf venue to the public or for archiving and reference.

Biofilm control plan

• A biofilm control plan should be developed and implemented. At a minimum, the plan should
  • Document in writing biofilm control procedures for all surf venue surfaces, including both
    • Accessible surfaces: Inspect daily and keep them free of biofilm as delineated in MAHC 5.6.10.4.2, 5.6.10.6.1, and 6.4.1.3.1
    • Inaccessible surfaces
  • Training of aquatics staff assigned biofilm control duties on procedures; and
  • Informing staff of any updates to the plan.
• The biofilm control plan should be kept on file at the aquatic facility.
• The elements detailed in the biofilm control plan should be implemented and in evidence in surf venue operation and are subject to review for compliance by the AHJ at any time.
• The AHJ may require submittal of the biofilm control plan for review and approval prior to opening the surf venue to the public or for archiving and reference.

Environmental and animal contamination control plan

• An environmental and animal contamination control plan should be developed and documented in writing.
• The owner or operator should hire contractors to implement environmental and animal contamination control plan or staff should implement the plan. If the latter,
  • Train aquatics staff assigned environmental and animal contamination control duties on procedures, and
  • Inform this staff of any updates to the plan.
• The environmental and animal contamination control plan should be kept on file at the aquatic facility. If contractors are hired to implement the plan, the contract should be kept on file at the aquatic facility.
• The elements detailed in the environmental and animal contamination control plan should be implemented and in evidence in surf venue operation and are subject to review for compliance by the AHJ at any time.
• The AHJ may require submittal of the environmental and animal contamination control plan for review and approval prior to opening the surf venue to the public or for archiving and reference.

Fecal/vomit/blood contamination response plan

• The operator should follow MAHC 6.5.2.1–6.5.2.2.2, response if fecal or vomit contamination of surf venue water occurs.
• The operator should follow MAHC 6.5.2.1–6.5.3.1.2, formed-stool contamination response, if the surf venue is at least suspected to be associated with an outbreak caused by Giardia or another pathogen with a contact inactivation value less than or equal to that of Giardia.
• The operator should follow
  • MAHC 6.5.2.1–6.5.2.3 and 6.5.3.2, diarrheal contamination response to hyperchlorinate, if the surf venue is at least suspected to be associated with an outbreak caused by Cryptosporidium and has no detectable cyanuric acid.
  • MAHC 6.5.2.1–6.5.2.3 and 6.5.3.2.1, diarrheal contamination response to hyperchlorinate, if the surf venue is at least suspected to be associated with an outbreak caused by Cryptosporidium and has 1–15 ppm cyanuric acid.
• The inspection frequency should be set as delineated in MAHC 6.6.1.3.

Inspection frequency

• The operator should correct violations or close surf venue immediately if any of the imminent health hazards as delineated in MAHC 6.6.3.1 number 1, 3, 4, 5, 6, 7, 8, 9, 10, 14, 15, 16, 17, 19, or 20 are identified, or if any the following imminent health hazards are identified:
  • Failure to provide the minimum disinfectant concentrations (i.e., free chlorine or total bromine) as delineated for surf venues previously,
  • Absence of any required lifesaving equipment,
  • Water turbidity exceeds 5 NTUs,
  • Total absence of or improper depth range marker and no-diving marker at any controlled access point, or
  • Number of surfers exceeds the peak surfer occupancy.