 I'm excited to be here. This is my first time speaking at FlowCon, so thank you very much for having me. So today we get to talk about the most fun thing, right, regulations, and the differences between guidelines and best practices and codes and standards, how to float the line. So the purpose of our talk today is so we can understand the differences between these various things so we can minimize the risk for your float centers. You guys don't want to have accidents or incidents, right? We're going to be making those health inspectors smile. So basically that's what this is about is just to minimize risk. So in order for us to do that, we need to understand some different terms. So let's kind of review that jargon. So we're talking about regulations. We're talking about things that are required by law. Things that are enforceable and mandated. This could be at a local level, state level, or the federal level. Standards usually are telling you how to meet your various requirements. They are not enforceable unless they are adopted into regulation. And they're usually higher in authority because they often require more rigorous review. Codes or model codes, I should be very specific here, is usually a set of rules that tells you what you need to do. They are also not enforceable unless they're adopted by regulation. But I should warn you that codes is often interchangeable with regulation unless it's specified as a model code. So if I confuse you, I'm going to apologize right now. When I say regulations or I say codes, I could actually be referring to regulations unless I'm talking about a model code. Guidelines. Those are typically lowest in the tier of authority. They're usually pretty broad. And an example of this is the North American float tank standard. Yes, it's called the standard because we're not confusing you guys at all, right? Who's confused, all right? You're not alone. The entire water treatment industry works this way. So where does best practice has been into all this? It is actually the best of all of these worlds, right? So we always want to make sure that we're following regulations because we have to. But sometimes things aren't regulated yet, right? And we want to tap into our other resources here. So this just shows you an example of various parties that produce these different types. Again, that changes that to model codes there to be specific. Regulations can be interchangeable with the word codes. A lot of states refer to their things and their country's stuff as codes. But that is regulation. So a few that you may or not be aware of. The Pool and Hot Tub Alliance is a prominent one in the pool and spa industry. You also have the American Society for Testing Materials. Those two bodies produce a lot of standards. Model codes, the CDC and the Council for the Model Aquatic Health Code produce the MAC. And these are just a few. The NFPA or the National Fire Protection Association produces fire codes. There's guidelines. You heard about the World Health Organization from Dr. Feinstein. There's lots of training offered by several different groups. And like today, what you're doing right here, this is education and training. So thank you all for being here. We all want to learn more and be better. OK. So let's talk about the difference between best practices and best available technology. Question. And by audio participation, because I can't see any of you guys, can you tell me by clapping who thinks that if you were using the best available technology that that is in line with best practices? Round of applause to who says yes. Round of applause to who says no. OK. Guess what? The answer is not necessarily. So best practices are, is it your question? Sorry, guys, is that best practices are things that are generally recognized as being like the most reliable, that gives really successful outcomes. They're usually like long time recognized before they end up being adopted into a guideline or standard or code. And especially before they become regulation. Best available technology is the latest technology. An example of this is AOP, right? Oftentimes it's available long before it gets the recognition that it deserves. Occasionally, but not often, something may not work out because it doesn't live up to the claims, the marketing claims for it. OK. So let's talk about some various regulatory agencies. These are just a few. I hope you're all part of the US EPA. You are, by law, required to comply with anything that's regulated by the EPA. So an example of that is bioscience, right? Anything that can disinfect or sanitize. And this is typically going to be enforceable to you all at the state and county level. OK. There's a few others here. Typically the Department of Justice, it hasn't branched into covering float tanks yet. The OSHA is required. You guys should all know about OSHA. Occupational Safety and Health Administration requires annual training, safety data sheets. And if you've had a CPO course, you know exactly what I'm talking about. The Consumer Product Safety Commission regulates different entrapment hazards. That's the part that's relevant to you all. I guess some of you may have heard of the Virginia Graham Baker Act for dealing with entrapment. We don't want to have anything happen to anyone. But right now that we know of, I'm at least aware of one float tank manufacturer that has been told that their tanks are excluded from being required to comply with Virginia Graham Baker. So that does not mean that we shouldn't do our very best to minimize entrapment hazards. And somebody who's a little bit smarter when it comes to float tanks than I am, at least in float tanks, gave me the tip that besides dream covers, you might consider having shower sensors in your float centers. If your floater is getting out of the tank and you have motion sensor in that float tank that made that motion sensor in the tank may not be reliable. But after they get out, if you have a motion sensor in the shower, you know for sure that that person is no longer in the tank and it is now safe to turn on the filtration system in the float tank to prepare it for the next floater. Okay. So a lot of times for your centers, you guys are required to have a lot of permits, right? You've got those required for construction-related activities. Those required by the Department of Health. If you're going to deviate from typical operations that can require what's called a variance approval. The permits required for the Department of Health usually have an annual renewal. And of course, if you serve food, then you will have a digital permit that you will need. There's also waste disposal permits. By a round of applause, who is being regulated for the disposal of your float solution? Anybody have float solution disposal requirements? No. Okay. Well, maybe not today, but maybe we will one day. All right. So let's talk about some various groups that produce standards and model codes. NSF International is a big one. Most of these are nonprofit, non-governmental organizations. And NSF does a lot of certifications and standards requirements for equipment or for chemicals. And things of that nature. You have United, sorry. You have UL and you have ASTM for various standards. We talked about that one. PHTA does ANSI certified standards as well as various codes that they produce. They're also responsible for the recreational water illness manual written by Dr. Royvor. And they provide the CPO course in manual. The NFPA has different codes for chemical storage and handling and various practices. And the CDC owns the model aquatic health code and produces that with the CMAC. They do have content that is specific to flotation tanks in that model code. Okay, some agencies for guidelines. World Health Organization has some guidelines for safe recreational water environments. This is mostly focused on pools and spas. The chlorine institute has a lot of educational materials to help promote safety with chlorine products. And of course you guys know all about the North American Float Tank Standard. Okay, talked about some of the training, folks. PHTA is the leader for CPO training. I heard we have 12 new CPO operators out there. Congratulations to you all this past week. Yeah, there is also the Aquatics Facility Operator excuse me, course that is offered by the NRPA and AOAP, the Association of Aquatic Professionals. American Red Cross also does training for Bloodborne Pathogens. And of course there's FTS, which you all know. And Roy describes Graham and Ashconn this way. What they do, per Roy, is they're responsible for inflicting his stories of feces on the float community. His words, not mine, it's white and red. All right, so I mentioned earlier the Council for the Model Aquatic Health Code. This is just a very, very high level overview of their process, which is pretty significant. And there's several different steps that are involved to modifying this model code, which happens on a three-year cycle. But I wanna point out that anybody can contribute to a suggested change in this code. You have to be a member to participate further than that. But I just thought I would point that out. All right, you guys can review that on your own time. So PHTA, you might know them, not real as you know them. They are the merging of two organizations, the National Swimming Pool Foundation and the Association of Pool and Spa Professionals previously. They produce various anti-standard, as I mentioned before. And they also have the International Code Council that they lobby to adopt these various PHTA standards. Including, for example, the International Swimming Pool and Spa Code, which is very prominent. So, used a big acronym here that I didn't define. Sorry about that. We're gonna talk about FIFRA by a show of applause. Who knows what FIFRA stands for? It is the Federal Insecticide, Fungicide, Rodenticide Act. This is what requires EPA to regulate our biosciences. So, wanna talk about the difference there. Key question for you all. What sentence appears under on every label of an EPA-registered biocide for the directions for use? Some of you guys have never heard this before. It is a violation of federal law to use this product in a manner inconsistent with its labeling. What does that mean? That means that if it's not covered under that label's directions for use, like it doesn't say you can use the product that way, you're in violation of the law. That's what that means. Very, very straightforward there. So if you have a public facility, what concentration of disinfectant should you use for your product on a pool or spa? This can apply to a float center as well. Well, let me put it this way. Think about it from who has the authority to shut down a facility, an aquatic facility? The EPA is not gonna come out there and shut you down. They don't have local field inspectors. So you wanna comply with your local and state requirements. That's what you wanna go by. All right, so just to give you an example of some of the different things to consider and the variations you're gonna see in terms of trying to figure out which answer is correct, got a little table here for you. So these are the pool codes for a few various states, the latest published version of the model aquatic health code and some biocide manufacturer labels from the EPA. Okay, this is just a few examples. You will see quite a variation in terms of the parts per million minimum free chlorine for a pool, the maximum free chlorine for a pool, the pH requirements, the stabilizer requirements, all these things and so many more are so variable and I found this to be very interesting because the pool industry has been well established. You'd think we'd be doing a little bit better by now but the answer is everybody's got a different answer. So I decided to take a look and I did an entire talk much larger than this one on looking at several different state codes in the US as well as other codes which is regulations and some other countries to see if I could find any trends, to see where there was room for improvement, how different places were doing things a little differently and what was working better for various places. So just to go over an example, I'm gonna go over an example of some of those for you all but before I do I wanna talk about two model codes that are probably the most prominent I would say out of all the ones that are available in the US. So there's the international swimming pool and spa code put out by PHTA. On the left hand side, it denotes which of those states have partially or in wholeness adopted those codes and the math that you see, that is for the model aquatic health code to show partial or majority or local level county kind of adoption. By large the ISPSC has gained a lot more traction and is more recognized. On the left hand side, the states that are highlighted in that table in yellow are the ones that I dug into for this project. All right, so the first thing I'm gonna talk about that is relevant to your float centers is beta hygiene. You all are doing an excellent job. I'm just gonna say that right now. You guys are doing an excellent job of float centers. Coming from the pool industry, I can honestly tell you that the shower in with the float tanks, it's absolutely necessary but it makes this part a lot easier for you guys. In the pool industry, this is a much bigger deal. We can't get bathers to shower before they get in the pool. So we try to do these things. These are some of my favorite visual aids to show them why they shouldn't be going to the pool if you're sick, why you need to shower, why you don't treat the pool as your bath toilet, right? As your bathtub or your toilet, right? And so the number of showers and bathrooms that you allow in your facility are important. I know a lot of float centers tend to have one bathroom and every room, typically every tank has a shower. Consider your business and whether or not you guys should have more bathrooms. We relax when we get in the float tank, right? Which means all our muscles relax. We really need to go to the bathroom before we get in the tank. Consider signages or signs like this for your facility and whether or not you should incorporate some social science innovation into your videos and your literature. By doing so, we will help contamination and prevent disease. Another thing that is very significant in the pool and spa industry that I looked at for various codes was bather load. And I know this is very different for you all, but I'm just showing here that there is a wide variation in this requirement for even just the 17 states I looked at and the few countries that I looked at. For water replacement, this one was mind boggling to me. Of these 17 states, absolutely not a single one requires any kind of water replacement. This was shocking to me. If you look at guidelines, they tell you that we should be having water replacement requirements when you have more than 1500 parts per million total dissolved solids at startup. And there's also this formula for spas, okay? Nobody's doing it. Nobody requires it in the U.S. You look outside the U.S. In fact, the World Health Organization has a very similar guideline that actually is very similar to that formula, at eight gallons per bather per day. But once again, almost nobody, or less than half of the countries that I looked at outside the U.S., excuse me, have any kind of water replacement requirement. This is a huge opportunity. Now I don't know as much about float tanks as you all do, but consider how often you're replacing your float tank solution. So filtration. Now once again, this is based on pool codes. It's a little different than what you guys are used to. But in the U.S., cryptosporidium is a huge problem in terms of disease. And since it can't be killed with chlorine, filtration is one of the biggest opportunities we have in the pool and spa industry to ward against this. And if you enhance your filtration in the pool or spa industry with any kind of enhancement that could be the use of coagulants, flocculants, a better, like a filter that has a higher bed height, something other than a very, very low grade, small sand filter, anything. Anything is considered enhanced filtration for this purpose. And when I looked at these various codes, I found that zero states of the ones I looked at had any kind of enhanced filtration requirement. Huge opportunity we're missing here. Outside of the U.S., once again, just under half of those countries had this kind of requirement. You guys have, for the most part, a lot of your equipment has pretty good filters on it. All right, so I wanna review a few scenarios with you all that you could come across at your float centers and kind of go through different paths you could choose in terms of how you handle it. Okay, so the North America float tank standard says that the best practice is to use hydrogen peroxide. Your website says our float tanks are disinfected by UVO zone and hydrogen peroxide. Is that statement correct? My round of applause, who says yes? Round of applause, who says no? The nays have it. Now here's why. Hydrogen peroxide cannot be used with the terms sanitize and disinfect. The reason for this is because these words are very important and what they mean, their meanings are very specific. And the EPA could come out for you guys if you have that in your literature, if you have it on your website. If you're consistently telling your patrons that hydrogen peroxide is your disinfectant. Technically, I know it's a word game, but that's how it works. So, UVO zone, disinfectant sanitized, you're good. Hydrogen peroxide, not so much. However, I will say that this technology, the use of hydrogen peroxide is a best practice and you should continue doing that. All right, another scenario. You want to get rid of that nasty scum water line when you're replacing your float tank solution. What EPA registered sanitizer or disinfectant do you use? Anybody shout something out at me? Anybody know? Okay, there aren't any that are out there that are specifically covering float tanks or pods or cabins. However, there are hard surface or non porous surface disinfectants and sanitizers. If you're using a pod with that hard surface, you could do that and you would be in line with the EPA label. So, the preferred formulas are generally speaking, alcohol and hydrogen peroxide wipes, but not sprays as quads because those are inactivated by high levels of salt. So, other things to consider when you're thinking about this. These are things that you guys should be talking about. So, learn from each other. What frequency do you do this at? Should it be based on how many patrons you have? How many are coming on certain days of the week? Maybe you have certain days of the week that are busier than others. How many volumetric turnovers are you doing in your tanks? How many do you do before the day begins, between floaters, after the end of the day, after your last loader leaves? All these things are relevant. So, this practice may not be regulated, right? However, consider something. If you have a health inspector that comes in and he sees something that he thinks is a health risk, if he finds biofilm, biofilm is a nice, cozy little home for a lot of nasty germs and pathogens. It protects them. If an health inspector finds something like that and says you have a health risk, you now have a finding. You wanna keep that from happening. So just consider that in your frequency and how you guys are running your centers. This is my personal favorite and I know Roy's favorite, right? Code brown, you have a code brown at your facility. All right? You diligently follow all laws and regulations, of course, but your state doesn't regulate float tanks. What do you do? You wanna follow best practices, right? What does that mean? You don't have any products that you know to use the directions on how to disinfect. Well, we talked about the hard surface sanitizers and non-course surface sanitizers, right? So that's one of your go-to's. But this is a fecal accident. What risk level could we be talking about here? Well, if that person had that accident, maybe it's a form stool, maybe it's diarrheal. Either way, a lot of pathogens could be there. Somebody could be sick. They may not even know they're sick. So you gotta consider your risk level, okay? At this point, you all should be thinking, what do I need to do to protect my floaters, okay? Not, what am I gonna do if I use this product in a manner inconsistent with the labeling at that point? Because the EPA is not gonna come after you, okay? So that's not your primary focus. In fact, Roy says, just so you all know, wants me to relay, that the likelihood of you guys getting in trouble with the US EPA is about the same as your chances of getting eaten by a shark, or a shark by lightning, or winning the powerball within any one five minute period, okay? So, the risk is what you gotta think about. What does your operations manual say? Have you adequately addressed this risk by your policies at your center? Consider cryptosporidium, okay? Very hard to kill. Diarrheal incidence is more typical with crypto. So like I said, you wanna make sure your practice is fed in with your risk level. There's very little information out there. Like I said, there's a little bit of information on the aquatic health code. I know there's some information on the float tank standard. You all are the ones that know float tanks best, not the counsel for the monoclonal code, not the pooled spa industry, not even the health regulators. It's you all, okay? So what do your best practices look like? Well, I talked to somebody who is a lot smarter than me, float tanks. And based on my understanding of how things are typically handled in the pooled spa industry, and considering the risk level that we're talking about here, my professional opinion is the best practice oughta look something like this. You drain that solution, you flush it out completely. You refill that pod with regular water, and you hyperchlorinate. That means getting somewhere between 20 and 40 parts per million of chlorine in that pod for a sustained period of time, depending on which concentration you choose. You want to make sure that you get all of that killed. You want any germ killed. That is the purpose of this activity. Then you drain it again. You hard surface sanitize, wipe that pod down, because the hyperchlorination might not have been enough friction to get everything. Throw away your cartridge or your filter. They're replaceable. It is not worth the $50 to try and scrub that one clean. Sometimes you can damage it. You try and chemically clean them really well. It's not worth it. After you've done all that, then you refill your tank, put salt, and you're ready to go. All right, bonus scenario. I love this one. Think back to the beginning of the presentation when we talked about what these different terms mean. Is this picture representing a code violation by a show of applause who says yes, by a show of applause who says no? Amazingly, the answer is no. But it is a violation of best practice. Let's just say, this is not good sense, right? We don't want to do this. What else is wrong with this photo? There are at least two more things that I can tell. Shout them out if you have them. I like the answer more than it. One is the left foot. Some wiring. That doesn't seem very smart to me. Another thing that I think is very wrong with this is, I don't know anybody but Dr. Roy Ward, who's extremely proud of being able to stomp on his own face all day long. Check out those socks, okay? Something very wrong with that in my mind. I don't know about you all. All right. So in summary, we need to share more. I know that this is all confusing stuff. Trying to understand the difference. Trying to figure out what best practices really look like. We are all gonna be better than where we share with each other. Consider getting some microbiological testing of your water, your solutions, okay? It's not very expensive. Get a certified lab, call them up. It's absolutely worth it. Send it in. We're doing that research. We got all that project. We've got that project going on right now. So please consider doing this. Also, if you'd like to just share your best practices and collaborate, I've heard through the grapevine that they are looking to add material for float tanks in the CPO manual and course. That could be extremely exciting. So please get involved. Please share. Please consider this testing. So I wanna thank you all. I know we're out of time for questions. But please note that if you have any complaints, please send them to the Complaints Department Head, Dr. Roy Vor, and he will take very good care of you and buy you a beer. I'd like to also give a special thanks to Dr. Roy Vor for his expertise and his help. Picture of him right here. Oh no, wait a minute. I screwed that up. That says Christian. I am very sorry in that name tag. Wrong photo. There we go. That microbiologist is telling you that he doesn't eat sushi. He lied. I got a photo right there. All right. Thank you all very much.