บทถอดความฉบับเต็มของ 🔥Controversial: Cyanuric Acid - How high is too high

chlorine free chlorine um what you 7:15 measure as free chlorine versus what what that's really telling us uh because that's really important to understanding 7:21 proper sanitation and we want to talk about current risk proposals that are out there um for some 7:28 of these codes and then um we're also going to talk about real world scenarios and data and 7:34 we really want to hear from you all so please interrupt us with questions as you have them um and let's 7:41 we'll get started um so like i said there's two codes of 7:47 interest um that we are going to point out to you today one is phtas ansi standard 11. 7:53 this code is driven predominantly by the phta recreational water quality 7:58 committee roy has served on that committee for a long time um and now he consults 8:05 um serves as a consultant for that committee tom and i have been actively involved and 8:12 participating but not as members um as guests with that committee um for the last year and a half or two 8:19 years i guess now um it's probably more like two years right tom 8:26 i guess he's needed almost almost two yeah um so and they there's also the standard 11 8:32 is also driven by recently added component structure to phda which is the standard writing 8:38 committees that they have for the various standards um but a lot of the people that are serving on that committee are also rwqc 8:45 members um then there's the cdc's model aquatic health code um if you haven't heard of that this 8:52 code is free um it's accessible online it is driven by the council 8:58 for the model aquatic health code um you can join anybody can join and become a member of 9:04 the cmac and that membership is a three-year membership because the cycle of the mac 9:10 gets edited every three years and we're going to talk about that both of these now have a what's called a change 9:16 request process and the ability for the public to um provide feedback there's mechanisms 9:23 for that but we're going to focus today on the mac and the cmaq 9:29 so um just want to add that the cmaq is a non-profit 9:35 organization the intent of it is to be the be the ones that contribute to the code 9:42 that is owned by the cdc um to put together a science-based code 9:49 and best practices tool for everybody to utilize um it is very very 9:56 exhaustive code i will say that compared to other pool codes that are out there um for us most of our focus is basically 10:04 on operations and water quality um for the purpose of this talk that's 10:11 you know we're going to focus on that in sanitization disinfection but there's a lot 10:17 more involved in that code um just in general um cmac 10:24 members you it's a very cheap membership i want to say it's anywhere between like 90 and 200 10:30 per individual not per company um and they allow being a member you get to 10:38 be involved you can provide public comments that are taken 10:44 into consideration um on different change request proposals that have been made 10:50

and a couple of recent changes this is going to come up again later from the last c-max cycle till now is 10:56 that they've increased the vote so the cmac body will vote on different change requests that have 11:02 been submitted and the vote has to be 61 or higher in order 11:08 to pass and this was a change that was made out of um necessity by the cdc they decided that 11:15 if there's any change requests that have been put forth that are very controversial and maybe not necessarily justified or 11:23 clearly that's what should be happening or they don't have issues with being adopted um they were getting 11:29 a vote that was below 61 and so that's why that was changed from 51 11:34 to 61 as a minimum it's important to note also that the vote from the cmaq body is weighted 11:40 50 public health officials and 50 industry since you guys are um a new category 11:47 thank you rudy who has worked with the um cmac board to get a category added to you guy for 11:55 you all um for membership there what is it called rudy is that the 12:00 pool service professionals i believe it's aquatic uh service professionals 12:08 the chunk that we were able to get but we do have we do have our own niche now so we are in there 12:13 i think you're in your own niche however i think you would get lumped in with the 50 percent industry vote weight 12:19 um where included in the aquatic sector the other half would be the 12:24 health department so we are definitely on the aquatic side okay so this is a health based code like 12:31 i said it's owned by the cdc and that is partially why it's um it's divided that way um 12:38 but that doesn't mean that you know it'll be that way forever and i i have heard from various folks 12:44 that 50 50 public health and industry split may not make sense and if you guys feel 12:50 you know differently you know you should be um sharing that and communicating that 12:56 because it's important you know and and they do want to hear from us in all of you so that is that is 13:03 the purpose of the council for the model called a kelp code um so some of these changes i'll just 13:10 tell you that tom and roy and i were all personally involved in the conversations that led to 13:17 multiple com public comment periods when there was previously only one that led to a minimum passing vote of 61 13:26 um those are changes since the last cmac cycle and they were they were spurred by some 13:32 change requests um that were very controversial that there was extra conversation that went 13:38 on and extra meetings that happened we were involved and so some changes can be made if you have a voice i just want to 13:45 emphasize that um present changes to the 13:50 cdc um are necessary to remain current with the latest 13:56 science so the cmac tries to coordinate that and prioritizes you know change requests 14:02 that are based on um science and data and and preferably peer-reviewed publications and best 14:09 practices um and then this is just this

is just a code so it has to be adopted by your 14:16 local authorities having jurisdiction and by states and different inspectors 14:27 okay so um c-mac um and i'm now going to talk about 14:34 they have they also have in the c-mac special ad hoc committees um one of those 14:39 is a chlorine stabilizer or ad-hoc committee it's the only one i'm going to talk about today but there are different ones out there 14:46 um it was originally organized by michael beach of the cdc and previous cmac director doug sackett 14:53 in late 2005 early 2006 and it was the goal was to have a group 14:59 of experts come together to analyze existing data on cyanuric acid and make different recommendations 15:05 for the code um 2016 not 2006. oh i'm sorry 15:13 2016. i apologize um late 2015 early 2016 that's the typo 15:18 um and the original members um were like i said hand-picked by 15:25 michael and doug um and they were designed that was by design to provide the right 15:31 balance of expertise and balance in terms of interest and um you know favors 15:39 in terms of you know potential bias on these issues so those members include dr ellen meyer of 15:45 um now segura formerly archlangela and innovative watercare and dr sam pickens who is retired from 15:52 axio westlake um tom one of our speakers today dr tom keegler he is retired from montana 15:59 oxychem at the time he was still working for oxy with intent to entire retire again he is a volunteer on this 16:06 committee and he's not a sponsored member for the work that he does um dr roy voor was um 16:13 previously bio lab and also a previous member of this committee richard fox um he often notes himself as 16:20 a private citizen but he has other affiliations for other companies 16:26 that are listed there and then dr chip blatchley of purdue university and he is the one that 16:31 was assigned to be the chair by michael for this ad hoc committee um 16:36 some changes that have been made since the original membership so those are the original members um dr 16:42 laura supps um of university of wisconsin who has um some health care or health um 16:49 official background um she joined in uh fall of 2016. um 16:57 roy stopped participating and officially left um in late summer 2018 and 17:05 i um joined and sort of actively participated um over 17:10 the last year and i'm no longer actively participating and i'll get back to that in a little bit but 17:16 that's mostly because of all the controversy that's gone on okay roy take it over 17:26 okay many of you have seen this slide before this is based upon cdc information about 17:32 what kind of germs we're actually seeing in outbreaks in public pools and so we're talking about public pools 17:38 because there's almost no data on residential pools but in about 89 17:44 of the people that get sick in public pools it's crypto and we all know that you cannot control 17:50 crypto with chlorine but that wedge up there at the top are the other ones that are considered 17:56 readily controllable by free chlorine if there is more than one ppm 18:03 uh measured by a test kit you know and that includes pseudomonas legionella e coli shigella norovirus and giardia 18:12 so this is the numbers that we're facing and and the numbers haven't changed that 18:17 much for the last uh 15 years uh there is additional information that's come out since then but it is not 18:24 significantly different than this next slide jim 18:30 all right a lot of the conversation over the last three years with the ad hoc committee 18:36 uh and it came down to talking about giardia so what do we know about giardia in 18:42 swimming pool well the last data that we have from the united states 18:48 is the summary that came out from the years 2011 2012 and probably the data's a 18:55 little bit older than we like but if you stop and you think about it since then the cdc's been involved in ebola 19:03 and now they're involved in uh uh covet 19. so it's like so the data is not exactly 19:11 as current as we would like but it's still probably exactly the same trend so if we look at what data we have 19:17 there's about 32 000 cases of reported grt in the united states less than seven 19:24 hundredths of one percent is from treated swimming pools 19:29 turns out those 21 cases were all from the exact same pool and so there has never been a 19:36 documented case of giardia according to the cdc data when there was at least one ppm of 19:44 chlorine as measured by dpd in the pool so what do we have on 19:49 giardia and pools well we do not know how much giardia there is in a pool 19:55 we do not know how fast charity is killed in a swimming pool and we'll get into 20:01 this in a minute but there's no real data on 20:06 kill rates of free chlorine with or without cyanuric acid there is some data that's 20:14 privately held by one of the manufacturers in here but this is the 20:20 entire data set that we have available today that is solid and defensible 20:28 on giardia are you guys comfortable making decisions on that 20:34 kind of data that's really the question i want you to think about i mean 20:40 we one outbreak 21 cases and that's the best data that we've got 20:47 and the entire concept that of changing cyanuric acid 20:52 relies on a data set like this okay next slide i just want to point out 21:00 that the kill rates that we do have on giardia are for drinking water and not pools and that's all we have 21:08 next slide jim okay uh after you heard jim talk about the ad 21:15 hoc committee well after five years of digging and you know i mean you saw all the academic adventures on there 21:21 uh you know everybody on that original committee except for one had a phd 21:27 we know how to dig for data if it exists couldn't find the data on grdnpools 21:34 and so the group could not come up with a reasonable worst case 21:40 scenario that everybody could agree on and so to develop this model that you've 21:46 heard about you took one

study and multiplied it by another study and multiplied it by 21:52 another study but that also multiplies the errors 21:59 and so it came up with a model and when you actually looked at it 22:06 and you take this mathematical model and you put in there and if you plug in the current 22:12 parameters that are in the model aquatic health code that is 90 ppm of cyanuric acid 22:18 2 ppm free chlorine as measured by dpd the risk from giardia is not significant 22:28 that's where the written you know i heard this talk about all these ratios and everything that's where the 45 to 1 comes in so the 22:36 the model that everybody talks about says if you do it the way you're doing right now with the limited data we've got it's not 22:44 an issue but if you go back 22:49 and you say well we could use one bather per 15 square feet 22:55 instead of one per 20 square feet and we could turn the filter off and we 23:01 could keep the pool occupied at one bather for 15 square 23:07 feet 24 hours a day seven days a week 23:12 52 weeks a year 365 or 66 days per year then there is a 23:19 slight change in the risk and if you put those assumptions in 23:25 there you calculate how much cyanuric and acid you have in there and you have to lower the ratio to 20 to 23:32 1. my argument with this is there is not a 23:37 pool in the world that is occupied at 100 capacity 365 days a year 23:46 and if any of us is running a pool that's it that crowded we had one 23:51 bathroom for 15 square feet with the filter turned off 23:56 the health department's gonna close us down anyway it's illegal to run a pool that way and so i 24:04 you know why i'm pissed off about the whole thing and i'll be honest i'm pissed about this it's 24:11 to get to that number you are running illegal an illogical conditions 24:19 it doesn't make sense i've been looking at the microbiology for 25 years 24:26 this is not the biggest threat but the model says it's the biggest threat the two threats 24:33 are crypto and not keeping one ppm of rechlorine in the 24:38 in the water that's what the data says the model is not reflective of what i see in the 24:45 real world that's my background jim 24:50 or tom europe let's be one thing the mac 24:58 is a is is lacking in and and the ad hoc committee has introduced change 25:04 requests for is is properly defining uh some of the terms around 25:10 measuring chlorine and and so the mac defines free 25:17 available chlorine uh or fac as the sum of hocl 25:22 and ocl minus and and that's fine and dandy or is properly defined 25:29 but then they go and use that everywhere in the mac as though that's 25:34 the number that you measure which is incorrect so the ad hoc committee is introducing this 25:42 term dpdfc to find the available chlorine that you 25:48 measure with a test kit as free chlorine you know a test kit based on dpdf 25:55 dpd uh and this is then the the free available 26:02 chlorine hocl and ocl minus plus the available chlorine that's bound to the cyanuric 26:08 acid ring and if you're looking at an outdoor pool 26:13 that's stabilized running one two three parts per million 26:18 available chlorine and 20 to 50 or 90 parts per million 26:25 cyanuric acid only a small fraction of the dpdfc that you measure 26:31 is really fac and so those are two very different values 26:38 and the mac just completely seems to equate the two so uh the mac really needs to be 26:45 changed to reflect that the mac also didn't define total 26:50 chlorine and combine chlorine uh adequately and we introduced uh definitions for those you know what 26:57 those things are next slide i just want to add that from 27:02 this point on you're going to hear us reference dpd fc or measured free chlorine 27:08 so from this point forward okay is there any questions on that what that term means that's that's the reading that you 27:14 actually get from your test kit uh we also define cyanurate bound 27:21 chlorine as the available chlorine which is bound to the cyanurate ring that actually exists in solution of 27:28 several different compounds which are in rapid equilibrium and and 27:35 so the chlorine-bound cyanuric bound chlorine actually dissociates to release 27:42 avail hocl when some free chlorine is depleted by reaction with demand so i i see the 27:50 cyanurate bound chlorine as a reserve of chlorine which allows you to release the free 27:56 chlorine when it's needed so you you know you've seen the equilibrium with with 28:02 hypochlorous acid uh the hypochlorite ion is in uh rapid equilibrium and and 28:10 with hocl and hocl is your active bicycle agent so that's 28:16 that that's the thing that really does your kill the same in the same way the the core 28:21 cyanurate bound chlorine uh is in rapid equilibrium with hocl 28:28 and can rapidly dissociate in a matter of seconds when more hocl is needed now there 28:36 are several like i said there's several different compounds in solution 28:41 and it takes several different equilibrium constants to 28:48 determine actually what's in solution to characterize that equilibria 28:54 but those determine what the concentration is for all the different compounds in solution including what the 29:00 concentration of hocl is o'brien and co-workers measured that in 29:06 1974. woman and alexander came in a couple years ago and 29:12 published the temperature dependence for two of the equilibrium constants that are important so 29:18 we now have some idea of how those equilibrium constants vary with temperature 29:23 [Music] next roy you're up well before we do that is 29:31 we've been seeing it flash up on my screen that we've got chats rudy are we are we not giving people the 29:37 opportunity to ask questions here no i think they're just being very polite at this time and 29:43 not wanting to interrupt so um i don't know who any of these people are 29:50 please please interrupt us we don't want to be blowing through information with you all and you guys 29:56 feel like

we're just talking at you we don't want any of that we want to hear um that we're making the information 30:04 um you know relatable to you all and relevant so if you guys have questions we we 30:09 definitely want to hear it feel free to please interject it's not a formal this is not a formal event well that's the whole 30:15 that's the whole point of it that's the idea behind it the goal in getting everybody together and 30:21 getting this group together and luckily these folks having some 30:26 availability for us is to um 30:31 get your feedback really um you know we can only take it so far without 30:36 information from the field and all of you have such a tremendous wealth of knowledge whether 30:42 you're watching uh whether you're you know attending right here you're gonna watch the video later or you're 30:47 checking us out on facebook as we roll along you all have a tremendous wealth of knowledge and that's extremely 30:53 valuable to um what we're working on and also with that 30:58 as i stated at the beginning we want to create more involvement in this as well um tom mentioned an area 31:06 where the cmac or the model aquatic health code was lacking i can tell you another area where it's 31:12 lacking is in his involvement from the 31:17 pool industry sector i know aquatics is a little bit better but as far as the 31:24 pool industry goes we don't have a great presence there but 31:29 we could so please definitely chime in ask questions 31:34 and i'll let jen get back to it just to clarify something rudy said 31:40 there is a good pool industry presence on the cmac but it's lacking in pool service professionals 31:47 that's where we're really lacking so there's there's other um involvement from other sectors of the 31:52 pool industry like manufacturers and builders that sort of thing but we 31:57 but we need to hear from service professionals so we're missing information from the field which is that's right 32:04 which is where the greatest intel comes from the front line and that's you guys at 32:10 one point there rudy i mean if you i sat in on most of the trc 32:16 uh discussions as they evaluated to change requests 32:22 and you could you could see that in a lot of the discussions the you know some many of the trc members 32:28 understood certain things about pools and and the discussion was intelligent 32:34 and then they got into other areas where it was clear they just didn't know what they were talking about and a couple of 32:40 experienced pool operators would have helped that discussion a lot so just to clarify for everybody what 32:45 tom's talking about the trc is what is called the technical review committee 32:50 these are people that have been selected to review all of the change requests 32:56 that have been submitted for the model aquatic health code in any given cycle um and they change for cycle they're not 33:04 always the same people but they have a huge influence on how we 33:09 see the cmac people vote um so

the technical review committee 33:16 will are supposedly have the resources to review change requests and then they provide a 33:22 recommendation on what they're telling counsel for a model aquatic health code members how to 33:28 vote and we usually see the vote results are usually very similar to those trc 33:34 recommendations that's what tom's talking about yep okay roy take it away 33:42 okay so what do we know about kill data on giardia because that's the one that keeps popping out on on you know after five years of work 33:49 well uh the only data that's publicly available was done by the u.s epa water 33:55 division out of cincinnati and they developed what's called a ct table on there it was done in drinking 34:01 water did not contain cyanuric acid and they do it over a range of temperatures 34:07 in there and so the value that we normally use in pools is 34:13 at the ct value for giardia and that gives you a 99.9 34:19 kill so it's uh one ppm of chlorine will kill uh 99.9 of the giardia in 45 minutes 34:27 so you've been through a cpo course if you increase it to 3 ppm then your kill 34:32 rate 15 minutes if you increase it to 10 ppm it's in 4.5 minutes 34:38 so this was the data that was then used and incorporated back into the 34:44 mathematical model that came out of it like we want to point out it's drinking 34:49 water not poor water and there is not data from the epa 34:55 that involves cyanuric acid so it is an estimated calculation at best 35:05 and as a microbiologist uh i probably run as many kill studies 35:12 in the lab as anybody alive today on swimming pools and i can tell you kill data in the lab 35:19 is kind of like a two-year-old with a bad attitude it works some days and some days you're 35:26 in for a screaming fit i'm not very satisfied with relying upon 35:33 estimated data if we're making uh serious changes so this is another reason why i'm not 35:40 very happy with this whole approach right now yeah and roy i'm not real happy with the ct tables 35:45 i i don't think they took care of the ph effect very well at all i i think 35:52 epa's uh treatment of the data was was flawed too yeah so it's like 36:00 you got no data in one area and you've got marginal or poor data in another one 36:05 you're putting mathematical model on it and you're trying to predict what your two-year-old is going to do on a bad day 36:13 that's where we are i just want to add to that too that um 36:18 vince hill gave a talk this past week at the world aquatic health conference and one of the things 36:24 that he reviewed was some of the models that have been developed including the one that we are um discussing here and you know models 36:31 are only as good as the amount of data that we have to put into them and they are a good tool but they are certainly 36:37 not a replacement for additional research and um they like i said they're only as good as 36:44 the as the data that we have by which you know we we make them and design them by so um 36:52 you know like i said the model is a good tool it's a good resource it helps give us an idea but it is an estimate and we 36:58 will never no matter how much data we have we will never ever be able to have 37:04 no uncertainty or zero um uncertainty in any kind of estimation that's why it's 37:09 an estimate but there is a large amount of uncertainty which is the point that we 37:15 are making when we talk about giardia kill data because all these proposals are being predominantly based on giardia where we 37:23 are severely lacking data and we have marty kelly right now 37:28 stating that the ct tables do not account for ph or the effect of 37:34 cyanuric or percent of cyanuric acid if anybody wants to address that 37:44 or not we can just agree the ct tables that epa publishes 37:51 cover a range of phs and temperatures the temperature range is shown there 37:59 33 to 77 degrees fahrenheit they don't go any higher temperatures than that they do cover a 38:05 range of ph 38:11 and those are in the tables and when you actually look it's not exactly certain how many of 38:17 those were actually solid experiments versus estimated values because yeah the entire set of ct 38:26 tables is is basically epa's fit to a bunch of literature data uh it 38:33 it it's really their mathematical fit to a bunch of data that they put together what you're 38:39 really saying is we've got a mathematically modeled table that now we're sticking in 38:45 an another mathematical formula so now we're multiplying the errors every time 38:51 we get in another formula good question marty and then we're using that to justify the 38:57 need to reduce risk just thought i'd add that okay are we ready to move on 39:06 my screen's blinking with another comment rudy is that for us uh that's craig saying good point roy 39:13 okay so i'll keep you posted as they come up if um you'd all like kudos as we go 39:18 along i'll let you know when those pop up as well okay so part of the recent i guess 39:25 um spur in in sort of reigniting the controversy with respect to cyanuric 39:31 acid has been this model that we've been talking to you about um which like we said is based 39:37 off of giardia um and there has been a lot of risk 39:42 reduction proposals that have been made have been made um based on this um a lot of 39:49 misinterpreting in the paper as well but i'm gonna focus on the original proposal because these are 39:55 your experts in pool industry and i know everybody in the pool industry thinks of themselves as an expert 40:00 but the cmac chlorine stabilizer ad hoc committee members are very influential um 40:06 based on this rudy is everything under control i just 40:12 heard my voice talking to myself you're fine okay great don't welcome but get you psychiatric helplessness 40:19 thank you for that 40:24 um the original proposal which was published in the paper um was based on trying to develop 40:32 a set of assumptions or worst case of worst case scenarios to

the point where 40:37 in our opinion the worst case of the worst case of the worst case is no longer 40:42 um realistic or reasonable um and here are some of the worst case 40:48 assumptions that were made um it was based on a pool depth of only three feet 40:54 shallow pool um the ingestion rate and the frequency and exposure was based off of children 41:00 um we obviously would assume children are probably ingesting more pool water than most adults i would say um there 41:07 was a couple set of equilibrium constants um that there are available at the time we only had o'brien's 41:14 that's what was chosen for the paper they are different and that needs to be addressed because 41:20 they shouldn't be different um in addition to that um a couple other assumptions that were made as roy 41:26 mentioned was the 15 square feet high bather load which i will point out 41:31 is higher than what is allowed for what's called flat water in pools um per the current monophotic 41:39 health code requirement um in addition they also assumed no pool 41:44 filtration um i can't imagine a pool that doesn't have a filter 41:49 and i can't imagine why you would have that filter turned off if you're running the pool um the mac does require pool filtration 41:57 and does require a minimum amount of filtration um in addition to that the original proposal 42:03 um had the pool being open 24 hours a day 365 days a year a pool that never ever closes there is 42:10 no such pool and this led to saying that oh we 42:15 estimate our risk means we need to not exceed an operational ratio of cya to 42:21 dpdfc of 20 to 1. another aspect of this which we're going to talk some more about too 42:28 is the giardia introduction rate parameters part of the reason why they have some error 42:33 is they are based off of a fecal matter shedding rate from e coli data because we don't have any for giardia in 42:40 addition to that that introduction rate of giardia is um utilizes how much giardia concentration there is 42:47 in that fecal matter which we're going to talk about that because that's very vague we'll talk about that coming up really 42:53 quick jen um i have uh coming from the facebook side we have uh wayne ivey sich is now 43:01 um watching from facebook he says a pool welcome wayne he says a pool with no filter is a pond 43:08 uh rob matthews wants to know he's asking selected by who and what 43:14 qualifications do they have so i'm assuming he's referring to the ad hoc um 43:22 committee uh patricia carr says we're here and josh mall says that he's here and watching but i did not mention 43:30 my book yet and i should do that that i have a book and that everybody should read it pretty 43:35 much i mean i ad-libbed some of it but he said i should mention it so there you go okay so to 43:42 i can't remember now who asked which question but uh yes wayne i agree with you and uh part of the reason why there was 43:49 no filtration um done for that proposal is because they assumed that the effects of minimum filtration 43:57 would be negligible at best and that's not really the whole story i don't think there was enough digging done on that 44:03 um with regards to the members of the chlorine stabilizer ad hoc committee for the cmac um they were hand-picked um 44:11 i mentioned earlier they were hand-picked by michael beach of the cdc and doug sackett which is the former director 44:17 former director of the c-mac um and that was basically to have a balance and 44:22 expertise and opinion honestly in terms of you know uh biased experience um based on 44:28 background of you know a pro-cya versus an anti-cya um perspective um but also like i said 44:36 expertise was really part of that conversation and then consider some parties that were 44:41 considered to be neutral as well so that was the membership composition 44:47 and you will hear me call them the experts because i sometimes get tired of saying 44:52 the cmaq chlorine stabilizer ad-hoc committee members because it's a mouthful so um just know 44:58 when i say that that's what i'm talking about i know that we are all in a lot of ways experts but 45:04 that's what i mean it's not just for just for the purpose of being short um okay so i mentioned to you all that 45:11 the original proposal had those unreasonable assumptions um and if you make some adjustments again 45:18 this is a model which is an estimate which is based off of thinking that she already has the highest risk pathogen we have that's chlorine 45:24 sensitive in pools um but all those assumptions being had if we modify the bather load to be at least 45:31 consistent with the maximum bather load allowed per the current mac that's appropriate for this model you'd 45:38 be looking at 20 square feet for bather instead of 15 if you modify your pool to actually have 45:45 your filter on um we estimate that you will have a very very ultra conservative estimate of 45:51 30 percent grd assist being removed per pass with a six hour turnover which is your maximum allowable um 46:00 and that is based off of because we've gotten some criticism from that minimum 46:05 pool filtration assist removal adjustment that is based off of uh 46:11 filtration removal that james ambergee has done of cryptosporidium 46:17 cysts showing an average of 25 um cryptosporidium usus being removed 46:23 uh by a slow or sorry a fast fan fast sand pool filter um 46:31 and which is the least efficient pool filter that is out there and giardia cysts are about 46:36 twice the size um of a cryptosporidium cyst you would 46:42 really be pretty safe assuming that you're removing substantially more giardiasis per pass than you are 46:47 cryptosporidium cysts um and there is some giardia um 46:52 you know filtration removal data but that's associated with drinking water did i get that right tom 46:59 yes there is some data on drinking water filters but drinking water filters are 47:04 very different from a typical sand filter on a pool but

yes that data does show better 47:11 removal of giardia so another adjustment that we made and this was not part of the model 47:17 originally when the paper was published is we accounted to say the pool does close 47:22 it's not open 24 hours so we adjusted it to say okay fine it can be open every day but it's going to close every night 47:29 so we um did hours of operation at 12 hours per day and that accounts for diurnal recovery that you 47:37 see um and we assumed that you know in that diurnal a recovery 47:43 assumption we utilize the worst time of day um as part of the calculation in the 47:50 model um for potential pathogen concentration the last two hours that the pools opened 47:57 per day in any given day and with these modifications that that led to a new estimate in risk 48:04 associated with a maximum operational ratio of 45 to 1 48:09 rather than 20 to 1. so that's a huge difference and those were these were the only changes we made for 48:14 that so we didn't account for like i mentioned in the previous slide the issues that i alluded to with 48:21 giardia introduction rate um which has a big impact on estimating your risk of infection 48:27 there is a very high amount of uncertainty it's it's significant which is basically 48:34 an error associated with the estimate there is a factor of about plus or minus 5.85 48:41 times um and that was based on a statistical log normality done by the 48:47 lead author on that richard um this estimate is probably due to the 48:53 fecal shedding rate which i mentioned is based off of e coli data not giardia data um also the model the giardia 49:01 concentration in fecal matter does not account for what percent of that giardia um in the fecal matter 49:09 is viable versus what is not and then even from what percent of giardia is viable does not 49:16 mean that it will result in infectivity so percent infectivity is another area 49:21 where data is lacking so these lead to overestimates um potentially over 49:27 estimates of of giardia introduction rate in the model let's stop right there and look at that air factor 49:33 all right everybody out here has got a test kit and everybody out here runs calcium 49:39 here's the math if you run your test kit and you get 206 ppm on your test kit 49:46 that error factor means your your test could give you a reading as 44 49:52 or a reading of 1521 ppm of calcium 49:58 so that air factor that they're using to change the standard says your pool is somewhere between 44 50:06 ppm of calcium and 1521 ppm of calcium 50:12 that's the kind of variability in the numbers that we're talking about here 50:17 really really i have rob matthews on facebook wanting 50:23 to know um why there are so many assumptions being used and why not just use 50:31 scientific fact great question great question because nobody has gone 50:39 out and done the basic research we don't know how much giardia is in a swimming 50:45 pool so we had to take three different studies that were totally unrelated 50:51 that had a whole bunch of air in them variability that's a better terminology and multiply 50:57 them together and that multiplies your error and then we had to make assumptions on cyanuric 51:04 acid we had to make assumptions on temperature what are the first three letters in the word assumption 51:13 that's where we are yeah you love being a free agent um and be happy if your reading is 51:21 somewhere between 44 and 1521 51:27 that's the numbers you're dealing with guys i mean we we tried to do as good of a job as we 51:32 could to get data out of the literature and use data in the model that that was 51:38 was reasonable but particularly roy on the giardia data that isn't so 51:43 you know some of that is error in the measurements but a lot of this is this variability from person to person 51:50 too we're looking at a person that's infected getting into the pool 51:56 well it looks like we have wendy purser um suggesting that we draw our samples from the spas 52:03 on cruise ships before they're drained except 52:08 wendy giardia is not a pathogen in spots there are no fecal born 52:16 pathogen outbreaks in spas even on cruise ships well she did give another example but she 52:22 mentioned a brand so i'm leaving it out 52:27 but but roy i am not right as as when a person's infected as they get 52:33 through their disease they're shedding different amounts of giardia day to day 52:38 too and so there's there's just there's a very small amount of data and when you're taking a 52:46 small amount of data there's a very large variability into it and a lot of the data is not directly applicable 52:53 and so one of the slides we're going to get to in a couple of minutes is if you want to do this kind 52:58 of you know analysis you have to do a serious serious serious 53:05 big study and nobody's done it and so we don't know 53:13 i mean we do not know how much giardia is in a swimming pool today with or without cyanuric acid yep but 53:21 the only data that we've got is the outbreak data and the outbreak data says 53:26 it doesn't happen but it may be there it may be at such a small level that 53:34 it's not significant so we're trying to match up 53:39 70 years of feeding studies but done back in the 1950s on prisoners that's 53:44 how they calculated how much giardia people required to get and trying to match it up to the way we 53:50 run pools today and there's a lot of holes in our data and 53:55 you're seeing why i'm very frustrated because it's like you it's the numbers just aren't there 54:03 can't do it guys just can't do it so all these are really good points i'm 54:08 going to keep us moving along we're going to run out of time and i really want to hear from you all so um i just want to just kind of back us 54:15 up a little bit a few feet higher and say that this initial proposal is really what spurred and 54:22 reignited and then sort of sent the message that's now the perception of many now 54:30 very very wide

perception that we need to reduce risk because they now think um there's a 54:37 problem with risk of infection particularly as proteins together just in general now that we need to reduce 54:43 risk so the 20 to 1 ratio that was proposed that was based on these 54:48 um you know unreasonable assumptions that we've now reviewed and the the 54:55 factor error that i said of 5.85 x plus or minus was not done at the time 55:01 but they did note they did do a sensitivity analysis and they did assess that you know any assumption that you change 55:07 in the model any input parameter that you modify can shift the curve of risk estimation and therefore the 55:14 recommended ratio around um and they did know that and they knew that there was a high 55:20 uncertainty but yet these risk reduction proposals are still being made and 55:26 trying they're attempting to justify at the cost and impact to you all so right roy 55:35 take it and take it fast okay all right you're on you've all run pools 55:41 we run pools every bit of chlorine out there's got it's good aspects and there's bad ass backs on there 55:47 and it's like you have to know what you're using at the right time you work with it you manage it 55:55 after five years to select a committee hand-picked by cdc 56:02 and c-mac in there couldn't come up with definitive information on giardia 56:08 and so you're seeing the frustration what we need is real-world data and the 56:16 cdc the only data that we've got does not show giardia to be an issue 21 56:22 cases in the one period on there that's the total number of cases all 56:29 right to show a problem with giardia the model has to use illegal conditions 56:36 that would immediately get the pool closed by the department of health and run a cool 24 7 365. 56:44 it makes more sense just to slow the whole thing down go out and do what we call science 56:52 do actual studies in the lab to find out what the kill rates really are 56:57 and then go out to pools and collect water samples 57:02 that's the logical approach we need to be doing not running off on some mathematical model 57:09 that has got an error that's unbelievably big 57:18 all right tell you roy all right measure the giardia in the pool today 57:23 we've only got to guess resolve the discrepancy in the equilibrium models because it's like the 57:30 science shouldn't be there and these mathematical equilibrium this is chemistry this biology is all over the map 57:36 chemistry should be pretty clear-cut and which one of these two mathematical equilibrium you pick 57:42 makes a big difference we've got to resolve that mathematically while we're doing these cool studies we 57:50 need to look at lazy rivers versus wave pools versus hotel pools hotel pools on a saturday 57:58 night versus a monday morning in there so we need to get data 58:04 particularly as it relates to the impact of bather load when we're looking at those different types of venues that is a huge impact on 58:13 um you know risk and you know originally we started 58:19 talking about only e coli and enterococcus in the in the 1960s now we talk about a whole bunch of other 58:25 organisms in here we don't have much data on these other organisms maybe we need to do some basic research on that 58:32 and once we've got the data then we sit down do the whole thing again and say now we've got a mathematical 58:38 model now we could actually put numbers in and come up with a 58:44 good estimation because in science that's what you do you come out with a hypothesis that's what this model is it's a 58:50 hypothesis you go out to the field you collect the data you compare it back 58:55 did the model predict what it said it was if it does you keep the model if it 59:02 doesn't you change it that's what you do in science you don't run off and just 59:10 launch something because you've got some idea on paper and that's what's being asked to done 59:15 right now that's what they're trying to do at mac is just launch this idea with no science behind 59:21 it i think the next one's you jen okay 59:28 before we move on from this slide i'm just gonna add this is gonna come up here in a minute but most of the focus so far has been 59:34 given to a max operational ratio that is for routine operation um you know what you would set your 59:41 limits at if you will but then there's a different section in the model aquatic health code that talks about um 59:47 what warrants an imminent health hazard um that would result in either immediate 59:53 correction or closure of the pool um and there are currently no like 1:00:00 criteria um requirements that speak to efficacy for imminent health hazard 1:00:08 or the closure or immediate correction section and we need to look at minimum 1:00:14 disinfection levels as a ratio for that and and determine where to go from there because we don't have 1:00:21 any good science to guide us right now for that criteria as well 1:00:29 okay so i'm just gonna preface saying i i'm throwing up a big table at you guys i'm sorry um we're just gonna we're just 1:00:37 gonna try and get through it together these are the issues we wanted to make sure you had this information 1:00:43 um for you know the understanding the different proposals that have been 1:00:49 thrown out there that could impact you particularly as it pertains to cyanurates and i know this is a lot and actually there's three 1:00:56 slides this is only the first one um so like i said when i talk about the 1:01:01 experts i'm referring to the chlorine c mach chlorine stabilizer i thought committee members um we have over on the 1:01:06 left our vote recommendation um the second column was added for roy's benefit which 1:01:12 i'm going to get to in a moment each change request that has been submitted to the mac 1:01:17 has a change request number um the those numbers correspond to what 1:01:22 area of the code that it is a change change request for um i also have on there what says 1:01:28 current

proposal and i put current proposal because some of these change requests have been changed and 1:01:35 the proposal that you might see on the cmaq website might not be reflective of what you see written here 1:01:41 in my table exactly um this has to do with how you find the information in the cmaq website so i 1:01:48 wanted to make sure that i differentiated between current what's current um and then in the next 1:01:54 column noting for you guys certain change requests that have been revised 1:02:00 um that might not be reflective in the description on the cmac website the only way to look 1:02:06 at these revisions is to go into the technical review committee's evaluation form 1:02:13 and you can find out what you're voting on so if you vote on basically the description itself um 1:02:19 and you don't click into it you might think you're voting on one thing and you're actually voting on another 1:02:24 because um that revision is what you're voting on so um the next column is talking about 1:02:32 whether the experts agree on a particular item and then the trc recommendation 1:02:40 for how they recommend cmac members vote based on their evaluation and the 1:02:46 rationale that's being utilized just kind of a quick summary or my paraphrasing of the rationale for any given current 1:02:53 proposal whether or not the proposal has additional cost or impact to pool 1:03:00 operations um for justifying a risk reduction based on large uncertainty um 1:03:08 and i feel like these are areas to highlight for you for consideration in your vote and then there's an additional comment section so we're just going to 1:03:14 quickly go through them and i just want to practice by saying ellen meyer did an hour and ten minute presentation on most 1:03:22 if not all of these change requests um and i'm going to try and do it in like hopefully 1:03:28 five minutes so bear with me here um so before we get started i just want 1:03:35 to point out that you should pay attention to column number two which is on each one of the following three slides 1:03:40 um roy has something he wants to point out to you about that what i'm 1:03:47 going to say on that is when you look at the uh change requests that are put in by segura 1:03:52 they're all over the map i mean the ratios are different the limits are different 1:03:59 is this a scientific proposal they're putting out here or are they just throwing out ideas to 1:04:04 confuse the issue and you know figure out what they can get i mean it's like they're the ideas are 1:04:12 vastly conflicting with each other but they've all got their company name on them what the hell is going on 1:04:21 you figured that one out i'll just say this that i the that column notes not only just ones 1:04:28 that various employees of segura have submitted but also ones where they are um through ellen 1:04:35 meyer she is a member of the c-mac chlorine stabilizer ad hoc committee so that means that segura is involved in 1:04:43 that cr so

and so i just kind of did that because it's important to note that because in 1:04:48 some scenarios because of ellen's involvement in that group she is supporting a change request that 1:04:55 might be conflicting with another exchange request that she has submitted as an individual so just want to point that out um so 1:05:03 we do recommend adopting um some of these changes um the first one is about the 1:05:09 definitions which we've already reviewed the next two are about increasing the 1:05:14 testing frequency of cyanuric acid concentration in pools if you utilize stabilized chlorine 1:05:20 one proposal was to do it every single day the other proposal was to do it once a week that once a week proposal was 1:05:26 made by the committee um and they are in agreement on that 1:05:31 um then there is the secondary disinfection systems being 1:05:36 required for all aquatic venues and not just high risk venues this was submitted by roy himself 1:05:42 i think this is an important piece although it does have a cost impact to you all 1:05:49 um the definition for agitated water is important because it is inconsistent and it impacts how 1:05:56 people are interpreting bather load in the mac so tom submitted that one 1:06:02 the change request for a minimum disinfection residual of one part per million dpd fc 1:06:10 as opposed to one part per million fac and for that one part per million dpdfc to be the 1:06:16 same regardless of cyanuric acid concentration this is important because you can adopt this 1:06:21 if you're going to adopt a max operational ratio to align the concept you wouldn't 1:06:27 necessarily need to have a minimum of two parts per million measured free chlorine with one part per 1:06:33 million cyanuric acid so the this is that was where this change came from 1:06:39 um there is a max operational several max operational ratios that have been 1:06:44 proposed i'm going to start at the bottom of the page um bottom of the page is a max ratio of 1:06:50 two and a half to one cyanuric acid to dpdfc this was put in by john kelly 1:06:55 it's based on a 0.32 part per million hypochlorous acid concentration 1:07:01 uh this is ridiculously high we don't recommend that one ellen meyer submitted a 15 to one max 1:07:07 operational ratio based on the her arbitrary assignment of one part per 1:07:12 million monochlorine efficacy equivalence um 1:07:18 the next i'm going to skip kind of to the middle where you see the no in the middle of the page on the left 1:07:25 the cya group the expert submitted an original well some of them submitted 1:07:30 an original 20 to one that has now been revised to a max operational ratio of 30 to one 1:07:35 so you'd be voting on a 30 to one and we do not recommend that because that is again a risk reduction proposal all the 1:07:42 ones i've said for max operational ratios are risk reduction proposals that are based on a huge 1:07:47 amount of uncertainty insufficient data um large amount of error and that would be 1:07:54 fine if it didn't have a impact on pool operation and cost 1:08:01 so if there was no trade-off then sure if if there's if we can reduce risk and 1:08:08 make our pools healthier with no negative impact let's do it that makes sense 1:08:13 but they all have negative impact and their the uncertainty is just significant so 1:08:19 the science is insufficient to back that up um we need to reduce the error another 1:08:25 cr right below that is the max operational 50 to 1. that was submitted on behalf of some 1:08:31 members of the chlorine stabilizer at hot committee at that time that referred to tom 1:08:36 roy and myself for a max ratio of 50 to 1. this 50 to 1 is based off of the 1:08:42 previous mac addition limit of 100 parts per million for cyanuric acid which was reduced to 90 1:08:47 based off of the inability for you all to perform um dilutions 1:08:54 which we all know is kind of bogus so that's where the 50 to 1 came from it 1:08:59 came from equating the previous mac um limits of two parts from only dpdfc and one hundred parts 1:09:05 with cyanuric acid this is basically the same risk that we currently have of 45 to 1. 1:09:10 so we're basically saying we don't need to reduce risk and our previous limits were fine and that's where the ratio is that is 1:09:17 the max operational ratio that we are recommending to you um so 1:09:24 okay what did i leave out the next um one near the end of the page with the 1:09:29 last yes on the left there that we're recommending is an adjustment for the current 1:09:34 planaric acid limit of 90 parts per million to be exceeded up to 180 parts per 1:09:42 million if you are able to demonstrate the ability to accurately test 1:09:47 such a high such a higher concentration in pools this was a joint effort change request 1:09:54 it's been revised it originally was to eliminate the 90 now it's been revised to have the ability to go up to 180 and 1:10:01 that was jointly done with the experts as well 1:10:06 any questions so far 1:10:13 okay so this next one is a little bit more complicated um 1:10:19 there is a closure cr that has been submitted that has four components to it 1:10:25 um those four components can include the one part per million minimum dpdfc regardless of cyanuric acid which 1:10:32 we've already talked about but we're saying that should be operational as well as closure um there is currently not a maximum 1:10:39 cyanuric acid concentration for closure we have proposed that that be 300 that's 1:10:45 based off of the epa swim model of 305 parts per million 1:10:51 um toxicity uh which has a built-in safety factor of a hundred just 1:10:57 thought i'd throw that out there um the other part that we recommend that 1:11:03 was recommended to change was uh the fourth part i should i'm gonna skip to the fourth question 1:11:09 bless you was spas have a minimum uh three part per million dpdfc as 1:11:15 opposed to fac um basically fac is equivalent to saying we know we 1:11:22 want

higher minimum disinfection levels in spas than pools but if you translate three parts per 1:11:28 million fac um at the lowest it can possibly go in terms of ph and temperature within a 1:11:35 spa you're talking about having basically roughly over 100 104 times more hypochlorous acid 1:11:42 in your spa for truly free chlorine fac um as three parts per million than you 1:11:48 would in a pool i don't think we're saying we need 104 times more so but so we're saying change though to 1:11:55 dpdfc but harmonize it with allowing cyanuric acid in spas which makes sense um 1:12:02 because you already have a higher minimum disinfection and that information can be found on the next yes cr which says to 1:12:09 eliminate the ban of cyanuric acid in spots the third component of the closure cr at the top 1:12:15 this is one cr that has four different criteria so the last one is the third one i'm going to talk about 1:12:20 that is for a max ratio of 45 to 1. so if we're saying that you should have 1:12:26 a max operational ratio of 50 to 1 certainly a lower ratio for closure doesn't make 1:12:31 sense um this proposal was kind of pushed through within the experts when they 1:12:37 were discussing it back when lower ratios were being looked at 1:12:42 and there was no actual formal vote taken on this after all the other changes that were made so 1:12:49 they just didn't revisit this conversation and it needs to be revisited um we are proposing because of the issue 1:12:56 within the current model aquatic health code this cr because it's a package of four different criteria 1:13:03 does need to be adopted uh because if you don't then your max operational ratio 1:13:09 will become a closure minimum disinfection requirement so we would want to see this we would 1:13:17 want to say yes we should vote yes on this cr because it's a package but we really need to change and this is 1:13:24 how you can make a difference by putting a comment in saying this 45 to 1 for closure needs to 1:13:29 be changed to 150 to one and more work needs to be done there to refine the efficacy requirements for 1:13:36 closure as well but certainly 150 to 1 would be the equivalent of having 300 parts per million of cyanuric acid 1:13:44 and two parts per million dpd fc we certainly don't want to see us going up to probably 301 that's likely too high 1:13:50 that's where the 150 to one comes from um ellen also submitted the next change 1:13:57 request is ellen's submission for a max closure ratio of 45 to 1. again she submitted this cr 1:14:04 this is where you can vote for a closure of 45 to 1 without having to allow your pools to get up to 300 parts 1:14:11 per million of cyanuric acid um it's just kind of separating out the one criteria 1:14:16 uh we do not recommend that um also segura submitted another 1:14:23 um i'm sorry john kelly submitted another cr saying we need to eliminate the possibility of immediate correction 1:14:29 as opposed to just closing the pool so everybody has

to close no matter what when you don't meet any of those requirements um 1:14:36 we talked about the next one for the elimination of the ban on cyanuric acid and spas there's also a cr that's been been 1:14:42 submitted to banned cyanuric acid in indoor pools this cr 1:14:47 um i don't know who has submitted it but it is um not there's insufficient science 1:14:54 that justifies any kind of need to ban um cyanuric acid and indoor pools 1:15:01 and it doesn't really address uh potential impact of cyanuric acid in indoor pools 1:15:06 from windows sunlight exposure um so we do not recommend that one there 1:15:13 is a requirement there's another cr that's been submitted um by segura again that requires 1:15:20 immediate correction or closure for any exceedance of cyanuric acid anywhere in the code 1:15:25 um very arbitrary and not really justified with the science at 1:15:31 this time and then there's another cr that ellen submitted that says we should add 1:15:37 theoretical peak occupancy to the closure section because it's already stated elsewhere in the code that you 1:15:42 can close based on that exceedance so it's just a matter of also including it in the relevant section 1:15:49 any questions about this before i move on 1:15:54 okay and the last set of change requests that are related to um to cyanuric acid that have been 1:16:03 submitted for the code are various the first three are all related two of which by the way have been 1:16:09 submitted by segura but the first three are all about reducing the cya limit of 90 the current 1:16:14 limit of 90 down to 25 40 or 60 um and 1:16:20 we do not agree with any of these and the last one is to add cyanuric acid effect 1:16:26 to training information and that does affect you all but the information that they put in 1:16:32 that change request is only talking about pools that have cyanuric acid concentration between one and ten parts per million 1:16:37 there aren't any real pools that do that so that's really not really relevant and if they want to add cyanuric acid 1:16:43 effective training they need to reconsider how they're putting together that information it needs to include the ratio concept 1:16:50 that you've heard us talking about um and that's it i think that's the end 1:16:57 oh okay not the end so we've reviewed and thrown a lot of information at you all and i'm 1:17:03 really grateful for you guys attending at the very very late notice um if it wasn't obvious from all these 1:17:11 different changes that are extremely controversial that are out there right now on the table um they're they're all 1:17:19 going to impact all of us and and you guys are included in that and you should have a voice 1:17:25 so we're really looking for your help um to have this balance 1:17:31 with your voice included to talk about how these changes impact you all what you guys see um that 1:17:37 could be incorporated to improving our aquatics industry and making sure that any changes that 1:17:43 are proposed make sense that they um include the impact that you guys see 1:17:49 and that they're that they're adopted smoothly um and that the right things get passed so 1:17:55 we're encouraging you to join the cmac and get involved and we 1:18:00 we re you should really also consider providing feedback for phda standard 11 as well 1:18:05 um but we've thrown a lot of information at you we want to spend the rest of the time hearing from you all what you guys think jen what was the 1:18:12 cost again to join um the cmac so cmac membership cost varies depending 1:18:19 on at what point in the cycle the current cycle that you join um right now i believe the cost is 190 1:18:27 per individual um starting i believe sometime next year i believe it will go 1:18:34 back down and then you pay for that for three years so if you join late in the cycle which 1:18:41 is right now because it's late in the cycle then it costs more than if you join at the beginning of a three year cycle 1:18:46 um so that three year cycle will start over i think sometime next year and then it'll cost less than that 1:18:55 by a good margin and it will be a three year membership so i know um this has been quite a bit 1:19:02 of information and for a lot of folks um you know 1:19:07 the first time they're hearing of some of it and i think if we have a means if not right now 1:19:12 that's fine we can add it as a as a comment later a means for post 1:19:19 uh presentation feedback um an email something along those lines i have got 1:19:25 received a couple of messages stating um that right now they're just trying to 1:19:30 digest and we don't know exactly what to ask we'd love to ask questions but this is a lot 1:19:36 so um if we can come up with something like that like i said it doesn't have to 1:19:42 be right this second because i can always add it later on but for an avenue for that i think that 1:19:47 everybody here would um appreciate that although if you do have a question right now i don't 1:19:53 want that to um make you hesitate i'd like to get 1:19:58 that out there and give everybody a shot to answer while we're all here live and in person as well um 1:20:05 so i think that's where we're at now in asking for additional questions same thing for those of you following 1:20:11 along on facebook i can see those so i am a little i'm a little bit slower in getting to them but if you guys post 1:20:17 questions if you're watching along live on facebook i can make sure that i um as we have done throughout this get 1:20:24 those asked um again the whole goal of this is to encourage participation uh jen 1:20:31 roy and tom um were kind enough to bring their presentation to us 1:20:38 um and present the facts and give you guys an idea of what's going on um we definitely would like 1:20:46 um ideas from you guys you you're you know you're 1:20:52 the you're the missing link um the folks in the field uh the intel that we don't have um so 1:21:00 that's where i'm at i'm gonna shut

up now if anybody wants to ask questions please definitely do so i 1:21:06 don't know if any of the uh rest of the three had anything they'd like to add to that rudy i want to add 1:21:11 one more thing so part of the reason why this was scheduled at such late notice because tomorrow 1:21:16 is a very important day tomorrow marks the beginning of the triennial cmac conference um and so if 1:21:24 you feel uh moved by the information that we've shared with you today and you want to get involved i'd 1:21:30 strongly encourage it um registration for the conference is free 1:21:36 if you have a current cmaq membership and we've already talked about that cost and how that works as well 1:21:41 so if you are currently a cmac member or you want to join and become a cmaq member 1:21:46 you get to go to the conference for free registration is free um and the reason why the conference is 1:21:52 so important is because currently based on the the policies of how the cmac 1:21:57 is being handled and how changes the code can be impacted is there there is some sort of mechanism 1:22:04 that allows conference feedback to be incorporated into the right path forward so if you do join 1:22:11 and you speak up at the conference and or you submit public comments um all of that can be taken into account 1:22:18 and can impact the vote and impact these changes that are currently on the table that 1:22:24 affect us all so that's why i wanted to try and meet with you guys at such late notice and 1:22:30 i apologize uh rudy has talked to me about joining you all and getting in front of you all 1:22:35 um for many months and i we should have done this sooner but i'm glad we're here today and i'm glad we're having the 1:22:41 conversation so again the cmac conference starts this week it's the rest of the week wednesday thursday 1:22:47 and friday we're going to be reviewing all these change requests there's going to be um there's going to be a public open 1:22:52 forum as well during that schedule and you'll get to hear a little bit more about some of these change requests from 1:22:58 various trc members um and also there'll be some caucuses 1:23:03 which is like subgroups that will be um where we can have more conversation with our different categories of 1:23:09 membership so now i'd like to open it for questions 1:23:16 and feedback we want to hear your guys's thoughts what do you guys think about all of this may not have a question but you just have things you want to share 1:23:22 most of you are muted right now so if you do want to ask a question make sure to unmute your mic and then just go for 1:23:32 it 1:23:39 i think we've got chat flashing at us rudy great to see you all i have to leave oh 1:23:48 wendy's building a house congratulations wendy um adam hold adam holbrook he is um he's a cmac 1:23:54 member he's encouraging folks to get out there and vote um scrolling along here we pop over onto 1:24:02 rob Talking Pools 🥤 Aquatic Facility Training & Consultants 5 / 13