February 21, 2025: the state of cold plunge

Good Morning,

One of the management consulting services we offer is writing documents (procedures, hazard assessments, dosing charts, reference guides, etc.) to operate aquatic facilities. Most people are qualified to write these themselves, but this usually comes up specifically with 1) a new facility seeking an operating permit, or 2) an existing facility at risk of losing their operating permit due to violations resulting from major gaps in operations.

Last week I was working with a client opening a wellness spa. This will include a variety of services: massage, hot tub, salt room, cold plunge, and a European feature called river walking.

In the final push to get this facility open, I sat down with cold plunge literature to figure out the basic way to disinfect a basin being maintained at a colder temperature. Here's a couple of things I learned. As always, these are my opinions based on research for one province and should not constitute a replacement for regulatory guidance in your jurisdiction or existing protocols.

1) Lots of provinces have outdoor spray parks, splash pads and wading pools that may not have a cooling element, but they lack heating elements. So although structurally they look quite different from cold plunge, there are precedents in many jurisdictions for operating "public pools" with cold or unheated water.

2) Lots of organizations have, ad hoc, created their own "cold plunge" system by retrofitting a smaller basin (e.g. hot tub/spa) with a chiller. Whether officially or privately, if you do a Google search, you are likely to find a lot more cold water facilities that your local health authority may be aware of or regulate. Key words like Nordic cycle, European sauna, hammam, Russian spa, etc. helped me discover many facilities I will not be patronizing.

3) We know from Chapter 13 (Spa & Therapy Operations) in the Certified Pool Operator (CPO textbook, that warmer temperatures pose increased risks due to accelerated bacteria growth; chlorine destruction; heavy bather load; smaller volume of water; etc. It makes sense to want to apply the same characterizations and caution to cold water, but there is currently no data. I emailed Dr. Roy Vore, a leading researcher in bacteria and the float tank industry and he confirmed "Katie, there is NO data." We need studies completed right away.

The procedures I ended up writing account for the potential for increased risk, but also do not pose an unfair burden on the new, well-intentioned operator relative to existing bad operators. The only references I came across for current guidance are as follows:
2024 MAHC Code (5th Edition) – 12/16/2024 [204 pages] 
2024 MAHC Annex (5th Edition) – 12/16/2024 (Revised 02/04/2025) [250 pages] 
Chen, T. Cold plunge tanks: Considerations for environmental public health. Vancouver, BC: National Collaborating Centre for Environmental Health. 2024 April.
Frequently Asked Questions: Cold Plunge Tanks and Pools

All of this to say, do I think there should be regulations? Yes, as a variance category; not as a pool or spa. Are there currently any operating or building code regulations right now in 2025? Probably not. But, if you are building one of these basins or projects, you need to look at ahead to what the standard of care will be. This is not an opportunity to stick your head in the sand and say "I don't have to do that," but consider what may or will be required in future regulatory revisions for public health and safety.

An industry news roundup from this week -

Hawaii Family Sues USA Swimming, Local Pool, and Swim Club Over Daughter’s Drowning
Swim meet warm ups are my worst nightmare because it's always been acceptable to not be able to see the bottom of the pool.

Sylvan Lake pool to get new upgrades thanks to grant dollars
"While users may not see flashy, 'on the surface' upgrades, this grant will allow us to move forward with a major project that is needed to keep the pool fully operational." $620K is what it costs sometimes to keep your pool open.  

Former Child Star, Who Played Cora in Titanic, Reveals Why This Heartbreaking Scene Was Cut from Film
The news story is not the story, but the (CONTENT WARNING) deleted clip on YouTube reminds me that Hollywood is still too kind to audiences about the reality of drowning. While I understand why the scene was cut, it could have had a real impact on conversations about drowning.

1,500-Year-Old Cistern Near Hagia Sophia Turned into a Spa
I do not take lightly or condone illegal renovations of national historic sites, but this is such a beautiful concept, I hope someone builds it LEGALLY. I went to Aire Barcelona a few years ago, and it was a highlight of the trip.

Kentucky bill aims to address property rights for people who rent out their pools
I haven't shared my opinion on Swimply fighting efforts to regulate residential pools rented for commercial purposes because it's an issue that long predates this newsletter. To quickly catch you up, Wisconsin backed down from regulation after Swimply sent their lawyers. On paper, Palm Springs, CA banned Swimply rentals as have individual towns in New Jersey and counties in New York. This information is hard to find openly because - in my opinion - Swimply is so aggressive with their legal team & lobbyists.

To sum up my opinion: I don't think these pools need to be at the same level as your local YMCA, but there can't be zero oversight or permitting...if only due to the hazard of entrapment (there is no requirement to retrofit a residential pool with a VGBA drain or suction outlet cover.) People will cut corners to make money. ICYMI, there has been at least one documented drowning fatality at a Swimply rental.

Kentucky may not be a heavyweight in the residential pool sector, but I appreciate that a state is willing to set a precedent we all need to keep regular people safe.

Five charged with assaulting lifeguard at Melbourne pool
Actions should have consequences.

For years, a Sunset roller-skating engineer has built free benches
When I worked at a municipality here in Alberta, I lost faith in humanity when the Parks & Cemetery Supervisor reported during a leadership meeting that she was "still having issues" with a local service group who refused to stop making and erecting wooden benches FOR FREE AS VOLUNTEERS.

I understand there are risks to everything in life, but can we please not throw the baby out with the bath water? Sometimes staff inconvenience is justified.

Quebec is getting a massive indoor waterpark and it's just 1 hour away from Montreal
Before you get too excited, this project has been on and off for five years.

This week's winner for stupid, unsafe water-safety behavior on social media goes to this post from a family who has repeatedly been in the news cycle over the last five years for many posts that viewers allege are unsafe and/or potentially exploitative

Thanks for being here.

Katie Crysdale
Lakeview Aquatic Consultants Ltd.