Swimming SPF

Treated water, open water and who owns the decision

Edition 2026-08-07Published by Northbank Media

Clubs and squads: outdoor training and the responsible person

Duty of careReviewed 7 August 20269 min readNo commercial links
Lane rope floats in a row on a clear surface.
Lane rope floats in a row on a clear surface.
The short answer

A club is an organisation running an activity, which brings duties whether or not it employs anybody. The committee owns the timetable, the coach owns the session, and the athlete owns their preparation. Outdoor training is where this matters most, because the timetable decision is made months before anybody is standing in the sun.

Swimming clubs occupy an awkward position. They are often run by volunteers, they frequently have no employees, and they nonetheless run organised activities for other people, including children, which brings real responsibilities. Many club officers carry those responsibilities without ever having been told what they are.

This article is about where those responsibilities sit for the environmental questions this publication covers. It is not legal advice, and clubs should take their own and should be affiliated to a governing body that provides guidance. In England that is Swim England.

The committee owns the timetable, which is the big lever

The single most consequential decision a club makes about outdoor exposure is when it trains. That is not a coach decision made at the poolside. It is a committee decision made when the season is planned, against pool availability, coach availability, school timetables and cost.

Because it is made months ahead and in a meeting, it does not feel like a health and safety decision. It is one. A summer programme that puts a junior squad in an outdoor pool in the middle of the day, twice a week, for eight weeks, has decided something significant about several dozen children's exposure.

The most important sun protection decision most clubs make is taken in a committee meeting in February.

The practical fix is to name it. A line in the minutes recording that the summer timetable was considered against exposure, and what was decided and why, converts a default into a decision. It also puts it where it belongs, in the club's risk assessment, per the Management of Health and Safety at Work Regulations 1999.

The coach owns the session within the slot

Within a fixed slot, a coach holds a great deal:

Coaches are the most exposed people at an outdoor session

A swimmer is in the water. A coach is on the poolside, in the sun, standing still, for the full session and frequently for the session before and after. If a club is thinking about exposure for its athletes and not for its coaches, it has missed the person with the largest exposure at the venue. See lifeguards and poolside staff, which covers the same point for employed staff.

What the athlete owns, and the culture problem

An adult athlete owns their own preparation and their own decisions. A junior athlete owns much less, and the gap is filled by the coach and the family.

There is also a cultural issue worth naming. Competitive swimming culture rewards not making a fuss: getting in when it is cold, finishing the set, not complaining. That culture is mostly a strength and it becomes a problem when it discourages an athlete from saying they are cold, burnt, unwell or unable to see because of glare. A squad where a swimmer feels unable to get out is a squad with a supervision problem regardless of how good the coaching is.

Naming that explicitly, in a squad briefing, costs nothing.

Indoors or outdoors

What does the club need to plan for?

Indoors

Indoors: air quality in the hall, particularly for squads doing high volume early morning and evening sessions, which means a lot of hours in that air. Water temperature for the session type. Changing arrangements and safeguarding.

Sun protection is not a factor and should not occupy planning attention.

Outdoors

Outdoors: timing, shade for poolside time, drinking water, reapplication stops, a shirt and hat expectation, and coach exposure.

For open water squads, add the whole of the open water section: water quality, cold, safety cover and the fact that the session is far longer than the swim.

Clubs running open water sessions

A pool club that adds open water training has taken on a substantially different activity and should treat it as one. The site is not assessed, the water is not treated, safety cover is a specialist matter, and the exposure profile is longer and harsher. This is covered in open water groups and supervision.

The commonest mistake is to run open water as an extension of the pool programme, with the same coaches, the same assumptions and the same paperwork. It is a different activity and needs its own assessment, its own briefing and its own cancellation rules.

Athlete health

Clubs should not be making clinical decisions. Whether an athlete with a skin condition, an ear problem, an infection or an injury should be training is a matter for that athlete, their family and a clinician. A coach holds what they have been told and acts on what has been agreed. If anybody is unwell at a session, the route is NHS 111, a GP or emergency services depending on urgency, and not a judgement call on the poolside.

Who owns this

The exposure of a squad training outdoors in summer

The swimmer

The athlete owns their own preparation and, for adults, their own decisions. Owns saying when they are cold, burnt or struggling, which requires a squad culture that makes that possible.

The session leader

The coach owns the session within the slot: where the squad sits, whether reapplication is scheduled, the shirt and hat expectation, drinking water, and the decision to shorten or move a session. Owns their own exposure too, which is the largest at the venue.

The facility operator

The club committee owns the timetable, which is the largest lever, and owns the risk assessment, the venue choice and the affiliation to a governing body whose guidance it follows. The facility operator owns the pool, the water and any shade that exists.

Where a duty attachesThe Management of Health and Safety at Work Regulations 1999 and the Health and Safety at Work etc. Act 1974 for the organisation's duties, with governing body guidance from Swim England. Sun protection guidance from the NHS, Cancer Research UK, sun, UV and cancer and NICE NG34, sunlight exposure: risks and benefits.

Volunteers, contractors and the people who are not employees

Club structures complicate the picture in a way that professional settings do not. A typical club contains employees, self employed coaches engaged on a contract, volunteer helpers, parent poolside helpers and committee members, all working on the same poolside on the same evening. The legal analysis differs across those categories and it is not something we are competent to set out.

What we can say is the practical point, which does not depend on the legal analysis. Everybody on that poolside is in the same sun, for the same hours, and a club that provides shade and rotation for its employed staff and not for its volunteers has not thought the problem through. The same applies to briefings, to drinking water and to who is expected to stand in the open for two hours.

Clubs should take their own advice on the legal position, and their governing body affiliation is the route to it. The organisational habit worth adopting is simpler: when a decision is made about exposure, ask who it covers, and then check whether that list is everybody who will actually be there.

One question a committee can ask each year

Before the summer programme is set, ask this in a meeting and record the answer: for each outdoor session in the plan, who will be outdoors, for how long, at what time of day, and what shade will be available to them. It takes ten minutes, it produces a written record, and it converts the largest exposure decision the club makes from an unexamined default into a decision that somebody has taken.

Summary

A club is an organisation running activities and it carries duties whether or not it pays anybody. The timetable is the biggest exposure decision and it is made in a committee meeting. The coach holds the session and is the most exposed person at the venue. The athlete holds their own preparation and needs a culture that lets them say when something is wrong. And an open water programme is a different activity, not an extension of the pool one.

Questions

Does a volunteer run swimming club have health and safety duties?

A club running organised activities for others carries responsibilities whether or not it employs anybody, and where it does employ or engage people the statutory duties apply directly. Clubs should take their own advice and should follow the guidance of the governing body they are affiliated to.

Who decides when a squad trains?

The committee, when the season is planned, against pool availability, coach availability and cost. Because it is decided months ahead in a meeting it does not feel like a health and safety decision, but for outdoor training it is the single largest exposure decision the club makes.

Who is most exposed at an outdoor training session?

The coach. A swimmer is in the water; a coach is on the poolside in the sun, standing still, for the whole session and often for consecutive sessions. A club considering exposure for athletes and not for coaches has missed the person with the largest exposure at the venue.

Can a club just add open water sessions to its programme?

It can, but it is a different activity rather than an extension of the pool one. The site is unassessed, the water is untreated, safety cover is a specialist matter and the exposure profile is longer. It needs its own assessment, briefing and cancellation rules, and advice from a governing body.

What about an athlete who is unwell or has a skin problem?

That is a clinical decision for the athlete, their family and a clinician, not a poolside judgement by a coach. A coach holds what they have been told and acts on what has been agreed. If someone is unwell at a session, the route is NHS 111, a GP or emergency services depending on urgency.

Sources

Cited because they are public, institutional and checkable. We publish no water quality figures or chemical concentrations of our own. This publication does not give medical, legal or engineering advice.

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