Anyone running an organised swimming activity should have a risk assessment. The Management of Health and Safety at Work Regulations 1999 require a suitable and sufficient assessment of the risks to employees and to others affected by the undertaking. That is a legal requirement rather than a paperwork tradition.
What follows is not a template and is not legal advice. It is a description of the shape a useful assessment takes, aimed at the person who has been handed the job and is looking at a blank page.
Why generic templates fail
A downloaded template lists risks that apply to swimming in general: drowning, slips, cold. Everyone already knows those. What a template cannot tell you is that this pool has a sudden depth change halfway down, that the changing village at this venue puts your group out of sight for thirty seconds, that the lifeguard here covers two pools, or that your Thursday group contains three children who cannot swim a length.
Those specifics are the assessment. Everything else is preamble. A one page document that names five things nobody would have thought of is worth more than a fifteen page document that names fifty things everybody knows.
If your risk assessment would be equally true at any pool in the country, you have not written one.
The shape: follow the group through the day
The most reliable structure is chronological, because it forces you to include the parts that are not the swim, and the parts that are not the swim are where most of what goes wrong happens.
| Stage | What to look at | Frequently missed |
|---|---|---|
| Travel and arrival | Route, drop off, road crossing, car park | The journey is often the largest risk of the day and is left out entirely |
| Waiting outside | Shade, weather, supervision, headcount | Outdoor exposure attached to an indoor session |
| Changing | Layout, supervision, safeguarding, other users, lockers, floors | Groups out of sight, mixed use with the public, wet floors |
| Route to poolside | Distance, surfaces, doors, whether the group stays together | The thirty seconds where nobody can see everybody |
| Entry to water | Depth, method of entry, order, competence check | Assuming stated competence rather than checking it |
| The activity | Supervision ratio, lifeguard arrangement, depth used, equipment | Who is watching the water while the leader is teaching |
| Exit | How, where, counted | The head count out, which is skipped more than the count in |
| Changing again and departure | Warmth, supervision, collection, handover | Handover to the correct adult, and children waiting to be collected |
The environmental part, which is our particular subject
Two environmental questions belong in the assessment and are routinely absent.
Indoors: air and water. What you will do if the hall is unusually strong smelling or the water is not clear. This is not a hypothetical: it happens, and a leader without a pre agreed answer makes the decision under pressure with a group already changed. The answer is usually straightforward: raise it with the duty manager, and if the water is not clear enough to see the bottom across the area you will use, the session does not run.
Outdoors: exposure, heat and shade. The time of the session, the shade available, whether reapplication is scheduled, whether there is drinking water, and what conditions would shorten or cancel it. See timing an outdoor session and an outdoor group session plan.
What environmental content belongs in this assessment?
Water clarity, hall air quality, water temperature for the group, floor surfaces and the changing environment. Plus the trigger for not running: if you cannot see the bottom, you do not start.
Also: whether the roof opens, because that converts the session to an outdoor one and the outdoor content then applies.
Ultraviolet exposure and timing, shade availability, heat, drinking water, scheduled reapplication stops, and the conditions under which the session is shortened or cancelled.
In open water, add the water quality check, the entry and exit points, the recall signal, the safety cover arrangement and the temperature.
What does not belong in it
- Water treatment parameters. Not yours, not something you can affect, and not something you should be writing numbers about. The operator holds this.
- Clinical management of anything. A risk assessment records that a participant has a condition you have been told about and what you have agreed with the family. It does not contain a treatment plan written by a session leader.
- Everything that could conceivably happen. A long assessment is a document nobody reads, which is worse than a short one.
- The operator's normal operating procedure. Reference it, know it, do not copy it in and do not attempt to rewrite it.
Hold what families tell you, agree what will happen, and act on what you have agreed. Do not decide whether somebody's condition is fit for swimming, do not adjust anybody's medication, and do not form a view on a rash. Where a decision is needed, the route is the family and their GP or a pharmacist, and in an emergency the emergency services. A session leader is not a clinician and should not be placed in that position by an organisation's paperwork.
The part everybody skips: keeping it current
An assessment written once and filed is a document about a session that no longer exists. Things that should trigger a revisit: a change of venue, a change of pool within a venue, a change in the group's composition or competence, a change in the lifeguard arrangement, a near miss, a change of season for outdoor activity, and any incident anywhere in the organisation.
The practical version is a short review before each block rather than an annual ritual, plus a line at the bottom recording when it was last looked at and by whom.
The moment where a child got to the deep end unnoticed and nothing happened is worth more than any amount of general guidance, because it is specific to your venue and your group. Organisations that record near misses find the site specific risks. Organisations that only record incidents find them later.
Producing and maintaining the session risk assessment
Owns telling the organisation what it needs to know about them. A swimmer or family who withholds relevant health information has removed something from the assessment that nobody else could have put in.
Owns writing it, keeping it specific to this venue and this group, reviewing it, briefing staff and volunteers on it, and actually applying its triggers on the day rather than proceeding because everybody has already changed.
Owns the normal operating procedure and emergency action plan, owns telling hirers what they are, owns the accuracy of what it says is provided, and owns notifying hirers of changes such as a different lifeguard arrangement or a roof that will be open.
Where a duty attachesThe Management of Health and Safety at Work Regulations 1999 require the assessment. The underlying duties sit in the Health and Safety at Work etc. Act 1974. Pool specific guidance is in Health and Safety Executive, HSG179 Health and safety in swimming pools, swimming activity guidance from Swim England, and for schools the HSE material on school trips.
Summary
Short, specific, chronological, and covering the parts that are not the swim. Name the things somebody arriving new would not know. Include the environmental triggers, indoors and outdoors, with a stated point at which you do not run. Record near misses. Review it before each block. And keep clinical decisions out of it, because they belong to people with clinical training.