ES-2025-01 BOS STAFF REPORT.PDF

Maricopa County — Formal (2025-08-01)

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Report to the Board of Supervisors 
Prepared by the Maricopa County Environmental Services Department 
Board of Health (BOH) 
Meeting Date: 
July 28, 2025 
Board of Supervisors 
Hearing Date: 
September 10, 2025 
Case #/Title:  
ES-2025-01/Public and Semi-Public Bathing Places: Variance Process 
Supervisor Districts: 
All Districts 
Applicant: 
Maricopa County Environmental Services Department (Department) 
Request: 
Approve proposed revision to Maricopa County Environmental 
Health Code (MCEHC), Chapter VI, Section 1.  
Support/Opposition: 
A stakeholder workshop was held on May 20, 2025. No comments, 
questions, or concerns were received about this case.  
Department 
Recommendation: 
The Department recommends that the Board of Supervisors (BOS) 
approve the proposed MCEHC revision.  
BOH  
Recommendation: 
The Board of Health (BOH) voted unanimously to approve the 
Department’s proposed revision and proceed according to the EROP 
expedited process.  
Executive Summary: 
This case aligns the MCEHC pool variance language with the A.A.C. 
The MCEHC allows a variance only for requirements that are more 
restrictive than the A.A.C. The A.A.C. allows for a variance upon 
demonstration by an applicant that an alternate design, material, 
appurtenance, or technology is equivalent to a requirement in code. 
This alignment will provide customers with regulatory clarity and 
remove the narrower parameters for which a variance can be 
requested.  
The proposal does not increase fees; it updates the language found in 
MCEHC. 
In accordance with the Maricopa County Resolution, “Moratorium on 
Increased Regulatory Burdens,” the County Manager authorized the 
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Department to proceed with this case on April 3, 2025, and the BOS 
was briefed on April 30, 2025. 
On July 28, 2025, the Department presented a Staff Report for this 
case to the BOH, at which time the BOH approved this case to 
proceed on the EROP expedited process for the BOS to adopt this 
proposed Department revision. 
Presented by: 
Andy Linton, Director 
Attachments: 
Report to the BOH - (2 Pages) 
County Manager Memo – (1 Page) 
Proposed MCEHC Revisions – (18 Pages) 
Presentation – Stakeholder Meeting (5/20/25) – (3 Pages) 
Stakeholder Meeting Minutes (5/20/2025) – (1 Page) 
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Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
P: 602.506.6616 
Maricopa.gov/Enviro 
Report to the Board of Health 
To Approve for Expedited Process
Prepared by the Maricopa County Environmental Services Department
Case #/Title:  
ES-2025-001/Public and Semi-Public Bathing Places: Variance Process 
Meeting Date: 
July 28, 2025  
Supervisor Districts: 
All Districts 
Applicant: 
Maricopa County Environmental Services Department (Department) 
Request: 
Approve proposed Maricopa County Environmental Health Code (MCEHC) 
ES-2025-001/Public and Semi-Public Bathing Places: Variance Process to 
advance on the Enhanced Regulatory Outreach Program (EROP) expedite 
process.   
Support/Opposition: 
The Department held a hybrid stakeholder workshop on May 20, 2025. Six 
stakeholders attended the meeting virtually, and two stakeholders said they 
had no comments or questions.  No other comments, questions, or concerns 
were received about this case.   
Department 
Recommendation: 
Discussion: 
The department recommends that the Board of Health approve the Department 
to move forward with the proposed changes to the Variance Process for Bathing 
Places section of the MCEHC for consideration by the Board of Supervisors.   
The design and construction approvals of public and semi-public pools are 
delegated to the Maricopa County Environmental Services Department 
(Department) by the Arizona Department of Environmental Quality (ADEQ). 
MCEHC and the Arizona Administrative Code (A.A.C.) allow for a variance 
submittal for pool design and construction. MCEHC allows a variance only for 
requirements in the MCEHC that are more restrictive than the A.A.C. The 
A.A.C. allows for a variance upon demonstration by an applicant that an 
alternate design, material, appurtenance, or technology is equivalent to a 
requirement in code. The Department proposes aligning MCEHC requirements 
for pool variances with the A.A.C. This alignment will provide 
3

Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
P: 602.506.6616 
Maricopa.gov/Enviro 
customers with regulatory clarity and remove the more narrow parameter 
for which a variance can be requested.   
This proposal follows the EROP policy and workflow process; no fee 
changes are requested. 
In accordance with the Maricopa County Resolution, “Moratorium on 
Increased Regulatory Burdens,” the County Manager authorized the 
Department to proceed with this case in April 2025.  Also, the Board of 
Supervisors were briefed in April 2025. 
Attachments: 
County Manager Case Approval (1 Page) 
Proposed MCEHC Revisions (18 Pages) 
Presentation – Stakeholder Meeting (5/20/25) – (3 Pages) 
Stakeholder Meeting Minutes (5/20/25) – (1 Page)
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MARICOPA COUNTY ENVIRONMENTAL HEALTH CODE 
CHAPTER VI 
BATHING PLACES - PUBLIC AND 
SEMIPUBLIC SWIMMING 
POOLS 
 
SECTION 1 
GENERAL PROVISIONS 
REGULATION 1. Definitions 
A. 
“A.A.C.” is an abbreviation for Arizona Administrative Code. 
B. 
“ADEQ” is an abbreviation for Arizona Department of Environmental Quality. 
C. 
“ADHS” is an abbreviation for Arizona Department of Health Services. 
D. 
“Air induction system” means a system whereby a volume of air is introduced into hollow 
ducting in a spa floor, bench or walls. An air induction system is activated by an air power 
blower and is separate from the water circulation system. 
E. 
“Algae” means microscopic, single-celled forms of plant life that exist in most surfaces 
and ground waters. Green, blue-green (frequently called black) and mustard algae are the 
types most common to swimming pools. 
F. 
“ANSI” is an abbreviation for American National Standards Institute. 
G. 
“Artificial bathing lake” means a man-made lake, lagoon or basin, lined or unlined, with 
an area equal to or greater than two acres (87,120 square feet), constructed and used or 
intended to be used for water contact recreation. This includes all recreational activities 
where there is a high probability of water ingestion and where related activities create a 
significant public health and safety risk. Such activities include, but are not limited to, 
wading, swimming, bathing, wind surfing, water skiing and jet skiing. 
H. 
“Approved” means acceptable to the Department or to the swimming pool agency that has 
the jurisdiction based on determination of conformity with principles, practices or political 
subdivision. 
I. 
“A.R.S.” is an abbreviation for Arizona Revised Statutes. 
J. 
“ASME” is an abbreviation for American Society of Mechanical Engineers. 
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K. 
“Backwash” means the process of thoroughly cleaning a filter by reverse flow of water 
through the filter. 
L. 
“Barrier” means a fence, wall, building or landscaping that obstructs access to a bathing 
place. 
M. 
“Bathing place” as used in these regulations includes all bodies of water used by persons 
for swimming, wading, hydrotherapy, recreation, bathing or special uses together with the 
shores, bathhouses, sanitary facilities, equipment and all other appurtenances to such 
bodies of water, except that these regulations do not apply to facilities constructed or 
maintained at any medical facility intended exclusively 
N. 
for therapeutic treatment and facilities constructed and operated by the state of Arizona. A 
bathing place for consideration of design, permits, and fees shall be considered separate 
and distinct if: 
1. Bodies of water are physically separate; or 
2. Bodies of water are at different elevations; or 
3. Bodies of water are separated by a fence, wall or visual barrier which prevents or 
impedes direct physical or visual access to any portion of the body of water; or 
4. Bodies of water are separated by a channel, less than ten (10) feet wide. 
O. 
“Cartridge filter” means a depth, pleated or surface-type filter component with fixed 
dimensions that is designed to remove suspended particles from water flowing through the 
filter. 
P. 
“Clean” means free from slime, scum, dirt or other debris. 
Q. 
“Construct” means, and includes, building or installing a new bathing place or enlarging or 
altering existing facilities. 
R. 
“Coping” means the cap on a swimming pool or spa wall that provides a finished edge around 
the swimming pool or spa. 
S. 
“Cross connection” means any physical connection between two (2) piping systems, one (1) 
of which contains potable water and the other sewage or water of unknown or questionable 
quality, through which water may flow from either system to the other. 
T. 
“Deck” means a hard surface immediately adjacent to or attached to a bathing place that is 
designed for sitting, standing or walking. 
U. 
“Deep area” means the portion of a bathing place that is more than five (5) feet deep. 
V. 
“Department” refers to Maricopa County Environmental Services Department. 
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W. 
“Discharge piping” means the portion of the circulation system that carries water from the 
filter back to the swimming pool or spa. 
X. 
“DPD” is an abbreviation for Diethyl-p-Phenylene Diamine. The indicator usually is used in 
tablet form which measures chlorine and bromine levels in pool and spa water. 
Y. 
“Diving area” means the area of the public or semipublic swimming pool that is designated 
for diving from a diving board, diving platform or starting block. 
Z. 
“Fill and draw pool” means a bathing place where the principal means of cleaning is the 
complete removal of the used water and the replacement thereof with potable water. 
AA. 
“Filtration rate” means the rate of water flowing through a filter during the filter cycle 
expressed in gallons per minute per square foot of effective filter area. 
BB. 
“Flow through pool” means a bathing place where potable water constantly enters the pool 
and an equal quantity of used water constantly flows out of the pool. 
CC. 
“Freeboard” means that section of the pool wall measured vertically between the water 
surface and the walkway or deck surface. 
DD. 
“GPM” is an abbreviation for Gallons Per Minute. 
EE. 
“Hose bibb” means a faucet with a threaded nozzle to which a hose may be attached. 
FF. 
“Hydrotherapy jet” means a fitting that blends water and air and creates a high velocity 
turbulent stream of air-enriched water for injection into a spa. 
GG. 
“Incontinent” means unable to restrain a bowel movement. 
HH. 
“Lifeguard” means an attendant with Red Cross or equivalent certification who supervises 
the safety of bathers. 
II. 
Make-up water” means fresh water used to fill or refill a bathing place. 
JJ. 
“Maximum bathing load” means the design capacity or maximum number of users that a 
bathing place is designed to hold. 
KK. 
“Natural bathing place” means unmodified natural outdoor lakes, ponds, rivers, etc. 
LL. 
“Operate” means to conduct, maintain or otherwise provide facilities and appurtenances at 
bathing places. 
MM. “NCAA” is an abbreviation for National Collegiate Athletic Association. 
NN. 
“NFSHSA” is an abbreviation for National Federation of State High School Associations. 
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OO. 
“Operator” means an individual who owns, runs, maintains, or otherwise controls or directs 
the functioning of a bathing place. 
PP. 
“Overflow system” means and includes gutters and other rim type overflows, surface 
skimmers and collection systems of various designs and manufacture. 
QQ. 
“Permit holder” means the entity that: 
RR. 
Is legally responsible for the operation of the bathing place such as the owner, the owner's 
agent, or other person; and 
SS. 
Possesses a valid permit to operate a bathing place. 
TT. 
“pH value” indicates the degree of acidity or alkalinity of water. The pH scale is from 0 to 
14 with pH 7.0 being the neutral point, i.e., water with pH of 7.0 is neither acid nor alkaline, 
and it is neutral. Above pH 7.0 the water is alkaline and below pH 
UU. 
7.0 it is acidic. 
VV. 
“Potable water” means drinking water. 
WW. “PPM” is an abbreviation for Parts Per Million. 
XX. 
“Private residential spa” means a spa at a private residence used only by the owner, members 
of the owners' family and invited guests, or a spa that serves a housing group consisting of 
no more than three (3) living units (e.g. duplexes or triplexes). Private spas are exempt from 
these regulations. 
YY. 
“Private residential swimming pool” means a pool operated by an individual for his own or 
his family’s use or for guests of his household, or by an owner, to serve a housing group 
consisting of no more than three (3) living units. Private pools are exempt from these 
regulations. 
ZZ. 
“Public spa” means a spa that is open to the public with or without a fee, including a spa that 
is operated by a community, municipality, political subdivision, school district, university, 
college or a commercial establishment whose primary business is the operation of a spa. 
AAA. “Public swimming pool” means a swimming pool that is open to the public with or without 
a fee, including a pool that is operated by a community, municipality, political subdivision, 
school district, university, college or a commercial establishment whose primary business is 
the operation of a pool. 
BBB. “Recessed treads” means a series of vertically spaced, preformed stepholes in a swimming 
pool wall. 
CCC. “Recirculating pool” means a swimming pool where a portion of the pool water is constantly 
being removed, filtered and disinfected then returned to the pool. 
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DDD. “Resurfacing” means any alteration that is greater than ten (10) percent of the pool interior 
surface. This shall include but not be limited to plastering, painting, tiling, application of 
pebble type finish, fiberglass or any other approved alternative surface. 
EEE. “Return inlet” means an aperture or fitting through which filtered water returns to a 
swimming pool or spa. 
FFF. 
“Return line” means that portion of the recirculating system piping which carries clean water 
from the filter back to the swimming pool. 
GGG. “Rope and float line” means a continuous line not less than three-quarter (3/4) inch in 
diameter that is supported by buoys and attached to opposite sides of a swimming pool to 
separate areas of the swimming pool. 
HHH. “Sanitary facilities” means a designated area that includes a toilet and sink and may include 
a shower or urinal. 
III. 
“Scum” means a film that forms on the surface of water. 
JJJ. 
“Secchi Disk” refers to a 200-mm circular plate, which has opposite quarters painted gloss 
white and black. 
KKK. “Secchi Disk visibility” is the depth at which the disk can be seen when raised and lowered 
in the water. 
LLL. “Semiartificial bathing place” means a natural bathing place that has been modified by man. 
MMM. “Semipublic spa” means a spa operated for the residents of lodgings such as hotels, motels, 
resorts, apartments, condominiums, townhouse complexes, trailer courts, mobile home parks 
or similar establishments. A semipublic spa includes a spa that is operated by a neighborhood 
or community association for the residents of the community and their guests and any spa at 
a country club, health club, camp or similar establishment where the primary business of the 
establishment is not the operation of a spa and where the use of the spa is included in the fee 
for the primary use of the establishment. 
NNN. “Semipublic swimming pool” means a swimming pool operated for the residents of lodgings 
such as hotels, motels, resorts, apartments, condominiums, townhouse complexes, trailer 
courts, mobile home parks, or similar establishments. A semipublic pool includes a 
swimming pool that is operated by a neighborhood or community association for the 
residents of the community and their guests and a swimming pool at a country club, camp or 
similar establishment where the primary business of the establishment is not the operation of 
a swimming pool and where the use of the swimming pool is included in the fee for the 
primary use of the establishment. 
OOO. “Shallow area” means the portion of a swimming pool that is five (5) feet or less in depth. 
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PPP. 
“Service animal” means an animal such as a guide dog, signal dog or other animal 
individually trained to provide assistance to an individual with a disability. 
QQQ. “Shock treatment” means adding chlorine to water in an amount sufficient to destroy 
ammonia, nitrogenous and organic contaminants in the water by elevating 
RRR. the free chlorine residual to a level 10 times the combined chlorine reading in parts per 
million. 
SSS. 
“Slime” means a glutinous or viscous liquid matter. 
TTT. “Slip resistant” means a surface that has a static coefficient of friction (wet or dry) of at least 
0.50. 
UUU. “Spa” means an artificial basin, chamber or tank of irregular or geometric shell design that 
is intended only for bathing or soaking and that is not drained, cleaned or refilled for each 
user. A spa may include features such as hydrotherapy jet circulation, hot water, cold water, 
mineral baths or an air induction system. Industry terminology includes “hydrotherapy pool,” 
“whirlpool”, “hot tub” and “therapy pool”. 
VVV. “SPAC” is an abbreviation for Swimming Pools Advisory Committee. 
WWW. “Special use pool” means a swimming pool intended for competitive aquatic events, aquatic 
exercise or lap swimming. A special use pool includes a wave action pool, exit pool for a 
water slide, swimming pool that is part of an attraction at a water recreation park, water 
volleyball pool or a swimming pool with special features used for training and instruction. 
XXX. “Spray pond” means an artificially constructed special use pool into which water is sprayed 
but not allowed to accumulate. 
YYY. “Suction outlet” means the aperture or fitting through which water is withdrawn from a 
swimming pool or spa. 
ZZZ. “Suction piping” means the water circulation system piping that carries water from the 
swimming pool or spa to the filter. 
AAAA. “Swimming pool” and/or “Pool” shall mean an artificial basin, chamber or tank, constructed 
and used, or intended to be used, for swimming, diving or bathing. A bathing place less than 
two (2) acres (87,120 square feet) shall meet the criteria for swimming pools. 
BBBB. “SVRD” is an abbreviation for Safety Vacuum Release Device. 
CCCC. “SVRS” is an abbreviation for Safety Vacuum Release System. 
DDDD. “Total alkalinity” means the measurements of the carbonates, bicarbonates and hydroxides 
in the water, which if insufficient, may cause the pH to be unstable and produce corrosive 
conditions. Conversely, if the total alkalinity is too high, scale could be formed. 
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EEEE. “Turnover rate” means the number of hours required to circulate a volume of water equal to 
the capacity of the swimming pool or spa. 
FFFF. “User” means a person who uses any bathing place included in Chapter VI or uses adjoining 
deck area. 
GGGG. “Variance” means a written document issued by the Department that authorizes a 
modification or waiver of one or more requirements of this Code if, in the opinion of the 
Department, a health hazard, safety or nuisance will not result from the modification or 
waiver. 
HHHH. “Wading pool” means a shallow pool used or intended to be used primarily for wading by 
small children. 
IIII. 
“Water circulation system” means an arrangement of mechanical equipment connected to a 
swimming pool or spa by piping in a closed loop that directs water 
JJJJ. 
from the swimming pool or spa to the filtration and disinfection equipment and returns the 
water to the swimming pool or spa. 
KKKK. “Water circulation system components” means the mechanical components that are part of 
a water circulation system of a swimming pool or spa, including pumps, filters, valves, 
surface skimmers, ion generators, electrolytic chlorine generators, ozone process equipment 
and chemical feeding equipment. 
LLLL. “Water level”. The water level referred to in these standards shall be established in one of 
the following ways: 
1. The water level shall be deemed to fall in the midpoint of the operating range of the 
skimmers; or 
2. On pools with overflow systems, the level shall be deemed to be that established by the 
height of the overflow rim. 
REGULATION 2. Approval of Plans and Construction Required 
A. 
A person shall obtain design approval from the Department prior to starting construction of 
a new public or semipublic swimming pool, spa, wading pool, or special use pool, changing 
in use from a semipublic swimming pool to a public swimming pool, changing in use from 
a private residential swimming pool to a public or semipublic swimming pool, or beginning 
major modifications to an existing public or semipublic swimming pool or spa. For purposes 
of this subsection, major modifications include a change to: 
1. The shape; or 
2. The depth; or 
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3. The water circulation system; or 
4. The enclosure; or 
5. Resurfacing the pool interior or deck; or 
6. Adding a water feature or planter; or 
7. The disinfection system; or 
8. The installation of diving equipment. 
At a public or semipublic swimming pool an appropriately licensed contractor, Architect, 
or Professional Engineer shall submit plans for a major modification. 
B. 
The owner shall make an Application for Approval to Construct any proposed bathing place 
and shall be submitted to the Department on forms furnished by the Department. Such 
application for approval shall accompany the plans, when required, and specifications at the 
time of submission to the Department for review. 
C. 
The operator/owner of a previously approved bathing place as defined in these regulations, 
intending to change the nature of the classification from public to semipublic or from 
semipublic to public must demonstrate, to the satisfaction of the Department, that the facility 
meets all requirements of these regulations as related to the desired classification. If any 
additional construction or modification of the facility shall be required, plans and 
specifications of the proposed facility shall be submitted for approval as required in Chapter 
VI, Section 1, Regulation 2, b. 
D. 
Plans and specifications shall be submitted to the Department with the appropriate fees as 
listed in Chapter I of the Maricopa County Environmental Health Code at least 30 days prior 
to the date upon which action is desired. Plan documents submitted for approval to construct 
shall include a general plot plan, plans and specifications showing the pool shape, 
dimensions, water treatment and pumping facilities, piping arrangement and sizes, source of 
water supply, method of disposal of wastes, and all pertinent data upon which the design is 
based on and shall include capacities of the various units, safety equipment, architectural 
drawings for fencing, water features and other information necessary to permit a clear and 
full understanding of the proposed project. Where required, detailed plans of bathhouses, 
dressing rooms, toilets, recreational and other pool appurtenances shall be included. 
E. 
All plans and specifications submitted to the Department for approval shall be prepared by, 
or under the supervision of, a currently registered Arizona Professional Engineer or 
Architect, or a swimming pool contractor with the following licenses (per project type) as 
listed in the table below, who shall certify that the plans comply with these regulations and 
criteria contained in the swimming pool design policies. 
 
 
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F. 
 
PROJECT TYPE 
R.O.C. LICENSE REQUIRED 
Any and all projects, all new construction 
A-9, A-19, KA-5, KA-6 
Safety vacuum release system, plumbing and 
equipment replacement 
K-37, K-77, L37, L-77 
Resurface and drain split/plumbing 
A-9, A-19, KA-5, KA-6 
Deck replacement only 
K-9, L-9 
Fence only 
As required by Arizona Registrar 
of Contractors 
 
G. 
All work shall conform to approved plans and specifications. Should it be necessary or 
desirable to make any changes in the approved plans and specifications of the proposed 
work, revised plans and specifications, together with a written statement of the reasons for 
such change, shall be submitted to the Department for review. The Application for Approval 
to Construct must be obtained in writing before the work affected by the change is 
undertaken. 
H. 
The Department will, upon receipt from the applicant of reasonable advance notice of 
readiness to, make necessary inspections to determine that the pool piping system, and 
thereafter the complete pool circulation, purification, and waste systems are in compliance 
with these regulations. The piping system shall be left open and exposed until the 
Department has examined and approved the system in writing. The complete pool, including 
circulation, purification and waste systems shall be deemed acceptable only after 
examination and issuance of written approval of construction by the Department. 
I. 
The design, operation and maintenance of bathing places shall be in conformance with these 
regulations and criteria contained in the Department swimming pool design policy. 
J. 
Before Approval of Construction shall be given for the operation of a bathing place, the 
swimming pool contractor or a currently registered engineer or architect shall certify that the 
completed bathing place is constructed in accordance with the approved plans and 
specifications. 
REGULATION 3. Permit Required 
No public or semipublic bathing place shall be maintained or operated in Maricopa County without 
a valid operating permit issued by the Department. The permit shall be displayed in a conspicuous 
place on the premises where the public may readily observe it. No permit shall be issued until the 
applicable permit fee has been rendered. Permit fees are listed in Chapter I, Regulation 5 of the 
Environmental Health Code. If the operating permit for a bathing place is determined by the 
department to be invalid due to permit revocation or the permit has been allowed to lapse for a 
period greater than (1) year, the bathing place shall comply with the current Environmental Health 
Code in order to qualify for an operating permit 
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REGULATION 4. Instructions 
Before entering a pool, all persons shall be instructed, by means of suitable, clearly lettered signs 
properly located, to observe all safety regulations. The signs shall contain, at a minimum, all of the 
following: 
A. 
Persons with sore or inflamed eyes, colds, nasal or ear discharges, boils or other acute or 
obvious skin or body infections, or cuts shall be excluded from the pool. 
B. 
No glassware allowed within the pool enclosures. 
C. 
No animals allowed except for service animals. 
D. 
No drinks, candy, tobacco, popcorn, gum, alcohol, or food of any kind shall be permitted in 
the pool or within the required walkways of the pool 
E. 
Keep gate(s) closed – do not prop open. 
F. 
Shower and use the toilet before entering the pool. 
G. 
If incontinent, wear tight fitting rubber or plastic pants or a swim diaper. 
H. 
Observe all safety regulations. 
REGULATION 5. Attire and Towels, etc. 
A. 
Bathing attire, towels, linens and similar articles shall be clean, dry and sanitary when 
provided to patrons. 
B. 
The provision of towels, drinking cup, combs, hairbrushes, soap and other similar items 
for use in common by the public is prohibited. 
REGULATION 6. Excluded 
Persons with sore or inflamed eyes, colds, nasal or ear discharges, boils or other acute or obvious 
skin or body infections, or cuts shall be excluded from the pool. No person in or at a swimming 
pool shall commit, or be permitted to commit, any act prejudicial to the life or health of any other 
person using the pool. Animals shall be excluded from the pool enclosure, except for service 
animals. All animals shall be excluded from bathing in the pool. 
REGULATION 7. Drinking Water 
Drinking water from an approved source and dispensed through one (1) or more drinking fountains 
shall be located on the deck of each public swimming pool or spa. 
REGULATION 8. Concessions 
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No drinks, candy, tobacco, popcorn, gum, alcohol, or food of any kind shall be permitted in the 
pool or within ten (10) feet of a public bathing place or within four (4) feet of a semipublic bathing 
place. 
A. 
No food or drink of any kind shall be allowed in the pool or within the required walkways 
of the bathing place. 
B. 
Food and drink will be allowed within the pool enclosure but outside the area noted in 
Chapter VI, Section 1, Regulation 8, a., provided that only paper or plastic service is used. 
No glass is permitted within the pool or spa enclosure. 
REGULATION 9. Operation 
All bathing place facilities shall at all times be operated and maintained in a clean, safe and 
sanitary condition. The owner of a bathing place shall close that facility if any of the following 
conditions exist: 
A. 
 Absence of an approved disinfectant; 
B. 
Violation of the physical standards of Section 2, Regulation 5; 
C. 
Filtration system is inoperative; 
D. 
Mechanical disinfectant feeder is missing, inoperative, or malfunctioning; 
E. 
Broken or missing main drain covers or other suction outlet covers; 
F. 
When required, lifeguards are not present or the required number of lifeguards is not 
present; 
G. 
Gates are not self-closing and self-latching or there is a breach of the pool enclosure; 
H. 
Leaking gas chlorinator; 
I. 
Absence of all safety equipment; 
J. 
Electrical wires over the pool; 
K. 
Broken glass in the pool area; 
L. 
Any other operational condition which may cause injury or present a danger to the public 
health. 
 
 
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REGULATION 10. Violations 
Any person, firm, or corporation who builds, offers for sale or operates a bathing place contrary to 
these regulations shall be subject to prosecution as provided by law. 
REGULATION 11. Retroactive Provisions 
Permitted pools that were constructed prior to the effective date of this code shall meet the 
operational requirements of this code as listed in Chapter VI, Section 1, Regulation 9 and the 
Structural Provisions in Chapter VI, Section 1, Regulation 12. 
REGULATION 12. Retroactive Structural Provisions 
A. 
Retroactive main drain requirements: 
The owners of all public and semipublic swimming pools, which were under a valid operating 
permit on the effective date of this Environmental Health Code and equipped with a single 
main drain, shall: 
1. Install a properly sized anti-vortex, anti-entrapment drain cover that complies with 
ANSI/ASME A112.19.8M, “Suction Fittings for Use In Swimming Pools, Spas, Hot 
Tubs And Whirlpool Bathtub Appliances” on all suction outlets by May 1, 2004. 
2. Install a hydraulically balanced dual main drain at the time the pool is resurfaced. If 
the pool or spa is not resurfaced and hydraulically balanced dual main drains are not 
installed, the owner shall install a Safety Vacuum Release Device (SVRD) or Safety 
Vacuum Release System (SVRS) that meets ANSI/ASME A112-19 Standards or 
equivalent by January 1, 2014. 
3. Install other devices or means as approved by the Department by no later than January 
1, 2014. 
B. 
Retroactive fencing requirements for public pools: 
1. Public swimming pools, special use pools, spas and wading pools who hold a valid 
operating permit on the effective date of this code that meet the requirements in 
Appendix C and shall comply with fencing requirements in Chapter VI, Section 6, 
Regulation 11 by January 1, 2014. 
2. Public swimming pools, special use pools, spas and wading pools who hold a valid 
operating permit on the effective date of this code that do not meet the requirements in 
Appendix C on the effective date of this code shall comply with fencing requirements 
in Chapter VI, Section 6, Regulation 11 by January 1, 2005. 
C. 
Retroactive fencing requirements for Semipublic pools: 
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1. 
Semipublic swimming pools, special use pools, spas and wading pools who hold a 
valid operating permit on the effective date of this code that meet the requirements 
in Appendix D on the effective date of this code shall comply with fencing 
requirements in Chapter VI, Section 7, Regulation 2 by January 1, 2014. 
2. 
Semipublic swimming pools, special use pools, spas and wading pools who hold a 
valid operating permit on the effective date of this code that do not meet the 
requirements in Appendix D on the effective date of this code shall comply with 
fencing requirements in Chapter VI, Section 7, Regulation 2 by January 1, 2005. 
D. 
Retroactive diving board requirements: 
All public and semipublic swimming pools and special use pools who hold a valid 
operating permit on the effective date of this code, constructed prior to February 1, 1998, 
and having met the requirements of the code for a diving board in force at the time of 
construction may continue to operate a diving facility under the following conditions: 
1. The pool was approved for construction prior to February 1, 1998. 
2. The height of the diving board above the water surface shall be limited to a maximum 
of ten (10) feet (three (3) meters). 
3. If the pool and diving board do not meet the dimensional requirements in Appendix A 
or Appendix B, diving must be under the direct supervision of a lifeguard or other 
responsible party and the pool owners shall provide and maintain on file with Maricopa 
County a current certificate of publicliability insurance documenting minimum limits 
of seven million dollars ($7 million) combined single limit for bodily injury and 
property damage liability. The certificate must further clearly indicate that Maricopa 
County is an additional insured and that no changes or modifications shall become 
effective in the coverage without 30 days prior written notice submitted to the 
Department. 
E. 
Retroactive vacuum outlet requirements: 
Public and semipublic swimming pools, special use pools, spas, and wading pools that 
hold a valid operating permit on the effective date of this code shall comply with Chapter 
VI, Section 3, Regulation 9 by January 1, 2005. 
REGULATION 13. Variance 
a. 
Purpose 
The purpose of this regulation is to allow the Environmental Health Officer to consider 
granting a variance from those parts of Chapter VI, which are more restrictive than AAC 
R18-5-2 and/or AAC R9-8-8. This would be possible when there exists an unusual or 
unreasonable hardship resulting from a literal interpretation of this Code, provided that 
the alternative method or work offered conforms to the general intent of this Code. The 
18

R. 2-18-2004 
6-14 
 
 
application for variance and the decision of the Environmental Health Officer shall be in 
writing and shall be officially recorded within the records of the Department. 
A.        The Environmental Health Officer may grant a variance from a requirement prescribed in 
this Code upon a demonstration by the applicant that an alternative design, material, 
appurtenance, or technology is equivalent to a requirement prescribed in this Code. If a 
variance is granted, it shall be conditioned upon the applicant’s use of the approved 
alternative.  
B.       The Environmental Health Officer shall not grant a variance that results in an unreasonable 
risk to the health of swimming pool or spa users.  
C. 
The applicant shall submit a request for a variance in writing with an application for design 
approval. A variance request shall contain the following information:  
1.  Identification of the requirement prescribed in this Code for which a variance is requested;  
2.    Explanation of the reasons why the applicant cannot comply with the requirement; 
3.    A complete description of the alternative design, material, or technology to be installed and 
used in the swimming pool or spa, including design plans, specifications, and a description of 
the cost; 
4.    A demonstration that the alternative design, material, or technology to be installed and used 
in  the swimming pool or spa is equivalent to the requirement in this Code and will not result 
in an unreasonable risk to users; and  
5.    A statement that the applicant will perform reasonable requirements prescribed by the 
Department that are conditions of a variance. 
D. 
In considering a request for a variance from a requirement prescribed in this Code, the 
Environmental Health Officer shall consider the following factors:  
1.   The intended use of the public or semipublic swimming pool or spa;  
2.  The safety of the alternative design, material, or technology for which a variance is 
requested;  
3.   The cost and other economic considerations associated with requiring compliance with 
the requirement prescribed in this Code as compared to the alternative for which a 
variance is requested 
b.         Conditions for Variance 
1. 
Any person may request a Variance to Chapter VI of this Code when it is claimed 
that: 
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R. 2-18-2004 
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(a) 
The true intent of the Codes or Ordinances described in this Code has been 
incorrectly interpreted by the Department; or 
(b) 
A decision by the Department is unreasonable or arbitrary when it is applied 
to alternate or new materials. 
E. 
The Swimming Pool Advisory Committee may recommend that the Environmental Health 
Officer issue a Vvariance only after the Committee has determined that  considered items 
listed in Chapter VI, Section 1, Regulation 13(d). 
(a) Special circumstances or conditions apply to this permit application; and 
(b) Authorizing of the variance is necessary for the preservation and enjoyment of 
substantial property rights; and 
(c) 
Authorizing of the variance will not be materially detrimental to persons 
residing or working in the vicinity, to adjacent property, to the 
neighborhood or to the public safety and welfare in general; and 
(d) 
Granting of the variance will be in harmony with the purposes sought to be 
attained by the Codes or Ordinances. 
F. 
If the applicant for the variance is dissatisfied with the decision of the Environmental Health 
Officer, the applicant may appeal to the Board of Health whose decision shall be final, 
except that any person aggrieved by a decision of the Board of Health may at any time, 
within 30 days after the filing of the Board of Health’s decision, file an appeal with the 
Superior Court of Maricopa County by following the various methods of appeal or review 
procedures in Arizona as set forth in the applicable statutes of the State of Arizona. 
G. 
Such appeals shall be presented to the Secretary of the Board of Health in writing within 30 
days after the filing of the decision of the Environmental Health Officer or the 
Environmental Health Officer may refer the appeal to the committee. 
H. 
Swimming Pools Advisory Committee (SPAC) 
1. Structure: 
a. There shall be and is hereby created, a Swimming Pool Advisory Committee, 
hereinafter called “Committee”, consisting of five members, who are residents of 
Maricopa County and citizens of the United States, and composed of and consisting 
of a representative of the industries, trades, and professions as follows: 
 
(1)  Swimming Pool Building Contractor 
(2)  Swimming Pool Service and Repair Contractor or Swimming Pool Industry 
Member 
(3) Certified Safety Professional 
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(4) Professional Engineer 
(5) Health Professional 
b. The members of the Committee shall be appointed by the Chairperson of the Board 
of Health for a term of three (3) years. The initial terms of office shall be as 
follows: 
(1) One member shall be appointed for a term of three (3) years; 
(2) Two members for a term of two (2) years; 
(3) Two members for a term of one (1) year. 
c. Upon expiration of the initial term of office of a member of the Committee, their 
successors shall then be appointed for a term of three (3) years. 
d. Continued absence of any member from three (3) consecutive regular meetings of 
the Committee shall render any such member liable for immediate removal from 
office. Removal shall be at the discretion of the Board of Health. 
e. Vacancies for an unexpired term shall be filled by the Chairperson of the Board of 
Health. 
f. The members of the Committee shall serve without salary or compensation. 
g. The Environmental Health Officer or his designate shall attend all meetings and 
furnish secretarial services for the Committee. 
2. Duties and Responsibilities: 
a. It shall be the duty of the Committee to hear appeals from the decision of the 
Department staff and to submit findings to the Environmental Health Officer. 
b. The duties and powers of this Committee shall be in an advisory capacity only. 
3. Procedures: 
a. The Committee shall annually elect one (1) of its members to serve as Chairperson. 
b. The Environmental Health Officer shall designate an administrative support from 
the Department to serve as Recording Secretary to the Committee, who shall keep 
a detailed record of all proceedings on file in the Department and perform other 
secretarial duties as required by the Board. 
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c. Special Committee meetings may be called by the Environmental Health Officer 
or at the request of the Chairperson or any three (3) members of the Committee. 
d. Three (3) voting members of the Committee shall constitute a quorum. 
e. Public Hearings: 
(i) 
Any person dissatisfied with a decision of the Department staff may 
request a hearing before the Committee at any time prior to closure 
of the file. The Environmental Health Officer may call a special 
meeting to hear this matter. Such a meeting shall be held within 
thirty (30) days of the date the appeal is filed. 
(1) All hearings shall be open and public and any person whose interest may be 
affected by a recommendation of the Committee shall be given an opportunity 
to be heard. 
(2) The Committee shall render all recommendations in writing to the 
Environmental Health Officer. The Environmental Health Officer shall render 
a final decision within ten (10) days of receiving the Committee recommendations. 
(3) The applicant may waive a hearing by the Committee and appeal directly to the 
Environmental Health Officer. The Environmental Health Officer will in such 
cases render a decision within ten (10) days of the date that the appeal is filed. 
(4) The applicant shall include a fee with the written Swimming Pool Advisory 
Committee appeals as shown in the Fee Schedule in Chapter I of this Code. 
f. Conflict of Interest: 
No member of the Committee shall vote on any question concerning a job or 
project in which that member is engaged as contractor or material dealer, or in the 
preparation of plans or specifications, or on any job or project in which that 
member has any direct or indirect personal or financial interest. In these 
instances, that member shall also make full disclosure of his or her interest to the 
Committee. 
REGULATION 14. Inspections 
A. 
An inspector from the Department, upon presentation of credentials, may enter into any 
public or semipublic swimming pool or spa to determine compliance with this code. The 
inspector may inspect records, equipment and facilities, take photographs and take other 
action reasonably necessary to determine compliance with this Code. 
B. 
The owner or manager of a public or semipublic swimming pool or spa may accompany 
the inspector during an inspection. 
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C. 
An inspector from the Department may inspect a public or semipublic swimming pool or 
spa during reasonable working or operational hours without giving prior notice of the 
inspection to the owner or operator of the swimming pool or spa. 
REGULATION 15. Applicability 
A. 
This code applies to all public and semipublic bathing places included in Chapter VI 
(Bathing Places - Public and Semipublic Swimming Pools) of Maricopa County 
Environmental Health Code. 
B. 
Section 11 of this code applies to natural and semi-artificial bathing places. 
C. 
Section 12 of this code applies to artificial bathing lakes. 
D. 
This code does not apply to any of the following: 
1. A private residential swimming pool or spa; 
2. A swimming pool or spa used for medical treatment or physical therapy and 
supervised by licensed medical personnel; 
3. Swimming pools and spas constructed and operated by the State of Arizona; 
4. Swimming pools and spas constructed and operated by the United States 
government; or 
5. A spray pond that utilizes potable water and does not have a recirculation system. 
23

Stakeholder 
Workshop
ES-2025-001
Public and Semi-Public Bathing
Places:  Variance Process
Environmental Services 
Department’s Mission
To provide safe food, water, waste disposal and vector borne 
disease reduction controls to the people of Maricopa County so 
that they may enjoy living in a healthy and safe community.
Agenda
• Background
• Purpose of Proposed Code Change
• Proposed Revisions to Code
• Result of Proposed Code Change
• Next Steps and Enhanced Regulatory Outreach Program
(EROP) Information
• Stakeholder Questions
Background
Variance Proce ss for Bath ing Place s in Maricopa County 
The design and construction approvals of public and semi-public 
pools are delegated to the Maricopa County Environmental 
Services Department (Department) by the Arizona Department of 
Environmental Quality (ADEQ). 
This regulatory oversight ensures the safety of users by 
maintaining water quality and preventing accidents and potential
health risks to Maricopa County residents. 
Background
Variance Proce ss for Bathing Place s in Maricopa County 
The Maricopa County Environmental Health Code (MCEHC) and 
the Arizona Administrative Code (A.A.C.) allow for a variance 
submittal for pool design and construction. 
A variance is an approval or waiver that authorizes a deviation 
from one or more requirements of the MCEHC if a health 
hazard, safety hazard, or nuisance will not result from the 
deviation. 
Purpose of Proposed Code Change
Variance Proce ss for Bath ing Place s in Maricopa County 
MCEHC allows a variance only for requirements in the MCEHC that are more restrictive 
than the A.A.C. 
The A.A.C. allows for a variance upon demonstration by an applicant that an alternate 
design, material, appurtenance, or technology is equivalent to a requirement in code. 
The Department’s proposal will update language in the MCEHC to mirror the requirements
for pool variances with the A.A.C. The alignment will provide customers with regulatory 
clarity and remove the more narrow parameter for which a variance can be requested. 
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2
3
4
5
6
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Proposed Revisions to Code
REGULATION 13. Variance
a.
Purpose
The purpose of this regulation is to allow the Environmental Health Officer to consider granting
a variance from those parts of Chapter VI, which are more restrictive than AAC R18-5-2 and/or
AAC R9-8-8. This would be possible when there exists an unusual or unreasonable hardship
resulting from a literal interpretation of this Code, provided that the alternative method or work
offered conforms to the general intent of this Code. The application for variance and the
decision of the Environmental Health Officer shall be in writing and shall be officially recorded
within the records of the Department.
A. The Environmental Health Officer may grant a variance from a requirement prescribed in this
Code upon a demonstration by the applicant that an alternative design, material, appurtenance,
or technology is equivalent to a requirement prescribed in this Code. If a variance is granted, it
shall be conditioned upon the applicant’s use of the approved alternative.
Maricopa Co unty E nvironmental He alth Code Chapte r 6
B. The Environmental Health Officer shall not grant a variance that results in an unreasonable risk to the health
of swimming pool or spa users.
C. The applicant shall submit a request for a variance in writing with an application for design approval. A
variance request shall contain the following information:
1.
Identification of the requirement prescribed in this Code for which a variance is requested;
2.
Explanation of the reasons why the applicant cannot comply with the requirement;
3.
A complete description of the alternative design, material, or technology to be installed and used in the
swimming pool or spa, including design plans, specifications, and a description of the cost;
4.
A demonstration that the alternative design, material, or technology to be installed and used in
the
swimming pool or spa is equivalent to the requirement in this Code and will not result in an
unreasonable risk to users; and
5.
A statement that the applicant will perform reasonable requirements prescribed by the Department that
are conditions of a variance.
D. In considering a request for a variance from a requirement prescribed in this Code, the Environmental Health
Officer shall consider the following factors:
1. The intended use of the public or semipublic swimming pool or spa;
2. The safety of the alternative design, material, or technology for which a variance is requested;
3. The cost and other economic considerations associated with requiring compliance with the requirement
prescribed in this Code as compared to the alternative for which a variance is requested.
b. Conditions for Variance
1. Any person may request a Variance to Chapter VI of this Code when it is claimed that:
(a) The true intent of the Codes or Ordinances described in this Code has been incorrectly interpreted by
the Department; or
(b) A decision by the Department is unreasonable or arbitrary when it is applied to alternate or new
materials.
E.
The Swimming Pool Advisory Committee may recommend that the Environmental Health Officer issue a
Vvariance only after the Committee has determined that considered items listed in Chapter VI, Section 1,
Regulation 13(d).
(a) Special circumstances or conditions apply to this permit application; and
(b) Authorizing of the variance is necessary for the preservation and enjoyment of substantial property
rights; and
(c) Authorizing of the variance will not be materially detrimental to persons residing or working in the
vicinity, to adjacent property, to the neighborhood or to the public safety and welfare in general; and
(d) Granting of the variance will be in harmony with the purposes sought to be attained by the Codes or
Ordinances.
F.
If the applicant for the variance is dissatisfied with the decision of the Environmental Health Officer, the
applicant may appeal to the Board of Health whose decision shall be final,
except that any person aggrieved
by a decision of the Board of Health may at any time, within 30 days after the filing of the Board of Health’s
decision, file an appeal with the Superior Court of Maricopa County by following the various methods of
appeal or review procedures in Arizona as set forth in the applicable statutes of the State of Arizona.
e. Public Hearings:
(i)
Any person dissatisfied with a decision of the Department staff may request a hearing before the
Committee at any time prior to closure of the file. The Environmental Health Officer may call a
special meeting to hear this matter. Such a meeting shall be held within thirty (30) days of the
date the appeal is filed.
(1)
All hearings shall be open and public and any person whose interest may be affected by a
recommendation of the Committee shall be given an opportunity to be heard.
(2)
The Committee shall render all recommendations in writing to the Environmental Health
Officer. The Environmental Health Officer shall render a final decision within ten (10) days of
receiving the Committee recommendations.
(3)
The applicant may waive a hearing by the Committee and appeal directly to the Environmental
Health Officer. The Environmental Health Officer will in such cases render a decision within ten
(10) days of the date that the appeal is filed.
(4)
The applicant shall include a fee with the written Swimming Pool Advisory Committee appeals
as shown in the Fee Schedule in Chapter I of this Code.
Result of Proposed Code Change
Variance Proce ss for Bath ing Place s in Maricopa County 
Remove the narrow parameters for which the MCEHC requires a variance
allowing customers more opportunities for a variance submittal.
Provides clarity to our customers
Aligns the MCEHC and the A.A.C. for which the Department is delegated
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25

Active Regulatory Process
Tentative Date
Regulatory Process Step
April 14, 2025
County Manager Briefs the Board of Supervisors
May 20, 2025
Stakeholder Workshop
July 28, 2025
Board of Health Meeting
September 10, 2025
Board of Supervisors Public Hearing
Time line of Ne xt Ste ps
Maricopa.gov/regulations
Enhanced Regulatory Outreach 
Program (EROP)
Enhanced Regulatory Outreach 
Program (EROP)
ES-2025-001 (Public and Semi-Public 
Bathing Places:  Variance Process)
ES-2025-001 (Public and Semi-Public Bathing Places:  Variance Process)
Get Involved
• Track active regulatory
processes.
• View current and previous 
documents for active 
regulatory processes.
• Provide comments on
proposed changes to 
MCEHC.
SIGN UP
to receive rule 
notifications at
ENHANCED 
REGULATORY 
OUTREACH 
PROGRAM 
(EROP)
Stakeholder Questions
Amanda Bond
Quality and Compliance Division Manager
Amanda.Bond@Maricopa.gov
(602) 372-2735
Thank You
Logan Peiman
Management Analyst
Logan.Peiman@Maricopa.gov
(602) 506-6481
Andy Linton
Environmental Services Director
Andy.Linton@Maricopa.gov
(602) 506-5211 
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Environmental Services Department 
301 W. Jefferson St., Suite 170  
Phoenix, Arizona 85003 
P: 602.506.6616 
E: esd@maricopa.gov 
Maricopa.gov/enviro 
Stakeholder Workshop 
Public and Semi-Public Bathing Places: Variance Process 
Date: May 20, 2025 
Stakeholder Present: Scott Coughlin – City of Phoenix, Joel Carbajal – City of Phoenix, Chris Smith 
– City of Chandler, Jeffrey Iverson – Shasta Industries, Curt Lonsdale – Shasta Industries, Jeff
Fordyce – California Pools
Staff Present: Amanda Bond – Quality and Compliance Division Manager, Andy Linton – Director, 
Gregory Epperson – Managing Supervisor for Aquatic Health & Safety, Logan Peiman – 
Management Analyst, Richard Bohan – Special Projects Manager 
Presenter: Gregory Epperson 
Minutes*: Gregory Epperson covered the Enhanced Regulatory Outreach Program (EROP) process 
and how stakeholders can stay informed on this and other upcoming cases.  He further explained 
that the purpose of this case is to update the Maricopa County Environmental Health Code 
(MCEHC) pool variance design and construction language to align with the Arizona Administrative 
Code (A.A.C.).  Gregory explained that the MCEHC allows a variance only for requirements in the 
MCEHC that are more restrictive than the A.A.C. The A.A.C. allows for a variance upon 
demonstration by an applicant that an alternate design, material, appurtenance, or technology is 
equivalent to a requirement in code.  To align with the A.A.C., MCESD is proposing to amend 
MCEHC Chapter VI Section 1. 
Chris Smith with the City of Chandler said they have no questions. 
Jeff Fordyce with California Pools said they have no questions.  
Meeting adjourned. 
27