Technical Review Committee

The Technical Review Committee's (TRC) mission is to review, process, and present a comprehensive report to membership on Change Requests submitted to the CMAHC. This role is the foundation of the CMAHC mission and relies on the skills of the Committee's leadership, the technical expertise of its membership, the support of the seven Technical Support Committees, and the willingness of all members to work together to improve the MAHC. The TRC's membership, duties, and responsibilities are summarized below. The committee completes a TRC CR Evaluation form to summarize their review.

CMAHC Change Request (CR) Triage and Communication with CR Submitter Guidance: Technical Director Role

Review and Process Change Requests (CR) before sending to TRC
  • Determine if CR package is complete.
    • The CR adheres to CDC’s MAHC Scope, Principles, and Style Guidance.
      • If the CMAHC determines the CR is out of the MAHC’s scope, it will be returned to the submitter without public posting with advice on where the submitter should be trying to incorporate such a change.
    • A complete CR will have information included in all seven sections of the CR form
      • MAHC Section and page number; Corresponding Annex section and page number. Ensure that the CR is proposing to modify the most recent MAHC Edition and not an earlier version.
      • Other MAHC sections and page numbers affected by the CR.
      • How the MAHC should change; Revise (add or delete) existing text, Add a new section, Delete a section w/substitution, or Delete a section w/o substitution.
      • Proposed new or revised text using the strikethrough to delete text and underline to add text.
      • Provide a statement of the reasons and benefits for the change.
      • Provide substantiation for the change. A simple grammar or typo correction does not need this section completed.
      • Provide an "Estimated Costs" section for costs incurred by regulated parties and/or manufacturers.
    • An incomplete CR will be missing adequate information in one or more sections, especially section 5) Reason and Benefit of Suggested Change, section 6) Substantiate Request with Data and Supporting Information, and 7) Estimated Cost section

  • If incomplete, contact submitter and ask for CR to be completed and sent back no later than 2 weeks after this initial submission deadline before sending to Technical Review Committee.

  • The CMAHC will assign each CR to a TSC category so TRC members can make assignments to the TSCs of interest. NOTE: Multiple TSCs may need to review the CR. Members can sort by category if they just want to read specific CRs. These are the same categories to be used by Industry CR Liaisons for alerting interested parties about CRs of interest.
    • Design and Construction; Disinfection and Water Quality; Injury Prevention/Risk Management/Safety; Lifeguarding and Bather Supervision; Operation and Maintenance; Recirculation and Filtration; Ventilation and Air Quality

  • Determine if the CR has been submitted before or modified from a prior submission and alert TRC.

Communicate with Submitter
  • Send email to all CR submitters thanking them for being engaged with the CMAHC process.
  • Encourage submitters to check the TRC conference call schedule for when their CR(s) are slated to be discussed so they can listen in and submit explanatory comments as needed.
  • Once the TRC has arrived at a recommendation, the CR author should be contacted to inform them about the status of the final TRC recommendation.

Communicate with Members, particularly Industry CR Liaisons
  • Post TRC conference call schedule so members can plan when they want to listen to the discussion.
  • If a call needs to be re-scheduled, it needs to be done at least one week ahead of the scheduled date, website updated to reflect the change, and a member notice sent out alerting members about the change.

CMAHC TRC Chair/Vice-Chair Duties and Responsibilities

Recruit members for the Technical Review Committee (TRC) in consultation with CMAHC Executive and Technical Directors
  • Recruit equal numbers of industry/user members and public health members. See the TRC Membership Qualifications.
  • Solicit additional technical expertise, as needed, from the Technical Support Committees (TSCs).

Communicate regularly with CMAHC Executive and Technical Directors regarding:
  • CR review status/progress,
  • Concerns regarding potential impact of a CR,
  • Needs for assistance in soliciting additional TSC expertise,
  • Issues with getting submitter acceptance of modifications, and
  • Other issues, as needed.

Coordinate and conduct meetings/conference calls with TRC members
  • Review and process Change Requests (CR) using the protocol in the TRC Duties and Responsibilities established above.
  • Assign a TRC Champion to each CR based on workload, expertise, etc.
    • TRC members should not be reviewing a CR that they submitted.
  • Seek a consensus of TRC members to assign the status of a CR and determine the TRC voting recommendation. The American National Standards Institute (ANSI) defines consensus as “substantial agreement has been reached by directly and materially affected interests. This signifies the concurrence of more than a simple majority, but not necessarily unanimity. Consensus requires that all views and objections be considered, and that an effort be made toward their resolution” (see 1.c.i). For the CMAHC TRC vote, consensus is defined as a 2/3 majority vote of the entire committee (after rounding any fraction to the nearest whole number) for a YES or NO vote. If consensus cannot be reached, then the TRC shall assign an ABSTAIN vote.
    • ANSI Essential Requirements, Issued January, 2017 (Copyright New York), page 25.
  • Remind TRC members that the review calls also include Members. They should identify who they are when speaking.
    • They are being listened to by CMAHC Members and TRC members. Let listeners know you reviewed all the first-round member comments and did a thorough review of all the materials prior to the meeting so Members realize how much work was done by TRC before summary discussion meetings.

Adhere to established timeline for processing CRs and conducting conference calls
  • Work with call coordinator and TRC or TSC members to set a schedule for conducting TRC discussions of each CR. Since these calls can be accessed by all Members, the TRC needs to stick to the schedule and discuss the CRs advertised to Members.
    • NOTE: the calls will be “listen only” for members so the TRC can conduct its business. The members listening should be told they can enter comments for each CR based on the calls.
      • To submit comments members should be told they should open the CR and add a comment by clicking on the "Submit Comments" box at the bottom of the page.
    • If a call needs to be re-scheduled, it needs to be done at least one week ahead of the scheduled date, website updated to reflect the change, and a member notice sent out alerting members about the change.
  • Ensure CR Champions are prepared to cover specific CRs according to published schedule.
  • TRC review calls will post a texting number for use during the call to expedite timely feedback from Members without disrupting the flow of the TRC review conversation. The group should plan to have someone regularly monitoring the feedback during the call.

Complete CR Reviews
  • Assign TRC members to write up CR review to be posted. All reviews shall include summaries of each viewpoint.
  • Assign TRC member to summarize discussion and dispensation of all first-round member comments for posting.
  • Review TRC summaries and recommendations before posting.
  • Chair transmits TRC summaries to Executive and Technical Directors for review and posting.
  • Ensure on-line forms are used and complete to reduce re-entry workload.

Prepare for the CMAHC Conference
  • Arrange for the submitter or a TRC designee to present the CR to membership using a standard format (e.g., identified problem, suggested changes to fix problem, intended outcome)
  •  Assign TRC designee/Champion to present pros, cons, write a summary of internal deliberations, summary of member comments, TRC recommendation, and rationale, using a standard slide format to be provided.

Present at Conference
  • Review slides
  • Make presentation assignments
  • Listen to presentations and Member discussion for suggestions and agreement that changes should be made to a CR

Post-Conference
  • Convene TRC Committee to determine if any changes made to CRs post-conference affect the TRC recommendation made prior to Conference. Amend and work with CMAHC staff to post changes as need to TRC reports and voting recommendation.

CMAHC TRC Duties & Responsibilities

Triage Change Requests
  • Completed by Technical Director prior to sending to TRC.
    • TRC should rapidly discuss with Technical Director if the TRC believes a CR is incomplete or out of MAHC scope.

Review and Process Change Requests (CR)
  • CMAHC will provide a spreadsheet with embedded CR content.
  • Triage the CRs and determine which CRs require input from appropriate Technical Support Committees (TSC).
    • Work with Technical Director to target TSCs with CRs needing input and send out to TSC members as rapidly as possible. Set deadlines for TSC submissions back to the TRC.
    • The TRC will strive to triage CRs early in the process so the TSC has reasonable amounts of time to review and return their report.
    • The TRC will fill out the top four lines (marked in light gray) of the TSC Evaluation Checklist with the pertinent CR information before sending to the TSC members.
    • Leadership will assign a TRC Champion to each CR. This Champion will be responsible for:
      In-depth review (pros, cons, response to Member comments received) for presentation on TRC conference calls and at the Conference.
    • Working with TSC and submitter on modifications, as needed.
    • Leading discussion of assigned CRs on conference calls. NOTE: the calls will be “listen only” for members so the TRC can conduct its business. The members listening should be told they can enter comments for each CR based on the calls.
      • To submit comments, members should be told they should open the CR and add a comment by clicking on the “Submit Comments” box at the bottom of the page.
    • Writing up in-depth summary of internal conference call discussion on their CRs including summaries of all viewpoints.
    •  Writing up the pros, cons, internal discussion and viewpoint summary, member comment summary, etc, for the Conference presentation.
    • Write-up how each member comment was dealt with during TRC discussion process
  • Champion will conduct technical review and evaluation of CR, review of supporting documentation and Member comments, and presentation to TRC members.
    • Determine if CR is well explained, supported, or has a positive/neutral public health impact.
    • Determine if CR is achievable.
    • Advise on member comment dispensation and how they were addressed.
  • Minor changes needed: If needed, improve CR presentation (i.e., minor wording changes, grammar, ensuring use of imperatives, making sure multiple requirements are keep in separate sentences/bullets vs. combining, etc.) keeping in mind that minor improvements must not change intent.
  • Major changes needed: Broaden or re-focus the proposal using TRC or TSC expertise or member comment to increase how the CR will improve MAHC effectiveness. This is to be done in consultation with the CR submitter. Major changes MUST be approved by the submitter.
    • If upon consultation, the CR submitter agrees with the TRC “improvement” and/or “re-focus” modifications, then the CR can be posted on the web as CR with approved modifications (the original submission will remain posted but will not be voted on).
    • If the CR submitter does NOT approve the TRC suggested modifications, then the original CR submission will be the version voted on by Members. Submitters must be told that not approving the modifications may result in a “No” vote recommendation by the TRC.
  • The Submitter must respond within one week of the TRC sending the last of three weekly Emails requesting their approval of TRC modification with a negative or affirmative response. If no response is received, then the TRC modification shall be accepted.
    • Summarize all internal deliberations by the TRC and TSC.
      • Each CR Champion will do this for their CR assignments. A summary of internal TRC and TSC discussion, including summaries of all viewpoints, is required for each CR.
      • The TRC strives to have a consensus on its deliberations. The American National Standards Institute (ANSI) defines consensus as “substantial agreement has been reached by directly and materially affected interests. This signifies the concurrence of more than a simple majority, but not necessarily unanimity. Consensus requires that all views and objections be considered, and that an effort be made toward their resolution” (ANSI Essential Requirements, Issued January, 2017 (Copyright New York), page 25.).
  • Think about what you would have liked to hear in a presentation—this includes the thought process, a clear pro and con summary, and a summary of all member comments including the number of comments.
    • Review all Member comments submitted during the CR posting, after TRC conference calls, and before the first-round Member comment closing date on the CMAHC website. As appropriate, address or incorporate these comments in consultation with the CR submitter. Follow the same procedures as in 2e. above concerning CR submitter agreement. A summary of all Member comments is required for the Conference presentation.
      • Create a summary of how all first-round Member comments discussion and dispensation for posting.
      • A summary of all second-round Member comments is required for the Conference presentation.
  • Determine the TRC voting recommendation.
    • For the CMAHC TRC vote, consensus is defined as a 2/3 majority vote of the entire committee (after rounding any fraction to the nearest whole number) for a YES or NO vote. If consensus cannot be reached, then the TRC shall assign an ABSTAIN.
    • Write cogent summary of CR, pros and cons of adoption, summary of TRC internal discussion, summary of different viewpoints, and of Member comments, and final rationale for TRC voting recommendation.
    • If a “NO” vote recommendation is assigned, include, as appropriate, recommendations for improvement if it were resubmitted. If this is a proposal that a submitter would not approve the recommended modifications, then include the recommended modifications for other submitters to consider at the next biennial conference.
    • Work with CMAHC to post CR reviews to the CMAHC website.
  • Work with Technical Director to prepare and present summaries of CR reviews to general membership at the biennial conference.

CMAHC Change Request Review Framework Guidance: For CMAHC TRC Members

1.    Download a copy of the CMAHC TRC Change Request Evaluation Form checklist for summarizing your CR review.

2.    Ensure the CR adheres to CDC's MAHC Scope, Principles and Style Guidance. If the TRC does not believe it does, contact the CMAHC Technical Director immediately to clarify.

3.    Read the “How MAHC Section Should Change (#3 of CR submission) ” such as “Add new text as follows”, “Revise as follows”, “Delete without substitution”, etc. to understand how the text in “Propose NEW or REVISED or DELETED Text (#4 on CR submission)” is configured to change the code section (refer to CDC MAHC Scope, Principles and Style Guidance).

4.    Consider if the wording changes would be in conflict with another code or law (e.g. NEC, ADA requirements, VGB, etc.).
  • Ensure the suggested changes are based on the latest version of the MAHC. Some submissions have mistakenly been based on earlier MAHC Editions.

5.    Read the proposal to understand how the existing text is being changed (existing words struck out, added words underlined). Complete new sections of text are entirely underlined.
  • Remember: Where a new section of text is to be inserted into the existing code, existing sections having the same section number will be moved down and automatically renumbered.
  • Check that the reason for a deletion is valid. Sometimes submitters don’t realize when deleting sections that they are in different areas of the code (training vs. operation) so the deletion may not make sense.
  • Consider whether a desired need can be met by referencing another code (NEC, fire code, etc.) rather than adding new wording. This relates to whether the CR is within scope.
  • Ensure you know what the MAHC section is covering. There have been issues with people editing the training course section and thinking they are in operations. Repetition is needed and OK between these sections so deletions are not invited.

6.    Read the “Provide the Reason and Benefit of Suggested Change (#5 of CR submission)”. Understand the intent of the proposal and how the proposed text changes support the requestor’s intent
  • Try and clarify if there are any unintended consequences of such a change.

7.    Consider how the change(s) in the proposal revise the current code (MAHC 2018 3rd Edition) to impact aquatic facilities and the enforcement of the code (See CDC’s MAHC Scope, Principles, and Style Guidance page.)
  • Remember: The MAHC is a model code that serves as the basis for adoption of the code by all adopting jurisdictions
  • If the proposed text is editorial, please ensure it improves the clarity and interpretation of the MAHC.
  • Rather than delete wording one may feel is vague, work to clarify wording.
  • Changing CODE wording from imperative to non-imperative is usually not acceptable.
  • Combining multiple requirements in one sentence vs. separating them (for saving words) is usually not acceptable since each enforceable element is best enforced if in its own separate sentence where it can be clearly pointed to—refer to the MAHC style sheet.

8.    Where you believe there will be an increase in the cost of construction or operation/maintenance, consider the costs versus the benefits (#7 of CR submission on “Estimated Costs”). Please work, as needed, with submitter to substantiate.

9.    Review all attachments and additional information in “Substantiate Request with Supporting Information (#6 in CR submission)” used to substantiate the code request.
  • Make a note about whether you are inclined to vote either “for” or “against” the proposal. Consider the reason(s) why you are so inclined and write that reason(s) down in your notes. The reason(s) and reasoning should be based on the review criteria and not on personal preferences. That reason might be what is stated during the conference.
  • Remember: If you initially do not fully understand the submitter’s proposal, you will be able to ask questions of the submitter as part of the change request review process. Write down your questions in your notes.

10. Consult Chair/Vice-Chair and TRC members to determine whether you need more input from an appropriate Technical Support Committee. If so, engage Technical Director for referral to TSC and tracking purposes. NOTE: Many TSC assignments may have already been made so you should check and send questions to corresponding TSC group.

11. As the process moves forward:
  • Summarize all internal discussions for your CRs
  • Summarize all first-round Member comments for your CRs
  • Summarize discussion and dispensation of all first-round Member comments.