SPASA - Sanitisation Industry Guide 2026

SPASA GUIDE

SWIMMING POOL AND SPA SANITISATION MARKETING CLAIMS

A practical, industry-led approach to ensuring sanitisation products and performance claims are transparent, verifiable and comparable.

CONTENTS Guide Overview Foreword SPASA’s role Introduction Applying the Guide

Clear Guidance for Claims

Acceptable Testing and Evidence Principles Innovation Note Emerging Technologies Table 1: Claim Guidance

4 5 6 7 9 10 10 11

Standardised Testing Protocols

Introduction Evidence Hierarchy Universal Outcomes Table 2: Universal Outcomes and Claim Validation Table 3: Technology-Specific Minimum Disclosure Table 4: Evidence Hierarchy for Claim Substantiation

13 14 14 15 16 17

Innovation and Standardised Testing Supporting Credible Innovation

Testing in Practice Primary Sanitisation Supplementary Sanitisation

Examples of Credible Organisations and Evidence Sources Testing Standards Test Provider Options Declare Test Conditions Evidence Hierarchy Protecting IP while being Transparent Accredited Testing Laboratories Academic and Research Institutions Manufacturer and Industry Data Peer-Reviewed Publications and Guidelines

Holistic Sanitisation Systems Multi-Element Systems System Classification

Emerging Technologies Innovation in Sanitisation

20 22 24

30 30 30 30 31 31 31 31 31

33 34

36

Reference Material

Glossary of Sanitisation Terms

Appendix of relevant Standards, Documents, and References Disclaimer

38 42 43

FOREWORD Confidence in swimming pool and spa sanitisation begins with confidence in the products and claims that support it.

In recent years, SPASA members have raised growing concerns about the inconsistent way sanitiser performance is measured, tested and promoted. Performance claims are often difficult to compare, challenging to verify and, in some cases, potentially misleading. This inconsistency creates uncertainty for consumers, pool professionals and regulators alike, undermining trust in product performance while raising important questions around safety, compliance and fair competition.

The SPASA Guide for Swimming Pool and Spa Sanitisation Marketing Claims has been developed in direct response to this industry feedback. Led by manufacturers, suppliers and technical experts, the framework addresses the need for greater consistency, transparency and accountability across the products and systems used to achieve and maintain safe, healthy pool and spa water.

As the peak industry body representing the swimming pool and spa sector across Australia and New Zealand, SPASA is committed to promoting best practice and providing practical guidance that benefits both industry and consumers. This voluntary Industry Guide establishes clear, evidence-based principles for the validation and communication of sanitisation performance claims for residential swimming pools and spas. By encouraging consistent, transparent and verifiable claims, the framework supports informed decisionmaking, recognises responsible manufacturers and contributes to higher standards across the industry.

To develop this guide, SPASA brought together a dedicated Advisory Working Group comprising industry representatives and technical specialists. Their collective expertise has produced a practical and credible framework that enables sanitisation claims to be assessed against consistent, transparent and comparable criteria.

Ultimately, this initiative is about far more than creating a level playing field. It is about protecting public health, supporting product integrity, and strengthening confidence in the products and technologies that pool and spa owners rely on every day.

LEADING THE INDUSTRY WITH INTEGRITY SPASA’S ROLE As the peak industry body for the swimming pool and spa sector across Australia and New Zealand, SPASA is committed to fostering a professional, trusted and compliant industry.

We achieve this by promoting best practice, supporting continual improvement and expecting members to uphold their obligations under applicable legislation, regulatory requirements, industry standards and SPASA's Code of Conduct.

While SPASA provides leadership, guidance and advocacy for the industry, it is not a regulator, investigative authority or enforcement agency. SPASA does not have access to the full range of evidence, technical information or commercial and legal matters that may underpin a dispute or allegation. Accordingly, it cannot investigate or determine matters that fall within the jurisdiction of government regulators, nor does it act as an arbitrator in disputes between businesses.

Where concerns arise regarding alleged unlawful conduct, regulatory non-compliance or product safety, these matters should be referred to the relevant government authority responsible for investigation and enforcement. Outcomes from those processes, including findings, determinations or regulatory actions, may subsequently be considered by SPASA where they are relevant to membership obligations or the application of SPASA's Code of Conduct.

SPASA will continue to champion this Guide and other industry guidance as practical resources that promote transparency, consistency and best practice. However, questions relating to legal compliance or regulatory enforcement must be addressed through the appropriate statutory authorities and cannot be determined by SPASA in place of those bodies.

INTRODUCTION A FRAMEWORK FOR TRANSPARENCY AND TRUST Clear guidance. Consistent standards. Greater confidence in pool and spa sanitisation.

Reliable water sanitisation is essential to protecting public health, maintaining consumer confidence and supporting a professional pool and spa industry. As technologies evolve and product claims become more diverse, the need for clear, consistent and evidencebased guidance has never been greater.

This guide provides a practical, industry-led approach to ensuring sanitisation products and performance claims are transparent, verifiable and comparable. Developed with input from industry, technical experts and regulators, it promotes consistency, supports innovation and encourages best practice across Australia and New Zealand.

The framework is built around four key focus areas that underpin product integrity.

It establishes clear guidance for product claims, including terms such as chlorine-free, natural, mineral pools and low chemical, while outlining the evidence required to substantiate environmental, health and performance claims.

It introduces standardised testing protocols using recognised, repeatable methodologies, with testing undertaken wherever possible by independent universities, accredited laboratories or recognised certification bodies to enable fair and consistent product comparisons.

The framework also provides guidance for water quality claims relating to safety, purity and drinkability, requiring independent evidence aligned with recognised standards. It further addresses the safe and compliant reuse of pool and spa water for irrigation, supporting responsible water management.

Finally, it adopts a holistic approach to sanitisation by recognising both primary sanitisers, such as chlorine and bromine, and supplementary technologies including ultraviolet (UV), ozone and Advanced Oxidation Processes (AOP). It also considers emerging technologies to ensure claims about complete sanitisation systems accurately reflect their overall performance.

Together, these four focus areas provide a practical, transparent framework that promotes consistency, supports informed decision-making and strengthens confidence in sanitisation products and technologies across the Australian and New Zealand pool and spa industry.

APPLYING THE GUIDE SUPPORTING CONSISTENT, TRANSPARENT AND RESPONSIBLE PRODUCT CLAIMS This guidance applies to all forms of marketing communications and inmarket claims, including but not limited to: Advertising: print ads, online ads, sponsored social media posts Labelling and packaging: product labels, safety data sheets, instruction manuals.

Sales collateral: brochures, catalogues, promotional flyers, trade show displays.

Digital presence: websites, online videos, influencer partnerships, blogs, online product descriptions.

Direct representations: verbal statements made by employees, agents, sales teams, dealers, or service technicians. .

By following this guidance, industry participants will reduce the risk of: Regulatory action by regulatory bodies.

Customer disputes and claims of misrepresentation.

Brand damage or reputational harm within the market.

Harming consumer sentiment towards the industry.

Clear, consistent and evidence-based claims benefit the entire industry by helping consumers make well-informed choices, creating a level playing field for responsible manufacturers and reinforcing the credibility of SPASA members and the broader swimming pool and spa sector.

CLEAR GUIDANCE FOR CLAIMS

MARKETING CLAIMS FRAMEWORK Marketing claims play a critical role in how consumers, builders and pool professionals choose sanitisation products and systems.

They influence not only purchasing decisions but also customer expectations, brand reputation and compliance risk. However, marketing statements can easily become problematic when they are vague, exaggerated or lack technical or legal substantiation.

ACCEPTABLE TESTING AND EVIDENCE PRINCIPLES Acceptable claims should be grounded in testing and evidence that are transparent, reproducible and capable of fair comparison. Standardised testing helps ensure products are assessed under stated and comparable conditions, supports confidence for consumers and industry participants, and provides a sound basis for determining whether a claim is technically defensible and legally supportable.

For example, if a chlorine output claim is made, it should be supported by testing conducted under clearly declared conditions, such as salinity, pH, temperature and turnover rate, so that the market can understand what is being measured and compare like with like.

Without that context, differences in test environments can create misleading impressions and undermine confidence in both the claim and the broader industry.

These claims may relate to water quality outcomes, chemical usage, efficacy, health or environmental benefits, operating costs, maintenance requirements, system compatibility, or other performance characteristics.

The purpose of this section is to provide the industry with clear, practical guidance on what constitutes an acceptable claim for use in marketing, packaging, websites, social media, brochures, sales presentations and verbal representations made by salespeople.

THIS GUIDANCE IS FOCUSED ON ENSURING THAT CLAIMS ARE: Compliant with the law: All claims must meet obligations under the Australian Consumer Law (ACL), which prohibits false, misleading or deceptive conduct, including silence on important qualifications or limitations. Claims must also comply with any relevant public health regulations, APVMA requirements and applicable Australian or New Zealand Standards.

Accurate and balanced: While ‘puffery’ is a part of marketing campaigns, marketing should not overstate benefits, omit significant limitations, or use ambiguous terminology that could give consumers a false impression. Where conditions apply, such as when results are based on a certain context, these need to be clearly disclosed.

Clear definitions and terminology: All claims should use the recognised industry definitions and terminology wherever they exist. Where no accepted definition exists, which can often be the case with innovative or hybrid systems, clearly explain what the term means, and if a term could have more than one meaning, the intended meaning should be stated upfront and used consistently.

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Truthful, not misleading: Claims should present an accurate, and truthful representation of the product, its performance, and its limitations. Marketing language should not omit key information that would materially affect how a consumer or professional interprets the claim. A claim is considered truthful and non-misleading when it: Accurately describes performance: The claim reflects how the product performs under normal, representative conditions of use.

States conditions and requirements: If a product’s performance depends on specific conditions these conditions should be disclosed clearly and accessibly.

Avoids overstatement: The claim does not overly exaggerate benefits or imply outcomes that are not consistently and realistically achievable.

Does not imply regulatory endorsement: Marketing material must not suggest that the product has government approval, certification, or health authority endorsement unless such approval has been formally granted and documented.

Acknowledges limitations: If there are known limitations on the performance and ensure these are stated so the consumer can make an informed choice.

Is clear and understandable: Avoids unnecessarily technical jargon or ambiguous language that could confuse or mislead consumers.

Outlines testing and claim conditions: Provides information which gives context to the manner in which testing was carried out, the conditions, and the variables which may change the results and outcomes of the tested performance.

INNOVATION NOTE Nothing in this framework is intended to prevent innovation. Its purpose is to improve clarity, comparability and truthful communication, while remaining flexible enough to accommodate emerging and future technologies that can demonstrate the required level of performance, safety and efficacy.

EMERGING TECHNOLOGIES There are new and emerging technologies entering, or seeking to enter, the market all the time, including technologies such as photocatalytic oxidation, plasma-based systems, nanotechnology-based materials, and enzyme treatments. Innovation should be encouraged, but claims for such technologies must remain evidence-based.

In practical terms, this means the technology should be classified according to its demonstrated function and supported by appropriate evidence of efficacy, safety, operating limits and, where relevant, residual sanitising performance, rather than by novelty or marketing language alone. If the evidence shows that the technology enhances oxidation, improves water quality, or supports an existing sanitiser, it should be described in that way. If it is claimed to provide primary sanitisation or complete system protection, that higher-level role should be specifically demonstrated.

EXAMPLES Table 1: Claim Guidance, gives an indication of the type of statements that would be acceptable and contrast them with those that would not be considered acceptable. The list is not intended to be exhaustive, nor could we hope to capture all the types of statements in an industry advice guide.

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TABLE 1: CLAIM GUIDANCE CLAIM TYPE

WHEN CLAIM IS ACCEPTABLE

WHEN CLAIM IS NOT ACCEPTABLE

Low chemical, minimal chemical use, or chemical free

Swimming pool operates with a free chlorine residual of 1.0 mg/L for outdoor pools and 1.5 mg/L for indoor pools. When measurable reductions in sanitiser or chemical inputs are demonstrated (e.g. % reduction vs. baseline). Residual levels meet the minimum levels required by jurisdictional health regulations and AS 3633.

"Chemical-free pool" is misleading if any type of chemical sanitiser is used. When used as a marketing term without supporting data or where chemicals are still at normal levels.

Health and Comfort Claims (including skinrelated claims)

When supported by credible and relevant studies such as dermatological testing in the case of a skinrelated claim. Note: visit the relevant claims regulator in your jurisdiction to learn more about what kinds of health-related claims are allowed, and what evidence is required to support such claims.

When anecdotal or misleading. Health-related claims stating that swimming pool water helps reduce inflammation of eczema and psoriasis without supporting scientific evidence.

Bacteria and microorganism Inactivation

Provides a statement of level of destruction, with substantiated evidence.

"Destroys all bacteria instantly!" (unsubstantiated, overstates effect). "Kills all microorganisms".

Chlorine-Free

When no chlorine is generated, dosed, or required as a residual sanitiser. Evidence must show microbiological safety achieved by another approved method. Operates without manually adding chlorine; requires a residual sanitiser (chlorine) generated via electrolysis. Claim should state clearly the other chemical(s) used instead of chlorine to achieve sanitisation.

When a chlorinator, tablet, or any chlorine-based chemical is used. "No chlorine required" (if chlorine is still generated as part of the process).

Natural or biological systems

Refers to water quality, characteristics, treatment outcomes or active ingredients, such as plants and biological elements, that are naturally derived and verifiable, relying predominantly on naturally occurring materials, substances or processes. It excludes the routine addition of man-made, synthetic or chemically manufactured substances, except where naturally present in the source water or environment.

When the system uses synthetic chemicals but markets as "natural" to imply chemical-free. Note: specialist microbiological testing may be required to verify these claims.

Safe to Drink / Water Quality Claims

When testing meets the Australian Drinking Water Guidelines (ADWG) or New Zealand Drinking Water When implied without testing, or when only partial Standards for microbiological and chemical parameters at the point of claim. parameters (e.g. bacteria) have been tested.

No Disinfection By-Products

When testing confirms negligible chloramines, DBPs, or other measurable by-products. Note: specialist When chlorine or bromine by-products are still present chemical testing may be required to verify these claims prior to distribution. at measurable levels.

Complete Sanitisation

Complete sanitisation claims would need to be able to demonstrate monitoring and control of all relevant variables within the pool sanitisation system. There is a high risk of real-world variables causing problems with actual performance against the claim.

Note: SPASA's advice is that this claim may be inherently misleading because testing conducted under laboratory conditions may not account for real-world variables such as bather load, debris, and environmental factors, which means that despite meeting these standards, pool water quality may not remain safe for drinking under normal use conditions.

When it's implied that the system will "take care of all the chemicals" or is "set and forget".

STANDARDISED TESTING PROTOCOLS

One of the biggest challenges in comparing sanitisation products is the absence of consistent testing and reporting methods.

Currently, chlorine generators, ultraviolet (UV) systems, ozone systems, and mineralbased pools may all be tested under different conditions, using different water chemistry, and reported in ways that make comparison impossible.

For example, one manufacturer might state chlorine output based on laboratory conditions with distilled water, while another reports using high total dissolved solids (TDS) and stabiliser (cyanuric acid) present. Without common protocols, these claims are not directly comparable, leading to consumer confusion and professional disputes.

When developing its advice on the topic of Standardised Testing Protocols, SPASA has been mindful of the need to be considerate of two key factors: Testing timeframes: Independent testing can be protracted and often affected by factors outside the product developer's control. These delays can have significant financial and market consequences.

Testing costs: Certain forms of testing may be commercially prohibitive, depending on factors such as profit margins, anticipated sales volumes, the extent and complexity of testing required, and related compliance costs.

To achieve consistency, all product performance testing should reference: Recognised standards: Testing should align with recognised and relevant standards, protocols or regulatory frameworks appropriate to the claim, product or system being assessed, including APVMA requirements, AS/NZS, UL, NSF/ANSI 50:2024, ISO protocols or equivalent recognised standards. This helps ensure that testing is credible, repeatable, transparent and capable of properly substantiating any claim made.

Accredited laboratories: Tests should ideally be conducted by NATA-accredited, ILAC-recognised facilities or other credible independent testing organisations.

Declared conditions: Reports should specify the full suite of test conditions (including pH, alkalinity, salinity, CYA concentration, temperature, bather-load simulation and dosing method) to demonstrate the extent to which real-world operating conditions have been replicated.

Evidence hierarchy: 1. Independent testing by a suitably qualified third-party laboratory, university or equivalent facility (gold standard), accredited by NATA or another recognised body for the relevant test method, where such accreditation exists.

2. Peer-reviewed academic/government research.

3. Manufacturer internal data, aka ‘in-house testing.’

Production results on performance and efficacy: Because of the infinite variation which exists when considering all the variables of pool management and situation, advice should be available on the following areas: Outline variables affecting the product's efficacy.

Calculations used to determine production.

Performance testing parameters.

The operating conditions under which testing was conducted. *An appendix of relevant standards is available at the end of this guide.

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UNIVERSAL OUTCOMES To improve consistency across the swimming pool and spa industry, this Guide adopts a universal outcomes approach to claim validation. Rather than forcing all sanitisation technologies into a single test method or metric, the framework works backwards from the claim being made. Each claim needs to be linked to the type of system involved, the performance outcome asserted, the minimum testing conditions to be declared, and the level of evidence required to support it.

This approach recognises that different sanitisation technologies perform different functions. For example, a chlorine generator may be assessed by available chlorine output under stated operating conditions, while a UV system may be assessed by delivered UV dose at a defined flow rate and the resulting microbial log reduction. An ozone system may require disclosure of ozone production, contact conditions and validated oxidation or inactivation outcomes. Each technology may therefore have different primary performance metrics, but all claims should still be assessed through a common framework of transparency, comparability and substantiation.

The purpose of Table 2: Universal Outcomes is to ensure that claims are expressed in a way that is technically meaningful, fair to compare, and clear to consumers, regulators and industry participants. It also provides a pathway for innovative and emerging technologies to be assessed within the same framework, provided their performance is validated using technically defensible, reproducible and clearly disclosed methods.

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Ideally, testing reports and associated claims should be able to disclose methodology and confirm repeatability.

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TABLE 2: UNIVERSAL OUTCOMES AND CLAIM VALIDATION CLAIM OR OUTCOME CATEGORY

TYPICAL CLAIM EXAMPLE

SYSTEM PRIMARY CLASSIFICATION PERFORMANCE METRIC

MINIMUM CONDITIONS TO BE DECLARED

MINIMUM EVIDENCE MINIMUM MARKET EXPECTED DISCLOSURE REQUIREMENT

CLAIM ACCEPTABLE WHEN

CLAIM NOT ACCEPTABLE WHEN

Primary sanitisation

Provides compliant primary sanitisation

Primary sanitiser

Continuous measurable residual in pool or spa water

pH, temperature, alkalinity, salinity/TDS. Where relevant: cyanuric acid, circulation/turnover, indoor or outdoor use

Independent or reproducible testing demonstrating maintenance of compliant residual under representative use conditions

Type of residual sanitiser, target operating range, conditions required to maintain compliance

A continuous measurable residual is achieved and maintained under declared conditions

No measurable residual is maintained, or compliance is implied without evidence

Sanitiser production / output

Produces 25 g/hr chlorine

Primary system or primary generating component

Available sanitiser output under standard conditions

Temperature, salinity/TDS, basis of calculation

Independent or reproducible bench testing under declared conditions

Output figure, unit of expression, standard test conditions, sizing assumptions

Output is stated under clear and reproducible standard conditions

Output is stated without declared conditions or is not comparable

Microbial inactivation

Destroys 99.9% of E. coli

Primary, secondary or supplementary depending on system

Log reduction or percentage reduction of nominated organism over defined period

Test organism, contact Accredited or time, water chemistry, otherwise credible temperature, flow rate, independent testing turbidity/UV transmittance where relevant

Organism tested, result achieved, conditions of test, whether claim relates to component or whole system

Specific, limited claim is supported by evidence

Absolute or exaggerated claims are made without substantiation

Oxidation / chloramine reduction

Reduces chloramines by 40%

Secondary or supplementary

Reduction in combined chlorine, chloramines or other oxidisable compounds

Starting concentration, Independent or contact time, flow, reproducible temperature, pH, comparative testing operating conditions

Parameter reduced, Reduction is extent of reduction, measurable and conditions and repeatable limitations

Claim implies total elimination or stand-alone sanitisation without evidence

Chemical demand reduction

Reduces Secondary, chlorine supplementary or demand by up whole system to 30%

Reduction in primary sanitiser demand against baseline while maintaining compliant water quality

Baseline comparator, operating conditions, bather load simulation where relevant, temperature and UV exposure where relevant

Comparative testing against a clearly defined baseline

Basis of comparison, conditions, continued need for residual sanitiser

Claim implies chlorine-free operation or no residual requirement

Measured surrogate parameters and/or validated comfort outcomes

Water balance, chloramine levels, TDS where relevant, study conditions and maintenance conditions

Credible third-party studies or measurable correlated data

Basis of claim, any Claim is qualified conditions or and evidencequalifications, based whether claim is sensory or clinically supported

Water quality / Gentler on comfort skin, reduced odour, softer water

Whole system or supplementary

Reduction is demonstrated while maintaining compliant sanitiser residuals and water quality

Claim is anecdotal, absolute or misleading

TABLE 2: UNIVERSAL OUTCOMES AND CLAIM VALIDATION CLAIM OR OUTCOME CATEGORY

TYPICAL CLAIM EXAMPLE

SYSTEM PRIMARY CLASSIFICATION PERFORMANCE METRIC

MINIMUM CONDITIONS TO BE DECLARED

MINIMUM EVIDENCE EXPECTED

MINIMUM MARKET DISCLOSURE REQUIREMENT

CLAIM ACCEPTABLE WHEN

Water clarity

Improves clarity

Whole system

Turbidity or equivalent measurable clarity parameter

Filtration conditions, circulation, loading conditions and sampling method

Measured testing under representative conditions

Metric used, operating conditions and limitations

Clarity is linked to Subjective language a measurable is used as if parameter objectively proven

Potable / safe to Safe to drink drink*

Whole system only

Compliance with applicable drinking water criteria at point of claim

Microbial and chemical parameters, sampling point, timing and limitations

High-level independent testing against relevant drinking water guideline criteria

Exact scope of claim, point of sampling and limitations

Claim is narrowly qualified and supported across all relevant parameters

Claim is implied from partial testing or used broadly without qualification

Irrigation / reuse Suitable for irrigation after treatment

Whole system / operational claim

Compliance with relevant reuse criteria

Chemical residuals, salts, metals, pH, treatment steps and end-use conditions

Testing aligned to applicable reuse guidance

Treatment steps, restrictions, limitations and intended use

Claim is conditional, qualified and treatmentdependent

Claim implies unrestricted direct reuse without treatment

Chlorine-free

Chlorine-free pool

Whole system claim

Absence of chlorine dosing, generation and residual dependence

Full system description, all inputs and all required residuals

System-level validation

What sanitiser is used instead and how safety is achieved

No chlorine is generated, dosed or required

Chlorine is still generated, added or relied upon

Natural / lowchemical / mineral

Natural, lowchemical, mineral pool

Descriptor claim

Defined characteristic supported by measurable evidence

Full system description, comparator where relevant and operating conditions

Evidence Clear definition of Term is defined Term is vague, proportionate to the term used, and substantiated undefined or the claim supporting data and misleading limitations

Complete sanitisation solution

Complete sanitisation system

Whole system

Combined system performance at system level

All components operating together, representative use conditions and maintenance dependencies

System-level validation, not component-only data

Role of each Whole system component, residual performance is sanitiser validated requirement, limits and conditions

CLAIM NOT ACCEPTABLE WHEN

Supplementary device is marketed as a complete stand-alone sanitisation solution without supporting evidence

*As noted earlier: SPASA's advice is that this claim may be inherently misleading because testing conducted under laboratory conditions may not account for real-world variables such as bather load, debris, and environmental factors, which means that despite meeting these standards, pool water quality may not remain safe for drinking under normal use conditions.

TABLE 3: TECHNOLOGY-SPECIFIC DISCLOSURE REQUIREMENTS The Universal Outcomes Table is intended to be supported by technology-specific disclosure requirements. These requirements do not force different technologies into the same test method but ensure that each class of product declares the minimum information needed for fair comparison and technically sound claims.

TECHNOLOGY

CLASSIFICATION

CORE COMPARABLE METRIC

MINIMUM CONDITIONS TO DECLARE

MINIMUM ADDITIONAL DISCLOSURE

MINIMUM CLAIM BOUNDARY

Liquid chlorine, granular chlorine, tablet chlorine

Primary sanitiser

Residual free chlorine maintained; dosing rate where relevant

pH, temperature, cyanuric acid where relevant, pool volume, dosing regime

Product type, active strength, dosing basis, intended use conditions

Must not imply chemical-free or maintenance-free operation

Salt chlorinator / chlorine generator

Primary sanitiser

Available chlorine output at standard conditions (g/hr)

Temperature, salinity/TDS. Ph, cyanuric acid range may be mentioned where relevant, circulation conditions

Recommended pool size, climate or region sizing assumptions, operating salinity range

Must not make output claims without declared test conditions

Bromine systems

Primary sanitiser

Residual bromine maintained; feed/output rate where relevant

pH, temperature, water balance, feeder conditions.

Indoor/outdoor suitability, UV limitations, operating range

Must not imply cyanuric acid provides stabilisation benefit

UV systems

Secondary / supplementary

Delivered UV dose at defined flow rate; validated organism reduction

Flow rate, UV transmittance.

Turbidity, lamp condition can also be considered.

Lamp type, lamp life, intensity monitoring, alarm/fail-safe features

Must not be marketed as a stand-alone primary sanitiser

Ozone systems

Secondary / supplementary

Ozone output and validated oxidation/inactivation outcome

Air feed conditions, humidity where relevant, temperature, contact time, injection/contact arrangement

Off-gas destruction, quenching/removal where relevant, installation limitations

Must state that a compliant residual sanitiser is still required

AOP systems

Secondary / supplementary

Whole-of-system validated outcome

Full system configuration, flow, contact conditions, water chemistry, temperature

Type of AOP, oxidant inputs, effect on chloramines and/or sanitiser demand

Must not claim removal of all contaminants without evidence

Ionisers

Supplementary

Target ion concentration achieved in water

pH, flow, operating time, water balance

Copper/silver levels, staining risks, health limits, pairing requirements

Must not be described as a complete sanitisation solution

Ultrasonics

Supplementary / algae-management

Coverage area or volume and validated performance outcome

Frequency, power, installation arrangement, pool conditions

Intended purpose, maintenance needs, evidence source

Must not be described as a stand-alone sanitiser

Mineral systems

Descriptor / system Depends on the actual sanitising type rather than mechanism used sanitiser on its own

Conditions relevant to actual primary sanitiser

Mineral composition, role of minerals, whether chlorine is generated or still required

Must not imply chlorine-free operation where chlorine remains the active sanitiser

Multi-element / holistic systems

Whole system

Full operating configuration, interactions between elements, maintenance dependencies

Function of each component, required residual, claimed reductions, limitations

Must be tested and described at system level, not only by component or in isolation

Whole-of-system compliant outcome plus any validated added benefit

TABLE 4: EVIDENCE HIERARCHY FOR CLAIM SUBSTANTIATION The level of evidence required should be proportionate to the nature and strength of the claim. The stronger, broader or more safety-sensitive the claim, the stronger the evidence that should support it.

CLAIM TYPE

INDICATIVE RISK / SENSITIVITY

PREFERRED EVIDENCE LEVEL

Potable / safe to drink / public health protection claims

Very high

Independent accredited laboratory testing and, where relevant, alignment with applicable guideline criteria. See SPASA’s previous notes in this guide.

Complete sanitisation / superiority / health-related claims

High

Independent third-party testing, preferably accredited or supported by peer-reviewed evidence.

Microbial reduction, oxidation or sanitiser demand reduction claims

Moderate to high

Independent testing or reproducible comparative testing with full methodology

Output claims, operating range, sizing guidance

Moderate

Reproducible bench or field testing with clear methodology and declared conditions

Descriptive claims with measurable basis

Moderate

Measurable performance data or third-party study where relevant

Simple technical description

Lower

Transparent and accurate product data, provided it is not misleading

INNOVATION AND STANDARDISED TESTING

INNOVATION AND TESTING FRAMEWORKS The swimming pool and spa industry is built on continual innovation, in products, technologies, water treatment and system design. If we want that innovation to flourish, our approach to testing and evidence must also evolve.

A modern, forward-looking industry cannot rely solely on legacy tests developed for today’s products; it must be willing to explore and embrace new testing approaches that better reflect and tomorrow’s solutions.

This is especially important where no established or standardised test yet exists for a new or hybrid technology. In those cases, it is both reasonable and necessary for industry, regulators and experts to work together to develop, trial and refine new test methodologies. Over time, the most robust of these should be validated, documented and, where appropriate, incorporated into future standards and guidelines.

At the same time, emerging testing methods should help both new and existing sanitisation systems demonstrate that they are safe, effective and capable of meeting current, and anticipated future legislative and regulatory requirements. In short, our testing framework should be rigorous but not rigid: strong enough to protect consumers, health and safety, yet flexible enough to encourage genuine innovation and continuous improvement.

Continual improvement is best supported by credible, repeatable and transparent ways to evaluate performance. Where established test methods exist, they should be applied consistently. Where they do not exist or where current methods are not fit-for-purpose, appropriate evaluation protocols may be developed, provided they are technically defensible, independently reproducible, and clearly scoped to the intended use conditions.

Any new or adapted test approach must be selected and applied with care to ensure it accurately characterises performance, including limitations, operating parameters, maintenance dependencies, and variability across real-world conditions. Testing must not be used to imply outcomes beyond what has been demonstrated; claims should remain evidence-based and aligned with applicable regulatory requirements and recognised standards.

This section should be read alongside the relevant parts of this framework covering system description, validation evidence, claims substantiation, and documentation for compliance (including any requirements for residual sanitiser, monitoring, and consumer information). Performance should be validated at the system level and expressed in a way that supports regulatory decision-making, professional practice, and consumer confidence.

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A modern, forward-looking industry cannot rely solely on legacy tests developed for today’s products; it must be willing to explore and embrace new testing approaches that better reflect and tomorrow’s solutions.

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TESTING IN PRACTICE

To illustrate how claim standardisation should apply across technologies, the following examples demonstrate how product claims can be validated fairly and consistently.

Note: this guide uses language which refers to primary and supplementary sanitisation systems. This language, and the categorisation of certain systems as one or the other, is in-line with definitions which can be found in a variety of legislative, regulatory, and health advice documents from Australia and the rest of the world.

PRIMARY SANITISATION A range of primary sanitising methods are currently used in swimming pools and spa pools, with chlorine and bromine-based systems remaining the most common and widely recognised.

While these are the principal sanitising approaches in current use, the industry continues to evolve, and new or emerging treatment methods may develop over time. Any such methods should be assessed against applicable health, safety, performance and regulatory requirements before being adopted as an equivalent primary sanitiser.

CLAIM PRACTICE EXAMPLES Correct: Present a primary sanitiser as the treatment element that provides the principal sanitising effect and, where required by the applicable regulatory framework, maintains a continuous and measurable sanitising residual in the water.

Incorrect: Describe a system as a primary sanitiser where it does not provide the required sanitising function or residual, or imply that another supporting process can be treated as primary sanitisation without appropriate regulatory recognition and validation.

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CHLORINE GENERATORS Chlorine generators are a common form of primary sanitisation used in swimming pools and some spa pools. These systems produce available chlorine by electrolysis, usually from dissolved salt or other chloride ions in the water. The chlorine generated provides the same essential sanitising function as chlorine added by other methods, namely the maintenance of a measurable residual to control microbiological risk.

As chlorine is a recognised primary sanitiser, chlorine generator claims should be based on verifiable technical performance, including chlorine output under declared operating conditions and the ability of the system to maintain an effective residual. Output can vary depending on water chemistry, temperature, salinity, cyanuric acid levels, circulation, and cell condition. For this reason, all chlorine production claims should be expressed under stated test conditions so they can be fairly compared across products.

Where a system generates chlorine through electrolysis, it should not be described as “chlorine-free”, regardless of whether the source is salt or a mineral blend. The active primary sanitiser remains chlorine, and claims should reflect that position accurately.

Chlorine-generating systems should state actual chlorine output in g/hr, expressed as gas chlorine equivalent, so that products can be compared on a consistent and verifiable basis. Consideration should also be given to guidance linking chlorine output to pool size, usage conditions and climatic region.

Where chlorine output is stated, the test conditions used to achieve that output should also be disclosed. At a minimum, these should include: g/hr as gas chlorine equivalent.

Salinity or TDS. Temperature, this is typically between 25°C and 28°C. pH, with a recommended range of 7.4-7.8.

Recommended sizing.

Climate assumptions, where relevant.

Cyanuric acid level or range, where applicable.

Additional technical information, such as A/m², anode type and coating life, may be disclosed as optional technical data, but should not be treated as a standard minimum requirement for general guidance.

Within the current regulatory and industry framework, chlorine should continue to be identified as a primary sanitiser. While technologies and treatment methods may continue to evolve, chlorine remains the recognised benchmark primary sanitiser, and guidance should reflect that position unless and until the regulatory framework changes.

CLAIM PRACTICE EXAMPLES Correct: As an example, “Testing chlorine output at 25°C, pH 7.4, salinity of 4,000 ppm, under defined circulation conditions.”

Incorrect: Claiming “highest chlorine output in the industry” without specifying water chemistry or test conditions, making comparisons meaningless.

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SUPPLEMENTARY SANITISATION A range of supplementary sanitising methods are currently used in swimming pools and spa pools to support, enhance or complement the effectiveness of a primary sanitiser.

These may include systems or processes intended to improve oxidation, reduce contaminant load, assist with water clarity, or provide an additional barrier to microbial growth. While such methods can play an important supporting role in overall water treatment, they do not replace the need for a compliant primary sanitiser where a continuous and measurable sanitising residual is required.

As the industry continues to evolve, new or emerging supplementary treatment methods may develop over time. Any such methods should be assessed against applicable health, safety, performance and regulatory requirements before being adopted or promoted for use.

CLAIM PRACTICE EXAMPLES Correct: Describe supplementary sanitisation as a supporting treatment that enhances water quality or treatment performance, without replacing the primary sanitiser.

Incorrect: Present supplementary sanitisation as a standalone sanitising solution or as removing the need for primary sanitisation.

ULTRAVIOLET (UV) SYSTEMS The UV light effective for inactivating microorganisms is in the UV-B and UV-C ranges of the spectrum (200–280 nm), with maximum effectiveness around 265 nm.

This guide recommends the following dosage levels:

TARGET PATHOGEN

DOSAGE FOR DRINKING WATER (mJ/CM²) TO ACHIEVE 4 LOG REMOVAL

Protozoa

22

Viruses

186

E. coli

22

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Claims regarding UV performance should be based on delivered UV dose at a defined and validated flow rate, together with the specific organism or parameter tested and the outcome achieved.

This is necessary because UV performance depends on several operating factors, including flow rate, UV transmittance, turbidity, lamp condition, lamp age, sleeve cleanliness and reactor design.

Any UV claim should therefore disclose, as relevant, the delivered UV dose, validated maximum flow rate, organism tested, performance result, and any maintenance or monitoring requirements necessary to maintain that performance. Systems should not be operated above the validated flow rate at which performance was established, as this may reduce delivered dose and compromise treatment effectiveness.

CLAIM PRACTICE EXAMPLES Correct: Validating microbial inactivation through third-party testing at accredited laboratories using ISO/IEC 17025 protocols.

Incorrect: Stating “kills all bacteria instantly” without data or only referencing internal manufacturer tests without peer-reviewed verification.

CLAIM BOUNDARY UV systems may be promoted as a supplementary treatment technology that contributes to microbial inactivation, chloramine control and improved water quality, provided those outcomes are supported by appropriate evidence.

They should not be promoted as a complete or stand-alone sanitisation solution unless the claimant can demonstrate, at system level and under applicable regulatory requirements, that the complete installation provides the required level of protection, including any required continuous residual sanitiser in the body of water.

For UV systems the key parameters: Stated UV dose at a defined flow rate.

Basic information on lamp type and expected lamp life.

Note on turbidity <1 and efficacy.

Megajoules.

Wattage.

Expected life/operating hours.

Frequency.

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OZONE DISINFECTION SYSTEMS Ozone is a strong oxidant and disinfectant that is moderately soluble in water. In swimming pools and spa pools, it may be used as a supplementary treatment system to assist with oxidation and microbial control. However, ozone does not provide a persistent sanitising residual in the pool water and does not replace the need for a compliant primary sanitiser where a continuous and measurable residual is required.

In water treatment applications, ozone dose rates vary according to water quality, contaminant load and treatment objectives.

The appropriate dose should be established through bench-scale ozone demand testing, pilot plant testing, or other validated assessment methods, supported by available Ct data (concentration × contact time) for the target microorganisms. The contact time required for effective inactivation may range from seconds to minutes, depending on the organism being treated, and is influenced by factors such as temperature and water chemistry. In general, ozone can achieve oxidation and disinfection more rapidly than chlorine or chloramines, although more resistant organisms, such as protozoan cysts, may require longer contact times.

To support meaningful comparison between ozone systems, product information and performance claims should be based on clearly stated, verifiable and repeatable test conditions.

At a minimum, disclosed testing information should include: Ozone production rate stated in g/h under defined operating conditions Feed gas conditions, including air or oxygen source, air flow rate, temperature and, where relevant, humidity.

Method of ozone introduction and contact, including injection point, mixing method and whether a contact vessel is used.

Contact time achieved under test conditions.

Water chemistry conditions, including pH, temperature, organic load and, where relevant, bather load assumptions Validated performance outcomes, such as chloramine reduction, oxidation performance, or log reduction of specified test organisms under stated conditions.

Off-gas management, including whether degassing, ozone destruction, quenching or other removal measures are required.

Installation limitations or operating assumptions, including whether the system is intended for indoor or outdoor use.

Claims relating to ozone performance should be limited to outcomes that have been properly validated under disclosed test conditions. Any such claim should also clearly state that ozone is a supplementary treatment system only, and that a compliant primary sanitiser remains necessary to maintain safe pool or spa water.

CLAIM PRACTICE EXAMPLES Correct: “Ozone output: 1.5 g/h using dried air at 20°C and stated flow conditions, injected by venturi to a contact vessel, tested at stated water temperature and chemistry conditions.”

Present ozone as a supplementary treatment, not a replacement for a primary sanitiser.

State ozone output and test conditions clearly.

Support claims with recognised or validated testing.

Disclose injection method, contact time and off-gas management.

State whether the system is for indoor or outdoor use.

Maintain a compliant primary sanitiser residual.

Incorrect: Present ozone as a standalone primary sanitiser.

Make performance claims without disclosing test conditions.

State ozone output without key operating parameters.

Omit off-gas, degassing or destruction requirements where relevant.

Suggest ozone removes the need for a measurable sanitiser residual.

Rely on selective test conditions to support marketing claims.

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ADVANCED OXIDATION PROCESS (AOP) Advanced Oxidation Process (AOP) is a water treatment process that generates highly reactive hydroxyl radicals (•OH) to oxidise and break down contaminants, including organic matter, some microorganisms and unwanted by-products in water.

In pool and spa systems, AOP is generally used as a secondary or supplementary treatment to improve water quality and reduce oxidant demand, rather than as a stand-alone primary sanitiser.

CLAIM PRACTICE EXAMPLES Correct: Demonstrating hydroxyl radical generation capacity under specified conditions, with third-party validation of combined disinfection and oxidation efficacy.

Incorrect: Broad claims such as “removes all contaminants” without evidence or explanation of system limitations.

IONISERS For ionisers, a small number of clear parameters should be disclosed to support comparison and proper positioning: Target ion concentrations in the water, such as copper and/or silver levels in mg/L, under normal operating conditions.

Validated performance outcomes at those levels, such as reductions in algae or specified bacteria over a defined period.

Clear acknowledgement of applicable health, water quality and staining limits for metals.

Clear statement that ionisers are supplementary only and do not replace the need for a compliant primary sanitiser.

CLAIM PRACTICE EXAMPLES Correct: Confirm copper and silver ion concentrations under controlled conditions, supported by evidence of bacteriostatic and algacidal performance.

Incorrect: Promote ionisers as a complete sanitisation solution without clearly stating that they are required to be paired with a compliant primary sanitiser and, where relevant, any complementary or supplementary treatment system.

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ULTRASONICS For ultrasonic systems, particularly as they remain an emerging technology in pool applications, testing and product information should remain clear, practical and evidence based.

At a minimum, disclosed parameters should include: Basic system specifications, such as power, frequency, and intended coverage area or water volume.

Documented performance outcomes in real pool conditions, such as reduction in visible algae growth or biofilm over a defined period and under stated operating conditions.

A clear statement of system position, confirming that, based on current evidence, ultrasonics should be treated as a supplementary or algae-management technology, not as a standalone sanitiser.

CLAIM PRACTICE EXAMPLES Correct: Clearly describe ultrasonics as a supplementary algae-management system and support claims with stated specifications and real-world performance data.

Incorrect: Present ultrasonics as a primary sanitiser or make unsupported claims about sanitisation or disinfection performance.

COMPLEMENTARY PROCESSES Complementary Processes are processes, treatments or operating practices that support the overall sanitisation system, water quality and user experience, but are not themselves the primary sanitiser and do not replace the need for a compliant primary sanitising residual. They operate alongside primary, secondary and supplementary sanitisation measures and may assist with water balance, clarity, comfort, stability, hydraulic performance or overall system efficiency.

CLAIM PRACTICE EXAMPLES Correct: Describe complementary processes as supporting water quality and system performance, not as standalone sanitising solutions.

Incorrect: Represent complementary processes as though they provide primary sanitisation or remove the need for a compliant sanitising residual.

EXAMPLES OF THE PROCESSES THAT MAY BE DISCUSSED INCLUDE: Filtration Coagulation or flocculation pH correction Alkalinity and calcium hardness adjustment Cyanuric acid management Phosphate control

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Clarifiers Scale inhibition Degassing or air stripping Dilution or water replacement Hydraulic optimisation and turnover management

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EXAMPLES OF CREDIBLE ORGANISATIONS AND EVIDENCE SOURCES

VALIDATING CLAIMS As mentioned earlier in this guide, when validating claims evidence should ideally come from recognised, independent and technically competent sources.

The following examples provide guidance on credible approaches to testing and evidence: TESTING STANDARDS Reference APVMA, AS/NZS, NSF/ANSI 50:2024, UL, ISO, or an equivalent standard, code or guideline relevant to your device and claim. You do not need to meet every standard; cite the ones that match your product class and the claims you make. Note: there may not always be an available standard which applies.

NSF/ANSI 50-2024 – Equipment and Chemicals for Swimming Pools, Spas, Hot Tubs, and Other Recreational Water Facilities: Provides recognised benchmarks for product performance and safety, including chemical feeders, filters, and disinfection systems.

ISO (International Organisation for Standardisation): Internationally recognised testing and quality management standards (e.g. ISO 17025 laboratory accreditation).

AS/NZS Standards: National standards such as AS 3633 (Private Swimming Pools – Water Quality), AS 1926.3 (Water Recirculation Systems), or AS/NZS 3000 (Electrical Installations) where relevant.

TEST PROVIDER OPTIONS There are different testing options available: Preferred: NATA-accredited / ILAC-recognised or other credible laboratory reports.

Manufacturer testing (cost-efficient): In-house testing may be used for screening or supplementary evidence if you provide full, reproducible methods and allow spot audit or replication on request.

DECLARE TEST CONDITIONS All reports, regardless of provider, should state the test conditions so results are comparable: pH, alkalinity, salinity/TDS, CYA, temperature, bather-load simulation (if used), dosing method/rate, contact time, hydraulics/turnover. A one-page summary table is sufficient.

EVIDENCE HIERARCHY Independent and verifiable evidence is the most trustworthy; however, ‘in-house’ testing can be accurate when it is replicable and transparent.

Best Practice: Independent, accredited lab testing.

Strong: Peer-reviewed academic/government research applicable to your device and conditions.

Supportive: Manufacturer internal data with full methodology (used to supplement, not replace, stronger evidence where claims are critical).

CLAIM–EVIDENCE FIT It is advisable to match the level of evidence to the claim.

Broad or superiority claims (e.g., “kills X faster than Y”) should lean on higher-tier evidence.

Basic performance disclosures may rely on well-documented internal or independent non-accredited tests.

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PROTECTING IP WHILE BEING TRANSPARENT Companies may take steps to protect their IP. This may include redacting proprietary schematics. Methods, variables, and results should be made visible so others can understand and, if needed, replicate the outcome.

This framework encourages consistency and comparability while letting companies choose the most practical, cost-appropriate path to substantiate their claims.

ACCREDITED TESTING LABORATORIES NATA-Accredited Laboratories (or equivalent ILAC-recognised labs): Testing performed under ISO/IEC 17025 to ensure repeatability, traceability and independence.

Certified calibration and verification facilities: For confirming dosing accuracy, sensor calibration or output measurement devices.

ISO standards related to the practices and methods used by a testing laboratory are not of themselves evidence that the correct tests are carried out. Reference to the nominated standards for the particular sanitisation method being tested must also be available.

ACADEMIC AND RESEARCH INSTITUTIONS Universities and Research Institutes: Independent testing and validation under controlled experimental design, with results published or peer-reviewed where possible.

Government research facilities: For example, CSIRO (Australia) or NIWA (New Zealand) studies on water treatment performance.

UL Solutions: As a global safety science leader in manage risk and verifying regulatory compliance..

MANUFACTURER AND INDUSTRY DATA Controlled manufacturer dosing data: Acceptable where testing is done under documented, reproducible conditions (e.g. specified temperature, pH, bather load simulation) and made available for verification.

In-field performance trials: Multi-site trials with statistically valid sample sizes, conducted over a meaningful period (e.g. full season) to demonstrate real-world effectiveness.

PEER-REVIEWED PUBLICATIONS AND GUIDELINES Published research: Articles in recognised journals (e.g. Water Research, Journal of Environmental Health) that validate claimed outcomes.

Government guidelines: Alignment with Australian Drinking Water Guidelines (ADWG), World Health Organisation (WHO) guidelines, or jurisdictional public health codes.

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HOLISTIC SANITISATION SYSTEMS

UNDERSTANDING SANITISATION SYSTEMS Sanitisation in swimming pools and spas is not achieved by a single element in isolation. It is the outcome of a coordinated system of treatment technologies, operating conditions and water management practices working together to maintain microbiological safety, water clarity and user comfort.

These may include a primary sanitiser such as chlorine or bromine, together with secondary, supplementary or complementary systems such as ozone, ultraviolet, Advanced Oxidation Process (AOP), filtration, water balance control and other emerging technologies.

Problems arise where secondary, supplementary or complementary systems are promoted as though they are complete standalone sanitisation solutions, or where claims overstate the ability of a single component to deliver full disinfection without clearly acknowledging the continuing role of a compliant primary sanitiser and sanitising residual.

This section provides guidance on how sanitisation systems should be described, positioned and validated as a whole, so that consumers and industry participants understand what each component does, how the components interact, and what limitations apply.

In particular, it seeks to: Clarify system roles by distinguishing between primary, secondary, supplementary and complementary elements.

Reduce misrepresentation by discouraging claims that overstate what non-primary systems can achieve on their own.

Support responsible innovation by allowing new and emerging technologies to be considered within an evidence-based and compliant framework.

Promote system transparency by requiring that performance claims identify the conditions, limitations and operating assumptions on which they rely.

Align with applicable standards and regulation by recognising that claims about complete or effective sanitisation must be assessed against relevant health, safety, water quality and recirculation requirements, including, where applicable, AS 3633 and relevant jurisdictional health requirements.

MULTI-ELEMENT SYSTEMS A multi-element approach provides layered risk control where each component addresses different pathways of contamination and different operational conditions.

A primary sanitiser with an effective residual provides ongoing protection throughout the pool/spa and distribution system, while supplementary technologies can reduce oxidant demand, improve breakpoint/combined-chlorine management, enhance clarity, and provide additional inactivation under peak bather loads or variable water chemistry.

Used together, these elements can offer greater robustness and consistency than any single technology operating in isolation, because overall performance is less sensitive to one parameter (e.g., dose, contact time, pH, flow rate, lamp intensity, or maintenance condition) drifting out of specification.

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SYSTEM CLASSIFICATION The current regulatory framework for pool and spa water treatment is based on the need to maintain microbiologically safe water through effective sanitisation.

For the purposes of this Guide, products, systems and processes should be classified according to the function they perform in achieving and maintaining safe pool or spa water.

In Australia, pool and spa sanitisers are regulated by the APVMA, and new sanitiser products must satisfy requirements relating to efficacy, safety, trade and labelling before registration.

APVMA guidance also reflects the longstanding position that pool and spa sanitisation has principally relied on chlorine- and bromine-based sanitisers, while allowing alternative or novel products to be considered where equivalent efficacy and safety can be demonstrated.

Primary sanitiser: The treatment element that provides the principal microbiological control function and maintains a continuous, measurable sanitising residual in the body of the pool or spa water.

Secondary sanitiser: A treatment element that enhances disinfection performance but does not provide the continuous residual protection ordinarily required of a primary sanitiser, and is therefore often required to be used with a compliant primary sanitiser unless demonstrated otherwise.

Supplementary treatment: A treatment element that provides additional benefits such as clarity improvement, algae suppression, oxidant support, comfort enhancement or reduced sanitiser demand, but does not replace the need for a compliant primary sanitiser unless demonstrated otherwise.

This Guide also recognises that technologies, standards and regulatory settings may evolve over time.

Accordingly, system classification should provide a practical framework for describing the present function of a product or process, while allowing scope for innovation where a new or hybrid technology can demonstrate, through credible evidence and regulatory acceptance, that it performs a different or expanded role.

APVMA guidance expressly allows alternative information and arguments to be considered for new pool and spa sanitiser products, provided the efficacy criteria are satisfied.

Nothing in this classification framework is intended to prevent innovation. Its purpose is to improve clarity, comparability and truthful communication, while remaining flexible enough to accommodate emerging and future technologies that can demonstrate the required level of performance, safety and efficacy.

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EMERGING TECHNOLOGIES

There are new and emerging technologies entering, or seeking to enter, the market all the time, including technologies such as photocatalytic oxidation, plasma-based systems, nanotechnology-based materials, and enzyme treatments.

Innovation should be encouraged, but claims for such technologies must remain evidence-based.

In practical terms, this means the technology should be classified according to its demonstrated function and supported by appropriate evidence of efficacy, safety, operating limits and, where relevant, residual sanitising performance, rather than by novelty or marketing language alone.

If the evidence shows that the technology enhances oxidation, improves water quality, or supports an existing sanitiser, it should be described in that way. If it is claimed to provide primary sanitisation or complete system protection, that higherlevel role should be specifically demonstrated.

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REFERENCE MATERIAL

GLOSSARY ADVANCED OXIDATION PROCESS (AOP) A treatment process that combines oxidisers such as ozone, UV light, and/or hydrogen peroxide to generate hydroxyl radicals.

Advanced Oxidation Process (AOP) is a secondary water treatment system that generates highly reactive oxidising species, such as hydroxyl radicals, within the recirculation system to rapidly reduce microorganisms and oxidise dissolved organic contaminants.

Because these oxidants react almost immediately and do not persist in the water body, AOP does not provide a disinfectant residual and must be used in conjunction with an approved primary sanitiser and appropriate circulation and monitoring.

ALKALINITY (TOTAL ALKALINITY) Total alkalinity is a measurement of the resistance of the pool water to a change in pH. For example, If the pool water has high pH and low total alkalinity, the addition of a small amount of acid will lower the pH sharply.

BREAK POINT CHLORINATION Break point chlorination is the process of adding a specific amount of free available chlorine to the pool or spa water to completely oxidise chloramines (combined chlorine), leaving only free chlorine residual behind.

To achieve breakpoint chlorination and oxidise chloramines, a minimum concentration of 10 times the amount of Chloramines (combined chlorine) must be added to the water.

BROMINE A halogen-based primary sanitiser often preferred in spas and heated pools, Bromine is a primary sanitiser that provides a disinfectant residual in pool and spa water through the formation of active bromine species, primarily hypobromous acid, which inactivates microorganisms through oxidative disruption.

Bromine remains effective across a wider pH range and at elevated temperatures, but effective sanitisation still depends on maintaining the required residual and circulation, with oxidation support needed to regenerate active bromine under organic load.

CHLORAMINES Chloramines / Combined Chlorine: Chlorine that has reacted with, and become chemically bound to, compounds (such as ammonia, sweat, urine, or bather waste).

Combined chlorine is a poor sanitiser and is the primary cause of "chlorine odour" and eye irritation in swimming pools and spa water.

CHLORINE The most common primary sanitiser used worldwide, available as liquid (sodium hypochlorite), granular (calcium hypochlorite), tablets, or is generated on-site via electrolysis in saltwater or mineral pools.

Chlorine provides a disinfectant residual in pool and spa water through the continuous formation of free available chlorine, primarily hypochlorous acid, which inactivates microorganisms by disrupting cellular processes.

Effective sanitisation relies on maintaining the required residual, as chlorine demand increases with organic loading and its efficacy is influenced by pH, circulation, and contact time, requiring routine monitoring.

CHLORINE-FREE A marketing term suggesting no chlorine is used. In practice, most “chlorine-free” systems rely on alternative chemicals (e.g., hydrogen peroxide, bromine) or supplementary oxidisers.

Such claims must be supported by data proving that water quality meets health regulations without chlorine.

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CYANURIC ACID (CYA) / STABILISER A chemical added to outdoor pools to protect free chlorine from degradation by sunlight.

DISINFECTION BY-PRODUCTS (DBPS) Secondary substances that form when sanitising agents react with organic or inorganic matter in pool or spa water.

FREE CHLORINE Free chlorine refers to the portion of chlorine in pool or spa water that is available to actively sanitise. It includes both hypochlorous acid and hypochlorite ion, the two active disinfecting forms of chlorine present in water.

FRESHWATER POOL A term describing pools with low salinity compared to salt-chlorinated pools.

Despite the name, freshwater pools still require chemical treatment to maintain safe, sanitary conditions.

HEALTH-RELATED CLAIMS Any statement indicating that a product or system provides a benefit to human health, comfort, or wellbeing in relation to pool or spa use.

HOLISTIC SANITISATION SYSTEM An approach that considers all components of water treatment together — primary sanitisation (chlorine, bromine), secondary systems (UV, ozone, AOP), filtration, and hydraulics.

Products marketed as “complete systems” must prove that they collectively achieve microbiological safety and water quality compliance.

IN-HOUSE TESTING (AKA MANUFACTURER TESTING) Test results generated by the manufacturer using its own facilities and personnel, based on a documented, transparent and reproducible methodology that another competent party could reasonably replicate.

IONISER A water treatment system that releases controlled amounts of copper and/or silver ions into pool water through electrically activated electrodes.

These metal ions inhibit algae growth and suppress bacteria.

LOW CHEMICAL Describes pools or systems that reduce chemical use compared to conventional pools, usually by combining lower primary sanitiser levels with supplementary technologies.

Such claims must be validated with data showing reduced chemical consumption while maintaining compliant microbiological water quality.

LOW-FUME SYSTEMS Sanitisation systems or chemicals that release minimal airborne vapours, reducing odour and improving air quality around the pool or spa.

MINERAL POOL A pool that uses magnesium chloride, potassium chloride, or similar salts as the feedstock for electrolysis. This still produces chlorine as the primary sanitiser.

Mineral pools are marketed for improved water feel, reduced eye/skin irritation, and potential wellness benefits, but they are not chlorine-free.

NATURAL POOL A pool that primarily uses biological filtration and plant regeneration zones instead of chemical sanitisation. These pools require careful design, monitoring, and maintenance to meet health and water clarity requirements.

ORP (OXIDATION-REDUCTION POTENTIAL) A measurement (in millivolts) of water's ability to oxidise contaminants. ORP is a better real-time indicator of sanitiser activity than free chlorine concentration alone.

Most automated dosing systems target an ORP range of 650-750 mV for pools and spas.

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OZONE A powerful oxidiser generated onsite via UV light or corona discharge, Ozone is a secondary water treatment system that generates ozone on site and applies it within the recirculation system, where it reduces microorganisms and oxidises organic contaminants through direct oxidation.

Due to ozone's short half-life and rapid decomposition to oxygen, it does not provide a disinfectant residual in pool or spa water and must be used in conjunction with an approved primary sanitiser and suitable system controls.

PH A measure of water’s acidity or alkalinity on a scale of 0–14 (7 is neutral).

Maintaining pH between 7.2–7.8 is critical for sanitiser efficiency, bather comfort, and equipment longevity.

PRIMARY SANITISER The main disinfectant responsible for maintaining a continuous residual in the water (e.g., chlorine or bromine). Primary sanitisers are legally required under most public health codes.

RESIDUAL DISINFECTANT / SANITISER The measurable concentration of a primary sanitiser (e.g., free chlorine, bromine) remaining in the water at any given time. Residual levels must remain within regulatory limits to ensure continuous microbial control.

SECONDARY SANITISER A supplementary system that enhances the disinfection capabilities of the system and water quality. Always used alongside a primary sanitiser.

SHOCK TREATMENT / OXIDISER The process of adding a high dose of chlorine (typically four times the normal daily dose) or a non-chlorine oxidiser to rapidly oxidise contaminants, reduce chloramines, and improve water clarity.

Shock treatment is commonly carried out following contamination events, algae outbreaks, or periods of heavy pool use.

SUPER CHLORINATION The process of adding a chlorine-based disinfectant at a very high dose (a minimum of ten times the combined chlorine level) to achieve breakpoint chlorination.

This process oxidises combined chlorine compounds (chloramines), helping eliminate chlorine odours, restore effective disinfection, and improve water quality.

TOTAL DISSOLVED SOLIDS (TDS) The total concentration of dissolved substances (salts, minerals, chemicals) in pool water. High TDS can reduce sanitiser effectiveness and may require partial water replacement.

TURNOVER RATE The time required for the entire volume of water in a pool or spa to pass through the filtration system once. Public health codes usually specify maximum turnover times (e.g., every 6–8 hours for pools, 20–30 minutes for spas).

ULTRAVIOLET (UV) A secondary disinfection system that uses UV-C light to inactivate microorganisms such as bacteria, viruses, and protozoa. UV reduces chloramine levels and improves water clarity but leaves no residual disinfectant.

WATER BALANCE The relationship between pH, total alkalinity, calcium hardness, and temperature. Proper balance prevents corrosion, scaling, and equipment damage, while optimising sanitiser efficiency.

WATER QUALITY STATEMENT Any marketing or technical claim regarding pool or spa water quality (e.g., “safe,” “gentle,” “drinkable”). Such statements must be supported by testing (e.g., Australian Drinking Water Guidelines) and clearly qualified to avoid misleading consumers.

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APPENDIX Relevant standards, documents and regulators: AS 1926.3 – Swimming Pool Safety: Water Recirculation Systems AS 3633 – Private Swimming Pools: Water Quality AS 2610.2 – Spa Pools, Part 2: Private Spas AS 1894 - The storage and handling of non-flammable cryogenic and refrigerated liquids AS/NZS 2927 - The storage and handling of liquefied chlorine gas 2024 Model Aquatic Health Code - December 2024 Australian Government Therapeutic Goods Administration (Using 'natural' claims in therapeutic goods advertising) https://www.tga.gov.au/products/regulations-all-products/advertising/applyingadvertising-code/general-requirements-advertising-therapeutic-goodspublic/using-natural-claims-therapeutic-goods-advertising ACCC Advertising and Promotion Claims https://www.accc.gov.au/consumers/advertising-and-promotions Commerce Commission New Zealand Making accurate claims https://www.comcom.govt.nz/business/dealing-with-typical-situations/makingaccurate-claims/ Australian Pesticides and Veterinary Medicines Authority (APVMA) https://www.apvma.gov.au/

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DISCLAIMER This document has been prepared by the Swimming Pool & Spa Association (SPASA) as an industry education tool. It is intended to provide general guidance on marketing claims, testing protocols and sanitisation practices relevant to the treatment of water in residential swimming pools and spas.

While every effort has been made to ensure the accuracy and currency of the information contained herein, SPASA does not provide legal, engineering or scientific advice through this guide. The material should not be relied upon as a substitute for professional advice tailored to specific circumstances.

SPASA accepts no liability for any loss, damage, claim, or expense arising from reliance on the information contained in this guide, whether such reliance is by members, manufacturers, regulators, consumers or other stakeholders. SPASA does not warrant or endorse any specific product, manufacturer or technology mentioned, referred to, or implied within this guide.

References to standards, regulations or guidelines (including but not limited to Australian Standards, New Zealand Standards, ISO, NSF/ANSI, APVMA and Australian Consumer Law) are provided for general educational purposes only and do not replace the requirement for parties to ensure their own compliance with applicable legal and regulatory obligations.

Furthermore, SPASA cannot guarantee the future accuracy of this guide, as standards, legislation, and industry practices are subject to change. Users are solely responsible for keeping themselves informed of updates to applicable regulations, standards and codes of practice.

This guide is designed to promote transparency, accountability, and integrity within the swimming pool and spa industry. Adoption of its principles is voluntary unless otherwise mandated by law or regulation.

Compliance with this guide does not remove or reduce the obligation on manufacturers, suppliers, dealers, or service providers to ensure that all products and marketing claims: meet all legal obligations under the Australian Consumer Law (ACL), Australian Pesticides and Veterinary Medicines Authority (APVMA) requirements and relevant public health legislation; conform to all relevant Australian, New Zealand and/or international standards; are truthful, substantiated and not misleading.

SPASA reserves the right to amend, withdraw or replace this guide at any time. By using this guide, readers acknowledge and accept that responsibility for compliance rests solely with the individual or organisation making or relying upon sanitisation claims.

Sanitisation in swimming pools and spas is not achieved by a single element in isolation. It is the outcome of a coordinated system of treatment technologies, operating conditions and water management practices working together to maintain microbiological safety, water clarity and user comfort.

V1 INDUSTRY SANITISATION GUIDE - JULY 2026