A practical, industry-led approach to ensuring sanitisation products and performance claims are transparent, verifiable and comparable.
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
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
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
Reference Material
Glossary of Sanitisation Terms
Appendix of relevant Standards, Documents, and References
Disclaimer
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
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
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
TABLE 1: CLAIM GUIDANCE
STANDARDISED TESTING PROTOCOLS
credible, repeatable, transparent and capable of prop made
Accredited laboratories: Tests should ideally be cond ILAC-recognised facilities or other credible independ
Declared conditions: Reports should specify the full (including pH, alkalinity, salinity, CYA concentration, t simulation and dosing method) to demonstrate the e operating conditions have been replicated.
Evidence hierarchy:
Production results on performance and efficacy: Be which exists when considering all the variables of po 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 wa *An
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
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
Ideally, testing reports and associated claims should be able to disclose methodology and confirm repeatability
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.
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.
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
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.
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
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 74-78
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
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:
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
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
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
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
Clarifiers
Scale inhibition
Degassing or air stripping
Dilution or water replacement
Hydraulic optimisation and turnover management
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
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
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.
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.
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.
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
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.
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
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
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
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
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
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 72–78 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
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)
Australian Pesticides and Veterinary Medicines Authority (APVMA)
https://www apvma govau/
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.
