Lifeguard In-Service Training Plan That Meets MAHC 6.3.3.4

Under the 2024 MAHC (check what your state adopted), a facility's safety plan must include an in-service training plan with four parts: how often training happens, how it is documented, how certifications are maintained, and how test-ready skills are demonstrated (6.3.3.4.3). Records must name the attendees, the content, the date and the trainers, and stay at the facility for 3 years (6.3.3.4.1, 6.3.3.4.2). How often you train is left to you.

What does the MAHC require, and what does it leave to you?

It sets the record, not the schedule. The Annex says "periodic" gives the operator flexibility for seasonality, staff scheduling and the training agency's requirements. So the number of sessions is yours to write down.

Item	MAHC clause	What an inspector can ask for
Plan: frequency, documentation, certification maintenance, test-ready demonstration	6.3.3.4.3	The written plan, on file at the facility (6.3.3.5.1)
Record fields: attendee names, content, date, trainer names	6.3.3.4.2	One record per session
Retention	6.3.3.4.1	3 years, at the facility, available for inspection
Who completes the record	6.3.3.4.1	The person who conducted the training
CPR/AED and first aid	6.3.3.4.4	CPR/AED completed annually, certificates unexpired; first aid certificates unexpired
Rescue demonstration	6.3.3.4.5	Three skills done consecutively

The plan is only half the test. 6.3.3.5.2 says the safety plan must be implemented and in evidence in operation, and the AHJ can review it at any time. A good plan with thin records is what fails.

What is the three-skill demonstration?

6.3.3.4.5 says guards must demonstrate the skills in MAHC 6.2.1 and be able to do the following consecutively:

1. Reach the furthest edge of the zones of surveillance within 20 seconds.
2. Recover a simulated victim, including extrication to a position of safety.
3. Perform resuscitation skills.

The Annex explains why: skills taught one at a time in a class may not add up to a rescue if they cannot be done in a row. It says this does not preclude scenario-based activities. So a staged scenario with a timed reach, an extrication and a resuscitation sequence counts, and a set of separate skill stations does not meet the consecutive requirement. Record the result per guard, not per session.

How do pre-service, in-service and the certificate fit together?

They are three layers, set by three different parties.

	MAHC	Red Cross	Your plan
Certificate length	Lifeguarding and first aid, max 2 years; CPR/AED, max 1 year (6.2.1.3.5)	Its page says recertification renews the lifeguard certification for another two years	Track CPR/AED on its own row
Late renewal	Expired more than 45 days: retake the course. 45 days or less: retake or complete a challenge program (6.2.1.3.7, 6.2.1.3.7.1)	Recertification needs a current certificate or one expired no more than 30 days	Alert at 60 and 30 days before expiry
Before duty	Unexpired certificate presented (6.3.3.3.6.1); facility policy training and skills demonstration (6.3.3.3)	Set by the employer, not the course	Per-pool sign-off
Ongoing	Periodic in-service (6.3.3.4)	Set by the employer, not the course	Written frequency

A guard 31 to 45 days past expiry sits in the gap. The MAHC allows a challenge program, but 6.2.1.3.7.2 requires the original certifying agency's training and an instructor certified by that agency, and the Red Cross recertification page limits its course to 30 days. Ask the agency what path it offers before you promise a guard a quick return.

The Red Cross lets certificate holders look up a certificate by email, by name and course date, or by certificate ID, and its page says to allow 12 hours after a course is submitted. A lookup is not a file copy. The MAHC wants originals or copies at the facility (6.3.3.3.5.1, 6.4.1.7), so save the document.

Pre-service has its own checklist. 6.3.3.3.4 lists nine criteria each guard must show before duty, including reaching the bottom at the maximum depth of the assigned venue, identifying every zone they could be assigned, recognizing a victim in the zone and reaching the zone's furthest edge in 20 seconds. Documentation is kept at the facility for 3 full years (6.3.3.3.6).

What does a season plan look like?

Map each session to the course content areas in 6.2.1.1 (hazard identification, emergencies, CPR, AED use, BVM use, emergency oxygen, first aid, legal issues) and to the facility topics in 6.3.3.3.3 (zone plan, rotation plan, minimum staffing plan, rescue and first aid response).

Block	Content	Clause
Pre-season day	Facility policies, EAP copy, zone and rotation walk, per-pool skills check	6.3.3.3, 6.3.3.3.3, 6.3.3.3.4
In-service 1	Victim recognition scanning, zone and rotation drill, timed reach	6.2.1.1.1, 6.3.3.1.1
In-service 2	Emergency response and EAP scenario with the full rescue sequence	6.2.1.1.2, 6.3.3.4.5
In-service 3	CPR/AED, BVM, oxygen, compressions relief	6.2.1.1.3
In-service 4	First aid, spinal care, body-fluid response	6.2.1.1.4, 6.5

Two more dates belong on the calendar. The EAP is reviewed with staff and management at least annually, with the review dates recorded in the EAP (6.3.4.5.3), and training documentation must be available on request (6.3.4.5.5). The Annex recommends EAP drills quarterly, citing the American Heart Association, and says seasonal sites may differ.

How do you size it for 20 pools and 3 trainers?

The MAHC gives no hours, so the number comes from your state code if it sets one. Texas rule 25 TAC 265.191 (as shown on Cornell LII) calls for a "continual" in-service program of at least 60 minutes for every 40 hours of employment, and requires records of the most current training (date, length, topic, trainer name and attendee) to be kept three years. The MAHC Annex cites a different Texas figure, 4 hours a month, so read the current rule text rather than the Annex. We use the Texas rule only to show the arithmetic.

Example: a company runs 20 pools with 8 guards each, 160 guards in all. Each guard averages 30 hours a week over a 12-week season, under a local rule of 60 minutes per 40 hours.

1. Hours worked: 30 x 12 = 360 hours.
2. In-service owed: 360 / 40 x 60 = 540 minutes = 9 hours.
3. Keep it continual rather than loading it at the end: every 2 weeks a guard works 60 hours and owes 60 / 40 x 60 = 90 minutes, so run one 90-minute session per pool every 2 weeks. That is 6 sessions per pool, 6 x 90 = 540 minutes, and 20 x 6 = 120 sessions.
4. Attendance lines: 120 sessions x 8 guards = 960 per season, so about 2,880 lines held across a 3-year window if every season looks alike.
5. Trainer time: 120 x 1.5 = 180 hours, or 60 hours per trainer for 3 trainers, about 5 hours a week over 12 weeks before travel.
6. If a pool must stay open while guards train, split the guards into two cohorts: 240 sessions, 360 trainer-hours, 120 hours per trainer.

Splitting into cohorts doubles the trainer time, so schedule sessions before opening or after close where you can.

What does an audit sheet look like?

Use one row per session per pool.

Field	Source
Date	MAHC 6.3.3.4.2
Content (topic and 6.2.1.1 area)	MAHC 6.3.3.4.2
Trainer names	MAHC 6.3.3.4.2
Attendee names, printed	MAHC 6.3.3.4.2
Start and end time	Our addition; the Annex says to record the time
Demo result per guard: reach, extricate, resuscitate in sequence, pass or fail	Our addition for 6.3.3.4.5
Certificate check: lifeguard, CPR/AED, first aid, expiry dates	6.3.3.4.4, 6.2.1.3.6

Then run an inspector's test. Pick five guards by name and produce, for each, the certificates, the pre-service sign-off for each pool they work, every in-service in the last 3 years, the EAP review date and the last demo result. If any item takes more than a few minutes to find, fix the filing before the season.

What breaks when guards float between pools?

Three things. The certificate copy has to be at each facility the guard works at (6.4.1.7.1). Pre-service is facility-specific (6.3.3.3), so on a plain reading a guard who floats to three pools needs a sign-off at each of the three. And shared trainers produce one roster that must reach each pool's file for its own attendees. Keep a matrix of guards by pools and mark the sign-off date in each cell.

Poolean keeps staff evaluations and feedback on the guard's record, which gives you one place to attach the notes from a skills check. For the certificate side, see lifeguard certification tracking. For staffing counts, see how many lifeguards a pool needs, and for the day a trained guard is not there, see lifeguard call-out procedure. To see the guard record, book a 30-minute call.

The short version

• The MAHC fixes the record (names, content, date, trainers; 3 years at the facility) and the four parts of the plan, but not the frequency.
• The rescue demo is three skills done in a row: 20-second reach, recover and extricate, resuscitate. Record it per guard.
• Keep certificate rules, the agency's rules and your own plan separate. Track CPR/AED on its own row and watch the 30-day and 45-day windows.
• Size sessions from your local rule. In the 20-pool example, 540 minutes per guard as biweekly 90-minute sessions means 120 sessions and 180 trainer-hours.
• Floaters need a certificate copy and a pre-service sign-off at every pool.