Pool Records Audit: MAHC 6.4.1 Checklist and 3-Year Retention

MAHC 6.4.1.2.1 (check what your state adopted; local law may require more, per 6.4.1.2.2) says operation, maintenance and management records are kept a minimum of 3 years and made available when the AHJ asks. Those records are spread over more than a dozen sections, and most companies only audit the water log. Here is how to audit the rest.

What does the MAHC say about retention and falsified records?

Section 6.4.1.2.1 gives two requirements: kept for a minimum of 3 years, and available upon request by the AHJ. In-service training documentation repeats the 3-year period and says it is maintained at the facility (6.3.3.4.1). The code gives no time limit for "available"; the one-day target below is our own standard, not a code number.

Section 6.6.5.3 says that falsifying, or presenting to the AHJ, falsified documentation or certificates is a civil violation as specified by the AHJ. The code does not define back-filling, so treat any entry that makes a test look like it happened when it did not as a risk. Our suggested house rules (not code text):

• A missed test stays missed. Record that it was missed, the time of the note, and the corrective action.
• Fix errors with a visible strike-through, initials and date, never an overwrite.
• Do not rewrite a messy log to look neat before an inspection. Keep the original.
• Keep original entry times. Poolean keeps notes, readings and photos entered without a signal on the phone with their original entry times and marks pending uploads clearly.

Which 17 items go in the daily record, and how often does each need a reading?

The lead-in to 6.4.1.6 says "daily, or as often as required". The cadence for each item comes from other sections:

#	6.4.1.6 item	Cadence implied
1, 2	pH, disinfectant residual	Before opening, then every 2 h (manual feed) or 4 h (automatic) while open (5.7.5.1 to 5.7.5.3)
3	Combined chlorine	Before opening daily (5.7.5.1)
4	Pump and filter pressures or flow	Daily, per the lead-in. No finer cadence stated
5	CYA	Monthly (5.7.5.7); weekly if stabilized chlorine is the primary disinfectant (5.7.5.7.2)
6	Equipment maintenance, malfunction, calibration dates (incl. WQTDs)	Event-based
7	Interlock challenge dates	Monthly unless the manufacturer says otherwise (5.7.3.5.1.4.1.1)
8	Water temperature, if heated	With each chlorine and pH test (5.7.5.10)
9	Filter backwash or cleaning time	Event-based
10, 11	Calcium hardness, total alkalinity	Hardness monthly (5.7.5.6); alkalinity weekly (5.7.5.5)
12	Saturation index	Monthly (5.7.5.8)
13	Microbiological results, if applicable	Date, time and result when sampled
14	Failures or outages over 1 hour affecting circulation, filtration or disinfection	Event-based
15	Daily attendance (a sign-in book is allowed where it is not ordinarily recorded)	Daily
16	Secondary treatment (ozone, UV)	Ozone and UV tables 5.7.3.7.7 and 5.7.3.7.8: several parameters recorded every 4 hours
17	Turbidity meter readings	No cadence stated in the code text

A 9-hour day makes the count concrete. With manual feed that is at least 5 chemistry entries (before opening, then hours 2, 4, 6 and 8). With automatic feed it is at least 3 (before opening, hours 4 and 8). Counting entries against open hours is the fastest completeness check you can run on a month of logs.

What else is on the list besides the water log?

• Daily preventive inspection (6.4.1.3, 6.4.1.3.1). Done before opening and recorded in a log or form kept at the facility. 21 items, from drain covers and suction outlets to fencing, first aid supplies and water clarity. Monthly GFCI tests and 6-monthly bonding conductor inspections follow (6.4.1.3.2).
• Illness and injury reports (6.4.1.4). Deaths, CPR, oxygen or AED use, transport or treatment at a medical facility, and diagnosed RWIs. Eight fields, and the AHJ is notified within 24 hours (6.4.1.4.3). Lifeguard rescues where the guard enters the water and activates the EAP are recorded separately (6.4.1.4.4).
• Chemical inventory (6.4.1.5). Kept onsite, with expiration dates for test reagents (6.4.1.5.1).
• Staff certificates (6.4.1.7). Kept at the facility. Staff who work at several facilities need a copy at each (6.4.1.7.1).
• Bodily-fluids log (6.4.1.8.3). 13 fields recorded at the time of the incident, including stabilizer concentration at the incident and at reopening, residual and pH at both, and contact time. CDC's sample response log asks only whether stabilizer was present, but 6.4.1.8.3 items 8 and 12 want the concentration.
• In-service training (6.3.3.4). Attendees, content, date and trainer, kept at the facility for 3 years.
• Indoor air handling (5.6.2.10). Commissioning set points with actual readings at least daily, maintenance dates and modification records.
• Contracted operator visits (6.3.1.2.1 to 6.3.1.2.3). Written documentation available at the facility.

CDC's MAHC inspection form scores records too: a daily checklist used and evidence of steps taken, and chemical records filled out daily with evidence of steps taken (items 43 to 46, 5 points each). An out-of-range reading with no action recorded is a gap in the record even if the water was fixed.

How do you run the audit?

For each sampled pool and each row, score three yes or no tests: it exists, it is complete (all required fields, and an action beside every out-of-range value), and one person can retrieve a given date within a day (our suggested target, not a code rule). Add an owner column, because a row with no named owner stays empty.

Example (made-up numbers, not a real company): 40 pools, 5 sampled (2 indoor, 3 outdoor), 4 of them with an off-site operator contract. Pass counts per test:

Record	MAHC	Applies to	Exists	Complete	Retrievable
Chemistry at cadence, CC daily	6.4.1.6 (1 to 3, 5)	5	5	4	5
Weekly and monthly chemistry	6.4.1.6 (10 to 12), 5.7.5	5	5	3	4
Flow, backwash, temperature	6.4.1.6 (4, 8, 9)	5	4	3	4
Equipment events, interlock dates, outages	6.4.1.6 (6, 7, 14)	5	3	2	3
Attendance and applicable extras	6.4.1.6 (13, 15 to 17)	5	5	5	5
Daily preventive inspection	6.4.1.3	5	5	4	4
Incident and rescue reports	6.4.1.4	5	5	5	4
Chemical inventory, reagent expiration dates	6.4.1.5	5	4	2	4
Staff certificates	6.4.1.7	5	5	4	3
In-service records	6.3.3.4	5	3	3	2
Bodily-fluids log and SOP	6.4.1.8	5	5	5	4
Air handling records	5.6.2.10	2	2	1	1
Operator visit documentation	6.3.1.2.1	4	3	3	2

Tests: (11 rows x 5 pools + 2 + 4) x 3 = 183. Passes: 14 + 12 + 11 + 8 + 15 + 13 + 14 + 10 + 12 + 8 + 14 + 4 + 8 = 143. Score 143 / 183 = 78.1 percent. Equipment events and interlock dates, in-service records and the chemical inventory with reagent dates account for 19 of the 40 misses, and none of them show up if you only audit the water log.

How much is 3 years of records, and where should it live?

Example (made-up): 18 year-round pools and 22 seasonal pools open 120 days.

1. Year-round: 18 x 365 x 3 = 19,710 pool-days.
2. Seasonal: 22 x 120 x 3 = 7,920 pool-days.
3. Total held: 27,630 pool-days.
4. Chemistry entries at the minimum cadence for a 9-hour day: 27,630 x 3 = 82,890 (automatic feed) to 27,630 x 5 = 138,150 (manual feed), before the other 16 items.

The window slides by date, not by season. In July 2029 a seasonal pool still holds the July to September records of 2026, so it holds parts of four seasons. Put a disposal date on every batch: last entry plus 3 years, or longer if local law says so (6.4.1.2.2).

Where the code says "at the facility", keep a copy there: inspection log, chemical inventory, certificates, in-service records, operator visit documentation, air handling records. The ops manual must be at the facility in printed and electronic form (6.4.1.1.1). Daily water records are written as available to the AHJ, so central storage works if someone can produce them quickly, but ask your health department whether it accepts electronic copies at an inspection. If you run sites for owners, put in the contract who holds the records after the contract ends.

How do you run this across 40 pools?

• Audit a rotating sample each quarter. Sample size = pools / quarters in the cycle. Five pools a quarter reaches each of 40 pools once in 8 quarters (2 years); 10 a quarter reaches each once a year. Add any pool with an inspection finding.
• Name one owner per record row, not per pool.
• Run a date drill: pick a random date from last year at one pool and time how long it takes to produce the inspection log, water entries, attendance, equipment events and any incident or visit record. That is the chain an inspector can ask for.
• Poolean builds daily or monthly logs from the readings, staffing, visits and closures recorded for each pool, and you can print them, save a PDF or download a CSV. To see it, book a 30-minute call.

For the basics of an inspection day, see pool health inspection preparation. For the log fields themselves, see the pool water test log template and paper versus digital pool logs.

The short version

• Records are kept a minimum of 3 years and are available to the AHJ (6.4.1.2.1). Local law may require more.
• The 17 daily items in 6.4.1.6 get their cadence from sections 5.7.3 and 5.7.5. Count entries against open hours.
• Never back-fill. Falsified documentation is a civil violation as specified by the AHJ (6.6.5.3).
• Score each record on exists, complete and retrievable, with a named owner. Sample pools every quarter.