SE2 - New and Modified Safety Equipment

Purpose

To provide guidance to aquatic facility owners and operators on the safe, lawful, and effective introduction of new or modified safety and emergency equipment. This guideline ensures that decisions regarding new equipment are consistent with the facility’s duty of care under Australian work health and safety (WHS) law, relevant codes of practice, and therapeutic goods regulation.

Scope

Applies to new or modified (non-standard) first aid, rescue, and emergency equipment (e.g., airway clearance devices, haemostatic dressings, naloxone, advanced oxygen delivery systems) for use at Australian aquatic facilities.

It covers the introduction, modification, or replacement of safety, rescue, and first aid equipment that falls outside the scope of standard accredited training or existing industry guidance.

Examples include:

• Airway clearance or anti-choking devices (e.g. LifeVac, Dechoker)
• Haemostatic dressings, tourniquets, and advanced first aid adjuncts
• Medications such as naloxone (opioid overdose reversal)
• Modified rescue or oxygen delivery equipment

This guideline does not apply to pool surveillance or drowning detection technologies, which are addressed in a separate guideline.

This revised guideline establishes a risk-based process aligned with:

• The Work Health and Safety Act 2011 and equivalent OHS legislation
• The Model Code of Practice: First Aid in the Workplace
• The Therapeutic Goods Act 1989 and Therapeutic Goods Administration (TGA) regulatory framework
• Applicable insurer and training obligations

Definitions

“Safety Equipment” -- includes but is not limited to: Rescue Boards, Throw Ropes, Reach Poles, Rescue Tubes, Radios, Safety apparel including helmets; medical equipment including Oxygen Resuscitation units, resuscitation devices (airways, masks etc.) and Defibrillation units.

“Modifications”- a change or alteration, in the design or the materials, to an item of safety equipment which has been previously endorsed for use in an Aquatic Facility.

Accountability

The owner or operator of an aquatic facility is responsible for ensuring that any new or modified safety or emergency equipment is:

• Legally compliant and fit for purpose
• Supported by an adequate risk assessment and consultation process
• Accompanied by suitable training, supervision, and procedures.

Legal and Regulatory Compliance

Facilities should ensure that:

• Any medical or therapeutic device or medication is approved for use in Australia and listed on the Australian Register of Therapeutic Goods (ARTG).
• The introduction of new equipment complies with relevant WHS legislation, including obligations to consult workers and Health and Safety Representatives (HSRs) and to provide appropriate information, instruction, and training.
• The use of the equipment does not breach privacy or surveillance legislation.
• The facility’s insurer recognises the equipment and confirms coverage for its use.

Risk Assessment

Prior to introduction, a documented risk assessment must be completed in line with AS/NZS ISO 31000:2018 Risk Management – Principles and Guidelines / GSPO – Risk Management.

The assessment should identify:

• The specific hazard or incident type the equipment addresses.
• Benefits, limitations, and any potential misuse or delay to existing emergency responses (e.g. CPR, defibrillation).
• Alternative or existing controls already in place.
• Required training and maintenance arrangements.
• The overall risk rating and justification for adoption.

Consultation

Facilities should consult with affected workers, Health and Safety Representatives, and key stakeholders before adopting new equipment. Consultation should include:

• Discussion of identified risks, operational impacts, and training needs.
• Review of manufacturer guidance and instructions for use.
• Consideration of advice from relevant peak bodies or regulators, such as:
  • Royal Life Saving Australia
  • Australian Resuscitation Council (ARC)
  • Australian Red Cross
  • State or territory WHS regulator
  • St John Ambulance Australia
  • The facility’s insurer or legal advisor.

Records of consultation must be maintained.

Training and Competence

All staff expected to use new or modified equipment should receive appropriate training prior to deployment.

Where the device or procedure is not included in accredited first aid or lifeguard qualifications, facilities should provide supplementary training, either internally or through the manufacturer or supplier.

Staff competence should be demonstrated through practical assessment and refreshed periodically.

Records of all training and competency assessments should be retained.

Integration into Systems and Procedures

The aquatic facility owner / operator should:

• Update Standard Operating Procedures (SOPs), Emergency Management Plans (EMPs), and first aid procedures to include the new equipment, its intended use, and any limitations.
• Identify the equipment’s storage location, authorised users, and accessibility during emergencies.
• Incorporate the equipment into inspection, maintenance, and inventory systems.
• Ensure signage, communications, and incident reporting templates are updated to reflect the change.

Maintenance, Review, and Continuous Improvement

The aquatic facility owner / operator should:

• Maintain the equipment in accordance with manufacturer specifications, including replacement of consumables and scheduled inspections.
• After each use, review the use of the equipment to evaluate performance and identify any procedural or training improvements.
• Conduct formal reviews periodically or following any relevant regulatory or manufacturer update, to confirm continued suitability and compliance.

Record-keeping

Facilities should retain documentation demonstrating due diligence, including:

• Risk assessment and consultation records.
• Manufacturer information and training materials.
• Staff training and competency records.
• Maintenance and inspection logs.
• Post-incident review and corrective actions.

References

• Australian Skills Quality Authority (ASQA). (2021). HLTAID National Training Package Units (Health Training Package – HLT). Canberra: Australian Government.
• Australian Red Cross. (2022). First Aid in the Workplace – Red Cross Guidance for Employers and First Aiders. Melbourne: Australian Red Cross Training Services.
• Australian Government. (1988). Privacy Act 1988 (Cth).
• Australian Resuscitation Council. (2021). ANZCOR Guideline 10.5 – Legal and Ethical Issues Related to Resuscitation.
• Royal Life Saving Society – Australia. (2021/2025). Guidelines for Safe Pool Operations – Risk Management, Incident Management, and Safety Equipment sections.
• Royal Life Saving Society – Australia. (2022). First Aid Manual. Royal Life Saving Society – Australia, Sydney.
• Royal Life Saving Society – Australia (2025). Lifeguarding 6th Edition. Royal Life Saving Society – Australia, Sydney.
• Safe Work Australia. (2018). Model Code of Practice: First Aid in the Workplace.
• Safe Work Australia. (2011–2025). Model Work Health and Safety Act and Regulations.
• St John Ambulance Australia. (2023). First Aid in the Workplace: Code of Practice Guidance for Employers and Workers. Canberra: St John Ambulance Australia.
• Therapeutic Goods Administration. (n.d.). Australian Register of Therapeutic Goods (ARTG) and Medical Devices Guidance.