Underwater surveillance technology – an additional layer of support for lifeguards

Swimming pool technology has been developed over time, with the intention of providing an additional layer of support to lifeguards on duty. A common form of this new technology involves images taken by an underwater surveillance camera system displayed on a monitor affixed to a lifeguard's chair.

Guidance is now common at many leisure centres instructing lifeguards to incorporate reviewing the images as part of the internationally recognised 10:20 scanning process: ten seconds of observations and 20 seconds to reach a person in difficulty. Yet despite this technology, recent incidents indicate that lifeguards are still not spotting persons in difficulty and rescuing them in time. This then begs the question: is the current technology more of a hindrance than a help?

Swimming technology

For many years, poor design of buildings with swimming pools has offered challenges to its operators seeking to ensure users safety. For example, inappropriately placed windows, skylights or poor lighting can lead to surface glare resulting in poor visibility of users for lifeguards. To overcome this, many operators have installed underwater camera surveillance systems to enhance visibility of all areas within a pool. It is therefore concerning that there are still cases of pool users not being rescued in time when lifeguards and underwater systems are in place.

Scanning a pool and up to nine images displayed on a monitor, which is of a similar size to an iPad, and carefully scrutinising them whilst in position for anything between 20 to 45 minutes is not a straightforward task. Further, it is questionable the amount of information the human eye and brain can realistically process in ten seconds. It is therefore part of ongoing industry discussion whether the internationally recognised 10:20 rule is appropriate or should be revised in light of the introduction of pool technology.

Operators, on the introduction of swimming pool technology, will need to ensure that their lifeguards are trained in the use of any technology and in particular, how scanning the monitors should be incorporated into the 10:20 rule. Training should include what to do in the event of camera failure or where the water clarity, lighting or lens is compromised therefore affecting the quality of the images produced. Such training may be required across a number of sessions.

In addition, to the effectiveness of lifeguards scanning a pool according to the 10:20 rule, swimming pool technology relies on a balance of factors in the control of an operator, such as water clarity, lighting and the lens of the cameras themselves not being obscured. Consideration should be given by operators as to daily checks required to ensure the effectiveness of said technology, such as water clarity. Operators will also need to revisit the Normal Operating Procedure for their pool and Lifeguard Zone Visibility Tests to check whether they still apply or need to be revised.

Health and Safety Executive guidance HSG179 ‘Health and Safety in swimming pools’ states that technology should not be seen as a replacement for lifeguards. A surveillance system cannot communicate, intervene or undertake a rescue. As such, lifeguards have to be trained to use the system but not become reliant on it and operators should not be complacent with its introduction. 

Operators and employees' duty of care

Operators have a duty under Section 3 of the Health and Safety at Work etc. Act 1974 to ensure that risks to users of a swimming pool are reduced so far as reasonably practicable.

Swimming pool technology is one such tool which seeks to ensure user safety, however, in our view, it is an imperfect system that relies on a number of factors being in good working order, such as water clarity and ensuring that the lifeguards are trained to use the equipment. An operator will need to ensure it takes account of these factors in its procedures and processes in fear of breaching Section 3.

Invariably, operators’ procedures and processes for the management of swimming pools are detailed and well-thought through documents. Lifeguards training is also rigorously given according to the IQL RLSS UK ongoing training. In our experience therefore, when underwater surveillance camera systems are in place, it is the lifeguard who is primarily exposed to potential criticism when an incident occurs.

Following an incident, lifeguards may find themselves required to provide their version of events under caution with a regulatory authority on suspicion of breaching Section 7 of the Health and Safety at Work etc. Act 1974.

Section 7 imposes a duty on every employee, whilst at work, to take reasonable care for their health and safety as well as the health and safety of others who may be affected by their acts or omissions at work. To be interviewed under caution can be anxiety provoking, on the back of an already traumatic event if a user has been badly injured on died. This is especially so given the fact that the majority of lifeguards are young adults at college or university. Legal representation at an early stage is therefore essential.


Technology aimed at improving safety for swimming pools is developing at speed within the leisure industry. There are clear benefits in the use of such technology, however it remains an imperfect system which cannot solely be relied on.

There is an ongoing conversation in the industry as to how to improve existing guidance and support for lifeguards. In the meantime, practical considerations need to be taken into account by operators as and when they introduce new technology to ensure it performs at an optimum level as well providing any extra training. Failing to do so risks operators and/or lifeguards being exposed to personal liability and prosecution.

Read other items in Crime and Regulatory Brief - July 2022

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