Share Your Views on PAS 520

Over the last few days STA has been inundated with enquiries from members about the publication of PAS 520 Safeguarding 0 to 4 year old children within the teaching of swimming, including any associated professional photography – Code of practice document.

Whilst STA fully support the development of British Standards on the regulation of swimming and professional underwater photography, we understand and share our members’ concerns over some of the points mentioned in the PAS document.

We wholly agree that there should be a policy and that much of the information contained in PAS is perfectly reasonable; however we concur with our members that there are several points that are unnecessary and impracticable for all types of swim school operations – the guidance is skewed towards one style of operation and not reflective of the different needs of the swim school market.

Therefore, in the best interests of our members we are working to address these concerns. In the meantime, to help us understand more about your individual concerns we invite you to sign this petition and add your comments (please note that all petition comments and signatures can be done anonymously).

As a united voice, we can then all work towards establishing a new/revised policy document that is representative of the baby swimming market as a whole; large and small swim schools, franchises, and leisure centres.

Top 5 Concerns

  1. The need for swim schools to hold a pool plant qualification – this is deemed impractical for most independent swim schools and not necessary
  2. That all babies and toddlers under 4 should be fitted with a disposable/reusable nappy, as well as a neoprene nappy cover – many leisure centres have expressed concerns that this would be impossible to manage; and the general consensus is that the age range to under 4 years is too high and should be lowered
  3. Baby and Pre-School teachers to also hold a Level 2 general swimming qualification – the pros and cons – cost implications – need to be debated and discussed in more depth as an industry. In the meantime, please be assured of your current qualification – see here
  4. Safeguarding – this is covered very basically in 1 section of the document, and doesn’t cover specific safeguarding issues. The title of this PAS document is Safeguarding 0 to 4 year old children within the teaching of swimming. This section needs to include more to guide teachers and swim schools on their responsibility and how they ensure all swimmers are safeguarded correctly. It also states that a swim school is required to have a ‘safeguarding lead person’ who is trained to to comply; this would add unnecessary added expense to a swim school’s operation, and especially as the leading swimming bodies already provide this specialist service to swim schools
  5. Clarity between so many contradictions and inconsistencies throughout the document. For example:
    • Section 15.2, teaching objectives and methodology. This section mentions that all qualified teachers should be trained in the delivery of ‘the teaching programme’ and should be assessed on a regular frequency. This needs clarifying – who’s teaching programme and how will the teachers be regularly assessed?
    • First Aid: The document states that there should be a member of staff available who holds first aid including paediatrics; however the next point says swim schools will need to have a documented first aid assessment to determine competencies; then in section 14 it says, where the swim school provides first aid cover. Therefore we are all confused; do swim teachers need to hold a first aid qualification? If so, which one, first aid or paediatric? HSE say a first aid risk assessment is required to determine how many first aiders are needed.

If you have any specific concerns about the PAS 520 document please email

Swimming Teaching

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