Technical Corner

August 25, 2026

There is no specific direction that exempts a lifeguard from wearing safety footwear when working on a pool deck. Aquatic professionals will agree that Ontario Regulation 565 - Public Pools is a blanket outline of responsibilities to be met by all selected pool operators by the pool owner. They will also agree that not every pool environment is the same. However, Regulation 565 must be balanced with Occupational Health and Safety Act (OHSA) responsibilities. As required in the OHSA, lifeguards in an aquatic setting require facility management to conduct a hazard analysis to determine appropriate worker protection based on the specific circumstances of the operation. The analysis should be well-documented so that if that decision is later called into question due to a claim or investigation, it can be supported by documented evidence.

Indoor and outdoor aquatic guarding are two separate risk environments to be assessed. If the guard is cross trained as an indoor pool operator, entry into to the pump and chemical areas of the facility will require a foot risk hazard assessment. Another could be stray electrical safety and bare feet in a wet area or slip and fall at heights hazards of drained pools. The issue to be considered is while on the deck and specifically in the chair in an observation role. There could be an argument that wearing safety footwear in this condition may place public safety at risk. There would be limited risk to foot injury while seated, but once descending and travelling on a surface, requiring protection from cuts or contusion would be reasonable.

Outdoor beach swim areas are a different risk as the sand may contain hidden dangers. In this environment, the low-cut safety footwear, such as those used by painters and drywall installers might be reasonable. What is a common statement amongst aquatic professionals is that footwear such as flip flops are unacceptable. [More] 

The ORFA has monitored this challenge and spoken with representatives of the Ministry of Labour, Immigration, Training and Skills Development (MLITSD) who are not eager to address the issue but rather suggest it is best left to an internal decision. The real issue to be controlled is having the lifeguard know when safety footwear must be worn based on task and risk, with the basic directive of OHSA personal protective equipment being required any time risk injury is present as a reasonable guiding light for an SOP to be developed.

Today's aquatic practitioners are challenged to balance historical practice and the higher expectations of worker health and safety principles for each work environment. Start by having the conversation that hopefully leads to the development of an internal best practice based on a reasonable balance of worker and public safety. The ORFA would appreciate receiving members opinion or approaches as it allows us to warehouse industry driven approaches that in time can lead to creating an industry best practice.