FAQ

The short answer in practical terms is: someone who holds a generic Certificate III or IV in Fitness, but has not completed any aqua-specific competencies, should not be considered appropriately qualified to teach aqua classes.

There is no single piece of legislation that says “you must hold SISFFIT038/039/048 to teach aqua”, but the combination of the national training framework, industry codes of practice and WHS obligations points very strongly in that direction. Here is how it breaks down.

National training framework and fitness qualifications

Nationally recognised fitness qualifications sit within the SIS Sport, Fitness and Recreation Training Package and are quality-assured under the VET Quality Framework, including the Standards for Registered Training Organisations and the Australian Qualifications Framework (AQF).

Within the current SIS30321 Certificate III in Fitness, group water-based exercise is treated as a specific specialisation stream. The elective units

• SISFFIT038 Plan group water-based exercise sessions
• SISFFIT039 Instruct group water-based exercise sessions
• SISFFIT048 Use anatomy and physiology knowledge to support safe and effective water-based exercise is listed as the water-based exercise units, and the packaging rules state that elective selection should be guided by the job outcome being sought.

So, under the AQF and training.gov.au, a person who has completed Cert III or IV without these water-based units has not been assessed as competent in planning and instructing group water-based exercise. They are qualified as a gym or group exercise instructor in land-based contexts, not as an aqua exercise instructor.

Industry code of practice and “appropriately qualified” AUSactive’s National Code of Practice for the Health and Fitness Industry includes a specific expectation for aquatic programmes. For group activities in an aquatic environment, the facility must ensure that the aquatic instructor is “appropriately qualified within industry standards” to provide those services.

AUSactive also publishes scope-of-practice documents for different registration categories. The Aqua Exercise Instructor category outlines water-specific responsibilities such as water safety, risk management and the ability to perform safe water rescues, which go beyond generic group exercise skills.

In practice, “appropriately qualified” for aqua is interpreted as holding either:

• the relevant aqua units of competency within a fitness qualification (for example SISFFIT038 / 039 / 048 or equivalent), or
• an aqua-specific instructor qualification recognised by an industry body.

A generic Cert III or IV without any aqua competencies would not meet that description.

Work health and safety and duty of care

Under Australian work health and safety (WHS) laws, a person conducting a business or undertaking (PCBU), such as a fitness centre or aquatic facility, must provide information, training, instruction and supervision so that workers can perform their duties safely and without health risk.

That duty of care extends to ensuring instructors are competent for the specific environment and population they are working with. For aqua, that includes understanding:

• how water depth, buoyancy and turbulence affect exercise intensity and joint loading
• aquatic-specific risks (slips, immersion incidents, cardiac events in water)
• emergency procedures, including appropriate responses in the pool environment.

If a facility knowingly allows an instructor to take aqua classes without any aqua-specific training or competency, they may struggle to demonstrate that they have met their WHS obligations if an incident occurs. This is reinforced by WHS guidance for fitness businesses that emphasises the need to provide appropriate training and safe systems of work. bp-fitnessaustralia-production.s3.amazonaws.com

Insurance and risk management

Professional indemnity and public liability insurers that partner with fitness industry bodies (for example, Marsh for AUSactive members and Guild Insurance for aqua instructors) expect professionals to work within their documented qualifications and scope of practice.

If an instructor is teaching aqua while only holding a generic Cert III or IV, with no aqua competencies listed on their transcript, there is a real risk that:

• They may not be covered for aqua-related claims, and the facility and instructor could be exposed if a claim or complaint is made, and their actual training does not match their role.

So, while there is no single law that names the aqua units, the combined effect of:

• the SIS30321 packaging rules that clearly separate water-based exercise as a specific stream
• the AQF principle that you are only recognised as competent in the units you have actually completed
• AUSactive’s National Code of Practice requirement for appropriately qualified aquatic instructors

WHS’s duties to ensure staff receive adequate, role-specific training and instruction means that the defensible, best-practice position is:

Someone who holds a Certificate III or IV in Fitness but has not completed any aqua-specific units or qualifications should not be used as an aqua instructor. They are not regarded as appropriately qualified for that environment under current training and industry standards, and it creates avoidable WHS, insurance and duty-of-care risk for both the instructor and the facility.

Use these public references:
• SIS30321 Certificate III in Fitness, packaging rules and aqua units:
https://training.gov.au/training/details/SIS30321

• National Training Register home (context for nationally recognised qualifications and training packages):
https://training.gov.au

• Australian Qualifications Framework overview from ASQA:
https://www.asqa.gov.au/course-accreditation/users-guide-standards-vet-accre
dited-courses/standards/standard-105-australian-qualifications-framework-levels

• AUSactive National Code of Practice for the Health and Fitness Industry (aquatic instructor section):
https://ausactive.org.au/wp-content/uploads/2022/04/AUSactive-National-Code-
of-Practice-for-Health-and-Fitness-Industry.pdf

• Safe Work Australia information on training and WHS duties:
https://www.safeworkaustralia.gov.au/safety-topic/managing-health-and-safety
/training-and-supporting-your-workers-stay-safe-work

According to Royal Life Saving Society Australia’s Guidelines for Safe Pool Operation (GSPO), every aquatic facility must have an on-duty supervisor who:

• Is at least 18 years of age
• Is working within an agreed Supervision Plan
• Holds skills equivalent to a qualified pool lifeguard
• Can effectively observe all areas of the pool and respond to anyone in difficulty within about 30 seconds
• Has timely access to rescue and first aid equipment, including a rescue device, spinal board, first aid supplies, oxygen resuscitation equipment and a defibrillator

For full details, refer to the GSPO on the Royal Life Saving website:
https://www.royallifesaving.com.au/Aquatic-Risk-and-Guidelines/guidelines/GSPO

In most facilities, the aqua instructor is responsible for the supervision and safety of people enrolled in the class, not the rest of the pool users. However, if your class is the only group in the water, your role may also include being the designated pool supervisor, depending on the facility’s Supervision Plan.

If you are supervising the whole pool, you must have clear access to:

• First aid equipment
• Oxygen equipment
• An emergency communication system, such as a phone

If you do not meet the requirements for pool supervision, another suitably qualified person must also be on duty in line with the facility’s safety and supervision policies.

Recommended maximum ratios are:

• 1 instructor only: 1:30
• Instructor plus lifeguard: 1:40

These ratios support safe supervision and class management.

All aqua instructors should be trained in their facility’s emergency procedures and practise them regularly. This includes knowing:

• How to raise the alarm
• How to communicate with participants during an emergency
• Your role and responsibilities if an incident occurs

Participants should also be informed of emergency signals at the beginning of class.

Water Temperature

• Ideal range: 24°C–33°C
• Above 29°C: Slow down the pace, include longer recovery, and remind participants to hydrate.
• Below 24°C: Keep the activity continuous to maintain warmth.
• Below 17°C: Classes should not be conducted.

Water Depth

For standing exercises, the water should be no deeper than shoulder height.

Hydration

All participants should be encouraged to bring a water bottle and rehydrate regularly.

Yes. Aqua classes should always be run in a clearly designated area and remain under the instructor’s full visual control at all times.

During your pre-class introduction, assess:

• Participants’ experience level
• Any known medical issues or injuries
• Their general fitness level

You should also explain:

• How to raise the alarm in an emergency
• Pacing and self-regulation
• Reminders to take breaks as needed
• Hydration expectations

Equipment Placement

Equipment should never block traffic flow areas, such as pool concourses.

Exercise Mats

Mats should be non-slip and placed so they don’t create trip hazards.

Sound Equipment

Any mains-powered equipment must have earth-leakage protection and be positioned safely to reduce electrocution risk.

General Equipment Check

All aqua equipment should be checked before class begins for safety and function.

Yes, but only after the safety of their own class is secured.
Under the direction of facility management, you may be required to assist in an emergency elsewhere in the centre.

Aqua instructors teach on a surface that is often wet and slippery, in a space that can be hot and humid, with poor acoustics, and with shared public traffic. That creates different safety risks compared with a dry, defined studio space. Safe Work Australia highlights slips, trips, and falls as common workplace hazards, and wet floors and obstacles are typical contributors.

Source: https://www.safeworkaustralia.gov.au/safety-topic/hazards/slips-trips-and-falls

Yes, a non-slip mat helps reduce slip risk and gives the instructor a defined footing zone for demonstrations. Safe Work Australia guidance on slips, trips, and falls focuses on managing wet surfaces and keeping walking and working areas safe.

Source: https://www.safeworkaustralia.gov.au/safety-topic/hazards/slips-trips-and-falls

A practical minimum set is:

• non-slip, cushioned mat
• aqua frame (stable support)
• stable chair (won’t tip easily)
• working sound system and working microphone
• outdoor shade (umbrella or shade structure) where relevant
• clear boundary signage or barrier items for the class zone

These items support safe delivery in a wet, noisy, shared environment. AUSactive’s Aqua Exercise Guidelines include points on sound and instruction support in aquatic venues.

Source: https://ausactive.org.au/wp-content/uploads/2022/12/Aqua-Exercise-Guidelines.pdf

A stable chair supports regressions, balance options, and inclusive coaching. It also reduces pressure to improvise using unstable deck furniture. The key requirement is stability and low tip risk.

The venue. If public foot traffic cuts through an active class zone, that is a site set-up and traffic-flow issue. Safe Work Australia’s model code on managing the work environment and facilities covers keeping walkways safe and managing the work environment to reduce risk.

Source: https://www.safeworkaustralia.gov.au/system/files/documents/1901/code_of_practice_-_managing_the_work_environment_and_facilities.pdf

Aqua instructors often demonstrate fast movements and directional changes on deck while supervising participants in the water. A person cutting through the teaching space can create a collision risk for the public, the instructor, and nearby participants. Venues should use boundaries and signage so the public can choose a safe route.

Source: https://www.safeworkaustralia.gov.au/system/files/documents/1901/code_of_practice_-_managing_the_work_environment_and_facilities.pdf

It’s necessary. Aqua instructors cue over water noise, echo, music, and other pool users, often across a wide space. A working microphone supports clear instruction and reduces the need to yell. AUSactive’s Aqua Exercise Guidelines include guidance related to sound and instruction delivery in aquatic environments.

Source: https://ausactive.org.au/wp-content/uploads/2022/12/Aqua-Exercise-Guidelines.pdf

Yes. Voice strain is recognised in teaching workforces, and research has examined voice amplification as a way to reduce vocal load.

Sources:

• https://pubmed.ncbi.nlm.nih.gov/20655172/
• https://pmc.ncbi.nlm.nih.gov/articles/PMC6848564/

Heat and humidity can increase physical strain and fatigue. Safe Work Australia treats working in heat as a workplace hazard and outlines approaches to manage heat exposure.

Source: https://www.safeworkaustralia.gov.au/safety-topic/hazards/working-heat

Options include:

• a fan positioned near the instructor zone (aimed to avoid blowing across the water where possible)
• ventilation strategies (fresh air in, hot air out) where appropriate
• shaded teaching position outdoors (umbrella or shade structure)

Safe Work Australia provides practical guidance on managing heat risk.

Source: https://www.safeworkaustralia.gov.au/safety-topic/hazards/working-heat/frequently-asked-questions

Start with items that address the highest-frequency risks and the biggest delivery barriers:

1. non-slip mat
2. clear class boundary support (signage or barriers)
3. working microphone and sound

Then add frame, chair, and shade based on programme needs and venue layout.

Simple wording you can use to the facility

“I’m happy to teach, and I want to make sure we’re both protected and aligned on safety and responsibilities. Can you please confirm the items below in writing, especially supervision expectations, emergency procedures, and insurance arrangements for group classes?”

1) Your status and agreement

1. Will I be engaged as a volunteer or as a contractor?
2. If you volunteer, do you have a volunteer agreement or induction process (including WHS)?
3. If a contractor, will you require an ABN and an invoice process?
4. Who is the on-site contact person during classes?

Safe Work Australia volunteer WHS duties reference:
https://www.safeworkaustralia.gov.au/safety-topic/managing-health-and-safety/volunteers/whs-duties

2) Insurance clarity (yours and theirs)

1. Can you confirm the facility’s public liability insurance applies to group aqua classes on site?
2. Do you require me to be named as an “interested party” or provide a certificate of currency?
3. Are there any exclusions I should know about (for example, no lifeguard on duty, depth restrictions, equipment restrictions)?
4. If I volunteer, does your insurance still require me to hold my own public liability and professional indemnity cover for instruction?

(You can tell them you’ll also confirm the site details with your insurer, so everyone is aligned.)

3) Supervision, lifeguard coverage, and emergency roles

This is a key one.

1. During the class, who is responsible for overall pool supervision: me (class only) or the facility (whole pool)?
2. Is a lifeguard or designated pool supervisor present during class times?
3. If there is no lifeguard, what are the facility’s rules around “supervision” and pool access while a class is running?
4. What is my role in an emergency, and what is the facility staff’s role?

Royal Life Saving aquatic risk guidance:
https://www.royallifesaving.com.au/Aquatic-Risk-and-Guidelines

4) Emergency procedures and equipment

1. Please provide the site emergency action plan and evacuation procedure.
2. Where is the AED located (if you have one), and who is trained and rostered to use it?
3. What rescue equipment is available poolside (e.g., a rescue tube or a reach pole), and where is it stored?
4. What is the process for calling emergency services from pool deck (phone access, reception, gate codes, directions)?

AUSactive aqua exercise guidelines emphasise facility-specific planning and emergency readiness:
https://ausactive.org.au/wp-content/uploads/2022/12/Aqua-Exercise-Guidelines.pdf

5) Pool conditions that affect safe delivery

1. What is the usual water temperature range and depth used for classes?
2. Are there any heating or ventilation issues affecting the comfort or safety of older adults?
3. Are there any water quality alerts or closure rules I should follow (chemical dosing schedule, visibility, filtration downtime)?

6) Participant process (screening, attendance, and incident reporting)

1. Do you want participants to complete pre-exercise screening before commencing (and how will that be stored)?
2. Do you have a preferred medical clearance process for higher-risk residents?
3. What is the maximum class size for that pool?
4. What is the incident/near-miss reporting process, and who do I submit reports to?

General fitness industry risk management reference:
https://bp-fitnessaustralia-production.s3.amazonaws.com/uploads/uploaded_file/file/14884/The-Australian-Fitness-Industry-Risk-Management-Manual.pdf

7) Site induction and practical access

1. Can I complete a site induction before the first class (including plant room rules, pool deck hazards, and emergency exits)?
2. Are there slip hazard controls in place (mats, footwear policy, signage)?
3. Where can I store equipment (if any) and where can I set up music safely (power, trip hazards, volume limits)?
4. Do you have any resident privacy or filming rules I need to follow?