Built for Churn
Disposable Workforce, Preventable Harm Part 3/4
Last week we asked what certified actually means in our industry. This week we ask the question behind that question: why does the system keep producing minimum viable training? Not because instructors do not care. Not because owners do not know better. Because the incentives are pointing in the wrong direction, and incentives are more powerful than good intentions.
Do the Math Out Loud
In many programs across the United States, ( I am focused on the US for now) instructors are paid between twelve and twenty dollars an hour. A thirty-minute lesson pays that instructor somewhere in the ballbark of half of that in wages. That is before payroll taxes, prep time, cleanup, debriefs, and the cognitive load of managing fear, caregiver dynamics, and real-time safety judgment in the water. We keep calling this prevention. Then we price it like entry-level labor. And when you build a prevention layer on entry-level economics, the outcomes are predictable.
Turnover Is a Predictable Outcome
High turnover is treated like an unfortunate side effect in aquatics, but it is not a surprise. It is a predictable outcome of a labor model built on low wages, short tenures, and minimal onboarding. Instruction is often positioned as a first job, a seasonal gig, a flexible side hustle, or a stepping stone to something else. That framing is not automatically wrong. Many of us started young, and there is real value in getting young people into this work early. But we cannot pretend the downstream effects are accidental. If the system assumes most instructors will be gone within months to several years, it will not invest like it expects them to become prevention professionals. It will invest like it expects them to be replaceable.
And when the workforce is designed for churn, the training system will always drift toward speed, because depth is expensive. Depth requires paid onboarding time, shadowing, supervised teaching, real feedback in live environments, and calibration meetings where instructors learn to recognize risk the same way. It requires ongoing in-service training that is hands-on rather than a checkbox. If you assume most instructors will be gone two years, investing in that infrastructure starts to look like bad business. So programs shorten training, skip mentorship, rely on enthusiasm, and hope that experience will fill the gaps over time. But hope is not infrastructure, and experience without structured feedback is just repetition.
What Training Compression Actually Signals
When training compresses without strengthening mentorship, the message is clear even when no one says it out loud: convenience matters more than depth. Instructors hear it even when it is never spoken. They are asked to do complex work with thin support, expected to manage emotional regualation and descalation, caregiver emotions,class managment and real-time safety judgment on the fly, and then held responsible for outcomes the system was never designed to deliver. This is the silent gap again. Responsibility rises while preparation shrinks.
This drift is not unique to aquatics, but injury prevention fields do not get to treat efficiency as neutral. Public health and pediatrics are blunt about why. The American Academy of Pediatrics is clear that even the best swim lessons cannot drown-proof a child, and the CDC reinforces that drowning can happen in seconds and is often silent. If pediatric and public health authorities treat swim lessons as one layer in a prevention system, the industry should not be allowed to market itself as though it is the whole system, especially in child-care-adjacent contexts like drop-off events, camps, and parents’ night-out programming. Compression without infrastructure creates fragility, and fragility looks like inconsistent standards across instructors, inconsistent promotion decisions across children, inconsistent risk recognition within the same facility, and near-misses treated as isolated events rather than as feedback the system should be learning from. The system works until it does not, and by the time it does not, the cost is already paid.
When the Gap Has a Name
In February 2018, a three-year-old named Mitchell Chang was found unresponsive in a pool during a parents’ night-out event at a swim school in Texas. He did not survive. Reporting at the time described the incident as a tragic accident, and local coverage noted that no one at the facility was facing charges. The Mitchell Chang Foundation, established by his family, has described what they believe were gaps that night, including questions about supervision, staff training, and how long he went unnoticed. Those are the family’s allegations, not court findings, and I am treating them as such.
But the legislative response that followed is documented and verifiable, and it points to something larger than one facility. At the time of Mitchell’s death, Texas had no dedicated state licensing framework for child swim instruction operators, no statewide baseline defining what trained meant across private swim schools, and no oversight structure built around routine licensing, enforcement, and public accountability. His family has spent years trying to change that. The Mitchell Chang Swim Safety Act has been introduced across multiple Texas legislative sessions, and the most recent version, filed as SB 63 for the 89th Legislature, explicitly proposes licensing and regulation of child swim instruction operators with penalties and enforcement mechanisms. As of this writing, it was referred to the Senate Business and Commerce committee in February 2025 and has not become law. That is not a Texas problem. Texas is simply where the gap is easiest to see, because a family refused to let it stay invisible.
When the Gap Has Another Name
Mitchell Chang’s story is not the only one. Two others are worth naming here, not to relitigate specific incidents, but because of what each family chose to do afterward.
In Los Angeles County, a six-year-old named Roxie Forbes drowned at the pool of a children’s summer day camp. Her parents established the Meow Meow Foundation and pushed for concrete policy change. On June 28, 2022, Los Angeles County approved Roxie’s Swim Safe Ordinance, an amendment to county health and safety code requiring aquatic safety plans, CPR and first aid training, incident reporting, and lifeguard services for public pools at children’s camps and schools in the areas where the ordinance applies. Requirements took effect January 1, 2023.
That same year, in Burke County, Georgia, a four-year-old named Israel “Izzy” Scott drowned during a private backyard swim lesson. Public reporting described a group lesson with roughly ten children and indicated that parents were not permitted in the swimming area during instruction. What followed was Izzy’s Law, which requires the Georgia Department of Public Health to publish a model aquatic safety plan for private instructors and requires private instructors to have an aquatic safety plan in place before providing lessons. The law’s core elements, including attention to student-to-instructor ratio, secondary supervision, and the right of parents and guardians to be present, are not nice-to-haves. They are a formal acknowledgment that when oversight is optional, safety becomes a branding claim rather than a verifiable system.
Why does the field so often resist greater accountability and oversight,especially when those proposals focus on verifiable basics like ratios, emergency planning, incident reporting, and caregiver access? Not every concern about regulation is cynical. Some operators worry about poorly written rules, one-size-fits-all requirements, added costs, and enforcement that penalizes good programs while missing bad actors. Those are legitimate implementation questions. But they don’t fully explain the pattern that keeps showing up at the exact moment oversight becomes enforceable: industry representation is on the record opposing bills in committee, and across sessions the same category of stakeholders repeatedly resists licensing, external review, and requirements that would make “safety” measurable rather than declared. So the question I want to ask out loud is simple: what, specifically, becomes harder when accountability is no longer optional? If we believe this work is prevention, oversight should function as proof; evidence that a program’s safeguards exist in practice, not as an existential threat.
Three families. Three different states. Three different regulatory mechanisms. The same gap underneath all of them. And in each case, the gap did not close because the industry decided to close it. It closed because a family refused to let it stay invisible and a legislature was finally forced to respond.
The Fragmentation Problem
Even if every program genuinely wanted to raise standards, the field is structurally fragmented in ways that make collective movement nearly impossible. Every program has its own internal training, its own language, its own certification, and its own definition of what qualified looks like. Some internal systems are rigorous. Others are superficial. Most are not comparable to one another in any meaningful way. Aquatics already has a precedent worth naming here. The CDC created the Model Aquatic Health Code precisely because pool safety rules vary widely across jurisdictions, but the MAHC only becomes enforceable when adopted by local, state, territorial, or tribal jurisdictions. Adoption is optional and uneven. We already acknowledge that the built aquatic environment needs a model code to reduce dangerous variability. The harder question is why we accept total variability in the human layer that actually touches children.
The parallels to other industries are instructive. Childcare is regulated not because every provider is negligent, but because children are vulnerable, risk is predictable, and parents cannot verify safety claims at the door. Federal law requires inspection results to be posted publicly so families can see compliance history and substantiated complaints. Youth sports has taken a similar approach to concussion risk, building mandatory coach training, removal-from-play protocols, and clearance requirements that create documentation and accountability even in decentralized, volunteer-heavy environments. Amusement parks and water attractions have faced renewed regulatory scrutiny after tragedies exposed what happens when self-inspection substitutes for external oversight. In each of these fields, the regulatory logic is the same: when harm is predictable, vulnerability is high, and consumers cannot accurately evaluate safety claims at the point of purchase, we build systems that verify what providers cannot simply declare.
Swim schools, learn-to-swim programs and swim instructors occupy a strange middle space: part education, part recreation, and sometimes functionally childcare. The standards governing them are often private, proprietary, and entirely unverifiable. Layered on top of that is what might be called the “me ahead of we” dynamic, where proprietary certifications, franchise incentives, brand protection, and market differentiation treat shared standards as a competitive threat rather than a collective responsibility. If the field agreed on a measurable baseline, some programs would have to admit they are not meeting it, some certifications would have to demonstrate effectiveness with evidence, and some marketing claims would have to become something closer to proof. That discomfort is real, but it is considerably smaller than the cost of the alternative.
A Draft Professionalization Ladder
One concrete thing the field could agree on is a tiered professional structure that makes progression visible and investment purposeful. This is not a finished product. It is a starting place for a conversation the industry needs to have collectively.
Level 1 is the Trainee Instructor, someone who cannot yet teach independently, works only under direct supervision, completes foundational coursework in child development, motor learning, and water safety, and must demonstrate core skills in a live environment before advancing.
Level 2 is the Verified Instructor, cleared for independent teaching after demonstrating competencies through observed sessions and formal feedback, participating in regular calibration with the team, and accumulating documented mentored hours rather than simply completing a course.
Level 3 is the Lead Instructor, an experienced practitioner who has been consistently evaluated and is now responsible for supporting the development of newer instructors, contributing to calibration sessions, conducting peer observations, and serving as a quality benchmark within the program.
Level 4 is the Mentor and Evaluator, someone specifically prepared for formal observation, feedback, and sign-off on instructor advancement, who participates in refining program standards over time rather than simply enforcing them.
This is what professional infrastructure looks like, not bureaucracy for its own sake, but the difference between a workforce that is managed and a profession that is built.
The Cost of Depth Thought Experiment
Try this exercise as honestly as you can. If you paid and trained your instructors like prevention professionals, what would change? If you paid more, you could require more. You could justify longer onboarding, retain people long enough for mentorship to matter, and build a culture where standards are practiced rather than posted on a wall and forgotten. But then the harder question follows. If depth costs more, who pays? Do lesson prices go up? Does the lesson format change? Do growth targets get reconsidered? Do we build models that do not depend on underpaying the people doing the most important work?
Right now, the gap is being paid for somewhere. Often by instructors, in burnout and emotional load they were not prepared to carry. Often by families, in false reassurance and inconsistent quality they have no tools to evaluate. And sometimes by children, in outcomes we call tragedies but that a better-designed system might have prevented. Mitchell Chang’s family has spent years trying to get one state to require basic oversight of the places families trust with their children’s lives, and the bill is still not law. Roxie Forbes’ family helped drive enforceable county requirements for pools at children’s camps and schools because they refused to let oversight remain optional. Izzy Scott’s family helped move a state to require private instructors to have safety plans in place before teaching a single child. That is the cost of the gap made visible, paid in grief, and converted into the policy work our industry should have done on its own.
The Question We Have to Ask Out Loud
What is the true cost of prevention-level instruction, and who is currently paying for the gap? I want to hear from operators specifically this week. If you built your pricing around what it actually costs to train and retain instructors at a prevention level, what would a lesson cost? And what do you think your community would pay for it? Drop it in the comments. This conversation needs daylight, not back rooms at industry events.
Next week we finish the series with the hardest question of all. If we know what is broken and we understand why, what would it actually take to build something better? Week 4 is about scalable depth, shared standards, and what it looks like to move this field from aspirational to operational.
Endnotes:
AAP (2019). “Prevention of Drowning.” Pediatrics.
https://publications.aap.org/pediatrics/article/143/5/e20190850/37134/Prevention-of-DrowningCDC (2026). “Summer Swim Safety.”
https://www.cdc.gov/drowning/prevention/summer-swim-safety.htmlTexas SB 63 (2025). “Mitchell Chang Swim Safety Act” — bill status (referred Feb 3, 2025).
https://legiscan.com/TX/bill/SB63/2025Texas SB 63 (2025). “Mitchell Chang Swim Safety Act” — bill text.
https://legiscan.com/TX/text/SB63/2025LA County DPH (2022/2023). “Roxie’s Swim Safe Ordinance” (approved June 28, 2022; effective Jan 1, 2023).
https://www.ph.lacounty.gov/eh/safety/roxie-swim-safe-ordinance.htmCDC (MAHC). Model Aquatic Health Code overview (adoption is voluntary/uneven).
https://www.cdc.gov/model-aquatic-health-code/index.htmlChildCare.gov. “Monitoring and Inspections” (oversight + public transparency model).
https://childcare.gov/consumer-education/regulated-child-care/monitoring-and-inspectionsGeorgia DPH (Izzy’s Law / SB 107). “Safe Swimming” (safety plan requirement; April 1, 2024).
https://dph.georgia.gov/health-topics/injury-prevention-program/safe-swimmingGeorgia Code § 31-45A-5. Aquatic safety plan requirement (statutory text).
https://law.justia.com/codes/georgia/title-31/chapter-45a/section-31-45a-5/Georgia Senate Press Office (2023). “Izzy’s Law” press release / background.
https://senatepress.net/senator-max-burns-introduces-izzys-law.html