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Lifesaving devices are not mandatory in the pools of Queensland's hotels despite more drownings in them than in any other Australian state or territory.
Three people have drowned in hotel pools on the Gold Coast this year, including a father and son who died in the same pool in an Easter Sunday tragedy.
The Sunshine State, marketed as a water-loving, fun-in-the-sun destination, recorded 22 of Australia's 36 drownings in hotel, motel, resort and caravan park pools between July 1, 2013 and June 30, 2023, according to figures from Royal Life Saving Australia (RLSA).
Fewer people died from shark attacks, which accounted for 20 deaths, across all of Australia during the same period.
And while millions of dollars are spent keeping beaches safe each year, RLSA says hotel pool safety often flies under the radar.
What do the rules say?
Regulations differ across Australian states and territories, but in Queensland, there is no difference in pool safety requirements between one in a backyard or a hotel — both must have a compliant pool fence and display a cardio-pulmonary resuscitation (CPR) sign in the pool area.
Some hotels are required to install fencing if they have a pool safety management plan (PSMP) approved by the state regulator, the Queensland Building and Construction Commission.
The National Aquatic Industry Committee (NAIC), a peak body promoting water safety in public and commercial settings, has developed safety guidelines for communal pools, including those in hotels.
They recommend communal pool areas have lifesaving devices, such as a rescue tube or life ring, a defibrillator, a duress alarm and staff trained in CPR.
RLSA general manager and NAIC chair, RJ Houston, said there were a few good examples of hotels operating within the guidelines.
"Unfortunately, that's not the case everywhere, and it's certainly not the average," Mr Houston said.
"It's quite common for us to go out after an incident to investigate what should have been in place, only to discover that nothing in relation to those guidelines was in place."
Mr Houston said it was difficult to understand the greater hotel sector's reluctance to adopt the NAIC guidelines, but some "large hotel operators" had offered occasional feedback.
"They've said that they don't deem those lifesaving recommendations being reasonably practical," he said.
What does pool safety cost?
David Brook has worked in Queensland's accommodation sector for more than 35 years and is now the general manager of Paradise Resort on the Gold Coast.
The resort, which markets to families with young children, can have hundreds of people using its pool areas at a time during peak periods.
"We don't tell people we have lifeguards around the pool because they become complacent. However, everyone is trained fully in what to do when there is an emergency," Mr Brook said.
"It's not if (an emergency arises), it's when — and we do see it very regularly."
The financial burden of training staff and keeping their water rescue and CPR skills up to date is huge, and is one of the reasons Mr Brook believes more hotels don't follow the NAIC guidelines.
"We've all got a bottom line to make, and it is a cost of doing business in our view," Mr Brook said.
He said pool areas were seen as added extras or facilities in many hotels, and were not treated with the same level of importance as a restaurant, bar or reception area.
"They are all seen as key revenue generators, and a swimming pool is something supplied as a service to a guest."
How safe are hotel pools?
Drowning fatalities in inland waterways and at beaches are far more common than in hotel pools and, respectively, had an average annual death toll of 121 and 58 during the past decade, according to RLSA data.
That data also shows backyard swimming pools account for an average of 16 deaths a year Australia-wide.
The concern, according to RLSA, is that unlike backyard pools, hotel pools are open to anyone who pays to use them.
Royal Life Saving Queensland executive director Paul Barry said although all hotel operators wanted to have a safe pool, there was a disconnect between the legal and best-practice definitions of what that looked like.
"We know those locations are frequented by people of differing capabilities and swimming skills, and when they do go there, they might be a little more relaxed," Mr Barry said.
"A lot of non-swimmers won't go in the surf because they know it's dangerous, but at a resort pool, their inhibitions are sort of opened up and they feel a bit safer.
"It may not be feasible for every hotel or motel to have a lifeguard on duty, but we do see that there is scope for improvement."
Mr Barry said an industry code of practice and better risk analysis of a pool's location and features could reduce risk in hotel pool settings.
"Things like their size, whether they have features that attract children and the really vulnerable and whether they're open 24 hours or if they're secured and locked at night so people can't go in them," he said.
The national peak body for the hotel sector, Accommodation Australia, declined an interview request from the ABC. In a statement, chief executive Michael Johnson said hotels always took guest safety seriously.
"Hotels follow legal requirements for fencing and signage, and many have rescue equipment and other safety measures in place," Mr Johnson said.
"There have been some tragic incidents this year, but thankfully they are rare.
"Hotel owners are always looking at better ways to make people safe."