Drinking Water Safety Plans
Implementation in England and
Wales
Claire Pollard
Drinking Water Inspectorate
28th & 29th February 2012
guardians of drinking water quality
DRINKING WATER INSPECTORATE
Presentation Outline
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WHO Guidelines
Water supply arrangements in UK
Legislation in England & Wales
Introduction of Water Safety Plans - Public water
supplies
Approach to risk assessment/risk management
Delivering risk mitigation
Positive [& negative] outcomes
Issues & challenges
Private Water Supplies
World Health Organisation (WHO)
Guidelines
• In 1983 – 1984 and in 1993 – 1997, WHO published 1st
& 2nd editions of Guidelines for Drinking Water Quality
as successors to WHO International Standards
• The 3rd Edition was published in 2004
• Describes a “Framework for Water Safety”
encompassing functions of suppliers, regulators &
surveillance agencies (i.e. Health Protection Agencies)
• Framework based on a Water Safety Plan (WSP) for risk
assessment & risk management of water supplies
• Provides for a rolling review & update of guideline
values
World Health Organisation (WHO)
Guidelines
• WHO published 4th Edition on 4 July 2011
• Consolidates advice on implementation of risk
based approach to management of drinking
water supplies using a water safety plan
approach
• Changes to some guideline values – mostly
relaxing the standard i.e. acrylamide,
antimony, benzene, boron, nickel, selenium
• Tighter standards for cadmium, vinyl chloride
• New standards proposed i.e. DBP (chlorite &
chlorate), NDMA
UK
public
supplies
4 regions
Scotland
Northern Ireland
Wales
England
UK water supply arrangements
Ownership/Organisation:
• Public water supplies - provided by a licensed
(statutory) water supplier
• private ownership E & W [27 licensed water suppliers],
• public ownership NI & S [each with one water
company]
• Private water supplies -not provided by licensed
water supplier (many used for commercial or
public activities)
• owned and operated by individuals, groups of people,
organisations (rarely publicly owned)
Population served by public & private supplies
England & Wales:
• 99% population served by public supplies
• 1% on private supplies [53, 945 discrete supplies]
Scotland:
• 97% population served by public supplies
• 3% on private water supplies [19,177 discrete supplies]
Northern Ireland:
• 99.6% population served by public water supplies
• 0.4% on private water supplies [4116 discrete supplies]
Water Quality LEGISLATION – England & Wales
Three levels of legislation:
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EC Directive
• 80/778 on the quality of water intended for human consumption. (Prior
to this there were no numerical standards other than the WHO guidelines)
• 98/83/EC on the quality of water intended for human consumption
[introduced standards based on WHO guidelines]
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National Primary Legislation
• Water Act 1989
• Water Industry Act 1991
• Water Act 2003
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National Secondary Legislation
• Water Supply (Water Quality) Regulations 1989
• Water Supply (Water Quality) Regulations 2000/2001
• Water Supply (Water Quality) Regulations 2000 (2001 in
Wales)(Amendment) Regulations 2007
• Water Supply (Water Quality) Regulations 2010 [Wales]
• Private Water Supplies Regulations 2009
Primary Legislation
Water Act 1989:
• Established model of privatised water companies &
water industry regulators
Water Industry Act 1991 & Water Act 2003
• Water companies duty to supply wholesome water
• Secretary of State [for environment, food & rural affairs]
has power to
• make regulations
• appoint a Chief Inspector of Drinking Water
• Secretary of State’s duty to enforce when breach of
regulations
• Chief Inspector has power to prosecute for supply of water
unfit for human consumption
Secondary Legislation [Public supplies]
Water Supply (Water Quality) Regulations 2000
(2001 in Wales)
• Defines wholesomeness by reference to water quality
standards - Based on 1998 EC Drinking Water Directive
• Defines requirements for:
• Monitoring i.e. Sampling points & frequencies
• Analytical requirements
• Level of water treatment & disinfection
• Approval of substances and products
• Records Provision and publication of
information
The Drinking Water Inspectorate (DWI)
• Established in 1990 (privatisation]
• Regulator of drinking water quality for England and
Wales [public supplies]
• Ensures that drinking water suppliers meet
requirements laid out in legislation.
• Enforces when there are breaches of the
regulations.
• Prosecutes when water ‘unfit for human
consumption’ is supplied
• Provides technical advice to Government
• Reports to the Secretary of State, Welsh Assembly
Government and the European Commission
Current Regulatory Framework in England &
Wales
EA
DWI
OFWAT
Public supplies 27 water companies
Local
Authorities
99%
Health
Authorities
Consumers
Private supplies
1%
Compliance with drinking water standards
[Public supplies]
Drinking water 2009
So why WSPs?
• >99.96% compliance but……..
• Reactive approach based on end point
monitoring
• Too much emphasis on treatment
• Too many incidents
• Too many “significant” failures
• Stakeholders not communicating
• Consumer confidence undermined
• Challenges – competition, new owners,
re-organisations, sub-contracting etc
Four 99% compliant waters, but forget the
tests, which one would you drink?
Incidents reported to DWI from 2001 to 2008
• Number classified as incidents in 2008 = 144
160
140
120
100
80
60
40
20
0
2001
July 2009
2002
2003
2004
2005
Drinking water 2008
2006
2007
2008
Implementation in England and
Wales – Where did we start?
• DWI has been an advocate of WSPs since the
launch of the 3rd edition Guidelines for ensuring
the safety of drinking water supplies [2004]
• Between 2004 to 2008, DWI encouraged water
suppliers to adopt a WSP approach on an informal
basis.
• Encountered resistance to implementation of the
approach at the start
• Risk assessment and risk management became a
regulatory requirement [for public water supplies]
from December 2007.
Amendment to the Regulations
• The Water Supply (Water Quality) (Amendment)
Regulations 2007 came into force 22 December
2007
• Notable changes include:
• The introduction of two regulations (27 & 28)
requiring water companies to carry out risk
assessments and report outcome to DWI
• Guidance to the regulations recommended
approach to risk assessment and risk management
should be based on the WHO’s WSP approach.
• No change to the drinking water quality standards
set out in 2000/2001 Regulations
Regulation 27
• Every water supplier must carry out a risk assessment of each of
its treatment works & connected supply system in order to
establish whether there is a significant risk of supplying water
from those works or supply system that could constitute a
potential danger to human health;
• Risk assessment should follow WHO WSP approach [source to
tap]
• Where a significant risk of supplying water that could be a
potential danger to human health is identified, [i.e. when WSP
residual risk is considered unacceptable in nature], the supplier
must identify further action that is required to control or mitigate
the risk.
• Every water supplier shall keep its risk assessments under review.
• DWI can serve a notice on a water supplier to carry out a risk
assessment or a review of an existing risk assessment by a date
specified.
Regulation 28
• Once a water supplier has carried out a risk assessment under
regulation 27, it must submit to DWI a report of the assessment.
• The report must contain:
• a description of the risk assessment methodology;
• a statement confirming where there is no significant risk of
supplying water constituting a potential danger to human health;
and details of the validation and other monitoring of any existing
control measures.
• Where the assessment establishes that there is a significant risk of
supplying water that could constitute a potential danger to
human health, the report must contain
• details of every risk or potential risk that has been identified; and
• details of the measures that the water supplier intends to take to
mitigate the risk.
• DWI can issue a Notice requiring the water supplier to take certain
measures for a period of time to mitigate the risk including to
prohibit supply until specified conditions are satisfied
The Water Safety Plan Approach Expectations
• WHO Water Safety Plan approach to identify
actual & potential hazards in catchment, at
treatment works, in distribution and at
consumers’ taps
• Assessment of short, medium & long term
control measures required for each hazard
identified
• Establish whether need for investment to
mitigate risk either in the area of catchment
control, or with treatment at works or in the
distribution systems or perhaps combinations
of these.
Risk Characterisation
• Many different approaches to risk assessment
adopted. Each company has a different risk
assessment methodology based on the WHO
approach.
• Most are based on the basic 5x5 matrix of
consequence x likelihood.
• In order to use any risk characterisation model
effectively and consistently, clear definitions and
guidance are required.
• At the start of Water Safety Planning in England and
Wales, risk assessment was based on expert
knowledge as well as data and evidence (not strictly
quantitative).
Types of risk identified
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Nitrates and Pesticides (raw water source)
Pathogens (Cryptosporidium)
Lead (consumers taps)
Contamination of service reservoirs (TC/EC)
Concessionary supplies (Variety)
Taste and odour
Raw water deterioration (raw water colour
& impact on THM formation)
• Discolouration in zones (Iron and
Manganese mainly due to pipes)
Initial findings from
implementation of RA/RM
• A risk assessment report for every public water
supply system was received by 1 October
2008(over 800 reports).
• Over 900 actions (short, medium & long term)
related to mitigating risks to human health
identified by the 27 water companies.
• Actions related to catchments, treatment works,
distribution systems and domestic/commercial
properties & were set out in Action Plans
• Risk assessments informed investment
requirements for the financial period 2010 - 2015
Delivering Risk Mitigation
• All actions identified to mitigate risk to human
health were formalised into legally binding
contracts for delivery i.e. Undertakings or Notices
(statutory instruments)
• At end of 2010, 251 of the 917 actions were
Notices and 138 were Undertakings.
• The remaining actions (528) are being delivered by
companies following the self regulation model.
Positive Outcomes
• Improved liaison with other stakeholders such as the
Environment Agency, Health Protection teams and Local
Authorities
• Greater clarity of ownership and responsibility for risks from
catchment to tap
• Incorporation of proactive risk management in all aspects of
water suppliers’ operations
• More robust contingencies requiring commitment &
agreements between suppliers
• Ability to influence organisations to cooperate in the
production of particular control measures (consumer
communications strategy)
• Reports are used as a resource to compliment DWI’s day to day
activities including audits, investigations, compliance
assessments etc
Negative Outcomes
• Variation in interpretation of what constitutes a
risk to human health
• Microbiological contamination at service reservoirs
[presence of Total Coliforms]
• Organics/colour – not an obvious risk by potential for
DBP formation i.e. THM
• Lead – identified as a ‘future’ risk but not a current risk
[assessment based on compliance with standard]
• Some suppliers not looking at longer term position
i.e. potential future risks
Experiences to date: Issues
• Companies based their WSPs on the WHO
Guidelines but they all tailored the
approach to fit their business, hence 27
very different risk assessment report styles
• The scope for insufficiently implementing
WSPs is huge (one supplier created a
methodology and then didn’t follow it!)
• Many companies struggled to put together
a comprehensive communication strategy
for stakeholders and consumers
Challenges
• The main challenge has been getting the WSP
implemented fully and embedded in the water suppliers
operations (& not a stand alone exercise)
• Also challenging to get cooperation from some
organisations that may hold information that can be used
to improve risk assessment
• Ability to influence organisations to cooperate in the
production of some controls (consumer communications
strategy)
• For DWI, challenge on resources to review and assess
large volume of reports which are all in very different
styles.
Private Water Supplies [E & W]
• 1% of the population on private supplies (not
‘mains’ supply)
• Management/control is not a licensed water
supplier
• Private Water Supplies Regulations 2009
introduced risk based approach similar to public
supplies regulation
• Local authorities responsible for carrying out risk
assessment, monitoring & taking enforcement
action to improve supplies
• DWI provides technical advice & support to Local
Authorities .
Private Water Supplies Regulations 2009 Risk assessment
Private supplies:
• Every local authority must carry out a risk
assessment every five years to establish whether
there is significant risk of supplying water that
would constitute a potential danger to human
health
• If any private supply constitutes a potential danger
to human health, a local authority must serve a
notice on the relevant person(s) to .........prohibit
or restrict supply....inform consumers and specify
remedial actions”
Private Water Supplies - situation
in 2010
• 349 Local Authorities are responsible for
carrying out the risk assessment of PWS
• Approx 54,000 PWS in total
• Approx 34,000 are single dwellings and are
not covered by the regulations
• 20,000 PWS will require risk assessment by
2014
Case Study:
Before introduction of risk assessment
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Borehole serving 23 domestic dwellings
Failure for E. Coli in annual sample
Remedial action was to install chlorination
Immediately afterwards sample taken and
satisfactory
No risk assessment
Root cause not addressed
No requirement for ongoing management &
control of disinfection system
Achieved a satisfactory annual sample but did not
make the supply safe.
Case Study
After introduction of Risk Assessment
• Local authority risk assessment carried out
• Uncontrolled risks (deficiencies) were
identified
• Open bore head works allowing ingress of
contaminants
• Lack of vermin protection on reservoir out flows
• No basic maintenance or management
• Supply deemed a potential danger to
human health and Notice served on
relevant person (owner)
• Users informed and advised to boil water
before use
Case Study
Remediation Steps in Notice
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Repair of borehole head works
Empty & clean storage reservoir
Vermin proof reservoir outflow & pump house
Install lockable reservoir cover
written management procedure for disinfection
with record keeping
• Regular inspection and cleaning of storage
tanks inside each dwelling
Case Study Borehole Head Works
Case Study storage reservoir protection
(vermin proofing of outflow and pump
house)
Conclusions
• Most water suppliers [public supplies] have adopted water safety
planning as part of their water supply management operations
[‘Business as Usual’ activities]
• Assessments under continuous review – new actions being
identified on a rolling basis.
• Risks are being proactively identified and addressed – in many
cases before DWI serves a Notice
• Actions are much less failure driven
• WS planning is a continually developing process with quality and
content of risk assessment reports improving
• DWI using risk assessment reports to focus its regulatory
activities i.e. To prioritise audits & inspections and event
assessments
• Risk assessments of private water supplies in infancy but already
seeing improvements to previously unsatisfactory situations
The importance of understanding how to do
a water safety risk assessment !