EPA Advice Note
on
Water Safety Plans in Ireland
Derval Devaney
EPA
28/29 February 2012
1
Introduction
• Background to Water Safety Plans
• World Health Organisation WSP Manual
• Implementation of WSPs in Ireland
• EPA Guidance – Advice Note No. 8
2
Why Implement a DWSP?
• EPA has adopted a safety plan approach to ensure:
• Safe → Meets standards
• Secure → Management System in place
• All potential risks identified source to consumer
3
Why Implement a DWSP?

EPA has adopted a safety plan approach to ensure:

Safe → Meets standards

Secure → Management System in place

All potential risks identified source to consumer
4
Boil water/restrictions
Notices in 2010
• 73 supplies
• 86,135 people
• Preventable
5
Why Implement a DWSP? (2)
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Outbreak of Cryptosporidium in Galway City in 2007 (242 cases of illness)
Compliance with micro, chemical and indicator parametric values was 99.1% the
previous year.
Monitoring did not tell us whether the supply was safe and secure
Need for a new approach
Galway City Council strongly advised to prepare WSP and EPA offered to assist in
guiding the process and in tandem develop guidance for other water suppliers
Initial concerns about scope of work involved and feasibility (e.g. catchment
issues)
Wholehearted enthusiasm for the WSP approach
WSP approach put in place by April 2010 and following this EPA prepared and
published Advice Note on Developing Drinking Water Safety Plans
6
International implementation
• WHO - WSP implementation under way in 70 countries
• UK Water Supply (Water Quality) Regs. amended 2007
• Legal requirement in UK private supplies - Private Water
Supplies Regulations 1999
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WHO manual, available on WHO website:
http://whqlibdoc.who.int/publications/2009/9789241562638_eng.pdf
Practical Guidance to facilitate WSP development
8
Philosophy of WSP approach
“The most effective means of consistently ensuring the
safety of a drinking water supply is through the use of a
comprehensive risk assessment and risk management
approach that encompasses all steps in water supply
from catchment to consumer”
“In these Guidelines, such approaches are called water
safety plans”
9
EPA Advice Note No. 8
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•
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Based on WHO guidelines and review
of practices in other countries
Advice Note is NOT a reproduction of
WHO guidelines but a brief note on
how they should be done in the Irish
context
It contains guidance on hazard
identification, risk assessment and
the preparation of action plans for
the hazards identified
EPA provided tool (developed with
GCC) for this
Available on web at
http://www.epa.ie/downloads/advic
e/water/drinkingwater/
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Key Components of a DWSP
• Identification of hazards
• Operational monitoring
• Documentation of the management arrangements
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Key steps in developing a WSP (1)
• Assemble a small team of experts
• Document and describe the system, capture all elements
• Identify the hazards that could occur (App 1)
• Perform a risk assessment using matrix
(likelihood/severity) (App 2)
• Define control measures to minimise risks
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Appendix 1 Hazard ID Sheets
13
Key steps in developing a WSP (1)
• Assemble a small team of experts
• Document and describe the system, capture all elements
• Identify the hazards that could occur (App 1)
• Perform a risk assessment using matrix
(likelihood/severity) (App 2)
• Define control measures to minimise risks
14
Appendix 2 RA Matrix (1)
15
Appendix 2 RA Matrix (2)
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Key steps in developing a WSP (1)
• Assemble a small team of experts
• Document and describe the system, capture all elements
• Identify the hazards that could occur (App 1)
• Perform a risk assessment using matrix
(likelihood/severity) (App 2)
• Define control measures to minimise risks
17
Key steps in developing a WSP (2)
• Validate control measures
• Re-assess risk to determine current risk (App 2)
• Establish improvement plan for significant risks
(App 3)
• Define monitoring of the Control Measures
• Verification of effectiveness of WSP
• Management procedures and documenting
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Appendix 2 - Action to be taken
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Key steps in developing a WSP (2)
• Validate control measures
• Re-assess risk to determine current risk (App 2)
• Establish improvement plan for significant risks
(App 3)
• Define monitoring of the Control Measures
• Verification of effectiveness of WSP
• Management procedures and documenting
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Action Plan for risks
• Appendix 3
• Medium Risk or
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Higher
Establish
Improvement
Target dates
Signed off by DoS
Target risk = eventual
risk rating
Hyperlink to hazard
spread sheet
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Key steps in developing a WSP (2)
• Validate control measures
• Re-assess risk to determine current risk (App 2)
• Establish improvement plan for significant risks
(App 3)
• Define monitoring of the Control Measures
• Verification of effectiveness of WSP
• Management procedures and documenting
22
Key steps in developing a WSP (3)
• Supporting programmes - develop skills & knowledge
• Working document – forms part of operational
practices
• Regular review of hazards, risks, controls (e.g. new
equipment)
23
Developing a WSP
• Not new, builds on good practice of risk assessment
and risk mitigation
• Links to HACCP but goes further
• Basically sound operating practice and common sense
• Puts emphasis on mitigating risks above sampling (after
the event, cause unknown)
BUT
• Targeted monitoring is still very important
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Developing a WSP
• A WSP applies to a specific water supply system
• Applicable to all types and sizes of water supply
systems
• What is a water supply system?
• source (catchment) → treatment → distribution →
consumer
• include other separate elements e.g. raw water
storage, service reservoirs, trunk mains
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Developing a WSP
• Essential that WSP is undertaken by someone who
understands the particular water supply system
• If expertise lacking external help or facilitation may
be needed
• Not solely a desk study, must involve site visits
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WSP Stakeholders
• WSP not just about the water supplier
• Agriculture
• Forestry
• Industry
• Road and rail
• Sewage works and septic tanks
• Consumers
• Regulator
• Other local authorities
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WSP Parameters
• WSP is not just about chemical and microbiological
parameters
• Sufficiency
• Flooding
• Power supplies
• Training
• Communications
• Laboratory facilities
• Etc…….
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Identifying Hazards
• Many hazards and potential hazards will be
identified
• Many will be low risk and not require further action
other than keeping under review
• Medium and High risk will require improvement
plans
• Important to document and justify the risk
assessment methodology to ensure a consistent
approach
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Improvement plans
• Needed for significant risks where there is no current
control or where the current control is not fully
effective or reliable
• Realistic and achievable
• Short, medium, long term
• Prioritised
• Need owner
• Need dates, progress chasing
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Its not that easy!
• Doesn’t always fit into a neat WSP manual format
• Enthusiasm and reluctance
• Misunderstanding the WSP approach
• Just another set of procedures
• Only considering parameters as hazards
• WSP teams too small or not empowered
• Stakeholders not involved
• Consumers not viewed as stakeholders
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Benefits of Water Safety Plans
• Catchment improvements
• Farming initiatives instead of treatment
• Sustainable improvements
• Staff understanding and involvement
• Improved treatment and ways of working
• Gaps in procedures and training identified
• Improved water quality and incident reduction
• Clearer, prioritised investment programmes
• Regulator confidence from water supplier sharing RA
and gap analysis
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WSP steps - Summary
Preparation
1
2
3
4
5
6
7
Assemble the WSP team
System assessment
Describe the water supply system
Identify hazards and hazardous events and assess the risks
Determine and validate control measures, reassess and prioritise the risks
Develop, implement and maintain an improvement programme
Define monitoring of the control measures (operational monitoring)
Verify the effectiveness of the WSP
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9
Management and communication
Prepare management procedures
Develop supporting programmes
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Feedback and improvement
Plan and carry out periodic review of the WSP
Revise the WSP following an incident
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EPA Action on WSP - 2012
• Implementation of WSPs - top OEE enforcement priority for
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2012
Recommendations of Drinking Water Report 2010
Develop the Enforcement Network webpage for WSP communicate guidance and training provisions, to promote
information sharing among the WSAs
Set up an Enforcement Network WSP group – support and
guidance to WSA
Develop criteria and methodology for assessment of draft
WSP and auditing of finalised WSP
34
Thank you
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