Proposed Strategy for Improvement of Private Water Supplies in Scotland

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1 Proposed Strategy for Improvement of Private Water Supplies in Scotland Philip Anderson DWQR Life Rural Supplies, Galicia, Spain 22 November 2013

2 The Drinking Water Quality Regulator for Scotland Regulator appointed by Scottish Ministers under the Water Industry (Scotland) Act Act confers the following functions on the Regulator: ensuring Scottish Water complies with its duty to provide a supply of wholesome water; and supervising the enforcement by local authorities of the drinking water quality duties which it is their duty to enforce (private water supplies)

3 Powers & functions of DWQR Public Supply Responsible for enforcing Water Quality Regulations Independent from Scottish Ministers Powers: Power to obtain information Power of entry and / or inspection Power of enforcement

4 Powers & functions of DWQR Private Supplies Regulated by local authorities No powers of enforcement DWQR supervises local authorities enforcement of their drinking water quality duties offers advice & guidance General Reports compliance with water quality standards (public & private) to European Commission No enforcement powers over local authorities

5 Public supplies Enforcement DWQR works closely with SW on noncompliance issues. DWQR will use enforcement powers if required. Private supplies LAs work with owners / users to achieve compliance LAs will use enforcement powers when necessary.

6 Why do we need a Strategy? Water quality of many PWS poor despite new Regulations and grants since 2006 Risk to health from many PWS of concern Time to step back and identify What s working well What s not working well Solutions to the issues Gaps in resources Additional resources Priorities

7 What is a PWS? Supply of water other than a supply provided by Scottish Water in pursuance of its core functions Applies to supplies for cooking, drinking, food preparation, washing (including the maintenance of personal hygiene), food production

8 Classification of PWS Type A PWS for human consumption purposes Provides 10m 3 or serves 50 persons Supply used as part of a commercial or public activity 2,434 reported to DWQR in 2012 Type B All other PWS for human consumption that are not Type A 17,482 reported to DWQR in 2012

9

10 PWS Water Quality Summary 2012 Parameter % Samples Failing Standard E. coli 19 Colour 18 Iron 16 Manganese 13 ph 24 Copper Lead 30 (2011 data) 5 (25µg/l standard) 12 (10µg/l standard 2011 data)

11 E. Coli Compliance Type A Type B Samples Taken Compliance (%) Samples Taken Compliance (%)

12 Compliance with E. coli Standard

13 Compliance with E. coli Standard

14 Compliance with E. coli Standard

15 E. Coli Compliance and Grant Spend

16 SW Raw Water Cryptosporidium Results 2011 Samples taken 1,753 Number of samples with Cryptosporidium 390 % Cryptosporidium 22.25% (26% in 2012)

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18 It s Not Just Us Problems world-wide DWQR involved with World Health Organisation Small Community Water Supply Management Network UN/WHO Protocol on Water and Health European Commission Guidance Scotland relatively well advanced

19 Aims of Proposed Strategy To make real and lasting improvements to PWS To prioritise improvements To reduce risk to health

20 Proposed DRAFT Strategy Initial draft by DWQR Takes account of suggestions from local authorities Needs input and agreement from all stakeholders

21 PRIVATE WATER SUPPLIES DRAFT PROPOSED STRATEGY FOR IMPROVEMENT

22 PWS - Who s Responsible? Area Water quality and supply management Provision of drinking water quality legislation Risk assessments, sampling and Environmental Health advice Enforcement of private water supplies legislation Supervision of local authorities water quality enforcement duties Enforcement of environmental protection legislation and guidance Health protection and advice Environmental Health Professional Development Local authority / Scottish Government / DWQR / liaison Management of Grants System Data reporting Responsibility Owners and users of private water supplies Scottish Government (Drinking Water Quality Division) Local authorities (Environmental Health) Local authorities (Environmental Health) Drinking Water Quality Regulator (DWQR) SEPA Forestry Commission Chemicals Regulation Directorate Health Protection Scotland Health Boards Scottish Government (Health) The Royal Environmental Health Institute of Scotland (REHIS) REHIS PWS subgroup. Current members: Highland Council (chair) Aberdeenshire Council Argyll and Bute Council Angus Council Moray Council Scottish Borders Council Perth and Kinross Council Scottish Government (Drinking Water Quality Division) DWQR Local authorities, Scottish Government Local authorities to DWQR DWQR / Scottish Government to DEFRA to Europe

23 Draft Categories 1. Education and awareness 2. Water quality and water treatment 3. Risk assessment and water safety plans 4. Legislation and grants 5. Compliance and enforcement 6. Health Protection

24 1. EDUCATION AND AWARENESS Education and Awareness WHAT S GOING WELL? WHAT ARE THE ISSUES? STRATEGY Many owners and users aware of risks from PWS. Significant numbers of owners and users stuff are not fully aware of the risks to health from PWS and the need to manage their supplies adequately. The need for an awareness campaign to be investigated by the Scottish Government with input from all stakeholders and communications experts, highlighting the potential risk to health from PWS and the need for adequate management of supplies by owners and users. A user friendly PWS information pack/users pack for all owners and users of PWS to be considered, involving input from all stakeholders. To include: Generic Information Information on water source (e.g. surface water) and catchment/source risks Water treatment, its management and limitations Risk from distribution systems and storage The significance of water quality results The importance of maintenance The risk to health from failing PWS and examples of outbreaks of illness Owner / users experience Supply Specific Information Maintenance schedule template Copy of operating instructions for water supply system A copy of the risk assessment for Type A supplies or a template for Type B supplies, guidance and local authority contact details Water Safety Plan template and guidance Contact details for local authorities and others as appropriate (e.g. plumber/engineer who has installed treatment) Many experienced Environmental Health teams carrying out risk assessments, sampling, water treatment and water quality. Comments from some Environmental Health teams that further training is needed. REHIS and REHIS PWS Subgroup review training needs for Environmental Health professionals Scottish Government (DWQ) update Technical Manual and PWS website in consultation with REHIS and REHIS PWS Subgroup VTEC ACTION PLAN RECOMMENDATIONS

25 2. WATER QUALITY AND WATER TREATMENT Water Quality and Water Treatment WHAT ARE THE ISSUES? STRATEGY WHAT S GOING WELL? Many treatment systems appropriately installed, operated and maintained. Poor microbiological and chemical quality of many PWS. 92% of PWS do not have disinfection. Evidence of inappropriate installation of and operation of treatment. Evidence of poor maintenance of many PWS. Education and Awareness importance of Installation, operation, maintenance Local authorities consider making production of a maintenance schedule condition of grant payment Scottish Government, DWQR, REHIS PWS subgroup update Technical Manual and PWS website to include details of requirements for maintenance, examples of maintenance schedules and technologies for water treatment. Local authorities enforce improvements. Many treatment processes are appropriate. Impact of colour on UV disinfection known to be an issue but scale of issue not clear. Technologies for colour and organics removal are limited and do not always perform well at high or variable colour levels. DWQR to commission appropriate research in consultation with local authorities and Scottish Water. REHIS PWS Subgroup - monitor experience of treatment technologies and development of emerging technologies make standing item on PWS Subgroup agenda. Detailed Technical Manual and PWS website available to local authorities and owners and users to advise on appropriate technologies for water treatment. Technical manual and PWS website launched in 2006 very limited changes since. Contain limited information on technologies for small supplies, including colour and organics removal. Scottish Government (DWQ) to survey local authorities to determine gaps in technical content of the Technical Manual and the PWS website. Scottish Government (DWQ), DWQR and REHIS PWS subgroup to update the Technical Manual and PWS website to ensure that it contains appropriate information for PWS.

26 Water Safety Plans Water Catchment and Source Treatment Distribution System Domestic Distribution System WHO: the most effective means of consistently ensuring the safety of a drinking-water supply Based on HACCP (Hazard Analysis and Critical Control Point) Catchment to tap risk assessment and risk management plan

27 Risk Assessment and Water Safety Plans 3. RISK ASSESSMENT AND WATER SAFETY PLANS WHAT S GOING WELL? WHAT ARE THE ISSUES? STRATEGY All Type A supplies require risk assessments to be carried out by local authorities, which must be reviewed annually. 95% of Type A had risk assessments in 2011 Part of requirement for risk assessments set out in Schedule 4 of the PWS Regulations and requires: Documentation of the supply Hazard assessment and risk characterisation Identification of control measures for risks Verification procedures Section 76G(2) of the Water (Scotland) Act 1980 allows local authorities to serve notice to require owners and users to have WSP. A small number of WSP have been developed for PWS and have been beneficial. DWQR Observations: Control measures tend to focus on source protection and treatment - lack focus on maintenance. Monitoring of control measures needed. Approx 90% of Type B supplies without risk assessments Education and Awareness WSP template and guidance for owners and users of PWS Local authorities enforce requirement where appropriate to have Water Safety Plans using Section 76G(2) of the Water (Scotland) Act 1980.

28 Legislation and Grants 4. LEGISLATION AND GRANTS WHAT S GOING WELL? WHAT ARE THE ISSUES? STRATEGY Scottish Government (DWQ) to prepare package of amending legislation for consultation. Non-means tested PWS grants scheme in place since 2006 Impact of the grants system on the quality of PWS difficult to assess. DWQR gathers information on supplies, not by property, so information may not be 100% accurate. DWQR and Scottish Government (DWQ) to amend annual data return template and grant return forms to allow collection of data on grant improved supplies in consultation with local authorities and software providers. Scottish Government (DWQ), DWQR and local authorities assess the effectiveness of the grants system.

29 Compliance and Enforcement 5. COMPLIANCE AND ENFORCEMENT WHAT S GOING WELL? WHAT ARE THE ISSUES? STRATEGY Legislation in place for environmental protection and enforcement of legislation. Local authority compliance with sampling requirements good in some areas. Statutory data returns from local authorities to DWQR significantly improved since Data returns allows a degree of analysis of PWS water quality information and statutory reporting to European Commission. Several reported cases of lack of clarity over enforcement of environmental legislation. Local authority compliance with sampling requirements mixed and in some areas poor. Overall compliance with compulsory check sampling 68% One data return not completed on time to DWQR for 2011 and results not published in DWQR Annual Report. Data return template not gathering enough information for year on year improvement between individual properties on PWS. DWQR and SEPA to prepare and circulate a Decision Tree to give clarity to all stakeholders on responsibilities for enforcement of legislation surrounding all areas of activities with PWS. DWQR to audit compliance with regulatory sampling schedules DWQR to send local authorities annual sampling compliance reports Scottish Government DWQ) to update Technical Manual and PWS website to include clearer guidance on sampling requirements DWQR to schedule risk based supervisory visits to provide support and guidance to local authorities From 2014, DWQR to publish details of individual local authority sampling compliance Supervisory visit by DWQR to local authority concerned. DWQR to amend data return form in consultation with REHIS PWS Subgroup and then all local authorities. Updated guidance on data return form to be provided by DWQR for local authorities. DWQR to investigate possibility of central reporting system akin to FSA system.

30 Health Protection 6. HEALTH PROTECTION WHAT S GOING WELL? WHAT ARE THE ISSUES? STRATEGY Few known outbreaks of illness caused by PWS Risk to health from contaminated PWS not fully understood. Faecal contamination rarely appears to lead to reported cases of illness. HPS, Scottish Government (Health) to determine risk to health from PWS. Technical Manual and PWS website contain information on emergency planning. Updates required to Technical Manual and PWS website following local authority and Health Board experience of incidents involving PWS. Local authorities, health boards, HPS and DWQR to prepare updated guidance for Technical Manual and PWS website on incident management for PWS. Arrangements in place where appropriate for local authorities and CPHMs to meet and discuss PWS issues. Reports of inconsistency in approach between Health Boards. E.g. immediate notification by local authorities of failures to owners and users. VTEC ACTION PLAN RECOMMENDATIONS

31 Next steps Finalise strategy. Identify key stakeholders. Form a Steering Group to manage the project. Steering Group to decide who best to take forward actions and agree timescales. Steering Group to monitor progress. Scottish Government Ministers to be kept informed.

32 Thank You Any Questions? Life Rural Supplies, Galicia, Spain 22 November 2013

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