Providing Safe Drinking Water in South Australia - application of the Safe Drinking Water Act 2011 to regulated care premises

Transcription

1 Providing Safe Drinking Water in South Australia - application of the Safe Drinking Water Act 2011 to regulated care premises Renay Cooke Water Quality Unit

2 Overview 1. Safe Drinking Water Act 2. Drinking Water Quality 3. Risk Management Plans

3 Safe Drinking Water Act 2011

4 Why a Safe Drinking Water Act > Prior to the Act drinking water was regulated under the Food Act Broadly defined a requirement to produce safe food that is fit for purpose and handled in a safe manner Lack of direction for drinking water providers on how this requirement should be achieved or measured > was increasingly providing direction to drinking water providers > During the millennium drought the need for alternative water supplies and a wider diversity of suppliers was raised > An Act providing clear direction was required

5 Purpose of Act > Provision of clear direction on how to provide safe drinking water and how safety will be measured > Protection of public health through assurance of drinking water safety > Protection against drinking water outbreaks > Improved consistency across the state for both urban and rural supplies level playing field > Improved transparency and accountability > Improved community confidence in drinking water supplies

6 Application of the Act The Act applies to all drinking water providers who supply water to the public including: > large corporations, e.g. SA Water > independent town supplies, e.g. Coober Pedy, Leigh Creek > supplies in rural and remote communities > regulated care premises, e.g. hospitals, aged care > regulated education premises, e.g. schools, child care > regulated food premises, e.g. restaurants, cafes > accommodation premises > water carters

7 Where the Act does not apply > Businesses that supply water delivered by a registered provider (e.g. premise providing mains water) > Domestic use of rainwater or other private supplies > Packaged water including bottled water > Non drinking water supplies

8 Exemptions: > Rainwater supplies at low risk premises - eg short-term accommodation (B&B, caravan parks,) > Optional rainwater supplies > Rainwater at cellar door (wineries) > Discretionary sources of water at recreation parks > Boiled rainwater in regulated food premises The exemption does not apply where rainwater is supplied to regulated care or education premises. Exemptions do not apply where rainwater is supplied to vulnerable populations.

9 Requirements under the Act Key requirements under the Act which apply to all drinking water providers: > Registration > Risk Management Plan (RMP) Approved monitoring program Approved incident identification and notification protocol > Audit and inspection > Reporting of results > Providing water quality results to consumers on request

10 Registration > Register with SA Health (no fee) > Previously stand alone registration form > Combined registration and adoption of a standard RMP now available on website

11 database of registrations > Currently 150 drinking water providers registered with SA Health (excluding schools) > Total of 47 regulated care facilities Hospitals (34) Aged care (11) Childcare (1) Other (1) > Of these 47, all are rainwater supplies with the exception of 1 on-supply: UV treatment 73%

12 Risk Management Plans: RMPs are the core of the ADWG and Act Under the Act a RMP should: > contain a detailed description of the drinking water supply > identify the risks to the quality of the water, and sets out steps to manage the risks > include a monitoring program covering both operational monitoring and water quality monitoring > include an incident identification and notification protocol

13 Risk Management Plans: > Develop a custom RMP (complex supply) > Adopt a standard RMP developed by Safe Drinking Water Act 2011 Safe Drinking Water Act 2011 Standard Drinking Water Risk Management Plan Rainwater supplies in regulated premises

14 Audits and Inspections > Schedule for audits and inspections published in the Government Gazette > It is the responsibility of the drinking water provider to arrange an audit or inspection activities to be combined with Food Safety audits where possible > List of approved auditors and inspectors is published on the website Safe Drinking Water Act 2011 Audit and Inspection Schedule for Drinking Water Providers The Audit and Inspection period is effective from 1 July CLASSES OF DRINKING WATER PROVIDERS INSPECTION/ AUDIT FREQUENCY Water Carters Inspection 2 years Small Water Providers Small Rain Water Supplies Inspection 2 years Small Bore Water Supplies Inspection 2 years Drinking Water Providers in Regulated Premises Regulated Care Premises Audit yearly Education - Childcare and Preschool Audit yearly Education - Primary and Secondary Schools Inspection 2 years Regulated Food Premises Inspection 2 years Primary Producers (excluding Dairies) Inspection 2 years Primary Producers - Dairy Inspection yearly Accommodation and Food Premises Inspection 2 years Wineries and Restaurants Inspection 2 years Community Supplies and Other Desalinated Water Supplies Audit 2 years Surface Water Supplies - River Murray or Dam Audit 2 years On-Supply from other Drinking Water Provider where materially altered by treatment or extended storage Inspection 2 years Indigenous Communities APY Lands - Homelands Inspection 2 years Indigenous Water Supplies - SA Water managed Audit 2 years Complex Supplies Mining Accommodation Audit 2 years Drinking Water Providers > 2,000 population Audit 2 years Drinking Water Providers > 50,000 population Audit yearly

15 Provision of water quality results to consumers: > Water quality information is to be made publicly available > Improve transparency > Large drinking water providers such as SA Water, provide consumers with drinking water quality reports Published annual reports Water quality monitoring information on website > Options for smaller providers include provision of results to consumers on request by letter, or telephone

16 Safe Drinking Water Act 2011, Safe Drinking Water Regulations March 2013 Act and Regulations commenced transitional period: registration 3 months RMPs 12 months 1 March 2014 Risk Management Plans in place 1 July 2014 Audit and Inspection period commenced 30 June 2015 yearly audits to be completed 30 June yearly audits or inspections to be completed

17 Drinking Water Quality

18 Safe Drinking Water > Safe drinking water is essential for maintaining public health and supporting healthy communities > Range of microbial and chemical contaminants in drinking water that have potential to affect human health > Most at risk are infants and young children, immunocompromised and the elderly > Disinfection of water (e.g. chlorination) has helped to eliminate water-borne disease in the developed world > Outbreaks can still occur when there is failure to adequately manage risks

19 Australian Drinking Water Guidelines > Focus of ADWG is ensuring safety through application of a preventative risk management approach to ensure safety before delivery to consumers > ADWG provides advice on sampling and monitoring programs > Fact sheets provided for microorganisms, toxic cyanobacteria and chemicals > Safe Drinking Water Act based on principles of ADWG

20 Microbiological Quality > Greatest threat to drinking water supplies is contamination by enteric microorganisms that cause gastrointestinal illness do not grow in water but enter water through faecal contamination > Include: Bacteria such as Salmonella & Campylobacter Viruses such as Rotavirus, Noravirus and Enterovirus Protozoa such as Cryptosporidium and Giardia > Water can support growth of environmental pathogens such as Legionella, mycobacteria and Naegleria fowleri Not transmitted by drinking Controlled by good practices

21 Measuring microbial quality > Generally performed by measuring preventative measures, effectiveness of treatment processes and verified by monitoring for E.coli > Preventative measures often based on common sense, e.g. ensuring storage tanks are covered and trimming overhanging trees to prevent animal access > Treatment processes are used to remove or kill enteric pathogens, e.g. Chlorine kills bacteria, viruses and Giardia (but not Cryptosporidium) UV light kills bacteria, viruses and protozoa Filtration removes all pathogens

22 E.Coli verification > E.coli is present in high numbers in human and animal faeces. Most E.coli are not pathogenic > Presence of E.coli indicates faecal contamination and the presence of enteric/faecal pathogens (Salmonella, Norovirus, Cryptosporidium, etc) > Most tests for E.coli also detect total coliforms no public health implications > Testing for individual pathogens not recommended too many, too expensive, methods not always available

23 Treatment processes > Chlorination Single most common form of drinking water treatment Can be used continuously or for one-off applications following detections of E.coli > UV light irradiation Increasingly popular Low maintenance and no chemical addition > Small package filters Can be very good if certified to demonstrate effectiveness Cost comparable to UV light

24 Sources of drinking water in South Australia > River Murray > reservoir catchments > desalination plant > bore water > rain water

25 Rainwater use in South Australia > South Australia has highest domestic rainwater use in Australia > Public rainwater supplies include accommodation, food businesses, hospitals, aged care State/Territory Households with rainwater tanks (%) Rainwater tank as main source of drinking water Capital city households with rainwater tanks (%) Non-capital city households with rainwater tanks (%) NSW VIC QLD SA WA TAS NT 5.5 nd 5.5* 0.0 ACT 6.7 nd Total ABS, 2007 cited from: Guidance on use of Rainwater tanks (enhealth, 2010).

26 Rainwater supplies > In most areas where rainwater collection & storage is via a well maintained tank and roof catchment system the risk of illness from drinking rainwater is low > Low risk NOT no risk > Decision to drink rainwater a matter of personal choice > Occasional cases of illness from contaminated rainwater

27 Outbreaks associated with rainwater > Adelaide Hills 2006: 19 cases of Cryptosporidiosis. Cause identified as co-location of cement pipe to rainwater tank and clay pipe to septic system in same trench. > Victoria school camp 2007: 27 cases of salmonellosis. Tank poorly maintained, incident followed heavy rainfall > Queensland island resort 2009: 23 cases of Campylobacter. Faecal contamination detected in 4 tanks. > Long term care facilities : 3 outbreaks (2 x Salmonella, 1 x Campylobacter, total of 18 cases). Evidence of poor tank maintenance with high E.coli counts. > Highlights need to maintain infrastructure

28 Risk Management Plans

29 Risk Management Plans > Risk management approach from catchment to consumer > Complexity of the RMP will depend on the system Standard RMP template for rainwater in regulated premises > Main parts of a RMP Assess water supply system, identify hazards/risks Identify preventative measures what measures are in place to manage risks? Operational monitoring What will be monitored to check preventative measures are functional? Verification (water quality) monitoring Final check to ensure whole system is operating well Incident identification and notifications protocols What to do if a water quality incident occurs

30 Standard RMP Rainwater in regulated premises > Rainwater supplies are simple systems > Hazards and risks will be similar between supplies > System specific hazards and how they are managed can be added > Adopt and fill out sections

31 Identifying potential hazards and health risks Hazard: Microbial faecal matter; birds, mice, rats, possums Overhanging branches provide access Risk: Illness due to ingestion of harmful pathogens Hazard: Microbial Frogs or dead animals in tank Unenclosed tank provides access Risk: Illness due to ingestion of harmful pathogens Hazard: Chemical Lead flashing, lead based paints Industrial emissions (Lead, Port Pirie) Risk: illness due to ingestion of chemicals Hazard: Microbial Buried pipes or tank potential for cross contamination. Surface water/faecal contamination Risk: Illness due to ingestion of harmful pathogens

32 Preventative measures Hazard: Microbial faecal matter; birds, mice, rats, possums Overhanging branches provide access Risk: Illness due to ingestion of harmful pathogens Hazard: Microbial Frogs or dead animals in tank Unenclosed tank provides access Risk: Illness due to ingestion of harmful pathogens Hazard: Chemical Lead flashing, lead based paints Industrial emissions (Lead, Port Pirie) Risk: illness due to ingestion of chemicals Hazard: Microbial Buried pipes or tank potential for cross contamination. Surface water/faecal contamination Risk: Illness due to ingestion of harmful pathogens

33 Preventative measure disinfection UV disinfection > Easily fitted by plumber into existing system > Most units can be fitted with monitors/alarms indicating that they are operational Chlorine disinfection > Not generally recommended for routine disinfection of rainwater supplies > Emergency disinfectant doses provided in RMP

34 Operational monitoring > Inspection and maintenance program for preventative measures > Records of monitoring and corrective actions must be maintained > Monitoring frequency varies depending on each preventative measure, i.e.: UV with no alarm daily Inspect and clean gutters 6 monthly

35 Area Inspection Corrective Actions Gutters Roof Tank inlets and overflows Insect proofing Leaf filters Tank & tank roof Tank Table 3a: Operational monitoring (6 monthly) Tank (cont) Inspect for presence of accumulated debris such as leaf and other plant material Inspect for presence of accumulated debris such as leaf and other plant material Inspect for accumulated material or damage Check structural integrity of tank including roof and access cover Internal inspection to check for evidence of access by animals, birds or insects Internal inspection for presence of mosquitoes or larvae Internal inspection to check for algal growth Clean and repair as necessary If large amounts of leaf material or other debris are present, the frequency of inspection and cleaning may need to be increased Clear any accumulated matter from the roof and prune overhanging branches Clean and repair as necessary Repair any holes or gaps as necessary If present, identify and close access points Remove bird /animal carcass and empty and clean tank. Chlorinate if emptying/cleaning tank is not possible If present, seal access points/ repair mosquito-proof screens to prevent escape of mosquitoes and further entry If larvae present, treat tanks with a small amount of kerosene or medicinal paraffin (used as a last resort - seek further guidance before carrying out this treatment) If there is evidence of algal growth (green), find and close the points of light access and replace any pipework which allows light penetration

36 Table 3a: Operational monitoring (6 monthly) Pipework Check for structural integrity Repair pipework as necessary Chlorination Ensure adequate supplies of chlorine for emergency chlorination Check use-by dates of supplies Dispose of out of date chlorine and replace as required Filters (if present) UV treatment (if present) Maintain as per manufacturer s recommendations to avoid problems associated with clogging and microbial growth Maintain as per manufacturer s recommendations Where UV unit does not include an alarm, minimum daily checking is required to ensure unit is operational Check that UV lamps have been replaced as required and that sleeves have been cleaned (more frequent maintenance may be indicated for some products) Clean filters as required Replace or repair filters as required Clean sleeves and replace lamps as necessary

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39 Verification monitoring (E.coli) > Final check to verify preventative measures have been effective > Sample collected at point of use > Analysed at approved laboratory > Rapid turn around time for results is essential > Frequency of monitoring determined by adequacy of preventative measures to manage risks > Consideration given to: complexity of supply water source treatment consumers of supply

40 Table 4: Water Quality Monitoring Sample Point Monitoring Frequency Small low risk supplies Point of use (drinking water tap/ after treatment) Test for faecal indicator E.coli 0/100 ml sample* Every 12 months Regulated premises Includes hospitals, aged care, schools, childcare facilities No treatment Point of use (drinking water tap) UV disinfection Point of use (after UV detection) Test for faecal indicator E.coli 0/100 ml sample* Test for faecal indicator E.coli 0/100 ml sample* Monthly basis Every 3 months # *No E.coli should be detected in a 100ml sample (Australian Drinking Water Guidelines) # Reduced frequency will be considered by where evidence of 2 years of E. coli monitoring data (0 detections)

41 Incident Protocol > List of potential incidents that could have an adverse effect on health if corrective actions are not implemented > Important to have a plan in place to manage incidents > Included in standard RMP > Include additional internal procedures for incident reporting/maintenance requests in RMP > Notification to

42 Table 5: Incident identification and notification protocol

43 assistance in incident management > Corrective actions > Emergency chlorination Instructions and calculations in RMP Correct dose? > Boil water > Alternative water source > Resample

44 What now? > Regulated care premises audited an annual basis > Responsibility of drinking water provider to arrange audit with approved auditor > Audits required under the SDWA will be combined with existing processes where possible (e.g. combined with existing Food Safety audits)

45 What now? > Audit will be based on RMP and accompanying documentation. Ensure that: All sections of the RMP template have been filled in Evidence of monitoring is available Operational, e.g. maintenance schedules, log books Verification E.coli monitoring results > Physical inspection of rainwater system will be undertaken > Audit report provided to drinking water provider and

46 Further Information > Website: > Water Quality Unit: Phone

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