Drinking Water Regulations – General Requirements Emer Cooney, Inspector EPA Drinking Water Team Private Supplies Workshop 24 May 2016

European Union (Drinking Water) Regulations 2014 Purpose of Regulations is to prescribe: n quality standards to be applied; n related supervision and enforcement procedures; n requirements as to: n sampling frequency; n methods of analysis; n the provision of information to consumers. in relation to supplies of drinking water. PROTECT PUBLIC HEALTH

Private supplies compliance and issues

nCryptosporidium risk due to inadequate barriers nMicrobiological quality nOperational issues nDisinfection by-products

Private Supplies nIndividual supply >10m 3 /day or >50 persons nIndividual supply <10m 3 /day or <50 persons and supplied as part of commercial or public activity n512 Public group water schemes n421 Private group water schemes n1758 small supplies nServing 7% of the population

Responsibilities of private supplier Reg 4: Ensure that water is wholesome and clean and meets the requirements of these regulations. Reg 8: Maintain records (if directed to do so) Reg 9: Prohibit or restrict supply and notify consumers if health risk is present. Comply with a direction to take action to reduce risk Reg 10: Notify LA in the event of a failure; investigate and take remedial action; inform consumer of action; maintain records of investigation. Reg 13: Quality of treatment

Responsibilities of Local Authorities (1) Reg 6: Ensure action is taken when non-compliance is due to distribution system Reg 7: Monitor compliance of supplies in functional area; ensure that monitoring is carried out; specify sampling points; establish monitoring programme; carry out additional monitoring where necessary, comply with any directions. Reg 8: Direct supplier to keep records; maintain register of supplies; maintain monitoring records. Reg 9: Prohibit or restrict supply and advise consumers if health risk is present; direct supplier to reduce risk.

Responsibilities of Local Authorities (2) Reg 10: Consider if there is a risk to human health in event of non- compliance; ensure that investigation is undertaken in the event of a failure; that action programme is prepared and action is taken; that consumers are notified; take enforcement action if required Reg 12: Intervene if action required Reg 13: Direct supplier to take measures to ensure that the treatment process does not compromise quality Reg 16: Issue and enforce directions Reg 17: Carry out audits in order to verify performance

Guidance and Tools - EPA Handbook Section 1: The 2007 Regulations Section 2: Standards for drinking water quality Section 3: Monitoring of drinking water quality Section 4: Guidance on sampling Section 5: Guidance on analysis Section 6: Procedures for non-compliance with standards Section 7: Drinking water complaints Section 8: Incidents and emergencies Section 9: Annual reporting Section 10: Drinking water safety plans Section 11: Water treatment and related matters Section 12: Distribution network and related matters Section 13: Audit of WSAs by the EPA

Enforcement Monitor/AuditInvestigateTake Action Verify Compliant drinking water

Compliance monitoring and verification nMonitoring programme nAudits nCompliance failures nIssue of directions nRemedial action plans nRecords and reporting

Monitoring Programme nAll supplies must have a programme for compliance monitoring nLA to monitor compliance with parametric values in Part 1 (microbiological, chemical and indicator parameters). nTwo types of compliance monitoring: nCheck - regular information on water quality and effectiveness of treatment. nAudit - determine if all parametric values are being complied with. nFrequency of monitoring is specified in Part 2,Table B nRadioactivity regulations (S.I. 160 of 2016) – guidance will be made available.

Monitoring Programme nIdentify supplies nLiaise with supplier to ensure that sampling points identified are representative nIdentify relevant monitoring requirements (minimum and discretionary) nEnsure sampling staff are trained nEngage accredited laboratory to carry out analysis

Operational and Investigative Monitoring Operational – make sure your treatment system is working: e.g; nChlorine residual nOn-line monitoring Investigative – in response to failure or incident nTo see where problem is arising nTo verify that remedial action has been successful

Auditing n Reactive audits to follow up on issues as they arise during the year n Planned audits: risk-based n Site selection n Aspect to audit n Criteria n Local Authority Handbook n Drinking Water Treatment Manuals n EPA Advice Notes n EPA audit reports on the website

Reasons for Audits n Where there is a risk to public health (e.g. BWN). n Where there is a failure in a disinfection system or indications of problems with disinfection systems. n Verification of compliance with a Direction. n Significant notification (e.g. e. coli, crypto or other). n To verify the effectiveness of remedial actions. n To determine if disinfection criteria are met and the systems are robust. n To assess the implementation of risk assessments. n In supplies that have received large number of complaints from consumers. n To assess monitoring programmes.

Compliance failures Non-compliances in general are dealt with as follows: nTable A (micro): use Reg. 9 nTable B (chemical): Reg. 10, unless risk to health, then use Reg. 9 nTable C (Indicator): nif there is a risk to health, use Reg. 9 nif there is no risk to health, but a direction is required, Reg. 16

Liaison between stakeholders Laboratory Local Authority HSE ConsumerSupplier

Where there is a risk to health nBe prepared: nknow who to call in HSE; ntemplate BWNs; ncommunications plan. nNotification of consumer and provision of advice nBoil water notice, water restrictions – may need to reinforce the message after some time nActions to be taken

Where it is not considered that there is a risk to health nImmediate investigation of failure nAction programme to be prepared and implemented nKeep records of investigation nLA to consider enforcement action – may not be required if supplier is taking action

Issue of Directions Reg 6: non-compliance due to domestic distribution system Reg 8: direct supplier to keep records and submit information Reg 9: where there is a risk to health, to ensure measures are taken to reduce risk Reg 10: where there is non-compliance with standards, direct supplier to prepare action programme / take action Reg 12: for purpose of achieving compliance Reg 13: for purpose of ensuring quality of treatment, equipment and materials Reg 16: general

Issue of Directions – examples of use n A previous recommendation has not been implemented and this is a contributory factor in an incident n A response to an audit is not submitted or is not satisfactory n A follow up audit finds no progress in implementing previous recommendations n An action programme has no completion date or there is evidence of significant slippage in progress n Following a notification it appears that there was an inadequate investigation or inadequate corrective action

Prioritising enforcement action – Remedial Action List EPA Criteria for inclusion nFailure of priority parameters – e.coli, nitrate, THMs, bromate, aluminium, turbidity nInadequate treatment nMonitoring results or compliance checks indicate lack of operational control nIdentified by HSE as supply where improvements were required Known problems / inadequate treatment

Record keeping and reporting Supplier nChemicals being used nMonitoring at plant and in network nLog of process failures Local Authority nRegister of supplies nReporting of monitoring results

EPA Guidance

Collaboration and Information Exchange - NIECE nAnnouncements nShared Documents nDiscussion Board nWorkshops nWorking groups

Regulation 14 nInformation leaflets nWebinar (link on bright talk?)

EPA recommendations – Drinking Water Report 2014 nMonitor all private supplies for e. coli nInvestigate failures nTake appropriate enforcement action nImplement guidance on HACCP (Group Water Schemes) Separate reports for public and private supplies in 2016

Thank You Any questions?