Risk Management from Source to Tap – a strategic approach

1. Risk Management from Source to Tap – a strategic approach Gerard O’Leary Office of Environmental Enforcement Environmental Protection Agency

2. Outline of Presentation • Overview of drinking water quality • 2007 Regulations • Walkerton and lessons learnt elsewhere • Safe water and Secure water • Lead

3. % with E.coli

4. Some Key points of 2007 Regs • Water supplier must supply water that is “wholesome and clean” • Standards for: • 2 Microbiological, • 26 Chemical and • 20 Indicator parameters • Meets the quality standards and is free from microorganisms or substances which constitute a potential danger to human health • Focus is on human health and corrective action to be taken in the event of a non-compliance

5. Walkerton • Walkerton, Ontario, Canada (population 3,800 people) • May 2000 – contaminated with Escherichia coli • Seven people died and more that 2300 ill • Inquiry by Justice O’Connor mentioned: • Failures in basic monitoring • Lack of effective operating procedures • Lack of training of operators • Failures to notice deficiencies in treatment & monitoring

6. Training • Walkerton “ we should not conclude that.. Ontario’s …system needs radical reform…the challenge is to ensure that the best practices are implemented across the province” • Improvements will continue to rely on better scientific understanding and technology, but these accounts also reveal the importance of the human element in assuring safe drinking water.

7. Effective Management : Walkerton Ultimately the safety of drinking water is protected by effective management systems and operating practices, run by skilled and well trained staff Two experts for the inquiry stated: “…….The more knowledgeable the operator, the greater the public’s protection”

8. Providing safe drinking water is essentially an exercise in risk management Risk management cannot be contracted out to others

9. Risk Management • Walkerton Inquiryessential characteristics of risk management: • Beingpreventive rather than reactive • Distinguishing greater risks from lesser ones and dealing first with the former • Taking time to learn from experience • Investing resources in risk management that are proportional to the danger posed

10. Four barriers • Prevention of contaminants entering the raw water supply • Removal of particles from water • Inactivation of microorganisms in the water • Maintenance of the quality of the water during distribution • These barrier if present and functional will minimise the chance • of failure that would give rise to incidents

11. Bahenhoch and Bouchier Reports • Minimise risks of crypto (1990) • Rapid gravity filters should avoid sudden surges of flow which may dislodge retained deposits • By passing of part of the water treatment process should be avoided • Second Report 1995 • Continuous turbidity monitoring can give early warning ….and alert operators to an increased risk of crypto

12. Lessons learnt Evaluation of outbreaks of crypto in US, UK and Canada Reliance on monitoring of Oocysts and total coliforms [Safe water] is less critical than protection of source quality, water treatment, good operation and monitoring of treatment plant performance[Secure water], …. A multiple barrier approach…is necessary to provide max protection.

13. EPA Audits in 2008 Main issues identified include: • Plants that do not match treatment needs • Poor operation of filters • Inadequate disinfection of water • Inadequate training • Poor knowledge of source water • Poor control over chemical dosing • Lack of chlorine alarms/turbidity meters

14. Water Safety [Plan] Approach • From the 70s to 90’s, drinking water quality guidelines kept adding more parameters or lowered limits or both • The premise being that water quality limits alone, assured safe water • Countless examples like Walkerton (and Galway!!) have shown this premise to be untrue • Treated Water Monitoring Does Not Assure Safety (need to secure supply!) • All of the Water Safety [Plan] approach is good practice and much should be in place already x

16. Enforcement Overview No of Notifications – 363 (262 in 2008*) No of Audits – 82 (55 in 2008*) No of Directions – 59 (37 in 2008*) No of Prosecutions – 1 in 2008* *up to end of September

17. EPA Guidance Booklets Booklet No 1. Guidance for Local Authorities on Regulation 9 and Regulation 10 of the European Communities (Drinking Water) (No. 2) Regulations 2007 (SI No. 278 of 2007). Booklet No 2. Annual reporting of drinking water monitoring results. Booklet No 3. Guidance for local authorities on the development of a remedial action list for public water supplies. Booklet No 4. Risk screening methodology for Cryptosporidium. Working on three new booklets - To Issue Booklet No 5. Auditing of water supplies by supervisory authorities. Booklet No 6. Exempted drinking water supplies. Booklet No 7. Monitoring function of local authorities.

18. FINAL THOUGHTS “……..Providing continuoulsy safe drinking water to all consumers at all times is a daunting task” Hrudey Few in the healthcare professions are afforded a greater opportunity to affect the health of so large a number of people through their actions or inactions”Smyth • Local Authorites (CCMA) • DEHLG • HSE • EPA • Risk Based Enforcement, Guidance, National Reporting and Working with others

19. LEAD Standards for lead in drinking water • 1970 WHO 300 μg/l “not to be regularly exceeded” • 1980(5) EU 50 μg/l (MAC) in “running water” • 1998(03) EU 25 μg/l (MAC) at consumers’ taps • 1998(13) EU 10 μg/l (MAC) at consumers’ taps

20. Influencing Factors

21. Acknowledgements Brendan Wall Darragh Page John Feehan