EPA Advice Note on Water Safety Plans in Ireland

EPA Advice Note onWater Safety Plans in Ireland Derval Devaney EPA 28/29 February 2012

Introduction • Background to Water Safety Plans • World Health Organisation WSP Manual • Implementation of WSPs in Ireland • EPA Guidance – Advice Note No. 8

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

Why Implement a DWSP? (2) • 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

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

WHO manual, available on WHO website: http://whqlibdoc.who.int/publications/2009/9789241562638_eng.pdf • Practical Guidance to facilitate WSP development

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”

EPA Advice Note No. 8 • 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/advice/water/drinkingwater/

Key Components of a DWSP • Identification of hazards • Operational monitoring • Documentation of the management arrangements

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 12

Appendix 1 Hazard ID Sheets

Appendix 2 RA Matrix (1)

Appendix 2 RA Matrix (2)

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 18

Appendix 2 - Action to be taken

Action Plan for risks • Appendix 3 • Medium Risk or Higher • Establish Improvement • Target dates • Signed off by DoS • Target risk = eventual risk rating • Hyperlink to hazard spread sheet

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

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

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

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

WSP Parameters • WSP is not just about chemical and microbiological parameters • Sufficiency • Flooding • Power supplies • Training • Communications • Laboratory facilities • Etc…….

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

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

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

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

WSP steps - Summary Preparation 1 Assemble the WSP team System assessment 2 Describe the water supply system 3 Identify hazards and hazardous events and assess the risks 4 Determine and validate control measures, reassess and prioritise the risks 5 Develop, implement and maintain an improvement programme 6 Define monitoring of the control measures (operational monitoring) 7 Verify the effectiveness of the WSP Management and communication 8 Prepare management procedures 9 Develop supporting programmes Feedback and improvement 10 Plan and carry out periodic review of the WSP 11 Revise the WSP following an incident

EPA Action on WSP - 2012 • Implementation of WSPs - top OEE enforcement priority for 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

Thank you

EPA Advice Note on Water Safety Plans in Ireland