By Chris Cornish, Independent Environmental Consultant

Oakridge Environmental Services Limited

European Directives ◦ Council Directive 89/106/EEC on the approximation of laws, regulations

and administrative provisions of the member States relating to construction products – Incudes water distribution networks

◦ Council Directive 98/83/EC of 3 November 1998 on the quality of water intended for human consumption

UK Acts and Regulations ◦ Water Industry Act 1991

◦ Water Fittings (Water Supply) Regulations1999

◦ Private Water Supplies Regulations 2009 (2006 in Scotland)

NOTE: Scotland has its own Byelaws and regulations and Northern Ireland its own version of the regulations. Mainly the same requirements but there are some differences, mainly with implementation and regulation overall requirements are the same.

Who enforces the Regulations

NOTE: The Drinking Water Inspectorate enforce the water industry act and water quality

regulations in relation to Public Supplies

Public Water Company

Local Authority Environment Agency

Water Industry Act 1991

Water Act 2003 (Boreholes exceeding 20m3/Day)

Water Fittings Regulations or Byelaws

Private Water Supplies Regulations

Food safety Regulations

Health and Safety Regulations

Types Of Supply and how they are regulated

Supply Source

Supply Classification

Primary Regulations Applied

Primary Enforcement Body

Borehole, Wells, Springs

Private Water Supply

Private Water Supplies Regulations

Local Authority

Incoming Public mains Water

Private Distribution System

Private Water Supplies Regulation Water Fittings Regulations

Local Authority

Public Water Company

Imported Water

Private water Supply

Private water Supplies Regulations

Local Authority

Scope

2. These Regulations apply in relation to private supplies of water intended for human consumption; and for these purposes “water intended for human consumption” means—

(a) all water either in its original state or after treatment, intended for drinking, cooking, food preparation or other domestic purposes, regardless of its origin and whether it is supplied from a distribution network, from a tanker, or in bottles or containers;

(b) all water used in any food-production undertaking for the manufacture, processing, preservation or marketing of products or substances intended for human consumption.

NOTE: Originates in section 218 Water Industry Act 1991 Other domestic purposes include, Washing, Central Heating and ‘sanitary purposes.

Wholesomeness

4. Water is wholesome if all the following conditions are met—

(a) It does not contain any micro-organism, parasite or

substance, alone or in conjunction with any other substance, at

a concentration or value that would constitute a potential

danger to human health;

(b) it complies with the concentrations or values specified in Part

1 of Schedule 1; and

(c) in the water: nitrate (mg/l) + nitrite (mg/l) is <1

50 3

Regulation 18 Notices

If any private supply of water intended for human consumption constitutes a potential danger to human health, a local authority acting under these Regulations must serve a notice under this regulation

The notice must —

(a) identify the private supply to which it relates;

(b) state the grounds for serving the notice;

(c) prohibit or restrict the use of that supply;

(d) specify what other action is necessary to protect human health.

Why Do We Care? Risk of Harm to Health from pollutants ◦ Pathogenic organisms and viruses These can cause Gastro Intestinal Illnesses which in extreme cases may lead to internal organ damage or even death Particularly in high risk populations (Under 5’s, The Elderly or immuno compromised)

◦ Chemical Contamination Most likely to come in the form of;

Metals either naturally occurring in the source (iron and Manganese) or from pipework and fittings (Iron, Lead, Zinc)

Hydrocarbons – from source or ingress into pipework through localised spillage

Nitrates Additives associated with water treatment

With the exception of hydrocarbons and some treatment additives most chemical contaminants in water pose a risk of harm over time to the consumer

Most waterborne disease is related to faecal pollution of water sources.

This is why testing is based on Faecal Indicators (sometimes test for Clostridium and Cryptosporidium)

Examples of waterborne illnesses that can be transmitted in the faecal matter of mammals (or by Carrier Humans)include.

Campylobacter species Salmonella species Escherichia coli (O157) Cryptosporidium Giardia Leptospira Paratyphoid fever Streptobacillary fever Viral gastroenteritis

Temporary supplies are High Risk by their nature, Especially where camping is involved. ◦ Temporary Infrastructure used once a year or temporary construction

Including above ground distribution networks, speed of commissioning

◦ Other infrastructure constructed around and on top of the supply network (Risk of damage)

◦ Temporary toilets showers plumbed in , e.g recirculation systems risk of backflow

◦ Illegal connection such as by traders risking contamination

◦ Foul Waste and Hydrocarbons often handled around exposed infrastructure

◦ Site Locations are often agricultural fields or parkland where cattle graze,

high presence of surface and subsoil faecal bacteria

◦ Site Conditions- The Weather

Temporary events often create small temporary encampments with village, Town or small city sized populations and provide good facilities.

Public Water Supply Zones in Rural areas Commonly cater for less than 10,000 people. The average public Supply Zone size is between 30-40,000, Stratford is a very large public supply for 90,000 people

A Festival in Suffolk provides water for 40,000 people. The public Water Supply Zone in this area is supplying 7,500 people for the other 362 day per year

A staged approach should be applied to minimise the risk of water at temporary events.

◦ Planning (Identify who is going to oversee the Water Supply)

◦ Documentation

◦ Appoint competent Contractor

◦ Contact relevant Authorities

◦ Audit/Check Build

◦ Sample for water quality before public get to site

◦ Supply and distribution Security

◦ Continue to Check integrity of the network

◦ Sample During Show for Due Diligence

Documentation

Documentation should include as much information about the supply as possible (Local Authority should require this)

Should include build design, uses on site, plumbing contractor details, Sampling being carried out, contingency plans

Best method is to Create a Water Safety Plan that can be included with your Event Management Plan. Involve all relevant people in this where possible

WSP’s are a step by step approach to risk assess the drinking water that you are supplying to the public

Water Safety Plans A Water Safety Plan (WSP) is the most effective way of ensuring that a

water supply is safe for human consumption and that it meets the health standards and other regulatory requirements. It is based on a comprehensive risk assessment and risk management approach to all the steps in a water supply chain from catchment/Source to consumer.

Devised by the World Health Organisation and supported by the Drinking

Water Inspectorate (DWI) and Water Regulations Advisory Scheme Ltd (WRAS)

The WHO guide is pitched at the highest level for large pubic style

supplies, but it is encouraged to scaled to any size or type of supply even in emergency situations. WRAS even recommend and produce guidance to apply to the domestic side of a water meter or connection point for developers

Water Safety Plans broadly comprise of 3 elements.

1. System Assessment (your build design)

2. Operational Monitoring (Water Quality/Verification Sampling)

3. Documentation ◦ Comprises the details of the System Assessment, including maps of the

network, storage, and any treatment from source to supply point. If a borehole is used any construction and catchment details

◦ Lists Details of the persons responsible (Includes plumber)

◦ Include details of the construction material, treatment products/additives and fittings used

◦ Details of storage and treatment

◦ Sampling Plan (update with results over time)

◦ Contingency planning

Guidance on Water Safety Plans

Water Safety Plan Manual, Step-by-step risk management for drinking-water suppliers

A Brief Guide to Drinking Water Safety Plans

WRAS Drinking Water Safety Plan Protecting The Quality

Of Water For Domestic Use Within Premises

Appointing a Competent Plumbing Contractor

◦ Should confirm they have a good awareness of water hygiene and

good practices for installing, repairing and general works around drinking water instillations. EUSR Blue Card (DOMS card in Scotland). Are their employees competent.

◦ They should be following BS:8551 Provision and Management of temporary water supplies and distribution networks. And be aware of BS EN 806-5:2012 which accompanies BS 8558:2011and replaces BS6700

◦ Ask what materials they are installing, are they clean and compliant. Evidence that fittings including tanks and pipework are clean and fit for use, get written agreement of their roles and responsibilities

Basic Build Principle

Audit the Build

The build, particularly for large events, is high risk. It is a high pressure, time dependant undertaking and there is a high risk of contamination being introduced during connection if care is not taken and for mistakes being made. ◦ Someone should check the installation physically to ensure that the build

is correct (following the design in the system assessment) ◦ Check for leaks on connections ◦ Check the fittings are In working order and clean ◦ Check what is going on around the fixtures, fittings and supply points

Independent auditing is recommended by the DWI

Monitoring/Sampling

Plumbing Contractor, Imported Water Suppliers should supply documentation showing that any ready to use tanks, tankers, fittings are ready to use. BS8551 suggests a method for doing this – Compliant Results of sampling following cleaning and then sealed (usually with green label) until connected.

Or if not ready to use a commissioning procedure should be followed such as super chlorination, flushing and the sampling

Any permanent ring main being brought back into use (Or re used pipework) should be super-chlorinated, flushed, refilled with drinking water and then tested before approved for use

Any new pipework above 32mm should also be super chlorinated and pressure tested following instillation (BS EN 805 & BS 8558)

Local Authority are likely to want to agree this Private Supplies need Audit Sampling, PDS Don’t! Suggested standard samples following Risk Assessment/Audit

Sampling

Note: It is recommended that satisfactory results are confirmed before the public arrive on site Other site specific parameters may include Metals, Disinfection By

Products, Temperature, Colony Counts, Hydrocarbons The Number of sample points will depend on the size of the site

Monitoring During the event

Main control where water is chlorinated will be to check the Chlorine levels regularly

Recommend that daily Microbiological tests taken ◦ Enteroccoci

◦ Escherichia coliforms ◦ Total Coliforms

Note: It takes 24 hours to get a confirmed result for coliforms and 24 – 72 Hours to get a confirmed result dependant on the laboratory

Number of sample points is a matter for risk assessment, Relates to the size of the

supply.

Remember that sampling is also to confirm integrity of the supply if 1 sample is taken and fails the whole supply may be down

If 10 samples taken and 1 fails the general supply is fine and the problem is sample error or localised contamination

Guidance Sources

The Drinking Water Inspectorate

WRAS Water Regulations Advisory Service

WATERWISE

The Local Authorities & Public Water Companies

Delivery of new pipe and storage tank

Contamination Risk?

Not Ideal

Trader Hose Union connections and ‘clean’ Water Storage drums

Connected to Elsom Tank for easy cleaning in Security compound

Water Fittings Offenses