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EPA Advice Note on

Water Safety Plans in Ireland

Derval Devaney

EPA

28/29 February 2012

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Introduction

• Background to Water Safety Plans

• World Health Organisation WSP Manual

• Implementation of WSPs in Ireland

• EPA Guidance – Advice Note No. 8

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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

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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

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Boil water/restrictions Notices in 2010

• 73 supplies

• 86,135 people

• Preventable

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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

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• 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

International implementation

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WHO manual, available on WHO website:

http://whqlibdoc.who.int/publications/2009/9789241562638_eng.pdf

Practical Guidance to facilitate WSP development

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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”

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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/

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Key Components of a DWSP

• Identification of hazards

• Operational monitoring

• Documentation of the management arrangements

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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

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Appendix 1 Hazard ID Sheets

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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

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Appendix 2 RA Matrix (1)

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Appendix 2 RA Matrix (2)

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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

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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

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Appendix 2 - Action to be taken

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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

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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

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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

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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)

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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

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• 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

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• 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

Developing a WSP

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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

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

WSP Parameters

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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

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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

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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

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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

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WSP steps - SummaryPreparation

1 Assemble the WSP teamSystem assessment

2 Describe the water supply system3 Identify hazards and hazardous events and assess the risks4 Determine and validate control measures, reassess and prioritise the risks5 Develop, implement and maintain an improvement programme6 Define monitoring of the control measures (operational monitoring)7 Verify the effectiveness of the WSP

Management and communication8 Prepare management procedures9 Develop supporting programmes

Feedback and improvement10 Plan and carry out periodic review of the WSP11 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

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Thank you