Risk Management from Source to Tap

– a strategic approach

Gerard O’Leary

Office of Environmental Enforcement

Environmental Protection Agency

Outline of Presentation

• Overview of drinking water quality

• 2007 Regulations

• Walkerton and lessons learnt elsewhere

• Safe water and Secure water

• Lead

% with E.coli

0.55%

0.02% 0.03%0.08% 0.08%

0.00%

0.10%

0.20%

0.30%

0.40%

0.50%

0.60%

0.70%

IRELAND England andWales

Scotland NorthernIreland

Netherlands

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

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

•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.

Training

WalkertonUltimately 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”

:Effective Management

Providing safe drinking water is essentially an exercise in risk management

Risk management cannot be contracted out to others

Walkerton Inquiry essential characteristics of risk management:

•Being preventive 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

Risk Management

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

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

Lessons learnt

Evaluation of outbreaks of crypto in US, UK and Evaluation of outbreaks of crypto in US, UK and Canada Canada

Reliance on monitoring of Oocysts and total Reliance on monitoring of Oocysts and total coliforms coliforms [[Safe waterSafe water]] is less critical than is less critical than protection of source quality, water treatment, protection of source quality, water treatment, good operation and monitoring of treatment plant good operation and monitoring of treatment plant performanceperformance[Secure water][Secure water],, …. A …. A multiple multiple barrierbarrier approach…is necessary to provide max approach…is necessary to provide max protection.protection.

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

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

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

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.

• Local Authorites (CCMA)• DEHLG• HSE• EPA

• Risk Based Enforcement, Guidance, National Reporting and Working with others

“……..Providing continuoulsy safe Providing continuoulsy safe drinking water to all consumers drinking water to all consumers at all times is a daunting taskat all times is a daunting task” Hrudey

Few in the healthcare professions Few in the healthcare professions

are afforded a greater opportunity are afforded a greater opportunity

to affect the health of so large a to affect the health of so large a number of people through number of people through their their actions or inactionsactions or inactions” ”

SmythSmyth

FINAL THOUGHTSFINAL THOUGHTS

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

Influencing Factors

Acknowledgements

Brendan WallBrendan Wall

Darragh PageDarragh Page

John FeehanJohn Feehan