The future of Victorias Safe

Drinking Water Regulations

Technical report
background to proposed regulations
The future of Victorias Safe
Drinking Water Regulations
Technical report background to proposed regulations

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Copyright, State of Victoria, Department of Health, 2013
This publication is copyright, no part may be reproduced by any
process except in accordance with the provisions of the Copyright
Act 1968.
Authorised and published by the Victorian Government,
50 Lonsdale Street, Melbourne.
November 2013 (1311004)
Introduction 1
1. Achievements and limitations
of the current situation 2
Achievements 2
Risk management approach from catchment to tap 2
Uniform safe drinking water quality 3
Limitations 4
2. The catchment and quantifying risk 5
Proposal for quantifying risk 5
Rationale 5
Health-based targets 5
What would this mean for the next set of regulations? 6
Options for quantifying risks 6
3. Monitoring at the treatment plant 8
Proposal for operational monitoring 8
Rationale 8
Operational performance monitoring survey 8
What would this mean for the next set of regulations? 9
Critical control point 9
Establishment of a critical limit 9
Operational procedures and processes 9
Effectiveness of treatment processes 10
4. Verication monitoring in the distribution system 11
Proposal for verication monitoring 11
Rationale 11
What does it mean for the next set of regulations? 11
5. Documentation and reporting 13
Proposal for documentation and reporting 13
Rationale 13
What does it mean for the next set of regulations? 13
Appendix 1: Reference group and working
group membership 14
Appendix 2: Regulation 6 risk management plan 15
Appendix 3: Schedule 2 drinking water
quality standards 16
Glossary 17
References 19

Contents
1
This report is supplementary to the Department of Health
discussion paper The future of Victorias Safe Drinking
Water Regulations.
The review of the 2005 regulations is being conducted
by the department in its capacity as the Victorian
Governments drinking water quality regulator. The
development of the discussion paper and proposal for
regulatory reform was undertaken in collaboration with
representatives from water businesses, the water industry
workforce, water industry peak bodies and researchers
(Appendix 1).
Three working groups met from September 2012 to April
2013 to inform and review the evidence base underlying
the review. The Existing Regulations Working Group
reviewed the current regulations in terms of consistency
with developing policy, good practice and effectiveness
and made recommendations for regulations that could
address regulatory gaps.
The Operational Performance Working Group considered
recent changes to the Australian drinking water guidelines
(ADWG) that shift the emphasis of monitoring from
endpoint testing at the consumer tap to operational
monitoring of water treatment barriers identied as critical
control points (CCP) (NHMRC & NRMMC 2011). This
group also assisted with a survey to obtain information
on current operational performance monitoring (OPM)
practices at water treatment plants.
The Health-based Targets Working Group considered
international trends towards health-based targets for
microbial safety, as they are likely to be adopted into
the next version of the ADWG. This group assessed the
implications of this change for Victorias drinking water
regulatory framework and contributed to considerations for
the practical application of health-based targets in Victoria.
Since the introduction of the Safe Drinking Water
Regulations 2005 the department and water industry
have worked together to establish a comprehensive
catchment-to-tap approach to managing drinking water
quality. This has involved developing and implementing risk
management plans that have helped water businesses to
achieve signicant improvements to the quality of drinking
water across the state. In this period, however, notications
received indicate a need to support and encourage
consistent approaches to continuous improvement.
For the next set of regulations it is proposed to further
align Victorias drinking water regulatory framework
with the latest evidence-based approaches to enable
water businesses to recognise future trends and better
manage their risks. The Victorian Government is also
committed to substantially reducing the burden of
unnecessary regulation on Victorian businesses. The
proposals in the discussion paper provide opportunities
to reduce regulatory burden for water businesses without
compromising the safety of Victorias drinking water.
This report provides the technical information that was
used to inform a direction for future regulations and
the changes being proposed.
1. Achievements and limitations of the current regulations
2. The catchment quantifying risk
3. Monitoring at the treatment plant OPM
4. Verication in the distribution system
5. Reporting and documentation
Introduction
2
Safe Drinking Water Act 2003. The required content of
a risk management plan is detailed in the regulations. The
regulations specify what risks the plan must address and
other matters that the plan must contain (Appendix 2).
It is consistent with a process-based approach to
regulation
1
, which the Victorian Government encourages
where appropriate to avoid prescriptive rules. In this way,
the framework enables innovation as it allows for water
suppliers to assess risks and develop tailored solutions to
mitigate those risks under their control.
In 2007 the department implemented an auditing regime
in accordance with s. 11 of the Act to ensure that water
businesses plans comply with the obligations imposed
under the Act. The regulations specify the documents to
be audited, the approval requirements for risk management
plan auditors and the form of the audit certicate.
Since the auditing regime was implemented the rate
of compliance by water businesses with their risk
management obligations under the Act has risen from
60 per cent to 92 per cent. Figure 1 demonstrates this
signicant improvement over time.
1 Process-based regulation is a risk-based approach that is preferable
when government and industry are seeking to manage a number of
risks simultaneously and where the industry has sufcient maturity
and capability (Department of Treasury and Finance, 2011).
The current regulatory approach has served Victoria well.
The regulations have been effective in introducing a risk
management approach to the management of drinking
water quality. This is evidenced by the water quality
improvements that have been achieved since 2005 by
the Victorian water industry. Continuous improvement is
an important element of risk management, but there are
inconsistencies that demonstrate the need to encourage
more consistent performance management processes.
Achievements
The signicant achievements from the current regulations
include the adoption of a risk management approach
and the promotion of uniform safe drinking water quality
standards across the state.
Risk management approach from
catchment to tap
Under the current framework, water businesses take a
proactive approach to managing water quality through
comprehensive risk management plans that are
developed in accordance with the requirements of the
1. Achievements and limitations
of the current situation
Figure 1: Compliance of water businesses risk management plans with the Safe Drinking Water Act 2003
0
5
10
15
20
25
Noncompliant businesses
Compliant businesses
201112 2009 2008
Year of compliance audit
N
u
m
b
e
r

o
f

w
a
t
e
r

b
u
s
i
n
e
s
s
e
s
15
10
23
2
23
2

Note: The noncompliant businesses in 201112 were not the same as those in 2009.
Source: Department of Health 2013a
3
Uniform safe drinking water quality
The regulations promote a uniform approach to safe
drinking water quality by dening water sampling
localities and water sampling points, drinking water
quality standards, sampling and analysis and approval
of water analysts. These systems and principles have
achieved continuous improvement in drinking water
quality throughout Victoria.
Under the regulations, water businesses regularly test
drinking water quality throughout their supply systems
to ensure that drinking water at the point of supply with
their customers meets a number of quality standards
specied in Schedule 2 of the regulations (Appendix 3).
The scheduled standards identify the parameters used
for assessing drinking water quality, the required sampling
frequency for each parameter and the quality standard
for each parameter. There is one microbial water quality
standard, Escherichia coli (E. coli), and eight physical
chemical standards. Compliance is measured against
these standards.
Figure 2: Water sampling locality
2
compliance with the drinking water quality standards
0
10
20
30
40
50
60
70
80
90
201112 201011 200910 200809 200708
Reporting period
85
67
50
62
38
N
u
m
b
e
r

o
f

w
a
t
e
r

l
o
c
a
t
i
o
n
s

Source: Department of Health 2013a
2 Each water business covers a discrete geographic area that is divided into a number of water sampling localities.
A water sampling locality is a dened area of similar water quality.
The current regulations have achieved improved
compliance over time, increasing from 82.5 per cent in
200708 to 92 per cent in 201112 (Department of Health
2013a). The steady reduction in the rate of noncompliance
against the scheduled drinking water standards seen
across the state is shown in Figure 2.
In 201112 fewer than eight per cent of localities were
noncompliant compared with 200708, when 17.5 per
cent of water sampling localities were noncompliant. The
only exception to this positive trend was during 201011,
when compliance with the turbidity and disinfection by-
product standards was adversely impacted by the 2010
Victorian oods (Department of Health 2013a).
The current regulations have also achieved a sustained level
of improvement in smaller regional water supplies, where
compliance increased by 64 per cent between the 200405
and 201112 reporting periods (Department of Health
2013a). Importantly, the water sampling localities in these
areas are benchmarked against the same standards as the
Melbourne metropolitan area, meeting a key objective of
uniform safe drinking water quality across the state.
4
Limitations
Under the Act, water businesses are required to report to
the department incidents indicating a risk to public health
or noncompliance with drinking water quality standards. In
201112 the total number of notications was signicantly
lower than in the previous four reporting periods. This
downward trend reects ongoing improvements in risk
management and systems maintenance that water
businesses have put in place and the passing of the worst
effects of the ten-year drought.
3

While notications have been few, and most have not
resulted in known adverse health effects for consumers
(Department of Health 2013a), all incidents including near
misses have been studied carefully by the department and
the affected businesses, and the lessons learnt from these
near misses are critical to this review. Three studied events
are summarised in Box 1 and demonstrate the need
to encourage water businesses to adopt a continuous
improvement culture in performance management.
These events highlight limitations to the current
arrangements with respect to managing all microbial
hazards (bacteria, protozoa and viruses). To date, the
approach to reducing risk from microbial hazards has not
prescribed numerical values for microbial safety, but rather
required drinking water sampled at the tap to be free of
E. coli as an indicator for bacterial hazards. However, E. coli
is not an appropriate indicator for viral or protozoan hazards.
The events described in Box 1 also highlight the problem
of relying on endpoint testing. Consistent production of
safe drinking water requires water treatment processes
to operate effectively and continuously within their design
parameters, as drinking water cannot be withheld while
testing veries safety. The current reliance on endpoint
testing also means solutions to problems occur reactively.
The proposal for future regulations is aimed at addressing
the following questions.
Are the barriers suffcient to manage hazards and risks?
Are the preventive strategies working now?
Did the preventive strategies work?

3 An increase in notications in 201011 was an exception to the overall
downward trend and reected the signicant impact of the 201011
oods on water quality.
Box 1
1. Water from an irrigation channel was being
passed through a water treatment plant with
conventional treatment processes. Indications of
an impending failure of the disinfection process
were acted upon too slowly because the
dosing plant was not identied as a CCP. The
eventual failure, coupled with the slow response
to the issue, meant that the plant ran without
disinfection for approximately 10 hours. Chlorine
disinfection is an effective control measure for
bacterial and viral hazards; while no reports of
illness were received, potentially unsafe drinking
water was delivered to customers.
2. Water from an unprotected catchment was
being passed through a water treatment plant
that had ltration and disinfection processes.
An underestimated rain event caused a very
signicant increase in the raw water turbidity,
which impacted on ltration performance. The
lters were not able to cope, but water production
was continued due to the potential for the town
to run out of water. The result was undertreated
and potentially contaminated water entering the
drinking water supply system. Effective ltration
is a control measure for bacteria and protozoa;
while no reports of illness were received,
potentially unsafe drinking water was delivered
to customers.
3. Treated water delivered to a town via a pipeline
required a booster chlorination system to maintain
safe levels of disinfection. Ongoing pump
problems prior to the failure, coupled with a poor
monitoring and maintenance regime, allowed a
very high concentration of chlorine to enter the
towns supply. This event resulted in short-term
health effects for some residents.
5
Proposal for quantifying risk
The proposal is to require additional mandatory content
in regulations, which will improve the management
of catchment hazards and risks. It would require risk
management plans to outline the steps that will be taken
to quantify and analyse the risk of each hazard identied in
the plan. This is aimed at addressing the question Are the
barriers sufcient to manage hazards and risk?
Rationale
Risk management plans require an assessment of risk.
While various hazards and risks can be described, the
determination of the appropriate level of treatment that
should be applied to reduce risk to an acceptable level
requires quantication of the risks. Currently businesses
are expected to undertake hazard identication, which
requires investigation of water catchments to identify the
potential hazards for all likely scenarios to human health.
The ability, however, to quantify these risks is limited by
the absence of an agreed methodology.
Currently there is no agreed methodology in Victoria, or
Australia, for quantifying microbial risk in drinking water.
Some water businesses with the capability to quantify risk
have developed their own approaches and applied targets
based on a range of available authoritative guidance.
4
This
has resulted in a range of inconsistent approaches being
applied across the water industry.
Health-based targets
Health-based targets for microbial risk is not a
new concept as they are considered current good
practice, and have been adopted by the World Health
Organization (WHO) and several developed countries
around the world.
5
They provide a quantitative measure
of safety for all microbial pathogens (bacteria, virus
and protozoa), and can be used to help determine the
level of treatment necessary to reduce microbial risk
to an acceptable level.
4 Sources include international guidance; general principles from ADWG
2011; risk assessment guidance from Cooperative Research Centre
for Water Quality and Treatment; QMRA process from the Australian
guidelines for water recycling.
5 Guidance is issued by the United States Environment Protection
Agency (USEPA), the WHO, the New Zealand Ministry of Health
and Health Canada.
2. The catchment and quantifying risk
Box 2: What is a health-based target?
It is not possible to undertake an activity with zero
risk. Health-based target is a term used to dene
the level of risk that is acceptable to the community
to protect public health. It is a benchmark that can
be used to dene the safety of drinking water and
can be expressed either as a water quality target
or as a treatment goal.
The two health-based metrics for microbial
pathogens in drinking water that are most often
discussed are the infection rate metric, which
has been adopted by the USEPA and the DALY
(disability-adjusted life year) metric, which is used
by the WHO.
Operationally it is important to understand that
health-based targets are a mechanism to work
out what treatment is necessary for a given source
water. It is neither practical, nor required, to measure
infection rates, DALYs or for that matter any other
health-based metric during normal operations.
A health-based target for the microbial safety of
drinking water will dene the level of water treatment
that is required to achieve an acceptable level of
health risk, in turn providing a level of certainty that
safe drinking water has been produced (Water Quality
Research Australia 2013b).
The Victorian regulations already apply health-based
targets for chemical and radiological parameters
measured at the consumer tap. For microbial risk the
current regulations do not prescribe numerical values
but rather require drinking water sampled at the tap to be
free of E. coli which is an indicator for bacterial hazards
only. Viral and protozoan hazards are not considered
by this approach.
The next major update to the ADWG, expected in 2015,
is likely to adopt a health-based targets approach for the
microbial safety of drinking water (NHMRC 2009). This
method considers all microbial hazards and has already
generated a lot of discussion among drinking water
stakeholders (Water Quality Research Australia 2013a).
6
What would this mean for the next
set of regulations?
In order to promote consistency across Victoria,
regulations could require the steps to be taken to quantify
the risk to human health for each hazard to be outlined
in the risk management plan. It is not proposed that the
new regulations would explicitly refer to health-based
targets but rather the regulations would be designed to
be consistent with their adoption and application.
Water businesses would be required to characterise
source water risk and demonstrate that they have
reliable barriers in place to effectively manage identied
microbial hazards such as bacteria, viruses and protozoa
in all scenarios.
6

To support this, the department could issue guidance
on how health-based targets may be used in risk
management plans, including:
guidance on the health-based target outcome that
represents an acceptable risk to human health
guidance on log reduction values to be used in
health-based target calculations.
The development of such guidance would follow
further consultation with the water sector and further
consideration of developments in relation to health-based
targets, for example, the work by the NHMRC and the next
revision of the ADWG.
In most cases, adjusting to microbial health-based
targets will be achieved by optimising existing water
treatment processes and would provide a more defensible
benchmark in relation to the investment required. This
would also support the changing focus to OPM, rather
than on endpoint testing.
6 Scenarios include environmental, climatic, human and animal behaviours.
Options for quantifying risks
Water businesses could be given the option to quantify
their own water quality risks using quantitative microbial
risk assessment (QMRA) or using default values,
for example, a bin classication system.
7

Quantitative microbial risk assessment
This approach requires the use of health-based targets
and direct pathogen monitoring data. The amount of data
required for this method could be considered onerous for
some businesses; however, this concept allows a business
to calculate its level of microbial risk and the associated
water treatment that is required to achieve an acceptable
level of health risk. This method provides an alternative way
of identifying performance targets for treatment systems.
The following case study highlights the impact of microbial
(virus, bacteria and protozoa) loads on treatment plants
during extreme events and when treatment processes
are underperforming. It demonstrates how QMRA can
be used to look at risk factors and develop options to
mitigate them in an efcient and planned way. It also
reinforces the importance of the preventive risk-based
management approach.
7 The USEPA utilises a bin system that categorises source water
Cryptosporidium concentrations into one of four bin classications
that have associated treatment requirements.
7
Default values
Another method for quantifying microbial risk is the use
of default values. A sanitary survey supported by E. coli
and turbidity data from the drinking water catchment
would be required for those businesses relying on a
default approach. An example of this approach is provided
in Table 1 below.
Table 1 shows example risk proles for different water
catchments and relates these to the different levels
Table 1: An example of using default values to quantify microbial risk by catchment type
Source water Risk
Log reduction value
Virus Bacteria Protozoa
Protected groundwater Very low 0 0 0
Unprotected groundwater Lowmoderate 2 45 0
Protected surface water
Moderatehigh 4 56 2
Very low 0 46 0
Unprotected surface water
Low 34 56 3
Moderate 45.5 6 44.5
High 5.56.5 6 5.5
Source: NHMRC 2009
Box 3: Case study Source water characterisation and quantied risk assessment
Recently, one Victorian water business undertook a risk assessment exercise using the QMRA methodology
outlined in the AGWR to review their preventive measures at seven drinking water treatment plants.
The primary objective of the water business was to update its understanding of the performance of its drinking
water treatment plants when under challenge from extreme weather events by using data collected as part of a
pathogen-specic sampling program. Using the microbial risk assessment methodology, all seven treatment plants
had calculated risks below the adopted minimum tolerable risk
8
under typical treatment process performance,
regardless of maximum, average or minimum source water pathogen concentrations.
The project also found that under certain scenarios (for example, theoretically compromised water treatment
processes) the calculated risks were above the adopted tolerable risk level for bacteria and viruses in some cases.
This was the case for the older plants and those where chloramination was the primary method of disinfection.
As a result, the risks identied have been incorporated into the water quality improvement program.
of bacteria, virus and protozoa that could be present.
This is matched with the level of removal required,
represented as log reduction values.
9
The log reductions
provided here have been estimated using information from
the USEPA and New Zealand guidelines (NHMRC 2009).
This information could be used to determine the treatment
targets of individual treatment measures. In most cases
this would result in the optimisation of barriers already
in place.
8 The minimum tolerable risk adopted was 1 DALY per person per year
(AGWR 2006).
9 A one-log reduction equates to 90 per cent reduction of a pathogen.
A two-log reduction equates to a 99 per cent reduction, a three-log
reduction equates to a 99.9 per cent reduction and a four-log reduction
equates to a 99.99 per cent reduction.
8
Proposal for operational monitoring
The proposal is to require additional mandatory content
in regulations, which will improve the management of
hazards and risks at the treatment plant. It would require
risk management plans to identify CCPs within a treatment
plant and outline the operational procedures and process
controls at each CCP. This would include determining the
critical limits and performance criteria for each CCP, along
with alarming, reporting and mitigation procedures in the
event of a breach of a critical limit. This would require
the inclusion of a denition of a CCP and a denition of a
critical limit in the regulations. This is aimed at addressing
the question Are the preventive strategies working now?
Rationale
This is considered to be the next evolution in the
protection of public health and risk management in the
delivery of drinking water, which is recognised in the 2011
ADWG. Consistent production of safe drinking water
requires water treatment processes to operate effectively
and continuously within their design parameters, as
drinking water cannot be withheld while testing veries
safety. Assuring the safety of drinking water requires an
effective monitoring strategy that is preventive rather than
reactive. Properly designed OPM programs provide an
effective measure of water quality and protect against
the production and distribution of unsafe water (NHMRC
& NRMMC 2011). An increased focus on operational
performance is one of the key changes proposed,
and is considered necessary to protect public health
into the future.
Shifting the regulatory focus from endpoint testing to OPM
would encourage activities that demonstrate and ensure
treatment processes are functioning effectively. OPM is
already applied throughout the Victorian water industry;
however, there is no provision in the regulatory framework
to ensure consistency in the OPM undertaken by water
businesses. One of the objectives of the Act was to
implement a standardised approach to the management
of drinking water quality across all water businesses.
3. Monitoring at the treatment plant
Box 4: Operational performance
monitoring
OPM can verify that safe water is being delivered at
all times, because data for CCPs can be continuously
monitored and is available in real time. Properly
designed and justied control limits around risk
management barriers and well-constructed treatment
plant monitoring programs provide an effective
measure of water quality and safeguard against the
production and distribution of out-of-specication
water. Control limits also assist in determining and
optimising treatment plant investment decisions.
Operational performance monitoring survey
As part of this review, the department conducted a survey
of current OPM practices at 211 (97 per cent) of the states
water treatment plants. The survey results showed that
the most common treatment processes are coagulation,
media ltration and chlorination. The survey also indicated
that it was adopted practice for water treatment plants to
have online monitoring capability and for water businesses
to have a monitoring program to characterise source water
quality. The results also conrmed that OPM has been
adopted by all water businesses in some form.
The results also highlight some differences from accepted
good practice.
While 73 per cent of plants use coagulation/focculation
as a treatment process, and some key parameters are
well monitored, continuous monitoring of coagulant
dose is below 50 per cent.
While 81 per cent of plants use media fltration, the
implementation of automated control for the ltration
process is low.
There are inconsistencies in certain aspects of treatment
performance, for example
how ltration backwash regimes are applied
management of critical limits
how corrective actions are implemented
monitoring of inuencing factors (such as
temperature) and process performance measures
(such as contact time) for disinfection processes.
9
The application of control limits to unit processes is also
variable. In particular, the level of online monitoring for
coagulation/occulation, media ltration and chemical
disinfection is highly variable (Department of Health 2013c).
What would this mean for the next
set of regulations?
The current regulations do not provide a legislative
mechanism to ensure appropriate treatment is matched to
the assessed level of microbial risk. The regulations also
do not promote consistency in the use and form of OPM
across the Victorian water sector. Therefore, it is proposed
to develop regulations to encourage the identication
of CCPs in risk management plans, with appropriate
monitoring and control limits being applied at each CCP.
Water businesses would need to identify the points in their
systems where a failure could increase the risks to public
health and ensure there is the capacity to monitor and
mitigate those risks.
Critical control point
Establishing a denition of a CCP would enable regulations
to be created around monitoring a CCP and reporting
breaches of critical limits. A CCP could be dened as
a key point, step or procedure at which control can be
applied and that is essential to prevent or eliminate a
hazard or reduce it to an acceptable level (NHMRC &
NRMMC 2011).
Where a treatment process was identied in the risk
management plan as a critical step where control must be
applied, the water business would need to ensure that the
process is identied as a CCP, and that appropriate critical
limits are developed and implemented for the CCP.
Establishment of a critical limit
In addition to including a denition for a CCP the new
regulations could include a denition of a critical limit as
a prescribed tolerance that distinguishes acceptable
from unacceptable performance at a critical control point
(NHMRC & NRMMC 2011).
Exceeding or deviating from a critical limit represents
a loss of control of a treatment barrier or process and
indicates an unacceptable health risk. The department
would require water businesses to have risk management
tools in place to ensure that water that is produced
under such conditions is not delivered to the consumer.
The department would expect that reporting would only
be required where a critical limit had been breached
and corrective action such as shutdown or diversion
of out-of-specication water had failed.
Operational procedures and processes
Water businesses could also be required to address in their
risk management plans the specic operational criteria
they have established for the entire water supply system
from catchment to tap, including the distribution system,
to ensure control activities are being carried out effectively.
This could include:
documentation on operational procedures, including the
identication of responsibilities and authorities
establishment of monitoring protocols for operational
performance, including selection of operational
parameters and thresholds and the routine review
of data
establishment of corrective actions to control excursions
in operational parameters
calibration and maintenance of equipment
the use of approved materials and chemicals in contact
with drinking water.
The provision of broad criteria in guidance could allow
for exibility in approach and support the process-based
approach to regulation that is currently being applied
through risk management plans. It could also consider any
perceived difculty in applying numbers to dynamic and
interrelated treatment processes. Compliance with such
criteria could be assessed through audit.
Greater rigour around operational performance would be
offset by reduced reliance on monitoring drinking water
quality at the consumer tap.
10
Effectiveness of treatment processes
To conrm effectiveness of water treatment processes in
reducing microbial hazards to an acceptable level, water
businesses could be given the option of undertaking their
own testing, also called validation.
10
For those businesses
that choose this option, non-mandatory guidance would
be developed by the department to support this activity.
Another method to validate treatment processes can
be undertaken with the use of default values. Table 2
shows a possible model for such default values.
For most water supply systems this would only involve
the optimisation of existing barriers rather than investment
in additional barriers.
Table 2: A possible model for default water treatment values
Treatment process Dose/Ct
a
Log reductions
Virus Bacteria Protozoa
Coagulation, sedimentation and ltration 1 1 13
Slow sand ltration 12 12 13
Coagulation and microltration 2 4 4
Ultraltration 24 4 4
Chlorine
10 mg.min/L 2 4
b
0
20 mg.min/L 4 4
b
0
Ultraviolet light
55 mJ/cmb 1 4
b
4
b
110 mJ/cmb 2 4
b
4
b
a Ct = concentration x time
b A maximum 4 log reduction allocated to disinfection barriers
Source: adapted from NHMRC 2009

10 Treatment validation is the process of demonstrating that a treatment
system can produce water of the required microbial quality under
a dened range of operating conditions.
11
Proposal for verication monitoring
While it is proposed to reduce the focus on monitoring
drinking water quality at the point of supply by
reducing the number of mandatory standards and
removing redundancies that currently exist, verication
monitoring would still be retained. Modifying the existing
regulations to ensure that verication monitoring is a
part of the broader risk management approach would
be implemented through incorporating water sampling
programs into risk management plans. The proposed
changes are aimed at addressing the question Did the
preventive strategies work?
Rationale
The system is currently focused on monitoring quality at
the point of supply (the consumer tap) and a number of
current regulations exist to support this focus on endpoint
testing. While monitoring at the point of supply is a
valuable indicator, it is of limited utility in managing risk,
because it is impractical to withhold supply while quality
issues are addressed.
The current situation is time-consuming, expensive for
water suppliers, and is of limited value for managing risks
to consumers; therefore, the current review provides a
good opportunity to look at ways for reducing regulatory
burden on water businesses.
Verication of drinking water quality, however, is important
to conrm that preventive strategies have worked and to
conrm that drinking water is still safe after it has passed
through the distribution system. Achieving improved
compliance with water quality standards, coupled with an
intention to strengthen risk management, could allow for a
reduction in mandated testing against specied standards.
This proposal is removing the requirement to monitor for
particular chemicals at set frequencies, but this does not
mean that water businesses shouldnt undertake this
monitoring if their risk assessment determines otherwise.
What does it mean for the next
set of regulations?
Regulations to support verication could involve
the following:
Verication monitoring:
Include details of verifcation monitoring in risk
management plans, including arrangements for water
sampling localities, sampling, analysis, testing and
reporting and assessment of customer satisfaction.
Risk management plans could be required to specify
water sampling points and the related sampling
regime. This means the requirement for approval and
registration of water sampling points could be removed
from the regulation.
Retain the regulation to vary the frequency of monitoring
of a specied standard.
Remove the requirement to independently assess and
approve individual laboratory technicians, but retain
the requirement for the analysis of water samples to
be undertaken by a laboratory that is accredited by the
National Association of Testing Authorities, Australia with
the relevant test accreditation.
Verication standards:
Remove drinking water quality standards which have
achieved high levels of ongoing compliance:
bromate
formaldehyde
chloroacetic acid
dichloroacetic acid
trichloroacetic acid
aluminium (acid soluble).
Retain three mandatory drinking water quality standards
to help identify problems within the distribution system:
E. coli
turbidity
total trihalomethanes (THMs).
4. Verication monitoring
in the distribution system
12
Adjust the standards that are associated with these
three parameters per water sampling locality in line with
the 2011 ADWG to:
100 per cent of samples free of E. coli, based
on weekly sampling
all samples below a turbidity of 5.0 Nephelometric
Turbidity Units (NTU), based on weekly sampling
total THMs less than 0.25 mg/L, based on
monthly sampling.
Retain a generic standard that drinking water cannot
contain an algae, toxin, pathogen, substance or
chemical in an amount that may pose a risk to
human health.
Consider developing a generic standard for OPM.
13
Proposal for documentation
and reporting
While it is proposed to reduce the reporting requirements
by removing monthly reporting, documentation and
reporting is still important and could be reformed through
the following mechanisms. The reporting regime for
water quality monitoring data could be reformed to
reduce the administrative burden on water businesses,
by replacing the monthly reporting requirement with an
exception reporting model. Annual reporting requirements
would remain and include a long-term review of CCP
performance as well as operator technical competencies
matched to specic treatment facilities.
Rationale
A number of regulations exist to support documentation
and reporting. Annual report details remain relevant
however the current requirement to provide monthly
water quality monitoring data to the department is time-
consuming and a burden on water businesses. At least
95 per cent of tested water samples are compliant with
the water quality standards set out in the 2005 regulations.
Monthly reporting creates administrative duplication and
is an unnecessary burden to both water suppliers and the
department. As there is now evidence that water quality
compliance is more consistent across the state, along
with a high level of ongoing compliance, this part of the
regulations has been identied as an area to consider
regulatory burden reduction.
What does it mean for the next
set of regulations?
The proposal to remove the requirement for monthly
reporting of water quality sample analysis data would
increase reliance on notications under ss. 18 and 22
of the Act.
11
This reporting is rmly entrenched among
water businesses, and removing the monthly reporting
requirement would reduce the administrative burden
and duplication of reporting of water analysis data to
assess compliance. In its place it is proposed that the
provision of detailed water quality monitoring data would
be required by the department regarding water which
poses a risk to human health because it does not comply
with a water quality standard or is known or suspected to
be contaminated and is supplied or potentially supplied
to customers.
The department would require that reporting only
occurs when a critical limit has been breached and
corrective action such as shutdown or diversion of
out-of-specication water has failed, or when a water
quality standard has not been met. This would include
reporting on failures in risk management, for example,
noncompliance with a critical limit (associated with a CCP
or barrier to contamination), a key performance target, a
standard or a guideline value when the noncompliance
may pose a risk to public health.
Review of businesses water quality monitoring processes
and documentation as part of the risk management
plan audit would provide an opportunity for review and
oversight of businesses compliance with these notication
requirements.
Regulations outlining annual report requirements would
remain however the proposed approach would require
the following to be included:
the performance of CCPs, to confrm that businesses
have systematic processes in place to manage drinking
water quality
a summary of data for all CCPs that are monitored
online. This could include the percentage of time or the
volume of water supplied, where target criteria (alert
limits) and critical limits were met and whether any
trends or problems can be identied
information on compliance with the Victorian
framework for water treatment operator competencies:
best practice guidelines (Department of Health &
VWIA 2010). This would conrm that businesses have
appropriately trained operators in place.
5. Documentation and reporting
11 Section 18 notication required if water is supplied or not likely
to comply with a water quality standard. Section 22 notication
required if water is supplied or to be supplied where there has been
known or suspected contamination (Safe Drinking Water Act 2003).
14
Reference group
Chair: Ms Jan Bowman
VicWater
Department of Environment and Primary Industries
Essential Services Commission
Consumer Utilities Advocacy Centre
Department of Health Water Program
Working groups
Existing Regulations Working Group
Chair: Mr David Sheehan
Water Industry Operators Association of Australia
National Association of Testing Authorities, Australia
Chisholm Institute of TAFE
Gippsland Water
Yarra Valley Water
Southern Rural Water
Department of Health Water Program
Operational Performance Working Group
Chair: Ms Jan Bowman
North East Water
Barwon Water
Melbourne Water
Water Industry Operators Association of Australia
Hydrological Services
Department of Health Water Program
Health-based Targets Working Group
Chair: Mr Rodney Dedman
Monash University
Melbourne Water
Barwon Water
Department of Health Water Program
Appendix 1: Reference group and working
group membership
15
(1) For the purposes of s. 9(1)(e) of the Act, a risk management plan must contain the following matters:
(a) the names and contact details of, and the positions held by, the persons responsible for managing hazards
and risks to the quality of the water identied in the risk management plan
(b) details of the activities undertaken, and measures taken, to manage hazards and risks to the quality of the water,
including the method by which the effectiveness of these activities and measures is veried
(c) details of the features of the system of supply designed to assist in the management of risks to the quality
of the water, including the method by which the effectiveness of these features is veried
(d) in the case of a water supplier, details of the procedures for consultation with water storage managers and other
water suppliers for the purpose of achieving agreement on the hazards and risks to quality of the water supplied
(i) to the water supplier by water storage managers or other water suppliers
(ii) by the water supplier to other water suppliers
(e) details of procedures and management systems for
(i) ensuring that the amount and purity of chemicals added to drinking water does not adversely affect the quality
of that water or pose a risk to human health
(ii) controlling any residue or chemical by-products imparted to drinking water as a result of the addition
of chemicals to water supplied for drinking purposes
(f) details of emergency management arrangements and procedures for dealing with an incident, event or emergency
that may adversely affect the quality or safety of drinking water, or result in water being supplied that poses a risk
to human health, including
(i) the names and contact details of, and the positions held by, the persons responsible for dealing with such
an incident, event or emergency
(ii) methods for communicating or disseminating information to the public in relation to any such incident, event
or emergency.
(2) For the purposes of s. 9(2) of the Act, a risk management plan must address the following risks:
(a) the risk to human health that arises from the presence in water of
(i) pathogenic microorganisms
(ii) inorganic chemicals, including inorganic disinfection by-products
(iii) organic chemicals, including pesticides, pesticide residues and organic disinfection by-products
(iv) radiological parameters
(v) algal toxins
(b) the risks arising from an incident or event that may cause the above organisms, substances and matters to enter
or be present in the system of supply
(c) the risk of transfer of those organisms, substances and matters.
Source: Safe Drinking Water regulations, 2005
Appendix 2: Regulation 6
risk management plan
16
Table 3: Drinking water quality standards
Parameter
Sampling frequency per
water sampling locality Standard
Aluminium
One sample per month
0.2 milligrams per litre of drinking water (acid soluble)
Bromate 0.02 milligrams per litre of drinking water
Chloroacetic acid 0.15 milligrams per litre of drinking water
Dichloroacetic acid 0.1 milligrams per litre of drinking water
E. coli One sample per week
At least 98 per cent of all samples of drinking water
collected in any 12-month period contain no E. coli per
100 millilitres of drinking water
Formaldehyde
One sample per month
0.5 milligrams per litre of drinking water
Trichloroacetic acid 0.1 milligrams per litre of drinking water
THMs 0.25 milligrams per litre of drinking water
Turbidity One sample per week
95 per cent upper condence limit of the mean of samples
of drinking water collected in any 12-month period must
be less than or equal to 5.0 NTU
Source: Safe Drinking Water regulations, 2005
Appendix 3: Schedule 2 drinking water
quality standards
17
Control limit A generic term used to describe both target criteria and critical limits.
Critical control
point
A key point, step or procedure at which control can be applied and that is essential to prevent
or eliminate a hazard or reduce it to an acceptable level (NHMRC & NRMMC 2011).
Critical limit A prescribed tolerance that distinguishes acceptable from unacceptable performance at a CCP
(NHMRC & NRMMC 2011).
DALY see disability-adjusted life year
Disability-adjusted
life year
Used to calculate a value that considers both the probability of experiencing an illness or injury
and the impact of the associated health effects.
Drinking water Water that is intended for human consumption or for purposes connected with human
consumption, for example, preparing food or making ice for human consumption or for
preserving unpackaged food.
Hazard A biological, chemical, physical or radiological agent that has the potential to cause harm.
Health-based
targets
A benchmark that denes the level of risk to protect public health that is acceptable to the
community.
Log reduction value Used in reference to physicalchemical treatment of water to remove or inactivate
microorganisms such as bacteria, protozoa and viruses (Department of Health 2013b).
DALY A unit of measure for risk. Microbial safety of water that does not give rise to a health impact
of 1 DALY (microDALY) per person per year is equivalent to between one and eight cases
of diarrhoea per 10,000 people per year (also see Disability-adjusted life year).
Monitoring Systemically keeping track of something, including sampling or collecting information
and documentation (NSW Department of Finance and Services 2012).
Multiple barriers The multiple steps in the water treatment process.
This approach aims to provide sufcient backup to allow continuous operation in the face of
normal uctuations in performance. A failure of one barrier can be compensated for by effective
operation of the remaining barriers, minimising the likelihood that contaminants will pass through
the treatment system and harm consumers (WHO 2004).
Operational
performance
monitoring
A planned sequence of measurements and observations to assess and conrm the performance
of preventive measures such as water treatment processes. Measurements are of operational
parameters that will indicate whether processes are functioning effectively (NHMRC &
NRMMC 2011).
Pathogen Disease-causing organisms such as viruses, protozoa and bacteria.
Regulatory burden Costs that extend to producers over and above business-as-usual costs
(Department of Treasury and Finance 2009).
Glossary
18
Risk The likelihood of a hazard causing harm in exposed populations in a specied timeframe,
including the magnitude of that harm (NSW Department of Finance and Services 2012).
Risk assessment The process of using available information to predict how often hazards or specied events may
occur (likelihood) and the magnitude of their consequences (NSW Department of Finance and
Services 2012).
Risk management The systematic evaluation of the water supply system, the identication of hazards and
hazardous events, the assessment of risks and the development and implementation of
preventive strategies to manage the risks (NRMMC, EPHC & AHMC 2006).
SCADA see Supervisory control and data acquisition
Supervisory
control and data
acquisition
Supervisory control and data acquisition (SCADA) systems are used to control dispersed
water supply assets, particularly where centralised data acquisition and control are important
to system operation. They are widely used in water and wastewater systems, oil and natural
gas pipelines, electrical power grids and railway transportation (National Institute of Standards
and Technology 2008).
Target criteria Quantitative or qualitative parameters established for preventive measures to indicate
performance and performance goals (NHMRC & NRMMC 2011).
Validation The substantiation by scientic evidence (investigative or experimental studies) of existing or new
processes and the operational criteria that demonstrate the pathogen-reduction capability of the
process to effectively control hazards (NRMMC, EPHC & AHMC 2006).
Verication An assessment of the quality of drinking water being supplied to consumers. It incorporates
monitoring drinking water quality in the distribution system and assessing consumer satisfaction.
It provides assurance that the preventive measures and treatment barriers in the water supply
system have worked, and are working, to supply safe drinking water (NHMRC & NRMMC 2011).
19
Department of Health & Victorian Water Industry
Association (2010) Victorian framework for water treatment
operator competencies, State Government Victoria,
Melbourne.
Department of Health (2013a) Annual report on drinking
water quality in Victoria 201112: managing drinking water
quality from catchment to tap, State Government Victoria,
Melbourne.
Department of Health (2013b) Guidelines for validating
treatment processes for pathogen reduction: supporting
Class A recycled water schemes in Victoria, State
Government of Victoria, Melbourne.
Department of Health (2013c) Operational performance
monitoring survey, State Government Victoria, Melbourne.
Department of Treasury and Finance (2009) Victorian
regulatory change measurement manual, State
Government of Victoria, Melbourne.
Department of Treasury and Finance (2011) Victorian guide
to regulation, State Government of Victoria, Melbourne.
EPHC see Environment Protection and Heritage Council
National Health and Medical Research Council (2009)
Health-based targets for microbial safety of drinking water
supplies: draft discussion paper, National Health and
Medical Research Council, Canberra.
National Institute of Standards and Technology (2008)
Guide to industrial control systems (ICS) security, NIST
special publication 80082, National Institute of Standards
and Technology, U.S. Department of Commerce,
Gaithersburg, Maryland.
NHMRC see National Health and Medical
Research Council
NRMMC see Natural Resource Management
Ministerial Council
National Health and Medical Research Council & Natural
Resource Management Ministerial Council (2011) National
water quality management strategy: Australian drinking
water guidelines 6 2011, National Health and Medical
Research Council, National Resource Management
Ministerial Council, Commonwealth of Australia, Canberra.
Natural Resource Management Ministerial Council,
Environment Protection and Heritage Council & Australian
Health Ministers Conference (2006) Australian guidelines
for water recycling: managing health and environmental
risks (Phase 1), Natural Resource Ministerial Management
Council, Environment Protection and Heritage Council &
Australian Health Ministers Conference, Canberra.
NSW Department of Finance and Services (2012) Urban
water regulation review discussion paper: joint review of
the Water Industry Competition Act 2006 and regulatory
arrangements for water recycling under the Local
Government Act 1993, NSW Government, Sydney.VWIA
see Victoria Water Industry Association
World Health Organization (2004) Water treatment
and pathogen control: process efciency in achieving
safe drinking water, eds. MW LeChevallier & K Au, IWA
Publishing, London.
Water Research Australia (2013a) Health-based targets
(HBTs) for the microbial safety of drinking water:
stakeholder viewpoints, Water Research Australia,
Adelaide.
Water Research Australia (2013b) Health-based targets
for microbial safety of drinking water: introduction, Water
Research Australia, Adelaide.
Legislation and regulation
Safe Drinking Water Act 2003 (Vic), available at <www.
austlii.edu.au/au/legis/vic/consol_act/sdwa2003188>.
Safe Drinking Water Regulations 2005 (Vic), available
at <www.austlii.edu.au/au/legis/vic/consol_reg/
sdwr2005297>.
References