Regulations force focus on water management
Companies in ‘high risk’ sectors such as food and drink processing could face criminal liability claims should they fail to ensure water management is carried out according to the Water Regulations standards set by DEFRA and enforced by the water industry. Ian Mitchell, water regulations manager at Severn Trent Water, gives you some tips on how to avoid those bars.
While instances are thankfully rare, contamination of the water supply can carry serious risks to public health as well as potentially raising some important liability issues for the businesses and organisations should they find they are the source of the outbreak.
While it may be impossible to prevent such outbreaks altogether, it is important that business managers are aware of their responsibilities and the potential criminal liability claims they could face, if they fail to ensure onsite water management is carried out properly and safely.
Under the Water Regulations, provided by the Department for Environment, Food and Rural Affairs (DEFRA) and enforced by the water industry, business managers have a responsibility to maintain high standards of on-site water management, to ensure the quality of onsite water is not compromised and to minimise wastage where possible.
Specifically, the regulations require those responsible for onsite water management to avoid ‘waste, undue consumption, misuse and undue contamination of the water supply’. Inspections are regularly carried out by water companies to check that management systems are adequate, especially in the case of ‘high risk’ sites such as those involved in food and drink production, as well as industrial and commercial sites and commercial agricultural businesses, where hazardous substances are used.
Such inspections can involve microbiological checks to ensure water quality is being maintained.
One of the first steps to be carried out by onsite managers is an audit of water-related risk areas. Water quality issues can typically arise where water is stored – for example, where there are onsite water storage tanks. However, another potential risk area is where water is stored in pipework, at the point where water supplies are drawn. Simple, monitoring devices can be installed to regularly monitor water quality at these points to ensure onsite supplies are protected.
Another important area of potential risk is where humidifiers or air cooling or conditioning systems are used. These systems are widely used at industrial sites where temperature control can be an important part of manufacturing processes. It is important to bear in mind that water borne contamination can occur wherever moisture is carried in the air and while water supplies to such units may be of good quality, contamination can occur if units are not kept clean and well maintained.
Many businesses are unaware that the temperature of onsite water is regulated. This is because the temperature of stored water can increase the risk of contamination. For example, there is a higher risk of water becoming compromised when cold water is allowed to heat and becomes warm, usually because it is stored close to water heaters or hot water pipes which may not be properly insulated. The Water Supply Water Quality Regulations require that cold water should not exceed 25ºC and water companies are required to ensure it is kept below 20ºC. Hot water should be maintained above 50ºC.
If onsite water quality is compromised, it can in some instances, present a risk to public water supplies. Clearly there is an important liability issue here for businesses, if poor onsite water management is found to be the cause of a water-borne outbreak of bacterial infection, such as legionella or E. coli.
The main risk of this kind of contamination is through back flow, where compromised water can literally be sucked back into the drinking water supply. Back flow is a reversal of the normal flow of water through a system. There can be a variety of causes, including a reduction in supply pressure due to a burst main or simply the poor installation and operation of an onsite water system.
One company, for example, called in Severn Trent Water, when their drinking water ran red when turned on in the morning. Because people had been drinking the water, environmental health officers and the Drinking Water Inspectorate were involved in the investigation. The problem was caused by back flow from a paint-spraying booth using cadmium-based paint, when the water supply was turned off in the evening and back on in the morning. The regulations are designed to prevent incidents such as these happening by specifying appropriate controls in the plumbing system, to prevent unclean water mixing with the potable water supply.
Regular maintenance of onsite water systems is vital to ensure installations are adequate. All water management work carried out onsite should be properly documented and regular inspections carried out at least every quarter, when storage temperatures, water quality, system integrity and leaks should all be checked. Being able to demonstrate this kind of ‘due diligence’ will not only minimise the risk of any potential liability, it will, of course, also reduce the risks of onsite water contamination.
As awareness of water quality issues grows, more businesses are choosing to outsource their water management services. They often find that water management improvements often equate to improved efficiency and reduced costs too. While water-related risk management is an important consideration, businesses should bear in mind that there are often efficiency gains too when they put water quality first.
The Water Regulations Advisory Scheme (WRAS), which is funded by all the UK Water Suppliers provides an advisory service. Copies of the Water Regulations Guide are available on request. For more information visit www.wras.co.uk. Information, leaflets and advice are available from Severn Trent Water, e-mail: email@example.com