Vagueness in water hygiene rules could be leaving gaps open for the contamination of drinking water supplies.
“Collective and coherent understanding” of the terms laid out in the rules is needed to ensure hygiene qualities.
That’s according to a whitepaper that suggests contractors and third-party suppliers may not be aware of or following the guidelines in place for people working in and around the supply of water.
The paper called Mind the Gap shows where the risk of water contamination could happen.
At points of contact between source and tap, workers are required to have hygiene training and certification as set out by the National Water Hygiene Scheme (NWHS).
The Principles of Water Standards Hygiene (PoWSH) rules state anyone working on “restricted operations” – at water sources, in treatment plants or at any operational assets – must be trained, authorised and carry a valid water hygiene training blue card.
Written as part of a NWHS review by Energy & Utility Skills, the paper states the regulations via PoWSH should apply to not only employees of water companies but also to contractors, suppliers and installers working in or around “restricted areas”. These include boreholes, wells, springs, treatment works, pumping stations, reservoirs and all pipes.
The paper suggests third parties, such as contractors or suppliers, working at remote unmanned sites are unlikely to be checked for their blue card and may even be unaware of the requirement.
Hygiene training and authorisation is a key part of PoWSH and the paper says following this is a fundamental requirement of working in a public health business.
From catchment to tap, the people who may be in contact with water includes farmers, landowners, the public, water company staff, contractors, suppliers and plumbers.
The paper says most companies could confidently confirm that any contractor visiting a manned water treatment works would be checked for compliance with the NWHS and be in possession of their blue card.
However, it says “the position is less clear for third parties attending unmanned sites or working on the water distribution network because there is unlikely to be any checking. Some contractors working on the network, especially smaller sub-contractors, are unlikely to be aware of the requirement and the work may be in a remote area.”
It advised identifying unmanned sites and places that could be overlooked. These could include: contractors and suppliers working on source works, water treatment works, pumping stations and service reservoirs; contractors and sub-contractors repairing or replacing water mains and services or laying new mains and services; and non-water company contractors laying new mains and services on new development sites.
Self-lay Providers (SLPs) installing piping for new housing or other developments are required to carry the same blue card but vagueness about what falls into the remit of “restricted operations” means there could be a gap in compliance.
The paper concludes improved specification, monitoring and enforcement processes are required to ensure that key requirements of PoWSH are fully complied with.
Energy & Utility Skills asks the water companies, their supply chain and the wider sector:
Does the water industry in England and Wales have one collective and coherent understanding of the term ‘restricted operations’ for the approved hygiene scheme and does it support its current scope?
- Is the existing scope of ‘restricted operations’ still current and robust to match the latest water quality regulatory risk approaches, and the changes in operational practices and industry structure?
- Does the water undertakers definition of ‘restricted operations’ still match the perceived need of the drinking water regulators?
- What procedures do water undertakers have in place to ensure that all personnel carrying out restricted operations, including those working for contractors, suppliers and subcontractors, comply with the requirements of the approved hygiene scheme?
- How is the supply chain keeping itself up to date on water hygiene requirements and ensuring its compliance across all UK restricted operations?
- Are all self-lay providers operating to the approved hygiene scheme?
- What further work can be done on frameworks and contracts to ensure the approved hygiene scheme is embedded across the water supply system from source to tap?