Drinking Water 2003
This annual report about drinking water quality in England and Wales, the fourteenth by the Inspectorate, represents a significant milestone in the history of monitoring the quality of drinking water supplies. In 1989, for the first time in England and Wales, numerical drinking water quality standards were set in the form of regulations. In 2000, these standards were updated and new regulations came into force on 1 January 2004. Thus, in this report, we cover the work of the Inspectorate during the last year of operation of the 1989 regulatory framework. The overall benefits of the regime are beyond doubt. There has been objectively measured and openly reported, year on year improvement in drinking water quality. This success has been brought about by many, but particularly it has happened as a result of the work of water company operational and scientific staff.
This is a good time to reflect upon our learning about the process of drinking water regulation, what has worked well and where all of the actors (water companies, regulators, stakeholders) recognise there is more we can and should be doing collectively to maintain consumer confidence and safeguard public health, through the provision of wellmaintained and sustainable drinking water supplies. The 1989 regulations enabled good progress to be made on those parts of the ‘source to tap’ supply chain within the control of water companies (treatment and distribution) but it will take a more holistic approach if we are to make similar good progress in the coming decade. Limiting and ideally reducing pollution of drinking water sources would reduce risk and avoid costly additional treatment in the longer term. We need to make sure everyone has access to good quality drinking water in public buildings, schools, workplaces and homes, by giving owners and occupiers the knowledge and the incentives to play their part as custodians of the plumbing that is the final part of the water supply chain.
Drinking Water Quality in 2003
Overall compliance with standards by the 26 water companies in 2003 was 99.88%, with the number of breaches of standards, 3,418 out of 2,896,252 tests, now standing at its lowest ever level. A decade ago the failure level was 25,171 out of 3,482,941 tests. There can be no doubt that drinking water quality nationally is the highest it has ever been.
The decline in failures in 2003 has been due to improvements made in the following specific areas: microbiological quality at service reservoirs (where treated water is stored before it passes to consumers’ taps); trihalomethanes and pesticides (due to improvements in raw water quality and treatment); and iron and polyaromatic hydrocarbons (PAH), which reflect improved conditions within the network of water mains (distribution systems). It is pleasing to see that improvements have taken place at all points in the ‘source to tap’ water supply chain.
Within this good overall picture there are some aspects of water quality during 2003 that buck the trend and have given the Inspectorate cause for concern. The microbiological performance of water treatment has declined. Whilst not statistically significant, this attracts close scrutiny by the Inspectorate because the parameters in question are arguably the most important indicators of quality in public health terms. Total and faecal coliforms have a long track record of value in verifying that water companies’ treatment processes and operational procedures are robust and able to cope under all raw water conditions. I am pleased to record that one company has put in place sitespecific water safety plans to improve the microbiological performance of their treatment works ahead of completion of upgrades to these works coming online. The Inspectorate will be paying close attention in 2004, to the way in which all companies investigate and act upon microbiological failures at treatment works and also at service reservoirs.
Measurements of phosphorus in water supply zones in 2003 revealed a higherthanexpected degree of failure. This happened because some companies had intermittent problems with the control of the phosphate dosing they had installed for plumbosolvency control. The parallel measured improvement in compliance with the standard for lead at consumers’ taps means that overall there has been a benefit to human health from phosphate dosing; however, the Inspectorate expects all water companies to pay attention to the need to optimise the process.
Preparing for the new Regulations
The Inspectorate has monitored the progress of water company programmes of work to meet the new and revised standards in the Water Supply (Water Quality) Regulations 2000 which came into force on 1 January 2004. Overall progress has been satisfactory, most programmes were completed on time and the few that were not complete by 25 December 2003 related to treatment works that are not in supply, or where sufficient improvement had been made already and further work is not considered necessary.
Part of the new regulations enable companies to apply to the Secretary of State or the National Assembly of Wales (the Authorities) for authorisation to supply water that is not wholesome. The Inspectorate received eight such applications (under Regulation 42). Authorisations were granted in each case and these provide for remedial work to be completed within a threeyear period. When granting an authorisation the Authorities must be satisfied that the level of contravention of a standard does not constitute a potential danger to health.
The process of applying for and granting an ‘authorised departure’ has been one of the notable learning points in moving from the old to the new regulations. Each case has to be judged on its own merits; for example, specific health advice needs to be obtained, and the granting of one authorisation does not set a precedent for any other applications that may follow.
Companies have been monitoring against the six new parametric values (benzene, bromate, 1,2 dichloroethane, nitrite exworks, Clostridium perfringens and Enterococci), since 2001. The gathering of information well ahead of the introduction of these new standards has proved beneficial because corrective action has been taken reducing uncertainty about the likelihood of failures in 2004. For example, companies detecting bromate at levels above the standard were able to further tighten control of contaminants in water treatment chemicals and optimise their treatment processes.
The most challenging of the new standards is that for lead which is derived from old plumbing or from the pipework connecting a household to the local water main. From 2004 the standard is 25 µg/l as compared to 50 µg/l in the old regulations. Although breaches of the new lead standard will occur in 2004, the plumbosolvency measures put in place by water companies means that the noncompliance level has fallen from 2.01 % in 2001 to 1.32% in 2002, and 0.74% in 2003. Although the new regulations will see an increase in the number of failures due to lead, these should be offset by far fewer contraventions of the standards for nitrite and PAH.
During the period of operation of the 1989 regulatory framework, water companies, regulators and other stakeholders have placed considerable emphasis on overall compliance as a single numeric performance measure for drinking water quality. Whilst useful in driving and demonstrating improvement due to investment, adoption of this aggregate measure has some inherent pitfalls. Not all parameters are of equal significance, nor are they measured at the same frequency or in the same locations in the ‘source to tap’ water supply chain. Greater weight can and should be given by water companies to monitoring and recording their performance against scientifically sound, operational control criteria that yield timely and reliable information which can be acted upon to manage and reduce risk.
The Periodic Review of Water Prices
In 2003 the Inspectorate continued to participate fully in the process of setting water prices for the period 2005 2010. The priorities for drinking water quality were identified as: completion of distribution (water mains) renovation; lead pipe replacement; investment in water treatment where source water conditions have changed; and enhancements targeted at improving the consumer acceptability of drinking water. Together with all the main parties involved, the Inspectorate supported an integrated consumer research exercise to objectively check on consumers’ priorities and their willingness to pay for improvements. This research confirmed the absolute importance to consumers of a clean and safe drinking water supply. Consumers recognised the direct link between maintenance of the water
system and the aesthetic quality of drinking water at the tap and gave this top priority in terms of their willingness to pay for improvements. Consumers were consistent in their views on drinking water quality across England and Wales.
During the period 1990 2005 about onefifth of the distribution system in England and Wales (comprising of mainly of old cast iron pipework) will have been replaced or relined, dealing with decades of insufficient ‘maintenance’. Five companies still have substantial programmes of work to complete, and arrangements are in hand for this. All companies’ need robust strategies to be in place to prevent such deterioration from ever occurring again. In 2003 the Inspectorate reviewed companies’ Distribution Operations and Maintenance Strategies and gave feedback to companies to assist them with developing a structured approach to the management of water supplies in the longer term. When working with Ofwat and the companies, the Inspectorate has emphasised that maintenance should be based on need, focusing on activities that further reduce the number of consumers who are still receiving rusty or discoloured water through their taps.
Events affecting Drinking Water Quality
The Inspectorate receives notifications from water companies of events which have affected or are likely to affect the quality of water supplies for a few hours to several days. In 2003 there were 353 notifications and the Inspectorate assessed 99 of these as incidents. In total these incidents affected the quality of drinking water supplied to
2.4 million consumers. The majority of theseincidents took place within the distribution system and led to consumers receiving dirty water. Less frequently the water tasted or smelt bad. Other incidents concerned situations where raw water quality had deteriorated or operational circumstances meant that the company could not be certain whether the integrity of water treatment or storage had been compromised.
Operational problems will always occur and often these cannot be foreseen even by the most well run of water companies. The Inspectorate’s assessment process focuses attention on those elements of the companies’ service recovery efforts that are important to consumer confidence. Nowadays, the regulatory framework has matured and the best companies will openly review and learn from incidents without being prompted by the Inspectorate to do so. None the less, in 2003, the Inspectorate found it necessary to make 49 recommendations to companies because their handling of an incident was not good enough. On three occasions enforcement action had to be taken. Consumers affected by water quality incidents want the Inspectorate to take a tough stance with companies when they fail to give consumers the information and reassurance they seek when things go wrong.
Consumer Complaints about Drinking Water Quality
In 2003 the Inspectorate has been putting in place plans to further enhance its website to make it even more useful to consumers and other stakeholders. The Inspectorate’s website is well used by those seeking objective and independent facts about drinking water quality and health matters, as shown by statistics on usage of the website (approximately 100,000 hits a month). A further indication of the benefit of the website is seen in the 20% reduction in the number of telephone or email enquiries received by the Inspectorate in 2003. The new drinking water regulations will facilitate an improved information service by enabling the Inspectorate to use tools such as GIS to accurately represent geographical variations in drinking water quality across England and Wales. We believe these developments will be of value not just to consumers but also to environmental health officers and health authorities in the course of carrying out their own checks on drinking water quality.
When I joined the Inspectorate in April 2003 I was interested to learn about the complaints about drinking water quality that consumers felt needed the intervention of the Inspectorate. Throughout the year we have seen a 22% increase in these complaints. Although small in number (167), these represent the tip of the iceberg as regards the issues that water company customer services staff deal with day to day in much greater volume. The majority of complaints received by the Inspectorate were about dirty water (38%) and unpleasant tastes and odours (25%). Consumers come to the Inspectorate for help when these problems are persistent, when the investigation undertaken by the company has been protracted or inconclusive, and when the water company has not adequately explained the cause or the remedy.
Sometimes it is the company or Water Voice, the agency that is responsible for overseeing water company complaints handling, that refer the consumer to the Inspectorate.
I am not convinced that water companies’ arrangements for handling drinking water quality complaints are as good as they should be. I have observed a lack of accuracy in the information given to some consumers. In other instances consumers have been given explanations of their complaint that are frankly bizarre! The application of scientific resource to investigating these complaints is not good either. It is frequently late or nonexistent. Other times the opposite happens and too much store and energy is put into taking tests that add no value, leaving the consumer utterly confused, if not alarmed. Water Voice also finds these situations perplexing and needs to rely on technical advice from the Inspectorate in order to bring complex water quality complaints to closure in a fair way.
It is against this background that the Inspectorate is requiring water companies, under the new drinking water quality regulatory framework, to provide it with details of all consumer complaints about drinking water quality from 2005 onwards. Additionally the Inspectorate has asked companies for details of its proactive drinking water quality customer information services. These data should enable a more complete picture to be built up and shared and it will identify good practice and hopefully reverse the rising trend in persistent complaints.
I would like to conclude my statement by illustrating how easily and unintentionally a water company can erode consumer confidence in drinking water quality. In 2003 an unprecedented number (27) of consumers from one community complained directly to the Inspectorate. The cause lay with an operational change in the source of the water supplied to the community. The water company had not felt the need to inform its customers fully of the reasons behind the planned change. Customers discerned the change because there was a difference in the natural hardness characteristics between the new and the original source. When faced with many unanticipated calls, the company’s staff told consumers that it was ‘not their doing – it was the regulator’s decision’. The Drinking Water Inspectorate was named in correspondence sent out to customers. Not surprisingly there was soon an active consumer campaign for the supply to be changed back; others perceived that the company had made the change to cut costs, and a few feared their health had been put at risk by drinking the original source for years! The local media were engaged and public meetings ensued. To give credit where it is due the company subsequently gave customers a full and accurate explanation of the reasons for the change. Most consumers then understood how they would benefit from receiving a more sustainable water supply that also provided a costeffective means of meeting the new drinking water standards. And turning to the message in this tale, I leave you with the question ‘was this an avoidable drinking water quality incident?’
