Drinking Water Inspectorate: Information Letter 13/2000 - 5 June 2000
WATER SUPPLY (WATER QUALITY) (AMENDMENT) REGULATIONS 1999: NOTIFICATION OF ANOMALIES IN SAMPLING AND ANALYSIS FOR CRYPTOSPORIDIUM AND ASSOCIATED MATTERS
Purpose
1. The purpose of this letter is to clarify notification and reporting relating to regulatory Cryptosporidium monitoring requirements.
Introduction
2. Water companies began continuous sampling and daily analysis (monitoring) for Cryptosporidium at some of the sites assessed as at significant risk under the Water Supply (Water Quality) (Amendment) Regulations 1999 (the Regulations) from 1 April 2000. The arrangements for water companies to report to the Inspectorate the results obtained were set out in Information Letters 10/1999, 4/2000 and 10/2000. These remain unchanged.
3. Regulation 23B requires that all samples for regulatory Cryptosporidium monitoring are taken and transported in an approved manner using approved equipment and that they are analysed in an approved laboratory using approved equipment and approved analytical systems and methods. The Drinking Water Inspectorate's "Standard Operating Protocol for the Monitoring of Cryptosporidium Oocysts in Treated Water Supplies to Satisfy Water Supply (Water Quality) (Amendment) Regulations 1999, SI No. 1524, Part1- Sampling and Transportation of Samples and Part 2 - Laboratory and Analytical Procedures", as revised (the Protocol) specifies in detail the approved sampling, transportation and analysis requirements.
4. This letter details those deviations from the protocol and other contraventions of the Regulations that require notification to the Inspectorate. Also included are details of the information required when notifying and in the follow up report, the timescale in which the matter should be notified and reported, the person to whom it should be notified and reported and the means to be used.
Notification and Reporting
5. A list of matters that water companies should report to the Inspectorate is attached at Annex A. Included are the timescale for notification and fuller reporting and an indication of the person most likely to identify the anomaly. The timescale for notification starts once the anomaly has been identified. Water companies should ensure that they have robust arrangements in place to ensure that the nominated person in the company (or a nominated deputy) is informed of all the relevant details without delay. Approved Cryptosporidium Analytical Laboratories will be expected to cooperate and participate fully in any investigation.
6. The notification requirements and arrangements for results contravening the treatment standard remain as given in Information Letter 10/2000, but are included at Annex A for completeness. All other telephoned notifications should be made initially to the company's Inspection and Enforcement Inspector. If this is not possible within the specified timescale the cascade system in the DETR Emergency Directory should be used. All written, faxed or E-mailed notifications should be sent to the company's Inspection and Enforcement Inspector, and copied to the Document Controller, other than those made with the monthly summary of Cryptosporidium results which should be sent to the Document Controller.
7. Any matters not included at Annex A that the company considers should be reported should, unless informed otherwise by the Inspectorate, be regarded as priority 3 as classified in Annex A.
Information to be included with Notifications of Anomalies
8. All notifications of results contravening the treatment standard should be made in accordance with the requirements of the Water Undertakers (Information) Direction 1998 (the Direction).
9. All other notifications of anomalies or other notifiable matters (including initial telephone notification) should include the following matters:
(i) The name of the water company;
(ii) The name and reference number of the sampling site;
(iii) If related to sampling, the name of the sampler;
(iv) If related to analysis, the names of the laboratory and analyst(s);
(v) Details of the anomaly or other matter;
(vi) Name of the person identifying the anomaly or other matter;
(vii) Date and time the anomaly or other matter was identified; and
(viii) The name of the person notifying.
A proforma notification form is given at Annex B. An electronic version is available in Word97.
Information to be included in Reports of Anomalies
10. All reports associated with notifications of results contravening the treatment standard should be made in accordance with the requirements of the Direction.
11. All anomalies or other matters notified (other than notifications of results contravening the treatment standard) should, unless advised otherwise by the Inspectorate, be followed up by a full report within the specified timescale. All such reports should follow a full investigation of the circumstances in which the anomaly arose, the nature of the anomaly and the cause of the anomaly. The investigation should also identify any action required to prevent a recurrence. Consideration should be given to the possibility of the matter arising at other sites. In addition to the information included in the notification reports should include the following matters:
(ix) Details of the investigation undertaken
(x) The findings of the investigation, including:
(a) the full circumstances giving rise to the anomaly;
(b) the nature and cause of the anomaly;
(c) any remedial action identified to prevent a recurrence; and
(d) the names positions of the investigating and reporting persons;
(xi) copies of the relevant training records of any person implicated in the cause of the anomaly; and
(xii) the date on which corrective action has been or will be taken.
A proforma report is given at Annex C. An electronic version is available in Word97.
Recording of Instantaneous Flow
12. A number of notifications have been made where the volume filtered cannot be measured either because the water meter reading was incorrectly recorded or the water meter has failed to operate correctly. In order for water companies to be confident that a satisfactory sample has been taken, the sampler should note the instantaneous flow recorded by the flow meter at the end of the sampling run. This value should then be recorded in the comments box on the evidence bag. For the purposes of obtaining a result, the volume filtered can then be estimated from the hours run and the average flow obtained for that site under similar conditions.
13. I would be grateful if you would ensure that copies of this letter and the Annexes are given to each nominated person (including nominated deputies) responsible for reporting results and other matters relating to regulatory Cryptosporidium monitoring.
Enquiries about this letter
14. If you have any queries on this letter please do not hesitate to contact Malcolm Morgan, Inspector, Zone 2/E3 (020 7944 5987) or Mark Smith, Inspector, Zone 2/A1 (020 7944 5958).
15. Copies of this letter are being sent to Pamela Taylor, Chief Executive, Water UK; Bob Dinwiddy, Water Supply and Regulation Division, Department of the Environment, Transport and the Regions; Bob Macey, Environment Division, The National Assembly for Wales; Tim Hooton, Water Services Unit, Scottish Executive; Randal Scott, Drinking Water Inspectorate for Northern Ireland; Rowena Tye, Office of Water Services and all approved Cryptosporidium Analytical Laboratories.
16. Please acknowledge receipt of this letter using the enclosed slip and envelope.
Yours faithfully
M J Rouse
Chief Inspector
DWI INFORMATION LETTER 13/2000 ANNEX A
Anomolies and Other Matters to be Notified
Priority of Notification
Each of the notifiable matters listed in this Annex has been prioritised in respect of the urgency with which they need to be notified and reported to the Drinking Water Inspectorate. The timescale for notification commences when the matter first comes to the attention of either the water company or its Cryptosporidium Analytical Laboratory. To aid water companies in setting up robust procedures for rapid internal notification to the water company's nominated person (or a nominated deputy), an indication of the most likely persons to identify each anomaly or other notifiable matter is included. It is the responsibility of the water company's nominated person (or a nominated deputy) to notify the Drinking Water Inspectorate within the specified timescale and to ensure that the Drinking Water Inspectorate receives a full report no later than the due date.
Priority Timescale 1 Immediate by phone, using cascade system if necessary. Fax or Email within one working day. Reports within water quality event timescale given in the Water Undertakers (Information) Direction 1998. 2 By phone within 24 hours. Fax or Email within one working day. Report within seven days. 3 By phone within 24 hours or next working day. Fax or Email within one working day. Report within seven days. 4 With monthly data return, to include report. 5 With monthly data return. No report required. Anomalies to be reported
Notification Code Anomaly Persons Most Likely to Identify Notification priority 01 Preliminary or confirmed result above regulatory limit Laboratory Staff 1 02 No sample taken, sample lost or sample damaged Sampler or Laboratory Staff 1 03 Sample container transit bag not sealed or evidence of tampering Sampler 2 04 Open Evidence Bag, evidence of tampering with Evidence Bag on receipt at laboratory or sample not in an Evidence Bag Laboratory Staff 2 05 Unauthorised breaking or removal of tags, seals or painted joints, or evidence of tampering with tags and seals on sampling cabinets and lines (excluding white tags replaced with blue ones) Sampler 2 06 Incorrect number tag or seal fitted in or to sampling cabinet or sampling line (excluding white tags replaced with blue ones) Sampler 2 07 Sample cabinet found unlocked or otherwise in an insecure condition Sampler 2 08 Gap in Chain of Custody at any stage (including during analysis) Sampler or Laboratory Staff 2 09 Modifications to sampling line upstream of filter holder Maintenance or Operations Staff 2 10 Volume filtered less than 40 litres per hour over sampling period Laboratory Staff 2 11 Damage to sampling equipment rendering it inoperable Sampler, or Maintenance or Operations Staff 2 12 Emergency repairs to sampling equipment (not otherwise notified) Maintenance or Operations Staff 3 13 Telemetry failure (disabled alarms) Sampler or Control Room 3 14 Sampling equipment failures (no alarm) Sampler or Control Room 3 15 No flow alarm Sampler or Control Room 3 16 Low flow alarm Sampler or Control Room 3 17 Total power failure Control Room 3 18 One hour sample changeover period exceeded Sampler 3 19 Deviations from approved sampling or analysis procedures not covered elsewhere Sampler or Laboratory Staff 3 20 Key to sampling cabinet or key safe lost or stored insecurely Sampler 3 21 Insecure green tag Sampler or Laboratory Staff 3 22 Broken green tag Sampler or Laboratory Staff 3 23 Incorrect number on green tag Sampler or Laboratory Staff 3 24 Sampling information missing from Evidence Bag or meaningless item of key information entered on Evidence Bag Sampler or Laboratory Staff 3 25 Any notifiable matter not included in this list 3 26 Modifications to sampling line or equipment downstream of sample holder Maintenance or Operations Staff 4 27 Minor errors or inconsistencies in recording information on Evidence Bag (ie correct information can be reliably established) Sampler or Laboratory Staff 4 28 Discrepancies in housing numbers Sampler or Laboratory Staff 4 29 Errors in sampling records Sampler or Laboratory Staff 4 30 Replacement of blue tags with white tags (or subsequent replacement of those white tags with other white tags) (excluding situations where white tags are standard) Sampler or Maintenance or Operations Staff 4 (include details of all changed tag numbers and locations with report) 31 Replacement of DWI seals with laboratory seals (or subsequent replacement of those laboratory seals with other laboratory seals) Sampler or Maintenance or Operations Staff 4 (include details of all changed seal numbers and locations with report) 32 Routine maintenance of sampling equipment Maintenance or Operations Staff 4 33 Sample collection device changed early because of high headloss Sampler 5 34 Sample collection device removed with less than 200 litres filtered Sampler or Laboratory Staff 5 (include reason with notification) 35 Sample collection device marked for "Express Analysis" Sampler 5 (include reason with notification)
DWI INFORMATION LETTER 13/2000
ANNEX B
Proforma Anomaly Notification Form
Water Supply (Water Quality) (Amendment) Regulations 1999
Notification of Anomalies and Other Notifiable Matters
(i) Water Company
(ii)(a) Sampling Site Reference Number
(ii)(b) Sampling Site Name
(iii) Name of sampler
(iv)(a) Name of analysing laboratory
(iv)(b) Name(s) of analyst(s)
(v) Details of matter notified
(vi) Name of the person identifying the matter
(vii) Date and time the matter was identified
(viii) Name of the person notifying
Date and Time Notified
Signature
For DWI use only
DWI Notification Reference Number
Notification Code
Notification Classification
Entered on database by
Date
DWI INFORMATION LETTER 13/2000
ANNEX C
Proforma Anomaly Report
Water Supply (Water Quality) (Amendment) Regulations 1999
Water Company/Analytical Laboratory Report of Investigation into a Notified Matter
A. Notification Details
(i) Water Company
(ii)(a) Sampling Site Reference Number
(ii)(b) Sampling Site Name
(ii) Name of sampler
(iv)(a) Name of analysing laboratory
(iv)(b) Name(s) of analyst(s)
(v) Details of matter notified
(vi) Name of the person identifying the matter
(vii) Date and time the matter was identified
(viii) Name of the person notifying
Water Supply (Water Quality) (Amendment) Regulations 1999
Water Company/Analytical Laboratory Report of Investigation into a Notified Matter
B. Report of Investigation
(xiii) Details of the investigation undertaken
(xiv) The findings of the investigation
(a) The full circumstances giving rise to the anomaly;
(b) The nature and cause of the anomaly;
(c) Remedial action identified to prevent a recurrence
Investigation undertaken by:
Name
Position
Signature
Date
Report prepared by:
Name
Position
Signature
Date
(xv) Copy(ies) of training records attached for:
(xvi) Date of or for completion of all corrective action identified in (xiv)(c) above.
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Drinking Water Inspectorate,
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Telephone : 020 7944 5956 - Facsimile : 020 7944 5969
E-mail: dwi_enquiries@detr.gov.uk
Updated 11 July 2001
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