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DWI Information Letter 28/2000

24 November 2000

To: Board Level Contacts of Water and Sewerage Companies and Water Companies in England and Wales

Dear Sir/Madam

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 advise companies of the revised notification and reporting arrangements relating to regulatory Cryptosporidium monitoring requirements. This letter replaces DWI Information Letter 13/2000.

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. DWI Information Letter 13/2000 detailed those deviations from the protocol, other contraventions of the Regulations, and other matters that require notification to the Inspectorate. Also included were 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. This letter provides further information on matters that require notification and the information that is required. It also revises the timescale for notification.
5. An anomaly is any event, action or other occurrence that either contravenes the requirements of regulation 23B (including contraventions of the Protocol) or affects the approved status of either a sampling point or a Cryptosporidium Analytical Laboratory.

Notification and Reporting

6. 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 co-operate and participate fully in any investigation.
7. 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.
8. 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.
9. Also included are notification requirements for matters that are not in themselves contraventions of the Protocol or the Regulations (anomalies), but abnormal occurrences which affect how the Protocol or the Regulations apply, eg the timescale for completion of analysis.

Information to be included with Notifications of Anomalies

10. 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).
11. Telephone notifications of other anomalies (priority 1 and 2 notifications) should include the following information:
1. Name of person notifying;
2. Date and time anomaly was identified;
3. Name of company;
4. Name of laboratory (if relevant to either cause or identification of the anomaly);
5. Name of site;
6. Provisional notification code
7. A brief description of the anomaly
12. All telephone notifications should be followed up in writing using the Annex B form, and must include at least the following:

1. The name of the water company;
2. The name and reference number of the sampling site (as recorded on the record of inspection);
3. If related to sampling, the name of the sampler;
4. If related to analysis, the names of the laboratory and analyst(s) (name of laboratory also required if anomaly was identified by the laboratory);
5. Details of the anomaly or other matter;
6. Name of the person identifying the anomaly or other matter;

An electronic version of the form is available in Word97, to facilitate communication by Email.

Information to be included in Reports of Anomalies

13. All reports associated with notifications of results contravening the treatment standard should be made in accordance with the requirements of the Direction.
14. All anomalies (other than results contravening the treatment standard) should, unless advised otherwise by the Inspectorate, be reported in full using the Annex C 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. The investigation of anomalies arising solely from routine maintenance may not be necessary, in which case "None" may be entered in the relevant investigation items. Consideration should be given in the investigation to the possibility of the matter arising at other sites. In addition to the information to be included in the notification (Annex B), reports must include the following matters:

1. Details of the investigation undertaken
2. The findings of the investigation, including:

1. the full circumstances giving rise to the anomaly;
2. the nature and cause of the anomaly;
3. any remedial action identified to prevent a recurrence; and
4. the names positions of the investigating and reporting persons;

3. copies of the relevant training records of any person implicated in the cause of the anomaly; and the date on which corrective action has been or will be taken.

An electronic version is available in Word97, to facilitate communication by Email.

Recording of Instantaneous Flow

15. A number of notifications have been made where the volume filtered cannot be measured either because the water meter reading was incorrectly recorded or because 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 box provided on the evidence bag (use the comments box on old style bags). 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.
16. 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

17. If you have any queries on this letter please do not hesitate to contact one of the Inspectors listed in Annex D.
18. Copies of this letter are being sent to Pamela Taylor, Chief Executive, Water UK; Rodney Anderson, 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.
19. Please acknowledge receipt of this letter using the enclosed slip and envelope.

 

Yours faithfully

 

Michael Rouse

Chief Inspector

Drinking Water Inspectorate

 

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DWI INFORMATION LETTER 28/2000

ANNEX A

Priority	Timescale
1	Immediate by phone, using cascade system if necessary. See comments for further reporting requirements.
2	By phone before end of next working day. Fax or Email of completed Annex B within one working day of telephone notification. Annex C report within seven days of telephone notification. NOTE: If Annex C sent within one working day, Annex B is not required.
3	With monthly data return, to include full Annex C report. Telephone notification and Annex B not required.
4	With monthly data return. No report required (Annex C).* THESE ARE NOT ANOMALIES, but abnormal occurrences which have regulatory implications.

*Details of priority 4 occurrences may be reported as individual reports, a single consolidated report or as commentary against the relevant sample in the monthly Cryptosporidiumdata returns, provided all the required information is included for each item.

 

Telephone notification (if required)

Telephone notifications should always be made directly to an Inspector, using the cascade system if necessary. Voice mail or E-mail messages will not be regarded as initial notification.

The information requirements for breaches of the standard are given in the Water Undertakers (Information) Direction 1998.

For all other telephone notifications (ie priority 1 and 2 notifications only) the following information is required at the time of notification:

1. name of person making the notification;
2. date and time the anomaly was first identified;
3. name of the company;
4. name of the laboratory (if implicated in the cause or identified the anomaly);
5. name of the sampling site (must be name on record of inspection);
6. provisional notification code;
7. brief description of anomaly;
8. any other relevant information;

Annex B notification (if required)

Annex B notification is required for all telephoned notifications, except Code 01, unless advised otherwise by the Inspectorate.

Items (i), (ii)(a), (ii)(b), (v), (vi), (vii) and (viii) and (ix) must always be completed.

The name of the laboratory need only be provided if it either caused or identified the anomaly. Only relevant names are needed as indicated in the comments column.

Annex C Report (for all anomalies ie priority 1,2 and 3 notifications)

Annex C Part A must be completed as for Annex B.

Annex C Part B items (i), (ii)(a), (ii)(b), (ii)(c) as well as details of the investigator and preparer of the report must always be completed.

If remedial action has been identified in (ii)(c), item (iv) must be completed.

If any tags or seals have been broken/replaced or painted joints broken or adjusted, full details must always be included in the Annex C report.

The name of the laboratory need only be provided if it either caused or identified the anomaly. Only relevant names and training records are needed as indicated. If a training record has already been provided in respect of a different anomaly, it need not be sent again but may be referenced to the earlier anomaly. A copy of the training record will be required if it has been updated since it was last sent.

Continuation sheets may be used as required.

Annex B is not required for priority 3 notifications, but Annex C Part A is required. Annex B is also not required if the Annex C report is sent within the Annex B notification timescale.

If there are more than one code 30, 31 or 32 anomalies to report at the end of the month, a combined report may be submitted (one report for each code), provided all the relevant information is included for each anomaly.

The signed copies of Annexes B and C need not be sent, but should be retained in case they are needed. Electronic signatures conforming to Section 7 of the Electronic Communications Act 2000 may be used.

Further information and copies of records may be requested. If the company’s investigation cannot be completed within the required timescale, an extension may be sought by application in writing to the Company’s Inspection and Enforcement Inspector. The application should include details of the investigation being undertaken, date for completion of the investigation, and why the investigation cannot be completed sooner. Further extensions may be granted on application in exceptional circumstances.

Anomalies to be reported

Notification Code	Anomaly	Persons Most Likely to Identify	Comment	Notification priority
01	Preliminary or confirmed result above regulatory limit	Laboratory Staff	Will be handled as a water quality event. Reports within water quality event timescale given in the Water Undertakers (Information) Direction 1998. This is instead of the requirements for anomaly notification.	1
02	No sample taken, sample lost or sample damaged. Include failure to sample for only part of the sampling period, and inability to obtain a valid result of analysis.	Sampler or Laboratory Staff	Relevant training record of any staff implicated required. Annexes B and C required within priority 2 timescale, unless regarded as a water quality event, when reports will be required as for Notification Code 01. Companies will be advised by the Inspectorate of any anomalies that are subsequently classified as incidents.1	1
03	Sample container transit bag not sealed or evidence of tampering	Sampler	Relevant training record of any staff implicated required.	2
04	Open Evidence Bag, evidence of tampering with Evidence Bag on receipt at laboratory or sample not in an Evidence Bag. Also evidence of tampering with sample during analysis.	Laboratory Staff	Including evidence of tampering during analysis. Relevant training record of any staff implicated required.2	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	Sampler	Excluding white tags replaced with blue ones. Relevant training records of any staff implicated required.	2
06	Incorrect number tag or seal fitted in or to sampling cabinet or sampling line (including number recording errors)	Sampler	Excluding white tags replaced with blue ones. Relevant training records of any staff implicated required	2
07	Sample cabinet found unlocked or otherwise in an insecure condition (including loosely fitted white tag on cabinet door)	Sampler	Relevant training records of any staff implicated required	2
08	Gap in Chain of Custody at any stage not covered above (including during analysis)	Sampler or Laboratory Staff	eg missing signature, failure to seal or lock away filter unit while unattended. Relevant training records of any staff implicated required	2
09	Modifications to sampling line upstream of filter holder, not previously authorised in writing by DWI (site specific or generic).	Maintenance or Operations Staff	Report authorised modifications as routine maintenance or emergency repairs as appropriate.	2
11	Damage to sampling equipment rendering it inoperable	Sampler, or Maintenance or Operations Staff	Relevant training record of any staff implicated required	2
17	Total power failure resulting in cessation of sampling while works continues to produce water	Control Room		2
18	One hour sample changeover period exceeded	Sampler or Maintenance Staff.	Reason for time exceedance required. Name of sampler and/or maintenance officer required. Relevant training record of any staff implicated may be required	2
20	Key to sampling cabinet or key safe lost or stored insecurely	Sampler	Relevant training record of any staff implicated required	2
10	Volume filtered less than 40 litres per hour over sampling period	Laboratory Staff	This code must not be used for recording errors resulting in apparent low volume.3	3
12	Emergency4 repairs to sampling equipment (not otherwise notified)	Maintenance or Operations Staff	Details of repair required.	3
13	Telemetry failure	Sampler or Control Room	Failures not resulting in failure of sampling. Include the disabling of any alarms. Use code 02 for failure of sampling.	3
14	Sampling equipment failures	Sampler or Control Room	Not resulting in failure of sampling. Including any failures not associated with an alarm condition. Use code 02 for failure of sampling.	3
15	No flow alarm	Sampler or Control Room	Not resulting in failure of sampling. Use code 02 for failure of sampling.	3
16	Low flow alarm	Sampler or Control Room	Not resulting in failure of sampling. Use code 02 for failure of sampling.	3
19	Deviations from approved sampling or analysis procedures not covered elsewhere	Sampler or Laboratory Staff	Details of the deviation required. Relevant training record of any staff implicated required. Use code 02 if no valid result of analysis is obtained.	3
21	Insecure green tag	Sampler or Laboratory Staff	Names of analyst/couriers and sampler required. Relevant training record of any staff implicated may be required	3
22	Broken green tag	Sampler or Laboratory Staff	Names of analyst/couriers and sampler required. Relevant training record of any staff implicated may be required	3
23	Incorrect number on green tag	Sampler or Laboratory Staff	Name of analyst required. Relevant training record of any staff implicated may be required	3
24	Sampling information missing from Evidence Bag or meaningless item of key information entered on Evidence Bag	Sampler or Laboratory Staff	Name of sampler/analyst implicated required. Relevant training record of any staff implicated may be required. Gaps or potential gaps in chain of custody must be reported as Priority 2.2	3
25	Any notifiable matter not included in this list.		Name of any person implicated required. Relevant training record of any staff implicated may be required. Include minor damage to evidence bags where this occurs on more than one occasion during the month for any individual sampling point.	3
26	Modifications to sampling line or equipment downstream of sample holder, not previously authorised in writing by DWI (site specific or generic).	Maintenance or Operations Staff	If authorised report as routine maintenance or emergency repairs as appropriate.	3
27	Minor errors or inconsistencies in recording information on Evidence Bag	Sampler or Laboratory Staff	To be used only when a traceable, contemporaneous record of the true record exists elsewhere, eg in site log book completed at the time the filter unit was changed. Name of sampler/analyst implicated required. Relevant training record of any staff implicated may be required. Gaps or potential gaps in the chain of custody must be reported as Priority 2.6	3
28	Discrepancies in housing numbers	Sampler or Laboratory Staff	Including wrong unit used. Name of analyst required. Relevant training record of any staff implicated may be required	3
29	Errors in sampling records not otherwise notified (ie any not covered by any other code)	Sampler or Laboratory Staff	Name of sampler required. Relevant training record of any staff implicated may be required	3
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	Must include full details of all removed and new tag numbers and their locations of use with report, including reason for removal/fitting.8	3
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	Include full details of all removed and new seal numbers and their locations of use with report including reason for removal/fitting.	3
32	Routine maintenance of sampling equipment not otherwise notified	Maintenance or Operations Staff	Include information on breaking of painted joints.	3
33	Sample collection device changed early	Sampler	eg because of high headloss. Include reason for change with notification. Indicate whether marked for express analysis.	4
34	Sample collection device removed with less than 200 litres filtered	Sampler or Laboratory Staff	Include reason for change with notification. Indicate whether marked for express analysis.	4
35	Sample collection device marked for "Express Analysis"	Sampler	Include reason with notification.	4

 

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¹ Including failure to sample for part of the sampling period for any reason (provided the works was putting water into supply at the time)

² Minor damage as a result of mishandling in transit should not be reported under this category, unless there is any reason to suspect that tampering may have occurred. Use code 25 for repeated minor damage.

³ Use codes 24 or 27 as appropriate for recording errors.

⁴ Emergency means anything that is not carried out as part of a prescheduled routine preventative maintenance programme or prescheduled upgrading/replacement of equipment ie carried out as an immediate response to breakdown or other failure or deficiency.

⁵ Use code 08 (or other priority 2 code if more appropriate)

⁶ Use code 08 for gaps or potential gaps in the chain of custody (or other priority 2 code if more appropriate). Use code 24 if no contemporaneous record exists.

⁷ Do not notify the replacement of blue tags fitted where white tags are normal

⁸ Seals should be replaced immediately following routine maintenance and as soon as possible following emergency repairs.

 

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DWI INFORMATION LETTER 28/2000

ANNEX B

Proforma Anomaly Notification Form

Water Supply (Water Quality) (Amendment) Regulations 1999

Notification of Anomalies and Other Notifiable Matters

1. Water Company

2. (a) Sampling Site Reference Number

2. (b) Sampling Site Name

3. Name of sampler

4. (a) Name of analysing laboratory

4. (b) Name(s) of analyst(s)

5. Details of matter notified
    
    
    
    
    

6. Name of the person identifying the matter

7. Date and time the matter was identified

8. Name of the person notifying

9. (ix) Date and Time Notified, and name of person notified

 

Signature

___________________________________________________________________________

For DWI use only

DWI Notification Reference Number

Notification Code

Notification Classification

Entered on database by

Date

 

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DWI INFORMATION LETTER 28/2000

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

1. Water Company

2. (a) Sampling Site Reference Number

2. (b) Sampling Site Name

3. Name of sampler

4. (a) Name of analysing laboratory

4. (b) Name(s) of analyst(s)

5. Details of matter notified
    
    
    
    
    

6. Name of the person identifying the matter

7. Date and time the matter was identified

8. Name of the person notifying

9. (ix) Date and Time Notified, and name of person notified

 

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Water Supply (Water Quality) (Amendment) Regulations 1999

Water Company/Analytical Laboratory Report of Investigation into a Notified Matter

B. Report of Investigation

1. Details of the investigation undertaken
   
   
   
   
   
   
   

2. The findings of the investigation

1. The full circumstances giving rise to the anomaly;
   
   
2. The nature and cause of the anomaly;
   
   
3. Remedial action identified to prevent a recurrence

 

Investigation undertaken by:	Name Position Signature	Date
Report prepared by:	Name Position Signature	Date

3. Copy(ies) of training records attached for:

 

Date of or for completion of all corrective action identified in (ii)(c) above.

 

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DWI INFORMATION LETTER 28/2000

ANNEX D

Inspection and Enforcement Inspectors

Company	Inspector	Telephone	Fax	Email	Mobile	Home
Albion	A Hallas	020 7944 5983	020 7944 5969	Tony_Hallas@detr.gov.uk		01869 246948
Bristol
Cambridge
Cholderton
Dee Valley
Dwr Cymru
Mid Kent
Portsmouth
South West
Wessex
Folkestone and Dover	M Morgan	020 7944 5987	020 7944 5969	Malcolm_Morgan@detr.gov.uk	0776 974 2269	01795 425079
North Surrey
North West
South East
Sutton and East Surrey
Tendring Hundred
Three Valleys
Yorkshire
Anglian	K White	020 7944 5992	020 7944 5969	Kevin_White@detr.gov.uk		01689 832520
Bournemouth and West Hants
Essex and Suffolk
Hartlepool
Northumbrian
Severn Trent
South Staffs
Southern
Thames

DWI Document Controller Email: dwidoc_controller@detr.gov.uk

Fax : 020 7944 5969

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Drinking Water Inspectorate,
Floor 2/A1, Ashdown House, 123 Victoria Street, London, SW1E 6DE
Telephone : 020 7944 5956 - Facsimile : 020 7944 5969
E-mail: dwi_enquiries@detr.gov.uk

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Published 24 November 2000 Updated 11 July 2001

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