Information Letter

6 January 2006

Information Letter 1/2006

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

Dear Sir/Madam

Annual Provision of Information on Consumer Contacts

1. Purpose
   

   The purpose of this letter is to provide companies with updated guidance on the provision of information to the Inspectorate in respect of sections 9 and 10 of the Water Undertakers (Information) Direction 2004 which deal with the reporting of consumer information about drinking water quality.
   

2. Background
   

   Summary consumer contact information was published for the first time in July 2005 in the Chief Inspector’s Annual Report: Drinking Water 2004. In the report the Inspectorate stated its intention to work with the water industry to clarify the reporting criteria and process. Representatives of companies and Ofwat participated in a workshop facilitated by Water UK and the Inspectorate in November 2005. This workshop explored in detail the potential barriers to consistent reporting of consumer information. The Inspectorate undertook to update its original guidance (given in Information Letter 02/2004) drawing on the outputs of the workshop.

3. Definitions
   

   This section sets out definitions to be used by companies in making their returns. These definitions are hierarchical: first a consumer contact about drinking water quality is defined (3.1) followed by definitions for 5 categories (subsets) of consumer contact (3.1.1 through to 3.1.5). More detailed guidance (with examples) on the application of these definitions follows in section 4. A pragmatic approach has been taken in developing the guidance so it reflects the broad range of consumer contacts received and recorded across the industry. It is recognised that some companies may receive few, if any, contacts in some of the categories.
   

   3.1 A consumer contact about drinking water quality is any communication about drinking water quality initiated by a consumer living or working in the area supplied by the water company including phone, letter, fax, email, in person, website request form and message left on a helpline. There are five categories of consumer contact that should be recorded and these are defined as follows:

   3.1.1  A consumer enquiry about drinking water quality is a contact made solely with the intent of eliciting information from the company about drinking water quality, in the absence of any expression of concern, dissatisfaction or service shortfall.

   3.1.2  A consumer contact about the appearance of drinking water is a contact where the consumer perceives something different about the appearance of the water from the “norm”.

   3.1.3 A consumer contact about the taste and odour of drinking water is a contact where the consumer perceives that the water has a taste or smell.

   3.1.4  A consumer contact about illness is a contact where the consumer attributes specific symptoms of illness to the water, including reports of illness amongst family members of the household, within their workplace or at another location such as a school.

   3.1.5 A consumer contact about a water quality concern is a contact where the consumer expresses a concern about drinking water other than its appearance, taste or smell and they are not attributing symptoms of a current illness to the water.

4. Applying the definitions
   

   This section provides guidance to help company staff with assessing and recording consumer contacts about drinking water quality.

   4.1  General principles

   Not every consumer contact will be a “customer complaint”. The definition of a consumer contact is wider and aimed at gaining an understanding of the public perceptions of drinking water quality. There is not a need to establish “dissatisfaction” or a “shortfall in the level of service” as a feature of a consumer contact for it to be recorded in the dataset. Some consumers may refer to more than one matter during a single contact; for example, a consumer may wish to query their bill at the same time as commenting on their drinking water quality. Companies should strive to ensure that these “multiple contacts” which deal in part with drinking water quality are recorded as a consumer contact about drinking water quality. If a consumer contacts the company on more than one occasion about the same aspect of their drinking water quality this should only be recorded as a single contact if the second, or subsequent contacts, are progress seeking in nature e.g. asking for results of testing. It is particularly important that the company does not judge for itself but establishes from the consumer whether any second or subsequent contact is perceived to be a new event or a continuation of the former one. Where this remains unclear each contact should be separately recorded in the dataset.

   4.2  Applying the definition of a consumer enquiry about drinking water quality

   A contact should only be recorded as an enquiry if the sole nature of the contact is seeking information from the company. If there are other elements to the contact then these should take precedence in deciding how to classify the contact, for example “my water tastes of chlorine, can you tell me the amount in my water” would be classified as a consumer contact about the taste and odour of drinking water whereas “can you tell me how much chlorine is in my water” would be classified as an enquiry. If the request for information by the consumer is clearly driven by worry or anxiety for the wellbeing of themselves or members of their household then the contact should be recorded as a consumer contact about a water quality concern (see section 4.6).

   Companies should record enquiries using the four categories below:
   - request for information about the fluoride level
   - request for information on water hardness, typically for the purpose of operating a domestic appliance
   - request for a water quality report (schedule 4)
   - request for other information, typically but not exclusively these will be asking about some aspect of how the water is treated or the source it comes from, alternatively they may be asking about drinking water quality standards or how drinking water quality is regulated. Only classify an enquiry in this category if it requires an answer to be specially prepared by the company’s water quality scientist, do not record enquiries that are so routine that they are answered by sending out a standard leaflet or fact sheet or an education pack for schools.

   Note 1: the emboldened words are the sub category names for reporting the data.
   Note 2: leaflets, fact sheets, education packs, website Q & A’s are covered below in Section 7.

   4.3  Applying the definition of a consumer contact about the appearance of drinking water

   A contact should be recorded in this category only when it is clear that the consumer’s concern about their drinking water quality is clearly based on an observation (or a perception) that its appearance is other than “normal”.

   Companies should record these contacts using the categories below:
   Discoloured water - brown/black/orange the colour of the water is the focus of the contact even though this may be understood by the company to be accompanied by mains deposits suspended in the water (also include here staining of laundry due to discoloured water and concerns arising from problems with tanks and boilers due to mains deposits after a burst).
   Discoloured water - blue/green the colour of the water is the focus of the contact (do not include here if the colour is only mentioned as being present on deposits adherent to a tap, bath or shower tiles/tray - these should be recorded in the General Conditions category, see below).
   Particles - the focus is reported as visible particles, either floating in the water or settled out in the bottom of a glass or jug (the water would be reported as clear).
   White - air the contact refers to white or milky looking water and the glass test confirms that the cloudiness clears from the bottom up leaving no sediment.
   White - chalk the contact refers to white or milky looking water and the glass test confirms that the cloudiness clears from the top down leaving white sediment on the bottom.
   Animalcules the contact refers to seeing a creature, living or dead, typically these will be either chironomid larvae or Ascellus but include here any contact where a specimen is subsequently provided and identified by the company’s water quality scientist as an aquatic animal. (Exclude contacts about slimes adhering to a tap or water fitting - these should be recorded in the General Conditions category, see below).
   General conditions the contact relates to the appearance of a deposit or slime or colour that is present on the outside of a tap or water fitting, included here are contacts about hardness deposits in kettles, staining of the sink, bath, shower cubicle, tiles etc. This category of contact deals with common consumer concerns where the water itself appears normal (it is clear and bright in appearance and free from taste and odour) and the phenomenon is arising within the household environment. A typical cause being inadequate ventilation combined with the use of aerosol dispensed household or personal products. This category should also be used for contacts relating to the quality of water in hot water systems or heating/cooling systems and humidifiers.
   

   4.4  A consumer contact about the taste and odour of drinking water

   A contact should be recorded in this category only when it is clear that the consumer’s concern about their drinking water quality is clearly based on an observation (or a perception) that its taste or odour is other than “normal”.

   Companies should record these contacts using the categories below:
   Chlorine the consumer states that the taste or odour is due to chlorine in the water. This category will include all chlorine related descriptions, for example, TCP taste, disinfectant/medicinal odours on boiling a kettle or taking a shower, smells like a swimming pool (exclude burning sensation in the mouth - these should be classified as illness as the description relates to a symptom not to the water).
   Earthy/Musty the consumer description of the taste or odour is such that it is clear they perceive a natural taste or odour relating to soil or vegetation (include here specific tastes known to be due to algae such as MIB or geosmin as well as general descriptions such as musty or stagnant, companies may wish to use this category for recording contacts where the investigation has shown conditions that give rise to warming of the mains water supply, long runs of pipe etc).
   Petrol/Diesel the consumer description of the taste or odour is such that they clearly perceive the presence of petroleum or hydrocarbon based substances (include here specific odours such as petrol, diesel, creosote, as well as general descriptions such as oily, solvent).
   Other taste or odour this category covers the less frequently encountered tastes and odours such as bitter, metallic, sweet, salty/saline. This category should also be used for any taste or odour not specifically mentioned in any other taste and odour category. Care should be taken in classifying contacts reporting a metallic taste because some consumers describe chlorine in the water in this manner.
   

   4.5  A consumer contact about illness

   A contact should be recorded in this category whenever the consumer reports symptoms of ill health in their household or workplace or some other location such as a school and attributes these symptoms to the water.

   Companies should record these contacts using the categories below:
   Gastroenteritis the symptoms are described as one or more of the following; sickness, diarrhoea, vomiting, nausea, bilious (or equivalent lay terms such as stomach upset).
   Oral the symptoms relate to when water is taken into the mouth (include here descriptions such as sore throat, burning sensation on tongue or when swallowing, heartburn).
   Skin the symptoms relate to a sensation (irritation, itchy) or a change in appearance (red, blotchy, dry, flaky) of the skin anywhere on the body (including the scalp and hair condition). Include here reports of results of tests on hair or patch tests for allergies where positive findings were attributed to tap water.
   Medical Opinion this category should be used when it is clear that the only reason for the contact by the consumer is advice they have been given by a doctor (or some other health professional such as a nurse, health visitor, consultant, or surgeon) along the lines of “my doctor said tap water was bad for me”. The advice may be verbal or in the form of a leaflet provided by the doctor or the health professional. Exclude from this category any contacts where consumers are reporting a confirmed diagnosis of cryptosporidiosis, these should be included in the Gastroenteritis category above. Also exclude contacts where the medical advice is indirect e.g. doctor writing in a magazine or on the internet or interviewed on TV, radio, internet (see section 4.6 for how to record these contacts).
   

   4.6  A consumer contact about a water quality concern

   A contact should be recorded in this category whenever the consumer reports a concern about their drinking water quality other than its appearance, taste or odour; they are not reporting symptoms of a current illness; and the contact is not a straightforward request for information (see section 4.2 above).

   Companies should record these contacts using the categories below:
   Pets and Other Animals the contact is a concern about the drinking water quality in relation to the wellbeing of a domestic pet or an animal, not the consumer or their family members (include here fish, reptiles and birds as well as cats, dogs, etc.). This category will also include concerns regarding drinking water for animals kept for commercial purposes such as aquaria, farms, studs, wild life parks or zoos).
   Lead and Other Analysis the contact is asking for the water to be tested, mainly this will be about the presence of lead because there are babies or young children living or visiting the house, or it is a school building but include here all contacts where the consumer’s perception (not the company view) is that “water testing” is the reassurance they require about the quality of their drinking water. Companies may wish to record lead analysis requests as a discrete subset.
   Life Style the contact may be about any aspect (parameter) of water quality but it is clear the contact was prompted by information the consumer has obtained from a newspaper or magazine article, from the internet or from a programme on the TV or the radio (this may also include references to historical water quality incidents in any part of the country or globally e.g. Camelford, the recent Chinese river and drinking water pollution incident). Contacts about the quality of bottled water as compared to tap water should be included here, as should contacts about the need to fit a water filter.
   Incident related the contact is prompted by the water company issuing boil water or similar precautionary advice and the contact is not a straightforward request for clarification e.g. do I live in the area affected? Rather it relates to a concern that is not covered by the incident Q & A fact sheet prepared for use by company staff and it requires a specific reply by the company’s water quality scientists or medical advisor.
   

   Note 3: Companies are reminded that although excluded from this category, consumer contacts received in the course of managing a notified water quality incident are required to be recorded under an incident code and reported to the Inspectorate in the company’s 3 or 20 day incident report (Information Letter 12/2004). (See section 6.2.2 and Annex).

   Campaigns the contact is responding to literature (or media reports) about a specific campaign relating to a substance or organism in drinking water (for example, contacts due to the activities of either the anti or pro fluoride lobby) or the contact is prompted by the aggressive marketing locally of devices which claim to remove “poisons” from the tap water. This category may also be used for contacts prompted due to business or regulatory Environmental Reporting, for example, if the consumer has made the incorrect assumption that drinking water is affected e.g. river pollution, endocrine disrupters in sewage works discharges, bans on chemicals etc.
   

5. Format and Timing of Returns to the Inspectorate
   

   Companies should send their annual returns to the Inspectorate in the form of a Microsoft Excel spreadsheet by 21st March each year. A template for this purpose and instructions on its use are provided in the Annex to this letter. The returns should be sent electronically to the Inspectorate’s Water Quality Data Unit at dwimonthlydata@defra.gsi.gov.uk

   It is recognised that a few companies may not be able to provide reliable 2005 information for every sub-category of consumer contact (as set out in section 4) but experience with returns for 2004 has shown that all companies will be able to provide information for the four categories (as set out in section 3). Companies should provide their nominated inspector by email with details of any deficiencies with their 2005 return and the steps being taken to ensure that the company will be able to make a complete return for 2006. This will enable the Inspectorate to acknowledge these circumstances appropriately in the relevant part of the Chief Inspector’s Annual Report: Drinking Water 2005.

6. Other Issues
   

   6.1  Customer Complaints: Companies record customer complaints (contacts expressing dissatisfaction and indicating a service shortfall) for routine business reasons. Since the early 1990’s Ofwat and WaterVoice have required companies to provide customer complaint information for the purpose of evaluating levels of service. However the Inspectorate’s requirement for information about consumer contacts about drinking water quality (section 3.1) is different. The definition of a “contact” is wider than “a complaint” and looks at the public perception of drinking water quality through measurement of drinking water quality specific communications between the company and all consumers (not just bill payers). The recording and analysis of drinking water quality contacts in the way set out in this guidance has been practiced by the water industry for many years and the first papers publishing such information date back to the turn of the 20th century (Metropolitan Water Board Annual Reports). More recently, there have been a number of substantial studies of the public perception of drinking water quality and these have all shown the valuable insights to be gained from the collection and analysis of such information. These insights could not have been attained from consumer satisfaction surveys or complaints handling process analysis nor by testing samples of water in the laboratory.

   6.2  Exclusions and Inclusions

   At the workshop in November 2005 companies identified a number of factors which they felt might lead to inconsistent reporting by companies. These points are listed below so that companies can take them into account.
   6.2.1  Consumer contact relates to water supplied by another water company (do not include these contacts in the dataset).
   6.2.2  During operational events, such as burst mains, the company may divert callers to a recorded message service as it is presumed that most of these calls are about no water or low pressure and consumers with a concern about water quality will call again and be recorded as a contact in the normal way. However this is not always the case and there have been occasions when substantial numbers of discoloured water or quality concern contacts have been diverted to a message service. Although it is understood that these contacts cannot be assigned accurately to a category the number of these incident contacts should be estimated as accurately as possible (see Annex to this letter).
   6.2.3.  Contacts may be received by companies through their websites. Many of these are from school children and college students seeking information to help them with an educational assignment - these contacts should be excluded from the dataset as many are not company specific. However if a company sets up a drinking water area of its website specifically inviting consumers to use the facility to contact the company about their drinking water quality then these should be recorded in the dataset (see section 3.1).
   6.2.4  Some companies have dedicated numbers for the public to ring and report specific matters e.g. leaks or use of hoses in a drought (these are not contacts about drinking water quality).
   6.2.5  It can be difficult to establish the nature of a contact, for example, where English is not the first language of the caller or the call is made on behalf of a consumer by somebody else. Companies are expected to take all reasonable steps to establish if a call is a contact about drinking water quality and where it is unclear to take the precautionary approach by including such contacts in the dataset.
   6.2.6 When a contact is investigated because it is also a “complaint” and the complaint is subsequently considered to be unjustified, the contact should still be retained in the dataset. However, when a company receives frequent contacts from one consumer (or household) over a long period of time (sometimes referred to as a vexatious caller) and another agency, such as Consumer Council for Water, the Local Authority or the Inspectorate, has investigated the matter and concurs with the companies’ judgement, all the contacts from the consumer can be recorded as a single contact.
   6.2.7  Contacts from representatives of consumers such as a local councillor or an MP usually relate to a water quality incident or to a consumer’s complaint and inclusion of these would duplicate information already recorded.
   6.2.8 Some contacts relate to the quality of drinking water in a public building or commercial premises and involve several different callers. These may be recorded as a single contact if they clearly relate to the same building or water system.
   6.2.9  On investigation some contacts will be found to relate to a private supply of water and not the company’s public water supply (exclude these contacts).

7. Section 10 of Information Direction

   In section 10 the Information Direction 2004 requires companies to provide details of the steps they have taken to inform consumers about drinking water quality. This return should be in the form of a list of company consumer communication tools as follows:
   

   Leaflets (by title)
   Fact Sheets (by title)
   Education Packs (by title)
   Website Pages (by web link)
   Schedule 4 Water Quality Report (example copy as would be sent to an individual consumer)
   Presentations to consumer/community groups (where, when, and copy of any Microsoft Power Point slides/outline or handout if different from above tools)
   

   Do not include in this list details of business or liaison meetings with other agencies or consumer representatives.

   Lists should be sent by email to Sue.Pennison@defra.gsi.gov.uk by 21st March 2005.

8. Copies of this letter are being sent to Pamela Taylor, Chief Executive, Water UK; Richard Wood, Water Supply and Regulation Division, Department for Environment, Food and Rural Affairs; June Milligan, Environment Division, Welsh Assembly Government; Colin McLaren, Drinking Water Quality Regulator for Scotland; Randal Scott, Drinking Water Inspectorate for Northern Ireland; Chairs of the Consumer Council for Water Committees; Rowena Tye, Office of Water Services; Tony Smith, Chief Executive, Consumer Council for Water; Tony Warn, Environment Agency; Nigel Harrison, Food Standards Agency; and Gary Coleman at the Health Protection Agency.

   This letter is being sent electronically to Board Level and day-to-day contacts. Please acknowledge receipt by email to dwi.informationletters@defra.gsi.gov.uk . Hard copies are not being sent but the letter may be freely copied. Any enquiries about the letter should be addressed to Sue Pennison.

Yours faithfully

Prof. Jeni Colbourne MBE
Chief Inspector of Drinking Water

Annex A