South East Water Limited – Hazard Review

Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)

Reference: SEW-2025-00039

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): South East Water Limited, with registered number 02679874 (hereinafter called ‘the company’).

Assets Affected:

• Whole company Assets

Details of this Notice:

1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a regulation 28(1) report of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the company dated 1 September 2025, which states that there is or has been a significant risk of supplying water from company treatment works (and associated assets as applicable) that could constitute a potential danger to human health or could be unwholesome.
2. Consequently, this Notice is served on the company by the Inspectorate on behalf of the Secretary of State, under regulation 28(4) for the assets listed above, for risks associated with:

Description of Risk	Hazard/ Hazardous Event/ Parameter
Pathogenic bacteria ingress route and failure of treatment process	E. coli
Pathogenic bacteria ingress route and failure of treatment process	Enterococci
Pathogenic Protozoa breakthrough presenting risk to public health	Cryptosporidium
Pathogenic Protozoa breakthrough presenting risk to public health	Total Coliforms
Increasing nitrate in source waters	Nitrate
Insufficient water supply to downstream consumers	No Supply
Failure of treatment poses risk to wholesomeness	Lead
Failure of treatment poses risk to wholesomeness	Aluminium
Failure of treatment poses risk to wholesomeness	Iron
Failure of treatment poses risk to wholesomeness	Discolouration
Failure of treatment poses risk to wholesomeness	Polycyclic Aromatic Hydrocarbons
Compromised disinfection process	Turbidity
Treatment by-products	Tetrachloromethane
Failure of treatment poses risk to wholesomeness	Pesticides
Failure of treatment poses risk to wholesomeness	Taste
Failure of treatment poses risk to wholesomeness	Odour

Table 1: Table of the hazards, hazardous events, and/or parameters covered by this Notice

3. The company are required to satisfy the following requirements.

The date given is that until or by which the requirements must be maintained or satisfied, as appropriate.

Requirements:

(a) To maintain the following measures for the period specified in each case:

1. Operate all treatment works in accordance with current company policy, standards and procedures, that align to recognised standards of good practice.
   Date: Ongoing for the duration of this Notice
2. Ensure all water quality related operational and maintenance tasks are carried out at the prescribed frequency
3. Date: Ongoing for the duration of this Notice
4. Enhanced microbiological and chemical parameter monitoring in line with company procedures where new risks to water quality from an asset are identified. Date: Ongoing for the duration of this Notice
5. Ensure that appropriate alarms and shutdowns parameters for on-line water quality monitors are documented, and shutdowns tested at the prescribed frequency

Date: Ongoing for the duration of this Notice

6. Ensure that operational staff are kept up to date on policy and procedural changes
   Date: Ongoing for the duration of this Notice
7. Maintain records of remedial work completed on all water treatment works

Date: Ongoing for the duration of this Notice

(b) To review, revise or make operational the following measures, by the dates specified in each case:

1. Review and update the company’s water quality method statements and operational risk assessments, ensuring they are applied appropriately to control drinking water quality risks. Date: 30 April 2027
2. Develop a process to enable the full review and documentation of catchment, operational and asset-based hazards at each water treatment works, ensuring compliance with Regulations 4, 26 and 27. This process will include:
   1. A review of current asset performance and efficacy against catchment hazards and raw water challenge. 
   2. A review of site pipework, valving, drainage and sanitary disposal facilities. 
   3. An end-to-end review of operational and maintenance tasks. 
   4. A review of asset criticality, including single points of failure. 
   5. An assessment of hazard containment and recovery requirements, including run to waste and automated shutdown facilities. 
   6. A review of sampling and online monitoring against good practice. 
   7. A review of contingency planning for the site. 
   8. A review of the use of all consumable materials (e.g. chemicals, filtration media, membranes and cartridge filters) used on sites, which are approved under Regulation 31(4)b to ensure the manufacturer’s instructions for use are complied with. 
   9. A review of the ability to install emergency treatment equipment as needed following a defined threshold/needs assessment.
   10. A review to assess compliance with the recommendations of the expert group on Cryptosporidium. for surface water treatment works
   11. A review of Company SSDP to include assessment of catchment hazards and gap analysis to determine where contact time within the Company’s contact tanks and mains is insufficiently understood.

Date: 31 October 2026

3. Develop and implement a comprehensive methodology for demonstrating staff training and competence in risk assessment and include a structured programme outlining how hazard reviews will be conducted at each company site.
   Date: 31 October 2027
4. Develop a work programme with defined timescales for completing hazard reviews and site-specific disinfection plans for each water treatment works as per the process developed in (b)2. The programme must be regularly reviewed and updated, with site priorities determined using a risk-based approach.
   Date: 31 January 2027 
5. Undertake the programme of works developed in measure (b)3 to conduct a hazard review and develop a new site-specific disinfection plan for each water treatment works.
   Date: 31 March 2030
6. Implement as soon as practicable short to medium term mitigation where required to control any uncontrolled hazards identified in measure (b)5.
   Date: From 28 February 2027 and ongoing for the duration of this Notice
7. Plan a programme of work to address all uncontrolled hazards identified in measure (b)5, for each site.
   Date: From 28 February 2027 and ongoing for the duration of this Notice
8. Implement the planned programme of work identified for each water treatment works in measures (b)7.
   Date: From 28 February 2027 and ongoing for the duration of this Notice
9. Review and update the company’s Water Safety Plan (WSP) Methodology to ensure it fully reflects the enhancements introduced through the measures specified within this Notice. Date: 31 January 2027

(c) To audit whether the measures have been effective by the following means:

1. Define an audit strategy to monitor the effectiveness of the measures specified in sections (a) and (b).
   Date: 31 July 2026
2. Implement, and keep under continuous review, the audit strategy defined in measure (c)1.
   Date: Following completion of measure (c)1. onwards.

(d) Not to supply water for regulation 4(1) purposes from all company treatment works or supply systems, or not to so supply unless the specified conditions below are satisfied:

1. Not applicable

(e) To provide the following information in the time and manner specified below to enable monitoring of progress towards the mitigation of the risks:

1. Provide a progress report annually.
   Date: by 31 January each year.
2. Provide a report on the updated water quality method statements and risk assessments, confirming how they are being applied to control drinking water quality risks, as specified in measure (b)1. Date: 31 May 2027
3. Provide a report defining the hazard review process for each water treatment works, covering the findings from the assessment, reviews and implementation, as specified in measure (b)2.
   Date: 30 November 2026
4. Provide a report evidencing the development and implementation of a comprehensive methodology for demonstrating staff training and competence in risk assessment and include a structured programme outlining how hazard reviews will be conducted at each company site, as specified in measure (b)3.

Date: 30 November 2027

5. Provide a report via an updated Annex 1 demonstrating the program of work, including defined timescales for completing the hazard review and site-specific disinfection plan for each water treatment works and showing how site priorities have been determined using a risk-based approach, as specified in measure (b)4.
   Date: 28 February 2027
6. Provide a report detailing the hazard review and the development of the new site-specific disinfection plan for each water treatment works, as completed in accordance with the processes outlined in measures (b)2 and (b)4, as specified in measure (b)5. Date: 30 April 2030
7. Provide a report detailing the short to medium term mitigation measures required to control any uncontrolled hazards identified in measures (b)6. Date: Six monthly from 30 September for the duration of this Notice
8. Provide a report outlining the programme of work developed to address all uncontrolled hazards identified in measure (b)5. Date: Six monthly from 30 September for the duration of this Notice
9. Provide a report detailing the implementation of the planned programme of work identified for each water treatment works in measures (b)7.

Date: Six monthly from 30 September for the duration of this Notice

10. Provide a report detailing the review and update of the company’s Water Safety Plan (WSP) methodology, confirming how the methodology has been revised to fully reflect the enhancements introduced through the measures specified within this Notice, as specified in measure (b)9. Date: 28 February 2027
11. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: 31 August 2026
12. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
13. Submit a report in the event that any completed measures of this Notice need to be altered in any way, for any reason.
    Date: Ongoing for the duration of this Notice
14. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 30 June 2030

Further Details of this Notice:

1. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
2. Under regulation 28(6) the Inspectorate, on behalf of the Secretary of State, may by notice served on the company, revoke or vary this Notice.
3. Failure by the company to comply with this Notice may result in enforcement proceedings under section 18 of the Water Industry Act 1991 (as amended).

Signed

 

Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
11 May 2026
Reference: SEW-2025-00039