Introduction – Regulations
Regulations 32 of the Water Supply (Water Quality) Regulations states that the Secretary of State may approve the use of any process in connection with water suppy – view the full section of the regulations. The Drinking Water Inspectorate (DWI) has provided guidance in relation to the Regulation 32. Comparable requirements are given in the other relevant national regulations.
Implications – Can a process be approved?
Regulation 32 of the Water Supply (Water Quality) Regulations does not contain provisions for approval of processes for suppliers and manufacturers, but only for the consent of the Secretary of State for a water supplier to use a specific process in the context of their own water treatment and supply. Water Suppliers may initially contact the Drinking Water Inspectorate (DWI) concerning the use of a new or novel process.
DWI can consider, however, applications for approval under Regulation 31 products used in processes for the following cases –
1) Major components parts or materials used in connection with a process when those major component parts or materials require approval under Regulation 31 (4)(a).
a. it is the component parts or materials that could be approved, not the process. An example is the approval of membrane or filter elements in treatment processes using membrane or filtration systems
b. the components of a process having a minor or transient contact with water fall under Regulation 31(4)(b) – see our website for more details – http://www.dwi.gov.uk/drinking-water-products/advice-and-approval/advicesheet8.pdf
2) A treatment chemical generated on-site by a process can be considered for approval under Regulation 31 (4)(a).
Note: it is the treatment chemical that is approved, not the process. An example is sodium hypochlorite made on-site by an electrochemical generation process.
What can manufacturers do to obtain agreement to the use of their processes in the supply and treatment of drinking water?
In the first instance they should consider the relevance of the requirements of Regulation 31 (4)(a) to the products (component parts/materials or chemicals) associated with their process, and, if appropriate, make a formal application to DWI for approval of these products under Regulation 31(4)(a). In most cases approval of the major component parts/materials or chemicals will enable the water suppliers to use the process. If a water supplier considers that such approval under Regulation 31 may not be adequate, the water supplier should contact DWI who will review the options. Options could include whether the water supplier should be required to seek approval under Regulation 32 to use the process, whether the water supplier should be prohibited from using the process, or whether the approval of the products under Regulation 31 is sufficient to enable the water supplier to use the process.