Current improvement programmes

Notice of Regulation: Southern Water – All Treatment Works



Southern Water Services Ltd: Public Health Training and Culture

All treatment works, storage assets and distribution systems in the Southern Water area.

Legal Instrument Database Reference number: SRN3925


  1. has on 20 October 2017 received a set of reports from Southern Water Services Ltd (the “Company”) dated with various dates (the “Reports”) which state that there is or has been a significant risk of supplying water from all sites and supply zones in the Southern Water area that could constitute a potential danger to human health.
  2. GIVES NOTICE to the Company under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended) that it must satisfy the following requirements:

For risks associated with:

  • Regulation 4 (wholesomeness), Regulation 26 (disinfection) and Regulation 31 (Materials in contact with drinking water) associated with operator competency.


(a) to maintain the following measures for the period specified

  1. All operational and construction staff to follow the existing works operational procedures as detailed in the Water Supply and Resources Manual and distribution staff to follow the procedures in the Water Distribution Manual until such a time that a revision is put in place.
    Date: Ongoing for the duration of the Notice.
  2. All new operators and maintenance technicians to be trained in accordance with company procedures.
    Date: Ongoing for the duration of the Notice.

(b) to review, revise or make operational the following measures, by the dates specified below:


  1. Update the Southern Water Hygiene Code of Practice (HCoP) incorporating the current Principles of Water Supply Hygiene and good hygienic practice.
    Date: Complete
  2. Produce and implement a training plan to embed the new Hygiene Code of Practice within Southern Water and its delivery partners.
    Date: Complete
  3. Establish a standard for operational site hygiene.
    Date: Complete
  4. Generate a standard hygiene audit proforma and a programme of water supply works site hygiene audits to audit against the new Hygiene code or practice and hygiene standard.
    Date: Complete

Materials in contact with drinking water

  1. Produce and deliver training material on Regulation 31 – products and materials in contact with water to relevant Southern Water employees to enhance awareness of the requirements.
    Date: Complete

Public health

  1. Update the current water quality manual used by the Customer Response and Resolution Centre to provide advice to customers.
    Date: Complete
  2. Create a Company Waterborne Hazard Plan and agree the contents with Public Health England.
    Date: Complete
  3. Produce and implement water quality and public health awareness training for all Southern Water staff and any delivery partners working on behalf of Southern Water in the supply of water to customers.
    Date: 31 March 2020

Planned works – Risk Assessments

  1. Develop a water quality risk assessment process (WQRA) for the proactive identification of water quality hazards and associated mitigations related to planned works.
    Date: Complete
  2. Revise and incorporate within the WQRA process a mechanism by which lessons learnt from each assessment can be captured and fed forward into future planned works.
    Date: Complete
  3. Implement the risk assessment process for all planned works carried out on the water supply system from source to tap going forward.
    Date: Ongoing for the duration of the Notice
  4. At six monthly intervals review the risk assessment process and make any necessary changes to the process to ensure the process is fit for purpose, useable and that the roles and responsibilities of those involved are clearly defined.
    Date: Ongoing for the duration of the Notice
  5. On an annual basis review the training and competency requirements for each role in the risk assessment process.
    Date: Ongoing for the duration of the Notice

Team Leaders and Managers

  1. Ensure staff responsible for the supervision and management of operational personnel as described above are included in the training.
    Date: Ongoing for the duration of the Notice


  1. Creation of NVQ 3 equivalent training modules for Water Production and Resources Operational Staff and training of those operators who took part in the training needs analysis between 8th and 22nd January 2019.
    Date: 31st March 2020
  2. All existing Water Production and Resources Operational staff to be trained to the above NVQ 3 equivalent training package.
    Date: 31st March 2021
  3. Any new starters to be working towards NVQ 3 or equivalent.
    Date: Ongoing for the duration of the Notice
  4. Develop and deliver training on the WQRA process for planned works to all relevant staff. Ensure that where there has been a significant change in the WQRA process due to the review process detailed above, training material is amended and delivered in a timely manner to capture any change and lessons learnt.
    Date: Ongoing for the duration of the Notice
  5. Develop and deliver training, competence criteria and procedures for handling water quality events. Training of staff in all areas detailed above to include awareness of the safety and acceptability of water for consumers such that these implications are considered when decisions need to be made regarding water supplies during events.
    Date: Complete
  6. Produce an Action Plan detailing how the Company;
    Date: Complete
    • Plans to continue the development of scientific capability and professional competence of staff in respect of water quality and public health.
    • Intends to measure the success of the plan.
    • Intends to complete training of all staff involved in the risk assessment process, to the required level.
  7. Review the effectiveness of the Action Plan against the measure of success detailed in step (b)19.
    Date: 31st March 2022

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

  1. Define a strategy for auditing the effectiveness of the measures made operational above, to include;
    Date: Complete
    • Review learning from any compliance breach or event associated with an inadequate level of staff competence.
    • Audit against the Hygiene Code of Practice and standards for site hygiene.
  2. Implement the audit strategy in (c)1.
    Date: Until revocation of this Notice.

(d) not to supply water for regulation 4(1) purposes.

  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 risk of supplying water that would constitute a potential danger to human health:

  1. Provide a progress report annually by 31st January on completion of the following milestones;
    • Confirm the audit strategy.
      Date: Complete
    • Completion of all actions associated with hygiene (b)1-4.
      Date: Complete
    • Completion of all actions associated with materials in contact with drinking water (b)5.
      Date: Complete
    • Completion of all actions associated with public health (b)6–8.
      Date: 30th April 2020
    • Completion of implementation and ongoing use of the water quality risk assessment process (following completion of step (b)10.
      Date: Complete
    • Completion of training steps (b)17 and 19.
      Date: 31st January 2019
    • Completion of the training of existing staff to NVQ 3 or equivalent.
      Date: 30th April 2021
  2. Submit a satisfactory completion report.
    Date: 31st October 2022

Failure by the Company to comply with this Notice may result in enforcement proceedings under section 18 of the Act.

Signed by authority of the Secretary of State
Milo Purcell
Deputy Chief Inspector
06 November 2020
DWI ref: SRN3925
Version 4