Coronavirus and Private Water Supplies sampling and Risk Assessment
The current advice in England and legislation in Wales requires employers to take all reasonable measures to maintain a distance of two metres between those in the workplace in order to reduce the transmission of coronavirus (CoViD-19).
Questions have been raised by local authorities in connection with arrangements for carrying out sampling and risk assessment duties on private water supplies in light of these restrictions.
The following information constitutes non-statutory advice and replaces any previous advice provided by the Drinking Water Inspectorate with respect to Coronavirus.
It remains for local authorities to satisfy themselves as to their legal obligations and to take decisions on where, when and why they cannot satisfy those duties.
This guidance is therefore a guide to what should be done practically as a minimum in the event of an authority having to take the decision not to comply with their obligations.
Monitoring for most private water supplies is required relatively infrequently. Where private water supplies require validation sampling and risk assessment, and this activity is prevented by Government controls relating to CoViD-19, there are a number of steps that may be taken :-
1. Maintain sampling if at all possible where samples can be taken safely without putting individuals at risk.
2. If sampling at the scheduled time is not possible, reschedule the samples to be taken once Government advice changes to permit closer interactions, to achieve the regulatory annual requirement.
3. Where a local authority has to prioritise samples because of capacity limitations on samplers or laboratories at a particular point in time, they should consider the following principles
a. Size/volume of supply
b. The level of risk recorded against the supply (is it Very High for example?).
c. Usage of water and nature of consumers – is it supplying a food manufacturer, or are there vulnerable consumers in a hospital or care home on the supply ? The risk assessment for health care premises caring for vulnerable individuals should be reviewed in light of the current situation due to the risk of an unwholesome water supply for immuno-compromised individuals. Where there is no risk assessment recorded then information should be collected from the site to identify the risks associated with the private water supply. Assurances should then be sought from these premises that controls are in place to manage the risks e.g. source water protection, maintenance of treatment, etc
Risk Assessment and Risk Management
CoViD-19 may impact the ability of Local Authorities to risk assess supplies. Where the risk assessment is an update of a previous assessment it might be possible to update the risk assessment if relevant persons are able to provide confirmation of any changes which might be verified by supplying information and photographs through email. They should also consider any potential impact on their emergency plans for alternative supplies arising from these additional restrictions.
Where a required update or new risk assessment cannot be carried out it should be rescheduled for later in the year. Where this causes an issue with capacity for the Local Authority, then the Local Authority should prioritise considering the level of known risk, or if not known the size and usage of the supply.
Working in People’s Homes
Changes of Supply Category
As the impact of CoViD-19 may be to cause changes in the normal pattern of usage, Local Authorities should be alert to changes of volume or use that would either prompt additional activities (e.g. a food business increasing water usage to a level requiring additional sampling) or conversely, to supplies where the commercial usage of the water ceases and they should reclassify supplies where these changes become permanent.
The World Health Organisation have issued advice on water, sanitation, hygiene, and waste management, for CoViD-19.
A risk management approach is advocated by DWI in line with the WHO drinking water safety planning approach, and as such sampling is simply a means of validating that the risk mitigation measures in place (source protection, treatment, storage etc.) are effective. Therefore it is recommended that where risks from supplies increases due to the circumstances brought about by CoViD-19, consumers and other relevant persons of private water supplies should be encouraged to bolster their operational checks and ensure that maintenance is being carried out as required (e.g. replacing UV lamps or monitoring chlorine dose) and that they have sufficient spares of essential equipment to ensure supplies remain wholesome at all times. They should document these actions, and if required present these to Local Authorities to confirm that supplies did not present a risk to health during these exceptional circumstances.
Reinstating Supplies after Temporary closure
Advice letter 02/2020 provides advice to local authorities and necessary information concerning supplies in buildings as a consequence of national restrictions due to CoViD-19.
Section 77 of the Water Industry Act 1991 requires a local authority to keep itself informed about the wholesomeness and sufficiency of every private water supply within its area. Each local authority achieves this by conducting its statutory duties which includes; risk assessments, investigations, authorisations and monitoring (sampling and analysis). The Regulations also make provisions for local authorities to charge fees to the relevant person(s) for conducting these duties.
If through these duties a local authority deems a private water supply to be unwholesome and/or insufficient then it has the power under the Regulations to serve notices on the supply in order to mitigate against these risks.
Local authorities are under a statutory duty to provide reporting information relating to private water supplies to the Secretary of State and Welsh Ministers. This submission of data is due on 31 January of every year, for records relating to supplies in their area during the previous calendar year.