Case study 5 – Reinforcing the challenges associated with identifying Regulation 8 supplies and the importance of fully understanding the Regulations to ensure the correct response during an investigation.

This case study relates to a water quality concern reported by a water company customer in Gloucestershire about a mains supply which on investigation revealed unusual supply arrangements which had some characteristics of a Regulation 8 supply.

The consumer lives on a farm which receives a mains supply from the local water company. The owner of the property also owns a number of other properties on the same land which they rent out. The occupiers of these properties are not customers of the water company, but are instead billed by the owner of the farm.

In July 2015 the land owner contacted the water company after experiencing a ‘gas’ type odour and discoloured water at the farm following a drop in mains pressure. The company visited the property and collected samples for taste, odour and microbiological parameters.

The sample results showed that while the sample was free from coliforms and E.coli, it was found to contain Clostridium perfingens (4 per 100ml). The company returned to the property to obtain resamples but could not initially gain access and so collected a sample from an outside tap. A sample was also taken from another property on the site as this was supplied by the same service pipe. Both samples confirmed the presence of Clostridium perfingens and as a result the company issued boil water advice to both properties.

The resamples contained a petrol taste and odour, and solvent analysis confirmed the presence of petrol-based compounds. The boil advice was changed to ‘do not drink’. To ensure protection of the wider distribution system a boundary box and non-return valve were fitted at the point of connection with the company’s main.

The company’s investigation identified that a leak had previously been reported on the service pipe but there was no record of whether the leak had been repaired. A water fittings inspection found no contraventions within the property, however, it did identify that the service pipe material was black alkathene which, while prone to fractures and splits, is also permeable to hydrocarbons.

The company advised the farm owner to replace their service pipe with a pipe of suitable material to resolve the leak and prevent chemical leaching through the pipe. The company initially concluded that the supply arrangements to the other properties on the land constituted a Regulation 8 supply and duly informed the local authority.

Questions were posed to both the water company and the local authority during the Inspectorate’s assessment of the event to confirm if the supply was a Regulation 8 supply. During this dialogue it was found that, as the properties on site were owned and rented by the occupier of the farm, the distribution arrangements did not meet the definition of a Regulation 8 supply under the Regulations.

The owner was required by the local authority to undertake the replacement of the service pipe leading to the other properties through an enforcement Notice served under the Housing Act 2004 Part 1.

This case study reiterates the advice outlined in previous case studies surrounding the challenges associated with identifying Regulation 8 supplies. Guidance on identifying Regulation 8 supplies has been issued by the Inspectorate, and should be referred to. The Inspectorate recommends that water companies use this guidance to verify whether or not a supply falls under the definition of Regulation 8.

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