Notice of Regulation: Portsmouth Water – Management and Training

NOTICE UNDER REGULATION 28(4) OF THE WATER SUPPLY (WATER QUALITY) REGULATIONS 2016 (AS AMENDED)

Portsmouth Water Limited: Management and Training

Reference: PRT-2021-00001

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Portsmouth Water Limited, with registered number 02536455 (hereinafter called ‘the Company’).

Assets affected: Whole Company

1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a set of regulation 28(1) reports of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company dated 21 October 2020, which state that there is or has been a significant risk of supplying water from all catchments, water treatment works, service reservoirs and zones in the Company’s supply region (and associated assets as applicable) that could constitute a potential danger to human health and 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:

Parameters

• Microbiological
• Chemical
• Parasites
• Viruses
• Turbidity

Hazardous Event Examples

• Inadequacy of training procedures and documentation
• Operator error due to insufficient training
• Contamination during maintenance activities
• Use of inaccurate documentation
• Inadequate management of procedures and documentation
• Inadequate disinfection
• Inadequate treatment

Description of Risks Management of Upskilling and Training

• Undefined competencies, accountability, roles and responsibilities of roles involved with the supply of water for regulation 4(1) purposes.
• Deficient training materials, training process, competency assessment and documentation thereof.

Management of Procedures and Documentation:

• Policy, standards and procedural deficiencies associated with the supply of water for regulation 4(1) purposes.
• Deficiencies with documentation of tasks or functions related to the supply of water for regulation 4(1) purposes.

Management of Disinfection and Treatment

• Inadequate verification of disinfection and treatment.
• Deficiencies in disinfection and treatment understanding against current standards and good practise. For example, deficiencies in understanding of turbidity and dosing operations, optimisation of chemicals and compliance with the recommendations of the Expert Group on Cryptosporidium ‘Badenoch and Bouchier’.

---

3. The Company are required to satisfy the following:

Requirements

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

1. All personnel involved with the supply of water for regulation 4(1) purposes to be trained in accordance with current Company policies and procedures.
   Date: Ongoing for the duration of this Notice
2. All new personnel involved with the supply of water for regulation 4(1) purposes to be trained in accordance with current Company procedures.
   Date: Ongoing for the duration of this Notice
3. Up-to-date site operating manuals for each operational Company asset.
   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:

Stage 1: Measure (b)1. to 8. applies up until the point where water leaves service reservoirs.

Management of Upskilling and Training

1. • a) Complete a critical review of all personnel involved with the treatment, supply and review of water (intended for regulation 4(1) purposes) to establish that relevant competencies are matched to defined roles and to adopt a drinking water safety planning approach for the supply of wholesome water. This review must include:
     Date: 31 December 2022
     • ‐ Identification of role required competencies;
     • ‐ A gap analysis between role required competencies and current competency levels;
     • ‐ A review of the Company’s competency assessment procedure;
     • ‐ A review of how to ensure staff are confident as well as competent in performing their tasks; and
     • ‐ A review of the Company’s sign-off process and its effectiveness to ensure new staff are competent in the roles they are required to complete, before undertaking work independently.
   • b) Identify any measures required to address the findings of the critical review completed under measure (b)1.a) above.
     Date: 30 June 2023
   • c) Implement any required measures identified under measure (b)1.b) above.
     Date: 31 December 2024
2. • a) Complete a critical review of the Company’s training procedures (relevant to the supply of wholesome water for regulation 4(1) purposes) to ensure they are fit for purpose. This must include a 30 September 2022 review of the Company’s induction training package.
     Date: 30 September 2022
   • b) Identify any measures required to address the findings of the critical review completed under measure (b)2.a). This must include:
     Date: 31 March 2023
     • Implementation of improved training record documentation;
     • Implementation of an ongoing process to review training programmes to ensure training packages remain accurate and up to date; and
     • Implementation of an on-going quality controlled system to ensure relevant personnel are re-trained following the revisions of policies, procedures or systems.
   • c) Implement any required measures identified under measure (b)2.b) above.
     Date: 30 June 2023

Management of Procedures and Documentation

3. • a) Complete a critical review of the Company’s policies and procedures (relevant to the supply of water for regulation 4(1) purposes) to identify any deficiencies.
     Date: 31 December 2022
   • b) Identify any measures required to address the findings of the critical review completed under measure (b)3.a).
     Date: 30 June 2023
   • c) Implement any required measures identified under measure (b)3.b). above, including the provision of training/briefing of any new/ amended procedures to relevant personnel.
     Date: 31 December 2024
4. • a) Create a programme for the ongoing review of all policies and procedures relating to the production of wholesome water for regulation 4(1) purposes that includes:
     Date: 30 June 2023
     • how the ongoing programme will be documented to evidence when reviews are completed and any changes made;
     • how updates to procedures or policies will be communicated to relevant personnel; and
     • the removal of outdated procedure or policies.
   • b) Implement the ongoing programme of review established under (b)4.a).
     Date: 31 December 2024
5. • a) Complete a critical review of the Company’s documentation (record keeping) of tasks or functions related to provision of water for regulation 4(1) purposes, to identify any deficiencies, including accountability, tracking and audibility thereof.
     Date: 31 December 2022
   • b) Identify any measures required to address the findings of the critical review completed under measure (b)5.a).
     Date: 30 June 2023
   • c) Implement any required measures identified under measure (b)5.b). above.
     Date: 30 June 2024
6. • a) Review the suitability of the Company’s scheduling of maintenance, and review tasks or functions related to provision of water for regulation 4(1) purposes, to ensure functions are completed within appropriate timescales.
     Date: 30 June 2023
   • b) Identify any measures required to address the findings of the critical review completed under measure (b)6.a).
     Date: 31 December 2023
   • c) Implement any required measures identified under measure (b)6.b). above.
     Date: 31 December 2024

Management of Disinfection and Treatment

7. • a) Complete a gap analysis between the Company’s understanding of disinfection and treatment against current understandings and good practise.
     Date: 31 December 2022
   • b) Identify any measures required to address the findings of the critical review completed under measure (b)7.a).
     Date: 31 March 2023
   • c) Develop an action plan, prioritised on the basis of risk, with dates for the deliverance of the measures identified in in measure (b)7.b).
     Date: 30 April 2023
8. • a) Complete a review of the Company’s operating standards. This must include a review of the standards for alarm settings as follows:
     Date: 31 December 2022
     • Operating ranges and set points;
     • Water quality related triggers and alarms;
     • Response to water quality triggers and alarms; and
     • Contingency procedures.
   • b) Update the Company’s operating standards following the review completed under (b)8.a) and embed an ongoing programme of continuous review.
     Date: 31 March 2023
   • c) Complete a gap analysis between the new and updated operating standards produced under measure (b)8.b)
     Date: 30 June 2023
   • d) Implement any required measures to address the findings of the gap analysis completed under measure (b)8.c). above.
     Date: 31 December 2023

Stage 2: Measure (b)9. applies from the point where water leaves service reservoirs up to the consumer’s tap.

9. Produce the programme of work to complete all section (b) measures above from the point where water leaves service reservoirs up to the consumer’s tap.
   Date: 31 December 2024

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

1. Define a strategy for auditing the effectiveness of the measures being delivered in section (b). This must:
   Date: 31 March 2022
   • a) Include the design and implementation of a regular programme of audit and review (incorporating any lesson learnt or improvements made through implementation of the measures in section (b)). This shall:
     • ‐ Ensure compliance with Company procedures and competency requirements;
     • ‐ Permit a continuous programme of identifying gaps in training and competency;
     • ‐ Ensure an ongoing programme for upskilling and training; and
     • Permit continuous learning and development beyond the life of this Notice.
   • b) Include how the Company intends to measure the success (including cultural changes) of the delivery of the section (b) measures.
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 multiple sites, 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 bi-annual progress reports outlining the progress of section (b) measures. One month after the completion of a section (b) measure, include the following details (as appropriate) within the next bi-annual progress report:
   Date: Bi-annually, until revocation of this Notice, on:31 January and 31 July
   • Evidence of the completion of the measure and the benefits delivered; and
   • Timescales of any measures identified to address the findings of a critical review.
2. Submit the strategy for auditing the effectiveness of the measures, as specified in (c)1.
   Date: 30 April 2022
3. Submit any revisions of the audit strategy produced under measure (c)2.
   Date: Within 1 month of a revision
4. Submit a report in the event that any completed measure of this Notice needs to be altered in any way for any reason.
   Date: Ongoing for the duration of this Notice
5. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
   Date: 31 December 2025

---

4. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
5. 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.
6. 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
Nick Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
22 October 2021
Reference: PRT-2021-00001
Version 1