South East Water Limited – Company Quality and Operating Procedures, Policies and Management

Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)

Reference: SEW-2025-00038

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): South East Water Limited, with registered number 02679874 (hereinafter called ‘the company’).

Assets Affected:

• Whole Company

Details of this Notice:

1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a regulation 28(1) report of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the company dated 1 September 2025, which states that there is or has been a significant risk of supplying water from all water treatment works and connected supply systems in the Company’s supply region that could constitute a potential danger to human health or 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:

Regulation 28(1) Control Measure	Description of associated risk
Procedures [Procedures are identified as a control measure for all Regulation 28(1) Hazards at all South East Water Limited water treatment works and therefore impact all connected supply systems]	If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.

Table 1: Table of the hazards, hazardous events, and/or parameters covered by this Notice, including the Hazard I D numbers and the description of risks.

3. The company are required to satisfy the following requirements.

The date given is that until or by which the requirements must be maintained or satisfied, as appropriate.

Requirements:

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

1. Ensure all relevant personnel are trained and competent in current standard operating procedures, site-specific schematics and manuals, and site-specific contingency plans.
   Date: Ongoing for the duration of this Notice
2. 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
3. Up-to-date site operating manuals for each operational Company asset. Date: Ongoing for the duration of this Notice
4. Carry out risk assessments using current company methodology for all planned works on the water supply network.

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:

1. Review and update the company’s regulatory governance framework to ensure that the resources, systems, and process improvements required to meet legal instrument obligations are in place, and that issues in legal instrument delivery are prevented. Date: 31 October 2026
2. Complete the company’s standard operating procedures. Ensure updates are communicated to frontline teams and provide documented evidence of these updates, such as revised documents, distribution records, and confirmation of implementation. Date: 31 March 2030
3. Review and update the company’s site-specific schematics. Ensure updates are communicated to frontline teams and provide documented evidence of these updates, such as revised documents, distribution records, and confirmation of implementation. Date: 31 October 2026
4. Review and update the company’s site manuals. Ensure updates are communicated to frontline teams and provide documented evidence of these updates, such as revised documents, distribution records, and confirmation of implementation. Date: 31 March 2030
5. Review and update the company’s site-specific contingency plans. Ensure updates are communicated to frontline teams and provide documented evidence of these updates, such as revised documents, distribution records, and confirmation of implementation. Date: 31 March 2030
6. Review, update, and internally communicate the company’s governance, processes and procedures to ensure the timely and consistent delivery of all proactive operational tasks. Date: 30 April 2027
7. Review and revise the company’s reporting procedures to ensure robust and consistent processes are in place so that sufficient and appropriate water quality sampling is carried out accurately, consistently and promptly following any incident or customer complaint. Date: 31 October 2026
8. Review and improve the identification and monitoring of water quality risks by reviewing and strengthening the company’s risk management procedures, ensuring clearer visibility of risks at the site level. Date: 30 April 2027
9. Review and update the company’s governance procedures to define clear accountability for water quality driven engineering projects and to support earlier identification of risks that could affect delivery timelines. Date: 31 October 2026
10. Review and enhance the company’s internal trigger management processes to ensure timely identification and escalation of water quality sample results that are below, but approaching, the Prescribed Concentration or Value (PCV). Date: 31 October 2026
11. Review and strengthen the company’s customer complaint management processes to prevent long-standing or recurring issues from arising. Date: 31 October 2026
12. Evaluate whether the existing resources within the company’s water quality and operational teams are adequate to support the effective and timely delivery of its responsibilities. Date: 31 December 2026
13. (a) Complete a critical review of all personnel involved with the treatment and supply of wholesome 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: 

• 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 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.

Date: 29 February 2028

(b) Identify any measures required to address the findings of the critical review completed under measure (b)13(a). 

Date: 30 November 2028

(c) Implement any required measures identified under measure (b)13(b)

Date: 31 August 2029

1. (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 review of the Company’s induction training package.  
   Date: 31 August 2027

(b) Identify any measures required to address the findings of the critical review completed under measure (b)13(a). This must include: 

• 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. 
• Implementation of an on-going quality-controlled system to ensure relevant personnel are re-trained following the revisions of policies, procedures or systems. 

Date: 31 August 2029

(c) Implement any required measures identified under measure (b)13(b). 
Date: 31 January 2030

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

1. Define an audit strategy to monitor the effectiveness of the measures specified in sections (a) and (b).
   Date: 31 July 2026
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 all company treatment works or supply systems, 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 a progress report annually.
   Date: by 31 January each year.
2. Submit a report providing evidence confirming the company has reviewed and updated its regulatory governance framework, demonstrating that the necessary resources, systems, and process improvements required to meet legal instrument obligations have been implemented to prevent future issues, as specified in measure (b)1.
   Date: 30 November 2026
3. Submit a report providing evidence that the company has completed its standard operating procedures, as specified in measure (b)2.
   Date: 30 April 2030
4. Submit a report providing evidence that the company has completed its site-specific schematics, as specified in measure (b)3.
   Date: 30 November 2026
5. Submit a report providing evidence that the company has completed its site manuals, as specified in measure (b)4.
   Date: 30 April 2030
6. Submit a report providing evidence that the company has completed its site-specific contingency plans, as specified in measure (b)5.
   Date: 30 April 2030
7. Submit a report providing evidence that the company’s governance, processes and procedures to guarantee timely delivery of all proactive operational tasks have been reviewed, updated and communicated, as specified in measure (b)6.
   Date: 31 May 2027
8. Submit a report providing evidence that the company’s reporting procedures to ensure accurate, consistent and timely water quality sampling after incidents and in response to customer complaints have been updated, as specified in measure (b)7.
   Date: 30 November 2026
9. Submit a report providing evidence of the improvements implemented to strengthen the company’s risk management procedures, demonstrating how these actions have enhanced the identification and monitoring of water quality risks and improved visibility of risks at the site level, as specified in measure (b)8.
   Date: 31 May 2027
10. Submit a report providing evidence that the company has updated its governance procedures to establish clear accountability for water quality driven engineering projects and to support earlier identification of risks that may affect delivery timelines, as specified in measure (b)9.
    Date: 30 November 2026
11. Submit a report providing evidence that the company has updated its internal trigger management processes to ensure timely identification and escalation of water quality sample results that are below, but approaching, the Prescribed Concentration or Value (PCV), as specified in measure (b)10. Date: 30 November 2026
12. Submit a report providing evidence that the company has strengthened its customer complaint management processes to prevent long-standing or recurring issues, as specified in measure (b)11. Date: 30 November 2026
13. Submit a report detailing the outcome of the evaluation of the company’s existing water quality and operational teams’ resourcing, confirming whether the current capacity and capability are sufficient to ensure effective and timely delivery of all statutory and operational responsibilities, as specified in measure (b)12. Date: 31 January 2027
14. Submit a report detailing the findings of the critical review of all personnel involved in the treatment, supply, and review of water for regulation 4(1) purposes, as specified in measure (b)13 (a). Date: 31 March 2028
15. Submit a report detailing the measures identified to address the findings of the critical review completed under measure (b)13(a), as specified in measure (b)13 (b). Date: 31 December 2028
16. Submit a report confirming the measures identified under measure (b)13(b) have been implemented, as specified in measure (b)13(c). Date: 30 September 2029
17. Submit a report detailing the findings of the critical review of the Company’s training procedures, as specified under measure (b)14(a). Date: 30 September 2027
18. Submit a report detailing the measures identified to address the findings of the critical review completed under measure (b)14(a), as specified in measure (b)14(b).   Date: 30 September 2029
19. Submit a report confirming the measures identified under measure (b)14(b) have been implemented, as specified in measure (b)14(c). Date: 28 February 2030
20. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: 31 August 2026
21. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
22. Submit a report in the event that any completed measures of this Notice need to be altered in any way, for any reason.
    Date: Ongoing for the duration of this Notice
23. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 31 March 2030

Further Details of this Notice:

1. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
2. 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.
3. 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

 

Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
11 May 2026
Reference: SEW-2025-00038