South Staffordshire Water Plc – Disinfection and Competency Improvements

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

Reference: SST-2026-00001

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): South Staffordshire Water Plc, with registered number 02662742 (hereinafter called ‘the company’).

Assets Affected:

• Whole company (Cambridge Water operating area).
  

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 March 2026, which states that there is or has been a significant risk of supplying water from multiple treatment works in the Cambridge Water operating area (and associated assets as applicable) 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:
   

Description of Risk	Hazard/ Hazardous Event/ Parameter	Hazard I D
Inadequate water treatment leading to consumer impact.	Failure/Inaccurate Online monitoring.	T021239 for example.
Contamination of water supplies leading to consumer impact.	Contamination – Inadequate training or supervision, Improper maintenance or equipment operation.	T021217 for example.
No supply to consumers.	Disinfection process resilience.	T021233 for example.

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. Embed the Company Water Quality Charter across all levels of the organisation to ensure the safeguard of drinking water quality.
   Date: Ongoing for the duration of this Notice.
   
2. Verify and calibrate all water quality chlorine monitors to ensure traceability, verification and demonstrate compliance.
   Date: Ongoing for the duration of this Notice.
   
3. Maintain and operate existing works treatment in accordance with Company standards and requirements.
   Date: Ongoing for the duration of this Notice.
   
4. Liaise with the United Kingdom Health Security Agency (UKHSA) and local authorities in the event of any breach of a health-based parameter.
   Date: Ongoing for the duration of this Notice.
   
5. Monthly leadership site audits to be undertaken with personnel, during which drinking water quality is actively discussed and reinforced.
   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. Update all site specific disinfection policies to explicitly identify and define critical controls for disinfection that are required to protect drinking water quality.
   Date: 31 December 2026.
   
2. Review Drinking Water Safety Plan documentation to ensure that all compliance‑critical control measures are clearly identified, subject to appropriate assurance, and have defined ownership.
   Date: 31 December 2026.
   
3. Complete a review of Production and Control Room personnel operating treatment works, including defining role‑required competencies, reviewing competency assessment processes, and commissioning an external review to benchmark and align assessment procedures with industry standards.
   Date: 28 February 2027.
   
4. Assess current personnel competency levels through a gap analysis, against established role‑specific requirements.
   Date: 28 February 2027.
   
5. Identify and implement measures to address any deficiencies identified through the skills gap analysis in measure (b)4, including the development and delivery of appropriate training packages.
   Date: 30 August 2027.
   
6. Improve training record documentation through the implementation and embedding of a quality‑controlled training records management system to ensure accuracy, completeness, and ongoing assurance.
   Date: 30 April 2028.
   
7. Complete a review the development of a programme of work to progress from single validation to dual validation of monitors.
   Date: 31 December 2027.
   
8. Complete the programme of works, developed and implemented in measure (b)7.
   Date: 31 March 2028.
   
9. Undertake a review of treatment works commissioning utilising the existing Authorised Operations procedure, including the introduction of new treatment approaches or installations, ensuring training is embedded and signed off.
   Date: 28 February 2027.
   
10. Review return‑to‑service arrangements to ensure the incorporation of clearly defined escalation criteria. Brief out any required improvements identified and verify understanding and acceptance by all relevant staff.
    Date: 31 December 2026.
    
11. Complete a review of control room operations to include response procedures and defined escalation arrangements for the control room. Brief out any required improvements identified during the review and verify understanding and acceptance by all relevant staff.
    Date: 31 May 2027.
    
12. Develop and deliver an Operational Technology (OT) Independent Computing Architecture (ICA) Compliance Framework to support consistent internal assurance by assessing and scoring conformity against internally agreed targets set against specific OT elements across the enterprise.
    Date: 28 February 2027.
    
13. Develop and deliver an active leadership programme across operational field roles, with a focus on visible, effective leadership behaviours that support the protection of drinking water quality. This shall be delivered through the Company’s internal “Brilliant Basics” programme.
    Date: 30 November 2026.
    
14. Coach and accredit existing operational leaders to enable them to enrol in and deliver the active leadership programme, with a specific focus on the effective delivery and embedding of the “Brilliant Basics” framework.
    Date: 28 February 2027.
    

(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 December 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 multiple Treatment works across the CAM operating area, 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. Provide evidence of completion of measure (b)1 updating site-specific disinfection policies and (b)2 reviewing drinking water safety plan documentation.
   Date: 31 January 2027.
   
3. Provide evidence of the measures (b)3 review of personnel and (b)4 gap analysis.
   Date: 31 March 2027
   
4. Provide evidence of the implementation of measures to address deficiencies, as required in measure (b)5.
   Date: 30 September 2027.
   
5. Provide evidence of the improvement of training record documentation, as required in measure (b)6.
   Date: 31 May 2028.
   
6. Provide the review, development and implementation of a programme works, as required in measure (b)7.
   Date: 31 January 2028.
   
7. Provide evidence of the completion of the programme of work, as required in measure (b)8.
   Date: 30 April 2028.
   
8. Provide the outcome of the review and measures taken, as required in measure (b)9.
   Date: 31 March 2027.
   
9. Provide the outcome of the review and the implementation of any improvements identified, as required in measure (b)10.
   Date: 31 January 2027.
   
10. Provide the outcome of the review, and any improvements implemented, as required in measure (b)11.
    Date: 30 June 2027.
    
11. Provide the OT ICA Compliance Framework and provide evidence of its implementation, as required in measure (b)12.
    Date: 31 March 2027.
    
12. Provide evidence of the development and delivery of the active leadership programme, as required in measure (b)13.
    Date: 31 December 2026.
    
13. Provide evidence of the embedding of the active leadership programme, as required in measure (b)14.
    Date: 31 March 2027.
    
14. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: 31 January 2027.
    
15. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision.
    
16. 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.
    
17. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 31 May 2029.
    

Further Details of this Notice:

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

Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
28 October 2026
Reference: SST-2026-00001 v1