Notice of Regulation: Thames Water – Training and Competency

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

Thames Water Utilities Limited: Training and Competency

Reference: TMS-2020-00004

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Thames Water Utilities Limited, with registered number 02366661 (hereinafter called ‘the Company’).

Assets affected:
All catchments, water treatment works, service reservoirs and zones in the Thames Water Utilities supply region.

The Drinking Water Inspectorate (‘the Inspectorate’) has on 19th October 2017 received multiple regulation 28(1) reports of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company, 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 that could constitute a potential danger to human health or could be unwholesome.
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:

For risks associated with:

Competency, accountability, roles and responsibilities of Company personnel
Competency, management and supervision of third-party contractors
Training procedures for water quality and human health protection

The Company are required to satisfy the following:

Requirements

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

All new Water Quality, Network, Production, Control and Operational Contact Centre personnel (at all levels) to be trained in accordance with Company procedures.
Date: Ongoing for the duration of the Notice

(b) to review, revise or make operational the following measures, by the dates specified in each case:

Competency, Accountability, Roles and Responsibilities

- a) Complete a critical review of competency within the Water Quality, Network, Production, Control and Operational Contact Centre teams to establish that relevant competencies are matched to defined roles. This review must include:
  Date: Complete
  - A gap analysis of current competency levels;
  - A targeted gap analysis of current competency levels for personnel responsible for slow sand filter operation and maintenance;
  - 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 ‘Licence to Operate’ process and its effectiveness to ensure staff are competent in the roles they are required to complete, before undertaking work on the treated water network.
- b) Identify any measures required to address the findings of the critical review completed under measure (b)1.a) above.
  Date: Complete
- c) Implement any required measures identified under measure (b)1.b) above. – Water Networks: Complete- Water Production: 31 December 2021- Control Team:
  Date: Complete- Operational Contact Centre Team: 31 December 2021
- a) Complete a critical review of third-party contractors’ competency to establish that relevant competencies are matched to defined roles.
  Date: Complete
- b) Review arrangements for the Company’s management and supervision of thirdparty contractors whilst carrying out activities on the Company’s behalf and whilst on Company premises.
  Date: Complete
- c) Identify any measures required to address the findings of the reviews completed under measure (b)2.a) and b) above.
  Date: Complete
  d) Implement any required measures identified under measure (b)2.c) above.
  Date: Complete
- a) Complete a critical review of staff actions, ownership, responsibilities, accountability and communication (including the escalation of potential water quality related issues) during water quality critical situations.
  Date: Complete
- b) Identify any measures required to address the findings of the critical review completed under measure (b)3.a) above.
  Date: Complete
- c) Implement any required measures identified under measure (b)3.b) above.
  Date: Complete

Training

- a) Complete a critical review of the Company’s training procedures to ensure that water quality and human health protection activities are fit for purpose.
  Date: Complete
- b) Identify any measures required to address the findings of the critical review completed under measure (b)4.a). This must include:
  Date: Complete
  - Implementation of improved training record documentation;
  - Implementation of an on-going system to ensure relevant personnel are re-trained following the revisions of policies, procedures or systems (including revisions made following the completion of measures in section (b));
  - Implementation of a fit for purpose externally led training course for all Network and Production Managers to provide key technical knowledge around water quality, network and water treatment processes.
- c) Implement any required measures identified under measure (b)4.b) above.
  Date: 31 December 2021

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

Define a strategy for auditing the effectiveness of the measures being delivered in section (b). This must:
Date: Complete
- 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 competency and training; and
  - Permit continuous learning and development beyond the life of this Notice.
- c) On an annual basis review the training and competency requirements for each role in the risk assessment process.
- d) Include how the Company intends to measure the success (including cultural changes) of the delivery of the section (b) measures.
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:

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:

Provide a progress report annually by 31 January and against the following milestones:
Date: Annually by 31 January
- a) Report outlining the implementation of the required actions under measures (b)1.c) for Water Production and the Operational Contact Centre Teams.
  Date: 31 January 2022
- b) Report outlining the completion of measure (b)4.c).
  Date: 31 January 2022
Submit the strategy for auditing the effectiveness of the measures, as specified in (c)1.
Date: Complete (30 October 2020)
Submit any revisions of the audit strategy produced under measure (c)2.
Date: Within 1 month of a revision
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
Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
Date: 31 January 2023

Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
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.
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
Laura Moss
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
06 January 2022
Reference: TMS-2020-00004
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