Guidance For Providing Safe Drinking Water in Areas of Federal Jurisdiction - Version 1

Part 2 - Application of The Federal Framework

7.0 Operational Requirements

Federal departments and First Nations may benefit from the use of a quality management framework to manage their drinking water systems. A framework can assist in coordinating existing or new operational activities, setting priorities and making decisions. It can provide a mechanism to identify and manage risks, apply and introduce measures for prevention and achieve continuous improvement. Such frameworks could include approaches such as HACCP (Hazard Analysis and Critical Control Points).⁽²¹⁾

7.1 Operational plans

An operational plan, specific to each individual drinking water system, must be prepared for each drinking water system or facility. Generic plans could be developed at a departmental level for office buildings serviced by municipal water. For leased buildings and/or office space, the department would need to negotiate with the other party to determine who is responsible for developing the plan. This responsibility should be clearly laid out in the lease.

The purpose of an operational plan is to characterize the capability of the system to provide safe drinking water, identify areas requiring improvement, and to allow the implementation of corrective actions where necessary.

The operational plan for each facility should include detailed guidance/instructions related to monitoring, as well as for reporting and record-keeping and should be developed in consultation with the system designer. In addition, operational plans should include:

• A system assessment noting where barriers are or should be in place
• The identification of all activities and processes essential to the control of water quality (critical control points), including a list of preventative maintenance activities;
• The identification of operational controls for each critical control point. This includes the monitoring methods for these controls to ensure proper performance and to trigger corrective actions in a timely fashion when required.

The operational planning process should include management and operational staff so specific, realistic, written operational procedures can be developed. The operational plan should be revisited through audit, inspection, or self assessment cycles in order to continuously improve the system over time. The operational plan is intended to be revised as technologies, methods, and/or risks change.

The detailed content of the operational plan forms the foundation for the quality management of the drinking water system.

7.2 Training and certification

All staff or personnel involved in drinking water quality management must be adequately trained for their role and function(s). This includes personnel whose duties relate only to distribution systems, including plumbing. Training should be planned, executed and documented on a continuous basis, and must be directly applicable to and appropriate to the person's specific job and the type of facility being operated or managed (e.g., its classification, the size of the population served, the complexity of operation and the source of raw water). Specific mechanisms should be developed for evaluating the appropriateness and effectiveness of the training.

Management must support initial and on-going training and provide a training budget. Federal departments and First Nations communities should provide opportunities for their operators to participate in approved training.

Many well-recognized training programs are available for drinking water treatment operators. Training sessions can range in rigour from educational seminars to certification courses with written examinations.

All operators are encouraged to participate in on-going training in an organized, continuing education setting under responsible sponsorship, capable direction, and qualified instruction.^{7 (39)} This training may include formal classroom training, conferences, online and interactive presentations, seminars or hands-on workshops or training sessions. It can include training on new or revised operating procedures, reviews of existing operating processes, safety training, computer training and/or training in related environmental or technical areas.

It is especially important for operators of very small systems to meet one another and develop network contacts amongst their peers. These relationships can facilitate the use of best practices and encourage continuous improvement.⁽²⁾

It is recommended that federal departments follow the Association of Boards of Certification (ABC) system for classification of facilities and certification of operators, used by most other Canadian jurisdictions. ABC has developed a designation for very small systems (defined by ABC as serving a maximum population of 100) which may be applicable to many federal or First Nations facilities.

Regardless of whether an operator is certified, training is essential. Operators of federal drinking water treatment facilities must be trained to the appropriate level for their facility.⁸

In the case of less complex treatment systems (i.e., a liquid chlorinator with no further treatment), operators may participate in system-specific training which would provide a site-specific equivalent to a certification for this role only. Such a certificate would not be recognized as valid at other facilities.

Initially, operator certification should be encouraged on a voluntary basis. Over time, certification should become a mandatory requirement, though this may not be possible in some situations such as in Canadian diplomatic missions overseas. For departments with an "equivalent to certified" program, mandatory certification may not be required, but operators should aim to have an equivalent amount of training as their certified counterparts.

7.3 Monitoring

Monitoring the treated water helps assess the effectiveness of the treatment and determine the presence and concentration of disinfection by-products. Operational monitoring will help ensure the plant is operated effectively, while compliance monitoring ensures the water leaving the plant and distribution system meets the established requirements, typically the Guidelines for Canadian Drinking Water Quality.

Sampling at various points in the distribution system will indicate the quality of water reaching consumers at the tap and identify problems which may arise due to faults with the distribution system. ^{(17, 20)}

Specific guidance regarding sampling frequencies, locations, and the interpretation of results is found throughout Section 4.

Parameters and frequency of sampling are dependent on many contributing factors including water source, historical results, population served, building factors, and local conditions. Routine monitoring should be performed to yield an overall understanding of the drinking water quality, protect consumers and increase acceptance and confidence in the water supply. Routine monitoring results can also serve as background data and can be used to compare water quality from one year to the next.⁽⁵¹⁾

7.3.1 Operational monitoring

Operational monitoring practices focus on critical control points in the drinking water system to ensure the system is being operated as required. This type of monitoring allows the operator to detect changes in water quality and adjust the treatment process accordingly. In addition, increased monitoring during extreme conditions yields important information on the ability of the system to cope, and assists in identifying required improvements. Where feasible, continuous monitoring at plants is recommended for some parameters (e.g., chlorine residual, turbidity).

Tests for operational monitoring do not need to go to an accredited lab.

Operational monitoring strategies:

• Are system specific.
• Are developed in the operational plan.
• Facilitate more comprehensive documentation of the system.
• Foster due diligence.

7.3.2 Compliance monitoring

Compliance monitoring ensures drinking water reaching consumers meets established requirements. Every facility will need to develop their monitoring program based on the results of the vulnerabilities assessment, sanitary survey and baseline chemical analysis. In addition, many federal departments and First Nations communities have their own documents and/or directives that provide guidance on sampling frequency and related monitoring issues. The guidance in this document is meant to complement existing protocols.

Federal facilities that receive water from a municipal source will usually have to monitor only a few parameters that may be affected by the facility's plumbing (e.g., lead levels). Regardless, it is important to be aware of issues related to the municipal water source and obtain water quality reports from the municipal purveyor. Federal facilities and facilities in First Nations communities that supply and treat their own drinking water will have to implement a more comprehensive monitoring program.

In addition to making sure water entering federal facilities is of acceptable quality, federal staff are responsible for ensuring water does not become contaminated once it enters the facility (e.g., through leaching of metals from pipes). Results of water testing within the building should be compared with the results of testing at the treatment plant or in the distribution system (municipal or federal), conducted during the same time period, in order to identify any discrepancies. All discrepancies should be investigated and remedial actions taken as appropriate.

Sampling procedures for bacteriological parameters, lead and copper are described in "National Drinking Water Sampling Procedures"⁽²⁶⁾ prepared by the Occupational Health and Safety Agency (now called Workplace Health and Public Safety Programme). Collection and preservation of any other samples should use procedures (collection, preservation, storage and shipment) recommended by the accredited laboratory analysing the samples.

7.3.2.1 Laboratory accreditation for compliance monitoring

When testing and analysing water samples (with the possible exception of E. coli and total coliforms under the conditions outlined below), federal departments or, in the case of First Nations communities, managers and operators of facilities and technical support personnel, must use a laboratory accredited by one of the following: Canadian Association for Environmental Analytical Laboratories (CAEAL), the Standards Council of Canada (SCC), or, in Quebec, the Programme d'accréditation de laboratoires d'analyse environnementale (PALAE).⁽²⁶⁾ SCC/CAEAL defines accreditation as "the formal recognition of the competence of a laboratory to carry out specific tests."⁽¹⁴⁾ Accreditation is awarded to a laboratory for each individual test, e.g., the analysis of pesticides in drinking water.⁽⁵¹⁾

A list of CAEAL accredited labs is available on-line at http://www.scc.ca/certific/labs

Canadian missions in other countries should use laboratory services accredited as meeting the International Organization for Standardization (ISO) standard IEC17025-1999, General Requirements for Competence of Calibration and Testing Laboratories.

A list of accredited laboratories worldwide can be found at http://www.ilac.org under the heading "Directory."⁽²⁴⁾

In the case of compliance monitoring for some microbiological parameters (i.e. E. coli and total coliforms), managers and/or operators of facilities may allow trained personnel to use portable test kits rather than an accredited laboratory. However, in order to ensure quality control, a minimum of 10% of all samples must be sent to an accredited lab for analysis or, if this is not physically possible, additional samples should be analysed using the kit for quality control purposes. Also, if using field-type kits, each new batch should be tested for accuracy.

Test kits should meet minimum requirements for accuracy and detection (sensitivity) for the contaminant of interest. When using test kits for monitoring purposes, the operator must ensure instruments are calibrated and reagents are not past their due date.

7.4 Operation of groundwater systems

Operating a groundwater system consists mainly of taking necessary measurements, maintaining yield, and preventing contamination.

In general, wells should be pumped within specific pumping rates. When there is more than one well they should be operated in rotation, if possible, to equalize wear on pumping equipment. If specified pumping rates are exceeded, sand and silt may pack in and around the well screen and clog it or may fill the voids in gravel-wall wells, reducing yield. Frequent starting and stopping of a well pump causes agitation in the aquifer around the well and may wash out sand or gravel, causing clogging or cave-ins that will reduce the yield. Any requirement for altering pump operation methods can be determined from well performance records and the quality of water produced.⁽³⁹⁾

It is good practice to monitor the quantity of water produced from a well over time to verify that the pump is working properly and the well yield is not dropping. Some of these activities can be completed by installing a water meter at the well head and routinely reading it. Static and operating water levels should be measured and plotted to determine if a trend exists over time.

7.5 Records and record-keeping

Maintaining a system of documentation is essential to quality management. Monitoring all operational and compliance aspects of a drinking water system establishes on-going verification that the water is safe to drink and the operational plan is being followed.

Documentation is equally important as a tool for verifying that training activities are taking place and that corrective actions have been taken as required. It also helps track the continuous improvement of operations or policies. Comprehensive documentation is a fundamental requirement in the event that any operator or manager should be required to make a case for due diligence.

Finally, well-maintained documentation facilitates a more effective and meaningful audit process which in turn leads to continuous improvement of the managerial and operational strategy to provide safe drinking water.

All records, including "as built" construction records, should be maintained. Records related to policy and procedures must be retained for a minimum of 5 years and all other "routine" records must be maintained for 2 years.⁽³⁷⁾ Where feasible, at a minimum, the following records must be kept for every federal facility:

• Reports from the municipality on the quality of drinking water from the municipal system (if municipally supplied water)
• Results of all bacterial and chemical analyses
• All recorded chlorine residual and turbidity levels
• A summary of analytical results obtained during the year, in table format (a sample table is included in Appendix 6)
• Reports of in-house operational procedures tests
• Correspondence
• Communications protocols
• Maintenance reports
• Assessment reports ⁽²⁷⁾
• Operational and maintenance manuals and "as-built" design drawings, including "life history cards" (these files contain data about each piece of equipment in the water system, including the date and conditions of installation, types of material, record of service problems/performance, and costs of operation and maintenance)
• Manufacturer's information for each piece of equipment ⁽³⁹⁾
• Reports of any incidents, including remedial and emergency measures, boil advisories, shock chlorination, etc.
• Auditor's reports
• A record of corrective actions taken as part of operational controls, or in the event of non-compliant finished water
• Training records, including test results, relevance of training, and validation of the source of training

7.6 Incident and emergency response plans

Federal purveyors of drinking water and, in First Nations communities, Chief and Council, must prepare and maintain written emergency and incident response plans to deal with events which occur outside of normal operating conditions. Such plans should also identify potential events. The water purveyor's response and remediation strategy will depend on the type of event affecting the water system.⁽²⁾

Events that a water system purveyor should plan for include weather events, natural disasters, unplanned human activities, line breaks, valve replacements, or extended electrical power outages. Any work on wells, standpipes, and distribution systems must follow proper disinfection procedures as described in the latest edition of American Water Works Association C650 series standards (C651-92, C652-92, C653-97, C654-87).

To address cases of a suspected/confirmed (see Section 4) event of microbiological contamination, the plan should include the possibility that a boil water advisory may need to be issued. Details about issuing and rescinding advisories are given in the box below.

It is important to remember that boil water advisories are not effective against chemical and radiological concerns. In cases of chemical contamination, water will need to be treated or an alternative source of drinking water will need to be found until the situation can be remedied. Incident response protocols should be established with the understanding that notification and reporting must be compatible with existing provincial / territorial approaches. These reporting relationships should be established well in advance and are fundamental to public health protection and due diligence. This type of integrated information sharing is typically the trigger for implementing appropriate response and keeps all agencies properly informed whether the incident originates at a federal facility or municipal supply.

7.7 Audits

A third party (i.e., an external evaluator) should evaluate and audit all federal drinking water facilities every three to five years to ensure that the quality of water and the service provided by the water facility is maintained. In some cases, such as in diplomatic missions overseas, this type of audit may not be feasible.

An audit can involve three phases, including planning, conducting the audit, and compiling the final report.

Prior to conducting an audit, there should be a detailed review of the water system. The review should pay particular attention to past audits and documentation describing previously identified problems and solutions. Other information to review includes: general documentation, water system plans, chemical and microbiological sampling results, operating reports, and engineering studies. This review will help auditors become familiar with the system's history and present conditions.

The pre-audit file review should generate a list of items to check in the field, and a list of questions about the system. It will also help to plan the format of the audit and to estimate how much time it may take. The next step is to make the initial contact with the system management to establish the survey date(s) and time. Any records, files, or people to be referenced during the audit should be mentioned at the outset.

The initial phase of the audit is a review of the purveyor's monitoring records to verify compliance with applicable microbiological, chemical, physical and operational parameters and radiological guidelines. The audit should provide an opportunity to review these records with the purveyor, and to discuss solutions to any parameter in non-compliance. The audit also provides an opportunity to review how and where samples are collected, and how field measurements (e.g., turbidity, chlorine residual) are made.

The on-site portion of the audit is the most important and involves interviewing management as well as operators and other technical people. The audit should review all major system components from the treatment point to the end of the distribution system.

An auditor should evaluate all water treatment processes in use at the water system. This evaluation should consider the design, operation, maintenance, and management of the water treatment plant to identify existing or potential risks. The treatment and other processes should be assessed against their ability to continually meet the requirements of the federal drinking water program.

Ideally, as the audit progresses any observed deficiencies would be brought to the attention of the water system personnel, together with a discussion of suggested corrective measures. At the very least, this should be done at the end of the audit, prior to writing the final report.

The final audit report should be completed as soon as possible to formally notify the purveyor and/or the regulator of the findings. The report may be used for future compliance actions and inspections.

Ideally, the final report provided by the auditor should include the following elements:

• The date of the survey
• Names and titles of the people who were present during the survey
• The findings of the survey
• Recommended improvements to identified problems
• Recommended dates for completion of any improvements.⁽²⁾

⁷ Based on the definition of continuing education unit (CEU)" registered to the Council on the Continuing Educational Unit in Washington DC.

⁸ For more information on the ABC system, see http://www.abccert.org