The Private Water Supply The Private Water Supply (Scotland) Regulations 2006(Scotland) Regulations 2006

Perth and Kinross CouncilPerth and Kinross CouncilEnvironment ServiceEnvironment Service

Mary AndersonMary Anderson

OverviewOverview

• Background to the new legislationBackground to the new legislation

• Risk Assessment based approachRisk Assessment based approach

• Type A suppliesType A supplies

• GrantsGrants

• Food BusinessesFood Businesses

• Questions welcome throughoutQuestions welcome throughout

Background to the new Background to the new legislationlegislation

• Real risks of ACUTE waterborne illnessReal risks of ACUTE waterborne illness• Bacterial - Campylobacter, Salmonella, Bacterial - Campylobacter, Salmonella,

Shigella, E.coli O157Shigella, E.coli O157• Viral – Hepatitis A and E, small round Viral – Hepatitis A and E, small round

structured (Norovirus etc)structured (Norovirus etc)• Protozoan – Cryptosporidium, Giardia, Protozoan – Cryptosporidium, Giardia,

EntamoebaEntamoeba• Others – Cyanobacteria (Blue Green Algae) Others – Cyanobacteria (Blue Green Algae)

pseudomonas, areomonaspseudomonas, areomonas

• ACUTE effects can include diarrhoea, ACUTE effects can include diarrhoea, sickness, kidney failuresickness, kidney failure

• Unquantifiable risk of CHRONIC Unquantifiable risk of CHRONIC conditions from metals, minerals, conditions from metals, minerals, pesticides etc.pesticides etc.

• Research shows severe under reporting Research shows severe under reporting of illness in rural areas due to stoicism, of illness in rural areas due to stoicism, busy farmers, problems of access etc. busy farmers, problems of access etc.

• Faecal coliforms (E.coli) - the main Faecal coliforms (E.coli) - the main contamination threatcontamination threat

• Human produces 2 billion E.coli per Human produces 2 billion E.coli per dayday

• Seagull - 2 billionSeagull - 2 billion

• Pig Pig - 8.9 billion - 8.9 billion

• Cattle Cattle - 9 billion- 9 billion

• SheepSheep - 18 billion- 18 billion

• E.coli O157 carried by humans, cattle, E.coli O157 carried by humans, cattle, sheep, deer, rabbitssheep, deer, rabbits

• Research by MLURI in Aberdeenshire on a Research by MLURI in Aberdeenshire on a large number of supplies showed that ALL large number of supplies showed that ALL failed at some point throughout the yearfailed at some point throughout the year

• Average failure rate for bacterial samples Average failure rate for bacterial samples throughout Perth and Kinross in 2005 was throughout Perth and Kinross in 2005 was 35% - the majority of the supplies tested 35% - the majority of the supplies tested had treatment on themhad treatment on them

• Failure rate can be 100% with adverse Failure rate can be 100% with adverse weather conditionsweather conditions

Private Supply Sampling 2004

0

50

100

150

200

Month

Num

ber

RAINFALL

NUMBER OF B6 FAILURES

% OF FAILURES

Risk AssessmentRisk Assessment

• Designed to include all types and sizes of Designed to include all types and sizes of supplysupply

• Highlight possible contamination routesHighlight possible contamination routes

• Increase awareness of the potential risks Increase awareness of the potential risks amongst usersamongst users

• Increase awareness of the importance of Increase awareness of the importance of ongoing maintenance of sources and ongoing maintenance of sources and treatment plant treatment plant

• Supplies are individualSupplies are individual

Risk Assessment – a new Risk Assessment – a new approachapproach• Previous legislation relied on infrequent Previous legislation relied on infrequent

sampling to show problemssampling to show problems• Risk Assessment based approach aims to Risk Assessment based approach aims to

reduce overall potential for harm for the reduce overall potential for harm for the whole supply, all year roundwhole supply, all year round

• Aim is to educate users that they need to Aim is to educate users that they need to consider and improve the complete supply, consider and improve the complete supply, reducing sources of contamination throughout reducing sources of contamination throughout and considering treatment as the final stepand considering treatment as the final step

• Result should be health benefits for all of Result should be health benefits for all of those that consume water from private those that consume water from private suppliessupplies

Type A suppliesType A supplies

• Hotels, Restaurants, CafesHotels, Restaurants, Cafes• Campsites and Caravan sitesCampsites and Caravan sites• Self CateringSelf Catering• Public Access such as village and church Halls, Public Public Access such as village and church Halls, Public

Toilets, Visitor CentresToilets, Visitor Centres• Dairy Farms, Deer Larders (?), Butcheries, Dairy Farms, Deer Larders (?), Butcheries,

Smokeries, Home caterers and other food businessesSmokeries, Home caterers and other food businesses• Schools and residential facilitiesSchools and residential facilities• Nurseries and home childmindersNurseries and home childminders• Domestic serving 50 or more persons (20 properties)Domestic serving 50 or more persons (20 properties)

Type A suppliesType A supplies

• Must conform to EC standardsMust conform to EC standards

• Within Type A there are three useage levels:Within Type A there are three useage levels:• 1 – <100m1 – <100m33/day/day• 2 – 100 – 1000 m2 – 100 – 1000 m33/day/day• 3 - >1000m3 - >1000m33/day/day

• The majority of Type A supplies are Level 1, this The majority of Type A supplies are Level 1, this can serve up to 500 userscan serve up to 500 users

• Over 200 Type A supplies in Perth and KinrossOver 200 Type A supplies in Perth and Kinross

Type A supplies – risk Type A supplies – risk assessment and samplingassessment and sampling

• Statutory duty for Local Authority to risk Statutory duty for Local Authority to risk assess all Type A supplies assess all Type A supplies

• Ongoing statutory sampling requirements, Ongoing statutory sampling requirements, frequency dependant on volume used. frequency dependant on volume used. Majority of Type A supplies will be once Majority of Type A supplies will be once per yearper year

• Costs – Risk Assessment £120, Check and Costs – Risk Assessment £120, Check and Audit monitoring Max £580 per year for Audit monitoring Max £580 per year for Type A 1Type A 1

Check MonitoringCheck Monitoring

• Basic bacteriological and chemical Basic bacteriological and chemical parametersparameters

• Once per year for Type A 1 suppliesOnce per year for Type A 1 supplies

• More frequently for Type A 2,3More frequently for Type A 2,3

• Very few exemptions allowedVery few exemptions allowed

Check Monitoring Check Monitoring ParametersParametersItem No Parameter Max Conc.

1 Aluminium 200 μg Al/l

2 Ammonium 0.50 mg NH4/L

3 Clostridium Perfringens (inc spores) 0 per 100ml

4 Coliform Bacteria 0 per 100ml

5 Colony Counts No change

6 Colour 20 mg/l Pt/Co

7 Conductivity 2500 μS/cm at 200C

8 Escherichia coli 0 per 100ml

9 Hydrogen ion (pH) 6.5 - 9.5

10 Iron 200 μg Fe/l

11 Nitrite 0.5 mg NO2/l

12 Odour 3 at 250C

13 Taste 3 at 250C

14 Turbidity 4 NTU

Audit Monitoring ParametersAudit Monitoring Parameters

• Wide range of organic and inorganic parametersWide range of organic and inorganic parameters• Once per year for Type A 1 supplies More Once per year for Type A 1 supplies More

frequently for Type A 2,3frequently for Type A 2,3• Agreement required from Consultant in Public Agreement required from Consultant in Public

Health Medicine with regard to Pesticides etc. Health Medicine with regard to Pesticides etc. • In the main, exemptions are only allowed if it can In the main, exemptions are only allowed if it can

be shown that the parameter is <75% of the be shown that the parameter is <75% of the prescribed concentrationprescribed concentration

• So - we have to sample to prove low levelSo - we have to sample to prove low level• Agreement required from the Consultant in Public Agreement required from the Consultant in Public

Health Medicine before omitting a parameter from Health Medicine before omitting a parameter from future testingfuture testing

Audit Monitoring ParametersAudit Monitoring Parameters

Item No Parameter Max Conc.

1 Acrylamide 0.10 μg/l

2 Aluminium 200 μg Al/l

3 Antimony 5.0 μg Sb/l

4 Arsenic 10 μg As/l

5 Benzene 1.0 μg/l

6 Benzo(a)pyrene 0.010 μg/l

7 Boron 1.0 mg B/l

8 Bromate 10 μg BrO3/l

9 Cadmium 5.0 μg Cd/l

10 Chloride 250 mg Cl/l

11 Chromium 50 μg Cr/l

12 Clostridium Perfringens (inc spores) 0 per 100ml

13 Copper 2.0 mg Cu/l

14 Cyanide 50 μg CN/l

15 1,2 dichloroethane 3.0 μg/l

16 Enterococci 0 per 100ml

17 Epichlorohydrin 0.10 μg/l

18 Fluoride 1.5 mg F/l

19 Iron 200 μg Fe/l

20 Lead 25 μg/l

Audit Monitoring Parameters Audit Monitoring Parameters cont.cont.

21 Manganese 50 μg Mn/l

22 Mercury 1.0 μg Hg/l

23 Nickel 20 μg Ni/l

24 Nitrate 50 mg NO3/l

25 Nitrite 0.50 mg NO2/l

26 Pesticides  

  Aldrin 0.030 μg/l

  Dieldrin 0.030 μg/l

  Heptachlor 0.030 μg/l

  Heptachlor epoxide 0.030 μg/l

  other pesticides 0.10 μg/l

27 Pesticides - Total 0.50 μg/l

28 Polycyclic Aromatic Hydrocarbons (PAH) 0.10 μg/l

29 Selenium 10 μg Se/l

30 Silver 10 μg Ag/l*

Audit Monitoring Parameters Audit Monitoring Parameters cont.cont.

31 Sodium 200 mg Na/l

32 Sulphate 250 mg SO4/l

33 Tetrachloroethene and Trichloroethane 10 μg/l

34 Tetrachloromethane 3 μg/l

35 Total indicative dose 0.10 mSv/year

36 Total organic carbon mg C/l

37 Trihalomethanes - Total 100 μg/l

38 Tritium 100 Bq/l

39 Vinyl Chloride 0.50 μg/l

40 Zinc 5000 μg/l

The Grants SchemeThe Grants Scheme

• The Private Water Supplies (Grants) The Private Water Supplies (Grants) (Scotland) Regulations 2006(Scotland) Regulations 2006

• Available to nearly all properties Available to nearly all properties served by a private water supplyserved by a private water supply

• Open to owner occupiers, landlords, Open to owner occupiers, landlords, tenantstenants

• Up to £800 per propertyUp to £800 per property

Grants Scheme - Grants Scheme - exemptionsexemptions

• We cannot issue grants - We cannot issue grants -

• retrospectively for works which are retrospectively for works which are already started or completedalready started or completed

• to allow users to connect to the to allow users to connect to the public mains water supplypublic mains water supply

• to certain people/propertiesto certain people/properties

Food Businesses on PWSFood Businesses on PWS

• Food business = Commercial activity, Food business = Commercial activity, therefore Type A supply under PWS therefore Type A supply under PWS RegsRegs

• Exemptions – no affect on final product, Exemptions – no affect on final product, dairy farms?, coffee grinders?, deer dairy farms?, coffee grinders?, deer larders? – FSA ‘guidance’ ?larders? – FSA ‘guidance’ ?

• Currently over 90 in Perth and KinrossCurrently over 90 in Perth and Kinross

Inspections – Info to Inspections – Info to gather/assess?gather/assess?

• Consider use of water? Clients/staff/family/activities/food Consider use of water? Clients/staff/family/activities/food operationsoperations

• Query source of water e.g. burn versus borehole?Query source of water e.g. burn versus borehole?

• Treatment available? Point of use > point of entry=grant Treatment available? Point of use > point of entry=grant available, advise water team.available, advise water team.

• Sample results retained/reviewedSample results retained/reviewed

• Maintenance records (FSMS, example form)Maintenance records (FSMS, example form)

• Contingency plan re failures, temporary only (FSMS record) Contingency plan re failures, temporary only (FSMS record)

• Poster displayed? Poster displayed?

Informal/Formal Action?Informal/Formal Action?

• Educate/adviseEducate/advise

• Liaison with Water Team/Food TeamsLiaison with Water Team/Food Teams

• Enforcement- better mechanisms under pws regs, Enforcement- better mechanisms under pws regs, but food legislation may be easier re but food legislation may be easier re improvements notices?improvements notices?

• Questions?Questions?

In ConclusionIn Conclusion

• The main aim is to safeguard the health of private water The main aim is to safeguard the health of private water supply users whether they inhabit or visit Perth and supply users whether they inhabit or visit Perth and KinrossKinross

• More information available from the Environment Service More information available from the Environment Service 01738 47647601738 476476

• www.privatewatersupplies.gov.ukwww.privatewatersupplies.gov.uk• The full Regulations can be viewed online at:The full Regulations can be viewed online at:• http://www.opsi.gov.uk/legislation/scotland/http://www.opsi.gov.uk/legislation/scotland/

ssi2006/20060209.htm ssi2006/20060209.htm

• Questions WelcomeQuestions Welcome