Drinking water 2015

Drinking water2015Private water supplies in England

July 2016A report by the Chief Inspector of Drinking Water

P r iva te water supp l i es in Eng land

1

Drinking water 2015

Private water supplies in England

Dr ink ing wate r 2015

2

Publ ished by

Dr ink ing W ater Inspectorate

Area 7e

9 Mi l lbank

c/o Nobel House

17 Smith Square

London

SW 1P 3JR

Tel: 0300 068 6400

Website: http: / /www.dwi.gov.uk

© Crown Copyr ight 2016

ISBN: 978-1-911087-02-1

Copyr ight in the typographical arrangement and des ign rests wi th the Crown.

This publ icat ion (exc luding the logo) may be reproduced f ree of charge in any

format or medium provided that i t is reproduced accurate ly and not us ed in a

misleading context . The mater ia l must be acknowledged as Crown copyr ight wi th

the t i t le and source of the publ icat ion spec if ied.


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Contents

Chapter 1: Summary 4

Chapter 2: Number and nature of private water suppl ies in

England

8

Chapter 3: Improving private water supplies 14

3.1: Risk assessments 14

3.2: Risk management 20

3.3: Review of Notices 22

3.4: Risk management case studies 26

Chapter 4 Summary of research on private water supplies 51

Chapter 5: Drinking water test ing results 56

5.1: Local authority progress in report ing test results 56

5.2: Results of 2015 monitor ing 57

Chapter 6: Legislat ive updates 69

6.1: Revised Private Water Supply Regulat ions 2016 69

6.2: Review of local author ity publ ished charges 72

Annex 1: Numbers of supplies, r isk assessments and

evidence of monitoring and enforcement

77

Annex 2: Summary of monitoring data for England and Wales 98

Annex 3: Guidance and technical advice 104

Annex 4: Enquir ies about pr ivate water supplies handled

by the Inspectorate

105

Annex 5: Glossary and descript ion of standards 106


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Chapter 1: Summary

Chapter 1:

Introduces the reader to the report and its contents.

Summarises changes in numbers of private suppl ies .

Puts the qual ity of private suppl ies in contex t relat ive to publ ic

suppl ies.

Reports on the performance of local authorit ies in making returns.

Indicates the extent to which local author it ies are exercising powers

to improve fai l ing private suppl ies.

Records the Inspectorate’s support of local author i t ies in answering

enquir ies and providing technical advice.

Drinking water 2015 is the annual publicat ion of the Chief Inspector of

Drinking Water for England and Wales. I t is the 2 6 t h report of the work of

the Inspectorate and presents information about dr inking water quality for

the calendar year of 2015. I t is published as series of seven reports, f ive

of which cover publ ic water suppl ies and two descr ibe private water

suppl ies. This report is about private suppl ies in England.

This report describes the key facts about private suppl ies in England. This

report is the f if th of its type and presents information based on the

updated private supply records provided to the Inspectorate by local

author it ies in January 2016. Due to the geographical dispersion o f private

suppl ies across the country the information in this report is general ly

presented by grouping local authority information into nine geographical

regions as i l lustrated in Figure 1. The more detailed information about

private suppl ies in each individual local author ity area can be found in

Annex 1 .


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Figure 1: Reporting regions

In 2015, local author ity records contained the details of a total of 3 9,017

private suppl ies in England, 66% of which serve a single household. In

England, over 850,000 l ive or work in a premises that rel ies on a private

supply. Whereas the quality of public water suppl ies in England in 201 5

was very high, with only 0.04% of tests fai l ing to meet the European Union

(EU) and national standards, the qual ity of private water suppl ies remains

a concern, with 4.5% of tests fail ing to meet the standards in 2015.

Nonetheless, this f igure represents an improvement when compared to the

9.6% of tests that failed in 2010, the year when report ing for private

suppl ies was f irst in troduced.

The results of test ing during 2015 demonstrate that private supplies in

England and Wales, while showing an overal l improvement over previous

years, cont inue to be of unsafe microbiological qual ity, with 8.9% of

samples containing E.col i and 10.2% containing Enterococci. Fai lures of

these two standards mean that the water supply is contaminated with

faecal matter and there is a r isk that harmful pathogens wil l also be


6

present. More detai led information about private supply test results can be

found in Chapter 4 and Annex 2.

Chapter 2 of this report contains information about the dif ferent types of

private suppl ies throughout England and Wales. Unfortunately, one local

author ity in England (Harlow Counci l) has failed to comply with Regulat ion

13 by not providing a val id annual return to the Inspectorate in 2015.

Similarly, one local author ity in Wales (Denbighshire County Counci l)

refused to provide a data return for 2015 cit ing resource constraints. The

Inspectorate wrote to the Council highlight ing the statutory nature of the

return.

The records show that in 2015 there were 406 pr ivate suppl ies (345 in

England 61 in Wales) that are a potent ial danger to human health where

local author it ies had to require the owners to make improvements and take

steps to protect publ ic health. This represents a signif icant reduction in

r isk management act ivity in Wales compared to 2014, but a sl ight increase

in act ivity in England, when act ion to safeguard public health was taken in

relat ion to 491 pr ivate suppl ies (326 in England 165 in Wales). In England,

almost two-thirds (64%) of these fail ing private suppl ies are large suppl ies

or suppl ies to commercial or public premises. More information about

fail ing private water suppl ies can be found in Chapter 3 together with eight

new case studies with learning points.

Chapter 3 also summarises the progress that local author it ies have made

towards compliance with Regulat ion 6 (duty to carry out a r isk assessment

within f ive years of each private supply other than a suppl y to a single

dwell ing not used for any commercial act ivity and not a publ ic bui lding).

Across England and Wales as a whole, the number of private suppl ies that

had been r isk assessed was 9,945 (8,075 in England, 1,870 in Wales)

cover ing over two-thirds (65%) of all relevant private supplies. This

compares favourably to the situat ion publ ished in Drinking water 2014

where it was reported that less than two-thirds (60%) of relevant private

suppl ies had been r isk assessed af ter f ive years and represents a year on

year improvement . However, this increase is largely due to r isk

assessments carr ied out in England which have increased by 1,357 in

2015. Local authorit ies in England st i l l have 39% of assessments to do

while in Wales there are only 13% of assessments requir ing complet ion. A

detai led breakdown of performance on r isk assessment at local authority

level is provided in Annex 1 . Overal l, this information shows that 116 local

author it ies (13 in Wales) have fully complied with the duty to r isk assess

al l relevant suppl ies in their area. In the annual data returns received for

2015, the Inspectorate identif ied a number of authorit ies who had ‘reset’

their r isk assessment progress to zero interpret ing the process as

restart ing on the commencement of each f ive-year per iod. In these cases

the Inspectorate l ia ised with the author it ies involved to correct the data


7

return, but there may be others who were not ident if ied. The Inspectorate

reminds local author i t ies that only r isk assessments completed within the

f irst year of the current regulatory regime were due for revision in 2015,

and all r isk assessments conducted between 2011 and 2014 remain val id,

unless changes to the supply require them to be reviewed ear lier than the

f ive-year review cycle.

During 2015, the Inspectorate has cont inued its advisory service to local

author it ies and private supply owners or users who make contact with an

inspector through the Inspectorate’s website or publ ic phone enquiry l ine.

Annex 4 shows how the enquiry rate init ial ly increase d in 2011. This

coincided with the publ icat ion of Drinking water 2010 , the f irst ever report

on the qual ity of private suppl ies in England, which made transparent the

poor qual ity of private suppl ies and explained the new Regulat ions that

were being implemented to address the issue.

During 2015 inspectors handled 428 contacts (compared to 495 in 2014)

and detai ls about the use of the enquiry service in England since 2008 can

be found in Annex 4 . I t has been notable that there has been a r ise in the

number of contacts from private supply owners or their legal

representat ives year-on-year (61 compared to 43 in 2014 and 11 in 2013).

Addit ional ly, the Inspectorate supports supply operators, the majority of

contacts coming through the DWI enquiry l ine.

The Inspectorate continues to provide support to local author i t ies and in

2015 enquir ies f rom local author it ies in England decreased from 348 to

269 and stayed the same for Wales (26 in 2014 to 27 in 2015). The

Inspectorate also provides its private supply r isk assessment tool which is

being widely used by local authorit ies and their contractors. This is

provided under a non-commercial government l icence protect ing the

intel lectual property f rom 2013.

During 2015 three research projects relevant to private water suppl ies

were completed, and summaries of this research can be found in Chapter

3. Defra and the Welsh Government transposed the Euratom Direct ive into

the Private Water Suppl ies Regulat ions and in England the opportunity was

taken to consolidate exist ing amendments and make a number of changes

to other parts of the Regulat ions. Af ter consultat ion, revised guidance was

draf ted and issued. Details of the key changes to the Regulat ions can be

found in Chapter 5.


8

Chapter 2: Number and nature of private water supplies in England

The Regulat ions classify pr ivate water suppl ies according to their s ize and

usage. These two factors denote their status in relat ion to the monitor ing

and report ing requirements of the European Union (EU ) Drinking Water

Direct ive. Large suppl ies, and suppl ies of any size serving publ ic premises

or used in a commercial act ivity, comprise those that fall in scope of EU

monitor ing and report ing whereas for small, shared domestic supplies such

report ing is voluntary at the present t ime. Supplies serving only single

domestic premises are exempt f rom monitoring unless the owner or

occupier requests this. The Regulat ions also recognise another category of

private supply, where a person or organisation other than a l icensed p ubl ic

water suppl ier further distr ibutes water that originates f rom a public

supply. These supplies require monitor ing as determined by a r isk

assessment. The tables in this chapter summarise the number and nature

of each type of private supply der ived f rom the returns provided by local

author it ies in January 20161. Anyone wishing to understand these f igures

in the context of a part icular local author ity area should refer to Annex 1 , a

look-up table l ist ing the f igures and other information by each local

author ity in England and Wales.

In England, 40 local author it ies missed the deadl ine of 31 January 2016

for submitt ing a data return, and two (Daventry Distr ict Council and

Gedling Borough Council) were so late that some or all of their data could

not be inc luded in the report. Only one local author ity (Har low Counci l) did

not submit a return for 2015. Sample data was missing f rom 23 local

author ity returns for Regulat ion 9 suppl ies, which are reportable to the

European Commission.

From Table 2 it can be seen that in 2015 there were 73,214 private

suppl ies in the whole of the UK, of which 39,017 were in England. Dur ing

2015, 1,300 pr ivate suppl ies were added to the register in England, f rom

1 On rece ip t o f re t urns f rom loca l autho r i t ies the Ins pec tora te ca r r i es out checks and makes

changes where the re a re obv ious e r ro rs in re la t i on to the type o f supp ly .

Chapter 2:

Provides details of private supply numbers by type and region.

Summarises numbers of private suppl ies used in the provision of

services to the public .

Reports on the performance of local authorit ies in making returns.


9

the total in 2014 of 37,717 reported in Drinking water 2014 . I t is to be

expected that there wi l l be some year-on-year variat ions in the number of

private suppl ies in England for operat ional reasons (new suppl ies being

commissioned and old suppl ies being abandoned) and the Inspectorate is

sat isf ied that al l local authorit ies have met the basic requirements of

Regulat ion 12 (keeping records) within the period of f ive years al lowed for

implementat ion of the new Regulat ions. The Inspectorate is also satisf ied

that al l but one of the local author it ies in England (Har low Council) have

met the requirements of Regulat ion 13 (notif icat ion of information to the

Secretary of State).

The area of England with the most private supplies (36%) is the South

West of England. There are also signif icant numbers of private supplies in

the West Midlands (16%), the North West (14%), East of England (12%)

and Yorkshire and Humberside (11%). Table 3 also i l lustrates that private

suppl ies can be found anywhere in the country with 12% (4,727) of all

pr ivate suppl ies being located in the other regions o f England.

Looking at Table 2 , and new for this year’s report, detai ls have been

provided of those pr ivate suppl ies used only for a domestic purpose other

than drinking, cooking and personal hygiene (showering and bathing). The

main use of these ‘non -human consumption’ suppl ies for domestic

purposes is toi let f lushing, but this category of supply can also include a

supply used only for clothes washing ( laundry). The separate recording of

this type of private supply is necessary because whi le such supplies are

required to be wholesome (Water Industry Act 1991), the current def init ion

of wholesome in the Regulat ions does not apply. The Inspectorate has

published a study on the outcome of research into the wholesomeness of

water required for these suppl ies (see Chapter 4: Summary of research on

private water supplies ) and has developed a simple r isk assessment tool

for such suppl ies.


10

Table 2: Number of private supplies reported in 2015, by region

Region

La

rg

e s

up

pli

es

an

d

an

y s

ize

su

pp

ly

us

ed

in

a p

ub

lic

bu

ild

ing

or a

co

mm

erc

ial

ac

tiv

ity

Sm

all

, s

ha

re

d

do

me

sti

c s

up

pli

es

Sin

gle

do

me

sti

c

dw

ell

ing

s

Priv

ate

dis

trib

uti

on

sy

ste

ms

Do

me

sti

c p

urp

os

es

– o

the

r

To

tal

East Mid lands 188 202 945 10 0 1,345

West Mid lands 584 618 4,929 34 0 6,165

East of England 507 1,239 2,810 25 1 4,582

Nor th East England 388 446 554 1 0 1,389

Nor th W est England 1,036 1,033 3,363 8 0 5,440

Yorkshire and Humbers ide

775 998 2,465 4 2 4,244

London and South East

380 367 1,191 31 24 1,993

South W est England 2,437 1,874 9,495 43 10 13,859

England total 6,295 6,777 25,752 156 37 39,017

Wales total 1,203 924 11,719 11 36 13,893

Northern Ireland* 134

Scotland* 20,170

*2014 data f rom the dr ink ing water regu la tors fo r Scot land and Nor thern I re l and. Data exc ludes fo r loca l author i t ies that d i d not prov ide a re t urn in t ime for inc l us ion or whose data cou ld not be l oaded due to e r rors .

Table 2 i l lustrates how two-thirds (66%) of all pr ivate supplies in England

serve a single domestic dwell ing. Apart f rom recording the locat ion of this

type of supply, local author it ies are not currently required to r isk assess

and check the quality unless requested to do so by the owner, or if the

supply comes to the attention of environmental health professionals for

some other reason, for example, where there is a change of ownership or

use, or a complaint about quality or suf f iciency. Accordingly, less is known

about these suppl ies and they have been excluded from the other tables in

this chapter describing the character ist ics of private su ppl ies. Of the

remaining 13,265 suppl ies, 13,072 require r isk assessment and monitoring

because they are either large suppl ies or supplies of any size used in the


11

provision of services to the public (15%) or small, shared domestic

suppl ies (17%). Suppl ies via piped systems that further distr ibute mains

water and domest ic purposes (other) require r isk assessment on which any

monitor ing should be based.

Table 3 provides more detai l about the private suppl ies in England used to

provide water for drinking, cooking and washing as part of a publ ic or

commercial act ivity. In 2015, local author it ies reported an addit ional 2,177

such supplies (a total of 7,440 compared to 5,263 in 2014). Around three -

f if ths (61%) of these supplies are used by the tourism and leisure sector

(hotels, bed and breakfast accommodation, campsites, and hostels),

represent ing the majority of the increase in this type of supply. Of the

remainder, around a f if th serve food premises (22%) and 15% supply

public buildings. These f igures reinforce the important contr ibut ion that

private suppl ies make to the economy of England (part icular ly in the North

West and the South West regions, which account for over half (51%) of all

the private suppl ies used in the provision of services to the publ ic). Tab le

3 also highlights where highly vulnerable individuals are exposed to

private suppl ies, for example, there are private suppl ies serving 40

hospitals and 46 schools or other educat ional establ ishments. Local

author it ies should always consider the nature o f the establ ishment and the

potent ial consumers when r isk assessing a supply as for some

establishments there are greater consequences of failures such as an

insuff icient supply with no cont ingency in place.


12

Table 3: Numbers of private water supplies used for commercial and

public activity

Region

Ed

uc

ati

on

al

an

d

tra

inin

g

es

tab

lis

hm

en

ts

Ho

sp

ita

ls/c

are

fac

ilit

ies

Fo

od

pre

mis

es

B&

B/h

ote

ls/c

am

p

sit

es

/ho

ste

ls

Pu

bli

c b

uil

din

gs

East Mid lands 1 4 88 167 83

West Mid lands 8 4 118 377 130

East of England 8 8 188 311 129

Nor th East England 0 1 101 305 66

Nor th W est England 5 4 338 727 121

Yorkshire and Humberside 5 4 205 636 223

London and South East 7 8 162 239 83

South W est England 12 7 429 1,807 321

England total 46 40 1,629 4,569 1,156

Wales total 4 9 218 592 115

Some suppl ies have more than one t ype o f ac t i v i t y .

In Drinking water 2014 the Inspectorate reported on areas where there are

signif icant numbers of private suppl ies in some rural communit ies. The

report highlighted that nationally , the failure rate for private supplies is

much worse than for public suppl ies and commented on the progress being

made on improving private water suppl ies. I t considered the investment for

addressing insuf f iciency of access to a safe and rel iable water supp ly

through the provision of a publ ic supply. Within the Wessex Water region

there are two local authorit ies where up to ten per cent of the populat ion

are served by private suppl ies and , following the report , Wessex Water

took act ion to see what it could do to help within its wider remit of

protect ing publ ic health for consumers.

The Inspectorate is pleased to report that Wessex Water has started a

project to gather information about the location of private suppl ies,

develop a priorit isat ion model and under take high level costings for

schemes to connect def icient private suppl ies to the publ ic network. The

project intends to look at the regulatory and legal barr iers to successful


13

transfer. The work has strong paral lels with f irst -t ime sewerage provision,

which has successfully operated for many years, connect ing propert ies to

the publ ic sewerage system, subject to an economic viabi l i ty assessment

and support f rom the Environment Agency.


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Chapter 3: Improving private water supplies

Chapter 3:

Descr ibes the progress of local author it ies in r isk assessing private

suppl ies.

Records the work of local author it ies in relat ion to improving fail ing

water suppl ies.

Summarises relevant industry research supported by the

Inspectorate.

Highlights best pract ice learning points about r isk management

through case studies.

From the beginning of 2010, local author it ies have been required to carry

out a r isk assessment of each relevant private supply in their area. This is

to determine whether it poses a potent ial danger to human health and, if

so, to take act ion to safeguard publ ic health in the short term and to

improve the supply in the long term. This duty transposes into law, act ions

required under Art icles 3, 7, 8, 9 and 13 of the European Union (EU )

Drinking Water Direct ive to safeguard human health and inform consumers

about the quality of their water supply, with detai ls of the nature and

t imescale of any necessary safeguards and improvements.

3.1 Risk assessments

Local authorit ies were given f i ve years to ident ify and r isk assess al l

relevant private suppl ies in their area (Regulat ion 6). The methodology of

r isk assessment is based on the World Health Organisation’s (WHO)

Guidel ines for Drinking water quality 2 and Water Safety Plan Manual 3 and

local author it ies have been provided with a r isk assessment tool 4 created

by the Inspectorate to enable this work to be carr ied out in a consistent

manner across the country. Enquir ies about the tool and feedback from its

use should be sent to dwi.enquir [email protected]

2 Guide l i nes fo r Dr ink ing -water qua l i t y 4

t h Ed i t ion W HO, 2011.

3 W ater Safe ty P lan Manual (W SP manual ) : S tep -by -s tep r i sk management for d r i nk ing -water

supp l i e rs – How to deve lop and implement a W ater Safe ty P lan – A s tep-by -s tep approach us ing 11 learn ing modules . W HO 2009 .

4 DW I r i sk assessment too l i s the sub jec t o f a non -commerc ia l gove rnment l i cenc e which

proh ib i t s any change o r us e o f the too l fo r commerc ia l ga in .


15

The duty to carry out a r isk assessment of every relevant supply is set out

in Regulat ion 6. Table 4 summarises the overall compliance of local

author it ies with this Regulat ion at the end of the period of f ive years

al lowed and detai led information showing the performance of each

individual local authority is set out in Annex 1 .

Table 4: Percentage of supplies with risk assessments

Use of supply*

Pe

rc

en

tag

e o

f re

po

rte

d

su

pp

lie

s r

isk

as

se

ss

ed

to d

ate

at

31

De

c

20

15

**

% of risk assessments in place

Fo

od

pre

mis

es

Be

d a

nd

bre

ak

fas

t/h

ote

ls

Pu

bli

c b

uil

din

gs

Sh

are

d d

om

es

tic

su

pp

lie

s

To

tal

nu

mb

er o

f

ris

k a

ss

es

sm

en

ts

in p

lac

e**

East Mid lands 70% 92% 85% 88% 57% 280

West Mid lands 58% 93% 80% 55% 38% 711

East of England 44% 83% 74% 65% 34% 788

Nor th East England 57% 95% 92% 95% 26% 475

Nor th W est England 60% 66% 68% 66% 57% 1.241

Yorkshire and Humbers ide

76% 88% 89% 98% 67% 1,359

London and South East 89% 93% 93% 98% 85% 689

South W est England 58% 77% 64% 96% 47% 2,532

England Total 61% 81% 74% 85% 49% 8,075

Wales Total 87% 95% 94% 99% 85% 1,870

Total 65% 83% 76% 86% 54% 9,945

*Double count i ng may occu r as some prem ises have more than one commerc ia l ac t i v i t y . * * Inc ludes a l l Reg 8 , Reg 9 and Reg 10 supp l i es . Th is data exc ludes Har l ow a nd Davent ry ( l a te re turns ) and Denbighsh i re ( re fus ed to prov ide a re tu rn )


16

In England the number of relevant private water suppl ies that had been

r isk assessed was 8,075, about three-f if ths (61%) of those required. This

compares favourably with the si tuation reported in Drinking water 2014

where only 55% of r isk assessments had been completed. However, it

highl ights that even a full year af ter the deadl ine for complet ion of all

pr ivate water supply r isk assessments, there is st i l l a substant ial gap in

secur ing safe drinking water supplies. In addit ion there are notable

regional var iat ions, for example in the Yorkshire and Humberside area 76%

of r isk assessments have been completed, despite that area having the

second highest total number of r isk assessments to complete (1,359). In

contrast, East of England and North East England have completed a

relat ively small proport ion (44% and 57% respectively) whi le having a lot

fewer numbers of r isk assessments to complete (788 and 475

respect ively).

Local authori t ies were advised to pr ior it ise r isk assessing those private

suppl ies, which are reportable under the EU Drinking Water Direct ive and

are used in the provision of services to the public (known as Regulat ion 9

private suppl ies). From Figure 5 it can be seen that this approach has

general ly been followed across England with higher compliance f igures

reported for these types of private supply: publ ic bui ldings (85%), food

premises (81%) and Bed and Breakfast/Hotel establishments (74%).

Figure 5: Percentage of risk assessments carried out

Considerable var iabi l i ty remains in achieving the minimum requirement of

the Regulat ions with continuing examples of no assessments having yet

been carr ied out for Regulat ion 10 supplies. The most obvious of which are

Rossendale, South Cambridgeshire, Allerdale and Copeland Distr ict


17

Counci ls accounting for 267 suppl ies between them or in the case of

Breckland Distr ict Counci l where only 4% of 687 assessments have been

carr ied out. In the case of Regulat ion 9 supplies , Teignbridge and Mid

Devon Distr ict Counci ls , for example, have carr ied out 38% of 96 and 53%

of 132 assessments respect ively.

The more detai led information in Annex 1 shows that, overall, 116 local

author it ies achieved 100% compliance with the duty to r isk asses s all

pr ivate water supplies (Regulat ion 8, 9 and 10).

The Inspectorate has identif ied that the local author it ies l isted in Table 6

have carr ied out less than 20% of the required r isk assessments during the

f ive years given for ful l implementation of the Regulat ions.

Table 6: English local authorities risk assessing 20% or fewer relevant

private supplies in their area within five years

Local authority

Number of risk assessments

requir ing completion

Number of risk

assessment completed

Percentage of risk

assessment completed

Blackpool* 2 0 0

Breck land 766 55 7

Gui ldford* 2 0 0

Hackney* 1 0 0

Hal ton* 1 0 0

Hyndburn 6 1 17

Rossendale 211 3 1

Rugby 1 0 0

South Hams 275 38 14

St Albans City* 9 0 0

Stoke-on-Trent* 2 0 0

Stratford-on-Avon 89 14 16

Waltham Forest* 1 0 0

Those local author it ies marked wi th * were h ighl ighted in 2014 as having r isk assessed fewer than 20% of their re levant suppl ies .

Regulat ion 6 of the Private Water Supply Regulat ions 2009 (2010 in

Wales) requires local authorit ies to r isk assess supplies within the f irst f ive

years of the introduction of the regulat ions and at least every f ive years

af terwards. Single domestic dwell ings are exempt f rom this requirement,

but must be r isk assessed if the owner or occupier of the dwell ing requests

it . In response to requests for assistance in undertaking these r isk

assessments, the Inspectorate developed a r isk assessment tool for local

author it ies to use. This was released in July 2012, and the Inspectorate

del ivered a ser ies of regional workshops during the latter half of 2012 to

introduce the tool and to demonstrate how it should be used.


18

Feedback is welcomed on the tool, and since 2012 two subsequent

versions have been issued. In addit ion, a simpler version for systems

compris ing of pref i l t rat ion and UV disinfect ion has also been published, as

well as one for Regulat ion 8 suppl ies. Al l of these are avai lable at

http:/ /www.dwi.gov.uk/private-water-supply/ locaut/ratool.html

Completed r isk assessment reports are not sent to the Inspectorate, but

local author it ies populate a column in the annual data return to conf irm

when the r isk assessment is complete. During 2015 , the Inspectorate

reviewed a number of r isk assessments carr ied out since the tool was

published to determine not only how many, but to what level of detail, the

r isk assessments had been completed.

25 Local author it ies were selected at random and approached for

information on r isk assessments they had completed in the period 2013–

2014. Of those 25, all but two responded (City of London and Shropshire)

and the remaining 23 either received a vis it to discuss their r isk

assessments or provided a select ion of r isk assessments via email.

Most (18 out of 25) local author it ies are using the r isk assessment tool,

and the vast majority of these are using the latest version. Of those not

using the Inspectorate’s r isk assessment tool, three have developed their

own methodology which involves using its hazard checklist and

determining presence or absence of the hazard, rather than assessing

l ikelihood or using the original r isk assessment methodology which is

incomplete for supply systems.

Sixteen of the local author it ies using the tool were using it appropr iately.

The others were not attr ibut ing a l ikelihood, or only doing this for high

r isks only. Half of those using the r isk assessment tool take exist ing

mit igat ion into account at the hazard checklist stage, and score hazards

based on exist ing mit igat ion in place. The Inspectorate has acknowledged

this approach but on the proviso that a record of the assumptions are

entered in the comments. For the remaining r isk assessments it was

unclear how or whether exist ing mit igat ion was being taken into account.

Eighteen of the 23 local author it ies using the r isk assessment tool are

successful ly developing act ion plans for the high and very high r isks.

However, very few are using the template act ion plans, instead populat ing

the outstanding act ions summary in preference. In the development of the

tool, the act ion planning stage was developed to demonstr ate any exist ing

mit igat ion, and also how future act ions would reduce the overal l r isk rat ing

to medium or low, and therefore local authorit ies are encouraged to

capture remedial act ions here. They have been designed to be entirely

f lexible; a blank one can be used, hazards can be grouped or several

act ion plans can be populated to represent r isks throughout the supply

system.


19

Over half of the local authorit ies involved are sett ing appropriate deadl ines

for complet ion of action. This can range from two or three months for very

high r isks to six months for other r isks. Some action plans are staggered

to enable very high r isks to be mit igated f irst before tackling lesser r isks.

However, the remaining local author it ies set no f irm deadl ines or

inappropr iate ones. Phrases such as ‘suggested deadl ine ’, ‘ongoing ’, ‘at

the next r isk assessment vis it ’ or ‘as soon as pract icable ’ are unhelpful to

the relevant person and help reinforce an informal att itude to the

remediat ion. The use of t ime-specif ic deadl ines gives clear and

unambiguous targets for supply owners and wil l help with any subsequent

enforcement if required. Some local authorit ies advised us that they are

not sett ing expl ic it deadlines as they do not have the resources to vis it the

suppl ies to conf irm the act ions are complete. In many situations it wi l l be

adequate for local authorit ies to verify complet ion of act ions in other ways ,

e.g. submission of photographic evidence, copies of invoices or complet ion

reports.

Risk assessments are most of ten carr ied ou t by the environmental health

off icers in the pr ivate suppl ies team, although in some cases off icers f rom

local author ity food teams with experience of r isk assessment have been

used. In the case of two local authorit ies, r isk assessments have been

subcontracted to external consultants on occasion.

The majority of local authorit ies deem their staf f competent through a

mixture of training and experience. Most local author it ies report having

received training through organisat ions including the Chartered Inst itute

for Environmental Health, Publ ic Health England, The Drinking Water

Inspectorate and the University of Surrey. In addit ion, water companies

have provided sampler training for some local author it ies. None have

formal audit procedures in place for ensu ring staff maintain competency,

but discussions take place at regional meetings which allows some peer

review to take place.

Local authorit ies use a var iety of sampling manuals. Fourteen of the 23

local author it ies use a writ ten procedure of some kind. The se range from a

simple f low diagram to internal wr it ten procedures to formal adoption of

exist ing manuals such as the Pr ivate Water Suppl ies Technical Manual. Of

the nine that don’t use a sample manual, some are using external sampling

manuals as references, but no wr it ten procedures are in place, and others

are not using or referr ing to any documented procedures. In one case,

senior staff check more junior staff to ensure that sampling is being

undertaken appropr iately. In al l other cases there is no check ing, and staff

are trusted to sample competent ly. In many cases, there is only a single

sampler, and there may not be anybody able to audit or assess the

sampling procedures.


20

3.2 Risk management

Risk management, in the context of the private supply regulat ions, refers

to the decisions and act ions that local authorit ies are required to take

when they become aware, through r isk assessment, monitoring or by other

means (such as consumer complaints or reports of water -related i l lness

f rom health professionals) that a supply may pose a potent ial danger to

human health or is insuff icient or unwholesome. Risk management involves

interpret ing the results of either the r isk assessment or any water quality

tests or user complaints in the context of the part icular wate r supply

arrangements (source, infrastructure, treatment and management

arrangements). I t is part icularly important that when a local authority

receives a report of an adverse sample result f rom the laboratory that this

is interpreted and acted upon in l ight of knowledge gained through the r isk

assessment about the part icular hazards and controls (r isk mit igat ion)

pertaining to the supply in question. Where a r isk assessment is in place,

the decision making of the local author ity should be relat ively

straightforward, with no need for repeated sampling or t ime spent seeking

the opinion of health professionals. Instead, checks can be made

immediately with the owner/manager of the supply to establ ish if there has

been any change in the supply circumstances or a ny malfunct ion of control

measures. The local author ity can then decide if there is a good reason to

carry out a site vis it to update the r isk assessment and independently

val idate the controls. In making this judgement, the local authority should

take into account the competence, att itude and behaviour of the supply

owner/manager, thereby focusing their own resources proport ionately

towards those situat ions where they add the greatest value in terms of

public health protect ion.

Once a local author ity has ident if ied that a supply poses a potential danger

to human health, or the qual ity of a private supply is not wholesome or the

volume of water output is insuf f icient, then act ion must be taken to ensure

that al l consumers are informed and given appropriate advice to safeguard

their health in the short term. Consumers must also be informed of the

nature and t imescale of any improvement works needed to affect a

permanent remedy. This is achieved by putt ing in place a Notice formally

sett ing out the requirements. There are two Notice options: for situat ions

where there is a potential danger to human health a Regulat ion 18 Notice

is used; for other situations where there is a problem only with regard to

suff iciency or wholesomeness, a Notice under Section 80 of t he Water

Industry Act 1991 is used. In certain instances it may be appropriate to put

in place both a Regulat ion 18 and a Sect ion 80 Notice. Both types of

Notice are f lexible instruments that can be varied to ref lect the owner’s

preferred option for provid ing a permanent remedy or to include addit ional

requirements that come to l ight as a consequence of an invest igation. The

benef its of a Notice (compared to informal verbal or writ ten advice) are


21

twofold. I f there is disagreement about the need for a supply to be

improved, or there is a dispute over who is responsible for carrying out the

work, the Notice provides for a formal process of mediat ion (appeal) and

thereafter, the relevant person(s) is under a legal duty to carry out the

necessary improvements.

Sometimes a local authority wi l l encounter a lack of co -operation by a

private supply owner and in these circumstances, if necessary, a stand -of f

situat ion can be resolved by the local authority serving the owner with a

third type of Notice (Section 85 Not ice under the Water Industry Act 1991).

This type of Notice makes it an offence for the person on whom it is served

not to provide specif ied information by a given date. Local authorit ies

should advise residents within its area that they must register any new

private water supplies with them, in order that it can carry out its dut ies

under Section 77-82 of the Act. Failure to do so may result in a Sect ion 85

Notice, with which failure to comply is an offence. In addit ion, if access to

the premises for the purpose of carrying out a r isk assessment or sampling

is being denied, the Act gives local authorit ies specif ic powers of entry

that they can and should exercise to gain entry.

The Private Water Supplies (England) Regulat ions 2016 have been

amended to close the previous gap whereby under Regulat ion 16 a local

author ity had an opt ion, if i t could not resolve the problem informally, not

to serve a Section 80 Notice. In effect this meant that neither informal or

formal act ion was secured to resolve a wholesome ness or suf f iciency

problem. The revised Regulat ions allow for a period of t ime to enable a

relevant person to take act ion without the need for a Notice (28 days),

af ter which a Notice must be served to secure the relevant improvements.

Table 7a: Number of supplies where local authorities have served

Regulation 18 Notices in 2015

Region Number of local author i t ies serving Notices

Reg 8 Reg 9 Reg 10 SDDW Total

East Mid lands 3 loca l author i t ies 0 1 2 0 3

West Mid lands 5 loca l author i t ies 0 26 19 9 54

East o f England 8 loca l author i t ies 1 11 5 5 22

North East England 2 loca l author i t ies 0 12 5 0 17

North W est England 12 loca l author i t ies 0 85 24 1 110

Yorkshi re and Humbers ide 5 loca l author i t ies 0 21 12 3 36

London and South East 13 loca l author i t ies 0 24 9 2 35

South W est England 10 loca l author i t ies 0 40 23 5 68

England total 58 loca l author i t ies 1 220 99 25 345

Wales tota l 9 loca l author i t ies 0 49 10 2 61

Grand total 67 loca l author i t ies 1 269 109 27 406


22

Table 7b: Number of supplies where local authorities have served

Section 80 Notices in 2015

Region Number of local author i t ies

Reg 8 Reg 9 Reg 10 SDDW Total

East Mid lands 1 loca l author i t y 0 1 0 0 1

West Mid lands 1 loca l author i t y 0 0 2 0 2

East o f England* 1 loca l author i t y 0 1 0 0 1

North Eas t England 1 loca l author i t y 0 0 1 0 1

North W est England 3 loca l author i t ies 0 18 4 1 23

Yorkshi re and Humbers ide 3 loca l author i t ies 0 2 1 0 3

London and South East 3 loca l author i t ies 0 2 1 0 3

South W est England 5 loca l author i t ies 0 5 2 0 7

England total 18 local author i t ies 0 29 11 1 41

Wales tota l 2 local authori t ies 0 51 41 11 102

Grand total 20 local author i t ies 0 80 52 12 144

Table 7a shows that in England in 2015 there were 345 private suppl ies in

58 dif ferent local authority areas where improvements were required to

protect publ ic health by means of a Regulat ion 18 Not ice. This represents

an increase in this type of r isk management act ivity compared to 2014

when 326 suppl ies in England were subject to such a Not ice. Sixty-four per

cent of these were served on suppl ies used in the provision of water to the

public, for a commercial act ivity or which supply more than 10m 3 per day.

Table 7b shows that in England 41 supplies were the subject of a Section

80 improvement Notice, of which around 70% were ones used in the

provision of water to the public, for a commercial act ivity or which supply

more that 10m3 per day. Over half of these were served by local

author it ies in the North West of England.

3.3 Review of Notices

2013 Notices

The publ icat ions Drinking Water 2014 – Private Water Supplies in England

(or Wales) identif ied 12 local author it ies with responsibi l i ty for 50 or more

Regulat ion 9 or 10 private water suppl ies who indicated in their 2013

annual return that they had not served any Section 18 or Regulat ion 80

Notices since the commencement of the current Regulat ions. These were

l isted in order of l ikelihood that an ef fect ive enforcement policy has not

been put in place and during 2014 vis its were made to some of these local


23

author it ies to understand why formal Notices had not been used. Reported

reasons included:

No r isk management in place (e.g. Rossendale DC, Sc arborough DC

Northumberland CC).

An informal approach to remediate r isk (the majority).

Schedule 4 of the Private Water Suppl ies Regulat ions 2009 detai ls the

records that a local author ity must keep in respect of the private suppl ies

in its area. This includes Notices served under Section 80 and Regulat ion

18. Regulat ion 13 requires local authorit ies to provide copies of the

records in schedule 4 to be sent to the Inspectorate by 31 January each

year. Dur ing 2013, copies of 344 Not ices were received f rom local

author it ies, which compares unfavourably to the total numbers reported in

the annual data return (478 Regulat ion 18 and 16 Section 80):

Table 8: Number of Notices received by the Inspectorate

Notice type Total received %

Sect ion 80 12 3.5

Regulat ion 18 332 96.5

Total number of Not ices issued 344 100%

A select ion of Notices received f rom the local author it ies were assessed to

determine if they contained the relevant specif icat ion , i.e. that they are

t ime l imited, and any remedial act ion required is set out and appropr iate.

They were also reviewed to determine whether they were served based on

failed samples or on the outcome o f the r isk assessment.

The results of this exercise conf irmed that almost all Not ices served were

in response to one or more parameter exceedances. The emphasis of the

current regulatory regime is on r isk assessment and management to

achieve mit igat ion of potential or actual r isk rather than reactive measures

based on sample results . This ongoing behaviour appears to ref lect a

histor ic response driven by the or iginal regulat ions and indicates t hat the

r isk-based approach has not been fully embedded in local authority

pract ices.

While there was a large degree of var iat ion in the qual ity and quantity of

information contained within the Not ices, in most cases the act ions

required were appropriate. The remedial act ion specif ied included specif ic

treatment systems (for example UV or nit rate removal) , and a very generic

requirement to ‘ install suitable treatment ’ . The remedial act ions required

did not always follow the mult i-barr ier approach and tended to concentrate

on treatment as a control measure. There were several examples where no

long-term mit igat ing act ions were specif ied ( for example where there were


24

plumbing metal exceedances). Var iat ion is to be expected as supply-

specif ic factors and local author ity expert ise inf luence s the information

contained in the Not ice. However, for the Notices to be legally binding, the

act ion required must be t ime l imited and in al l Not ices examined this was

the case.

In addit ion to the f indings above, o ther observat ions were relevant. There

were two cases where the Not ice was served in response to both chemical

and microbiological parameters, yet the short-term mit igat ion was advice

to boi l rather than not to use. Somet imes outdated terms had been used

such as ‘shock chlor ine dosing ’ which may not be helpful to relevant

persons.

2014 Notices

In 2014 a total of 342 copies of Notices were received by the Inspectorate

which compares unfavourably to the numbers reported in the annual data

return (491 Regulat ion 18 and 24 Sect ion 80). Eighty-two per cent of the

Regulat ion 18 Notices served were in response to microbiological

exceedances. Six per cent were due to lead failures and 11% were due to

unspecif ied unwholesome factors. In one instances a Section 80 Not ice

was served in response to an arsenic failure. Only one Not ice was served

based on a potential r isk alone.

2015 Notices

In 2015 a total of 220 copies of Notices were received by the Inspectorate

which compares unfavourably to the numbers reported in the annual data

return (406 Regulat ion 18 and 144 Sect ion 80 or Section 85 Notices).

Eighty-f ive per cent of the Regulat ion 18 Notices were served in response

to microbiological exceedances. Two per cent were in response to lead

failures, and 15% were due to unspecif ied unwholesomeness factors.

In conclusion, the serving of both Regulat ion 18 and Sect ion 80 Notices

continues to be driven by parameter exceedances as opposed to r isk

assessment. Regulat ion 18 Not ices are most commonly used, and are

almost always in response to microbiological failures. Copies of Notices

served are not all being sent to the Inspectorate, however , f rom those we

have reviewed, the qual ity of information continues to be var iable but

largely adequate.

Local authorit ies continue to rely on informal act ion in remediat ing r isks

under Regulat ion 16. This is not appropriate where r isks to human health

have been identif ied and is in breach of Regulat ion 18. Regulat ion 18

requires that Notices MUST be served where such r isks have been

identif ied. Action is not restr icted to where exceedances of health-based


25

parameters have occurred, and local authorit ies are encouraged to adopt a

r isk-based approach in applying the Regulat ions, and to ut i l ise the

enforcement powers available to them to bring about improvements in

private water supplies. Similar ly local authorit ies should ensure that any

Notices which are served adequately specify the remedial act ions required

rather than using Notices as a mechanism to issue boi l water advice alone.

The Inspectorate has provided examples of both Regulat ion 18 and

Section 80 Not ices on their website to assist local authorit ies with their

complet ion, and to ensure that a consistent approach is adopted that

contained al l required and appropr iate information. Where local authorit ies

are unsure of the content and format of Notices they should refer to

www.dwi.gov.uk or contact the Inspectorate for advice.

Appeals

In 2015, three Sect ion 80 Not ices were appealed by the relevant person(s)

on whom they were served. in these instances, the Inspectorate hears the

appeal in the most appropr iate f orum; it may be dealt with by

correspondence (exchange of information), a meeting between the key

part ies may be held, or a public meeting can be convened. Once all the

available and relevant information has been assessed, the Chief Inspector

may decide to uphold the Not ice with or without modif icat ion, or revoke it .

In the f irst case the Notice had been served requir ing improvements to the

distr ibut ion network within a rural vi l lage on a private water supply, af ter

two instances of loss of supply due to le aks. The person in control of the

supply, who had been charging the consumers for many years to manage

the supply, appealed on the grounds that those charges did not cover large

capital maintenance schemes. In the second case, the appeal also related

to who should be l iable for paying for improvements in the case of a long -

term agricultural lease. In the third case, the Notice was appealed on the

interpretat ion of the r ight to a suff icient supply and how this was l inked in

deeds to payment of a proport ion o f the cost of maintenance of the supply.

A signif icant element of the appeal hear ing stemmed from historic disputes

about payment of bil ls and what const ituted ‘reasonable costs’. A common

element among al l three conf irms the general s ituat ion that in many shared

private water supplies there is a lack of clear, legal ly -binding agreements

about what charges are made, how these are calculated and what aspects

they cover (e.g. sampling and r isk assessment costs, electr ic ity bi l ls,

operat ional and capital maintenance work, alternative suppl ies during

maintenance, treatment upgrades, c leaning of storage tanks, etc.). In all

three instances, dur ing 2015, the Not ice was upheld with or without

modif icat ion.


26

3.4 Risk management case studies – England and Wales

The Inspectorate has included case studies to i l lustrate the range and

scope of the situations that can ar ise in the r isk management of private

suppl ies in each of its annual reports . This aspect of the report is

part icularly appreciated by local authorit ies a nd has been continued again

this year. The select ion of case studies is guided by enquir ies received

during 2015, either from local authorit ies or private supply owners and

their service providers. The Inspectorate has also drawn on records of

events notif ied to the Inspectorate by water companies to highl ight, for

learning purposes, those scenar ios where the task of safeguarding water

suppl ies relies on ef fect ive local col laboration and communications

between the local authority and its local water company . The case studies

published in Drinking water 2015 wi l l be added to the archive of published

case studies on its website and this can be accessed at

http:/ /dwi.defra.gov.uk/private-water-supply/Case-studies/ index.html as a

learning tool for anyone coming new to the subject.

Case study 1 – cross connection with a public supply

In Apri l 2015, a Regulat ion 9 supply near Sal isbury was r isk assessed by

the local author ity. During the r isk assessment, it was discovered that

there was also a metered mains water supply connected to the private

water supply network. This enables the use of mains water when there are

problems with maintaining pressure on the private water supply. Suppl ies

can be manually swapped by a switch in the pump house. This is operated

through an informal arrangement with a local plumber.

The source consisted of a well in a shed (see Figure 9). The untreated

supply fed a nearby property as well as another property and a farm which

owns the supply. The supply was sampled for the f irst t ime in March 2015

when a sample taken at the t ime of the assessment was found to contain

77.4mg/l nitrate, in breach of the Regulat ions, and 15 col iforms/100ml.


27

Figure 9:

Well in shed (covers removed)

Figure 10: well cover consists of

a number of wooden planks. The

chamber cover is not lockable,

watertight, made of a suitable

material or vermin proof.

The local authority promptly issued boi l water advice pending an

investigation into the l ikely cause of the presence of coliforms. They

subsequently provided advice to the consumers of the supply that,

although there was no concern to adult health at the levels of nitrate

found, they should not supply the water to infants, and that the local

author ity would revisit to cont inue investigating the so urce of the nitrate.

The invest igation into the presence of coliforms concluded that the

condit ion of the headworks was poor and a potent ial route for

contamination.

The local authority raised the matter with the local water company three

weeks later, during a planned l iaison meeting. The water company visited

the property the next day in order to f it a non -return valve to the mains

water supply feeding the farm to prevent any backf low. A f it t ings

inspect ion was also arranged and undertaken which conf irmed the

existence of a cross connection between the mains and pr ivate suppl ies. I t

was also found that the pump for the private supply was broken and the

propert ies were being suppl ied by the mains supply.

The local authority, through discussion with the owner , took informal act ion

to resolve the situat ion, giving him two months to carry out remedial work

to mit igate r isks associated with the well headworks. The wel l headworks

was located in a shed at ground level with only old and rotten planks of

wood cover ing the wel l. The cover was not lockable and did not prevent


28

animal or surface water ingress. The private supply was permanent ly

disconnected in February 2016.

There was some uncertainty about whether the consumer was being

suppl ied by a private or a public supply at the t ime of the original sample,

so the water company issued advice to boi l the water, some three weeks

af ter the local author ity had, and the day af ter f it t ing backf low protect ion in

the form of a non-return valve. All bacter iological sample results were

subsequently shown to comply with regulatory standards. In January a

f it t ings inspect ion was undertaken which conf irmed that the contravent ions

had been rect if ied and that the two affected propert ies were now

connected to mains water. Fol lowing satisfactory sample results the boi l

advice was rescinded. This case highl ights the importance of effect ive

l iaison between local authorit ies and water companies to ensure that r isks

to consumers where both mains and private supplies exist are identif ied

and resolved in a t imely manner. Although, in this case, the local author ity

did inform the water company of the cross connection, it took three weeks

for this to happen. The Water Fit t ings Regulat ions are enforceable where

cross connect ions with mains suppl ies exist and when the water company

were informed, they acted quickly to undertake a f it t ings inspection and

instal l a non-return valve on the customer pipework to protect the wider

distr ibut ion network f rom the r isk of contaminat ion by the pr ivate supply

Case study 2 – Consequences of a lack of procedures, site schematic

or communication about the operating regime for a pr ivate water

supply.

In Apri l 2015, a consumer in Devon, whose water for domestic purposes

was being served by a Regulat ion 9 supply, e xperienced f looding in the

garden of their rented property. To rel ieve what they assumed to be a

blocked drain, the tenant called out a plumber, who located a manhole

cover and saw what he descr ibed as ‘a lot of dirty looking water and a blue

rope’ within the pit . Although the purpose of the rope was unknown to the

plumber, he nevertheless pul led it , which resulted in the f lood water

receding f rom the manhole. In the bel ief that he had solved the problem,

the plumber lef t the site. Later that day consumers of the private supply

started to notice a drop in water pressure on their supply, which

histor ical ly was not an unusual occurrence. However, on this occasion the

f low began to diminish and eventual ly stopped altogether.

The plumber had in fact removed a plug from the private water supply

storage reservoir and had caused insuff iciency of the supply. A member of

the local committee responsible for the upkeep and maintenance of the

supply contacted the plumber’s employer and threatened the company with

legal act ion. Uncertain of their legal posit ion, the plumber’s employer


29

contacted the Inspectorate for advice and was advised to contact the local

author ity as the regulators of private water suppl ies.

The local authority discovered that those in control of the s upply had

responded to recover the situat ion by recharging the reservoir manual ly

f rom the publ ic supply using bowsers, which had taken several days. Since

the supply had been restored by this t ime the local author ity advised those

in control of the supply to make a record of the incident and document the

act ions they had undertaken to rect ify the situat ion for future reference,

and to include the contact details of the company who supplied the

bowsers, the quantity of water required, key user contacts etc. This would

then form an emergency and management procedure for future reference

and evidence a procedure for future r isk assessments by the local

author ity.

The local authority took the opportunity at this t ime to refer those in

control of the supply to their r isk assessment, which they had undertaken

in 2012, using the Inspectorate’s r isk assessment tool. This had ident if ied,

among other r isks, the need for securing reservoir inspect ion chambers to

prevent unauthorised access. An act ion plan for the mit i gat ion of the r isks

had been produced with complet ion deadl ines , however, the local author ity

did not return to ver i fy that these act ions had been completed to the

deadl ine they had set due to other pressing priorit ies. This included the

urgency to complete al l of the private water supply r isk assessments in

their area to meet the regulatory f ive-year deadline.

The local authority agreed informally with the relevant persons that

remedial work should be undertaken immediately to prevent any further

recurrence. Although the Regulat ions give scope to al low local authorit ies

to make this judgment, they are reminded to use their powers of

enforcement where this approach has not been ef fect ive and/or the supply

presents a r isk to human health. This gap in the cur rent enforcement

regime has been addressed in the revised Regulat ions giving a f ixed

t imescale for act ion to be taken by the relevant person(s), before

enforcement act ion must be taken. The local author ity has since taken

regulatory samples f rom the supply which had sat isfactory results for the

parameters tested.

The r isk assessment tool developed by the Inspectorate ident i f ies the lack

of an appropriate schematic as being an inherent r isk for a private water

supply. This case study conf irms the importance of having documented

schemat ics, as wel l as appropriate procedures and records for its

management. I t also highl ights the lack of control or awareness that many

tenants in rented propert ies have in respect of their private water supply.

Where local authorit ies agree act ion plans with relevant person(s), either

as an informal arrangement, or as part of the steps within a Notice, they


30

must have systems in place to ver ify the complet ion of mit igat ing act ions

to appropr iate deadl ines. As set out in the act ion plans in the

Inspectorate’s r isk assessment tool, this can be through site vis its if

convenient or through the submission of documentation or photographs by

the relevant person. Where act ion is agreed informally and it is not

completed on t ime, the local authority should then use the relevant

enforcement power to secure act ion. As this case study i l lustrates , an

informal approach is not always a rel iable method to br ing about the

necessary measures to ensure that suppl ies are wholesome and suf f icient,

and f ree f rom risks to human health.

Case study 3 – Identification of a new Regulation 8 supply, and the

need for local authorities and water companies to adopt a joint

approach.

In May a local authority in the Midlands became aware that the occupier of

a single domest ic dwell ing in their area served by a borehole had ceased

using the water for domestic purposes because they had problems in

maintaining it . To maintain a supply to the property, the occupier

connected into their neighbour’s mains water supply vi a their service pipe.

This was a verbal arrangement with the owner of the neighbouring

industr ial unit , such that he would make no charge for the water supplied

to the property. In so doing both owners had unknowingly created another

private water supply system, subject to and def ined by Regulat ion 8 of the

Private Water Supplies Regulat ions 2009 (2010 in Wales) . In these

suppl ies, water originating f rom a water company ’s mains is further

distr ibuted by a person other than a water undertaker f rom a primary

premises ( in this case, the industr ial unit) to a secondary premises (the

property that had previously been supplied by a borehole).

Some months af ter this connection and pipe had been instal led, the owner

of the secondary premises was taken into hospital , during which t ime the

connection was severed by the owner of the industr ial unit , as the water

was no longer being used. Seeking to restore the supply, a relat ive of the

owner of the premises then contacted the local authority, who in turn

contacted the Inspectorate in their capacity as providers of technical

support, for advice on how to proceed.

The Inspectorate advised that in creat ing the Regulat ion 8 supply, it was

possible that an offence had been committed in that water was being taken

unlawful ly f rom the water undertaker, in breach of the Water Supply (Water

Fit t ings) Regulat ions 1999. They were advised to contact the local water

company and to work with them to conf irm whether or not the arrangement

had constituted a Regulat ion 8 supply and to put the supply arrangement

on a proper legal basis if i t was to be reinstated.


31

The water company carr ied out an inspection of the supply to check

whether or not the connect ion had bypassed the meter to the industr ial

unit or not. This conf irmed that the connection had been made downstream

of meter, i.e. all water being used was accounted for.

The water company conf irmed that the Regulat ion 8 supply could be

restored to the property without compromising the water quality or the

f it t ings regulat ions. However, it soon became apparent that the owner of

the industr ial unit did not want to reconnect the property to their supply

and was not obl iged to as no legal ly -binding agreement relat ing to the

arrangement was ever put in place. The situat ion remained unchanged

unti l the property on the secondary premises was inher ited by the

subsequent owner later in 2015. At this t ime the local author ity contacted

them to understand what water supply arrangements they intended to put

in place to restore a suff icient supply.

The new owner had a geological survey carr ied out and conf irmed there

was suf f icient yield for a reinstated borehole supply , but by the end of

2015 the property was unoccupied and was st i l l without a water supply. I t

is essential in these situat ions that local author it ies maintain relevant

communications regarding any prospective new supply to ensure that they

are kept informed of developments. The revised regulat ions which came

into force in 2016 have sought to plug the previous gap in publ ic health

protect ion for new supplies, making it a requirement to r isk assess and

monitor them (except to single domestic dwell ings not used as part of a

commercial act ivity or provided to the publ ic) as soon as pract icable once

the local author ity becomes aware of them.

This case study i l lustrates the importance of effect ive communication

between local author it ies and water companies when potent ial Regulat ion

8 suppl ies come to l ight. I t is necessary that they work together to ver ify

whether or not Regulat ion 8 appl ies and to ensure consumers are

protected under the respect ive regulat ions they have accountabi l i t ies

under. I t also demonstrates how Regulat ion 8 suppl ies arise unknowingly

through the i l legal act ions of property owners seeking to overcome

insuff iciency on their premises.

Regulat ion 8 suppl ies of ten come to l ight when consumers report issues of

water insuf f iciency or quality to local authorit ies, as this case study

i l lustrates. Local authorit ies should remain vigi lant of any similar s ituat ions

and invest igate in a t imely manner.


32

Case study 4 - Further evidence of farms as a category of premises at

high risk of causing water to be unsafe as a consequence of

unsuitable water supply arrangements

In September, a customer contacted their water company over concerns

they had about part icles in their dr inking water at their farm in

Herefordshire. Samples taken by the company as part of their investigation

were found to contain high counts of coliforms, E.col i and Enterococci.

In response, the water company issued boi l water advice to the owner of

the farm and del ivered bott led water as an alternat ive supply whi le they

investigated the cause and extent of the issue. This included taking

addit ional samples f rom within the property and from neighbouring

propert ies in order to isolate possible sources of contamination.

The water company carr ied out an inspection which identif ied a storage

tank present within the grounds of the farm, which was receiving water

f rom a private spr ing supply (see Figure 11). I t found that a pipe had been

connected f rom the farm’s service pipe to this storage tank and mains

water was being used to supplement the volume of water within the tank.

The mains connect ion did not have an adequate air gap or back -f low

protect ion and, due to the tank ’s elevat ion, the company concluded that

untreated spring water mixed with mains water was f lowing back into the

property’s service pipe as it was at greater pressure than the mains supply

alone.

The company disconnected both piped

feeds to the tank and served a Not ice

to the farm owner for a category 5 r isk

under Section 75 of the Water Industry

Act 1991. To provide protect ion to the

wider distr ibut ion system, the company

f it ted a double check valve at the

boundary box.

Samples, taken from a neighbouring

property dur ing the investigat ion were

also found to contain similar numbers

of coliforms, E.coli and Enterococci.

The company issued boi l water advice

to the occupant of this property,

however, they were not able to obtain

any resamples as there was no longer

a supply of water avai lable.

Figure 11: Storage tank


33

A water f it t ings inspection conf irmed that the property was being solely

suppl ied by the storage tank and that the disconnection of the inlet

pipework had resulted in the loss of supply to the property.

The water company made a temporary connect ion to their mains supply in

order to restore a potable supply to the property. Samples f rom this new

connection were found to meet regulatory water qual ity standards and so

the boil water not ice was l if ted f rom the property. The temporary

connection remained at the property unt i l a permanent connection was laid

later that month.

Fol lowing the removal of the cross connection with the spr ing supply,

samples taken from the farm were also satisfactory and the company

revoked the boi l water advice f rom the farm. However, due to the potent ial

r isk of addit ional cross-connections on the farm, a further water f it t ings

inspect ion was carr ied out in ear ly 2016.

This case study i l lustrates that cross connections between pr ivate and

public suppl ies must have adequate backf low protect ion as specif ied in the

Water Supply (Water Fit t ings) Regulat ions 1999 in order to protect

consumers against the r isk of contaminat ion. These def iciencies occur

where cross connect ions have not been made by competent plumbers ( i.e.

those approved under the Watersafe scheme). Such def ic iencies of ten

come to l ight through water companies fol lowing up on reports from their

consumers of unusual taste, odour, appearance or cases of i l lness, as this

case study demonstrates.

While this case study reinforces the Inspectorate’s advice that private

water supply owners and operators should use plumbers wh o are deemed

competent under the Watersafe scheme, it also highl ights the public health

value of local author it ies recording the detai ls of all sources of water used

on premises in their area. Keeping as full a record as pract icable can help

investigations of this nature.

Case study 5 – Reinforcing the challenges associated with identifying

Regulation 8 supplies and the importance of fully understanding the

Regulations to ensure the correct response during an investigation.

This case study relates to a water quality concern reported by a water

company customer in Gloucestershire about a mains supply which on

investigation revealed unusual supply arrangements which had some

character ist ics of a Regulat ion 8 supply.

The consumer l ives on a farm which receives a mains supply f rom the local

water company. The owner of the property also owns a number of other

propert ies on the same land which they rent out. The occupiers of these


34

propert ies are not customers of the water company , but are instead bil led

by the owner of the farm.

In July 2015 the land owner contacted the water company af ter

exper iencing a ‘gas’ type odour and discoloured water at the farm

following a drop in mains pressure . The company vis ited the property and

col lected samples for taste, odour and microbiological parameters.

The sample results showed that whi le the sample was f ree f rom coliforms

and E.col i , i t was found to contain Clostr idium perf ingens (4 per 100ml).

The company returned to the property to obtain resamples but could not

init ial ly gain access and so col lected a sample f rom an outside tap. A

sample was also taken from another property on the s ite as this was

suppl ied by the same service pipe. Both samples conf irmed the presence

of Clostr idium perf ingens and as a result the company issued boi l water

advice to both propert ies.

The resamples contained a petrol taste and odour, and solvent analysis

conf irmed the presence of petrol -based compounds. The boil advice was

changed to ‘do not drink’. To ensure protect ion of the wider distr ibut ion

system a boundary box and non-return valve were f it ted at the point of

connection with the company’s main.

The company’s investigation identif ied that a leak had previously been

reported on the service pipe but there was no record of whether the leak

had been repaired. A water f it t ings inspection found no contraventions

within the property, however , it did identi fy that the service pipe material

was black alkathene which, whi le prone to f ractures and splits , is also

permeable to hydrocarbons.

The company advised the farm owner to replace their service pipe with a

pipe of suitable material to resolve the leak and prevent chemical leaching

through the pipe. The company init ial ly concluded that the supply

arrangements to the other propert ies on the land constituted a Regulat ion

8 supply and duly informed the local authority.

Questions were posed to both the water compan y and the local authority

during the Inspectorate’s assessment of the event to conf irm if the supply

was a Regulat ion 8 supply. Dur ing this dialogue it was found th at, as the

propert ies on site were owned and rented by the occupier of the farm, the

distr ibut ion arrangements did not meet the def init ion of a Regulat ion 8

supply under the Regulat ions.

The owner was required by the local authority to undertake the

replacement of the service pipe leading to the other propert ies through an

enforcement Notice served under the Housing Act 2004 Part 1.


35

This case study reiterates the advice outl ined in previous case studies

surrounding the chal lenges associated with identifying Regulat ion 8

suppl ies. Guidance on identifying Regulat ion 8 suppl ies has been issued

by the Inspectorate, and should be referred to. The Inspectorate

recommends that water companies use this guidance to verify whether or

not a supply fal ls under the def init ion of Regulat ion 8.

Case study 6 – Inappropriate use of a private supply by a food

business can give rise to substantive economic, reputational and

regulatory costs

This case study relates to the use of a contaminated pr ivate water supply

by a large food factory that resulted in the author it ies issuing a Detent ion

of Food Notice and the granting, by magistrates, of a Food Condemnation

Order under Section 9 of the Food Safety Act 1990. The consequential

direct costs incurred by the food company were of the order of £1mill ion.

Both the company and the managing director were prosecuted, found gu ilty

by the courts of several of fences and f ined a total of £5,000.

The food premises site

The factory opened in 2006 providing special ist bread products for several

national cater ing companies and major supermarkets. There were about

150 employees on site and around 80% of the bread product was supplied

to a single internat ional sandwich chain. The site was located on an

industr ial s ite with a history of other industr ial and manufacturing uses.

Immediately adjacent to the food premises was a car plant that had been

operat ional s ince 1968. The site also comprised an abandoned waste

disposal s ite for the incinerat ion of a wide range of industr ial chemicals

and other hazardous waste material.

The water supply arrangements

In March 2010, the food company, when asked direct ly by the local

author ity indicated use of a borehole for food production use, thereby a

private water supply. This water supply had probably been in use for some

t ime without the knowledge of the local authority or any authority with an

interest in such matters. Once aware of the supply, the local author ity

carr ied out a r isk assessment and monitoring as required under the private

supply regulat ions. There was a publ ic mains water supply to the factory

providing a supply of water for domestic purposes for employees (hand

wash basin, toi lets and kitchen). In ear ly December, the water company

disconnected this publ ic supply due to non -compliance by the food factory

with statutory Not ices served previously requir ing remedial act ion to

mit igate a signif icant r isk posed by the food premises plumbing

arrangements whereby untreated borehole water could enter the publ ic


36

mains. By coincidence, that same day, the local authority col lected its

planned private supply regulatory compliance monitoring sample f rom the

borehole.

A fortnight later the local author ity was notif ied by the laboratory that the

borehole sample results indicated the presence of volat i le organic

compounds (VOC’s) . Fol lowing an investigation, in early January a further

water sample taken by the local authority conf irmed the presence in the

private supply source of tr ichloroethene (TCE) at a level of 210μg/l

(health-based standard for TCE in water is 20μg/l). This compound is

primari ly used in metal degreasing operat ions. Fol lowing this f inding, the

local author ity sought advice f rom Public Health Wales (PHW), the Food

Standards Agency (FSA) and the Dr inking Water Inspectorate and then

served a Regulat ion 18 Not ice restr ict ing the use of the private supply,

effect ively prohibit ing the use of the borehole as an ingredient in food

processing or for drinking water. This Notice meant that al l food production

was stopped pending further investigat ion. As a further precaution, a

Detent ion of Food Notice under Sect ion 9 of the Food Safety Act 1990 was

also served on the same date. This Notice required the detent ion of al l

foods made at the premises between the date of collect ion of the f irst

adverse water sample (2 December) and the date of the Notice (30

January). On the next day, the food company was advised to commence

the withdrawal f rom their customers of all bread products made during this

period. Two weeks later Magistrates granted a Food Condemnation Order

(under Section 9 of the Food Safety Act 1990) requir ing foods made on

and between the 2 December and the 31January to be disposed of .

The cause and remedy of the water contamination event

The invest igation concluded that the borehole water contamination arose

f rom a combinat ion of several factors. The food factory had been reducing

the use of the public supply and increasing abstract ion f rom its borehole

over a per iod of t ime leading up to when the publ ic supply was

disconnected. At this point abstract ion was around 150,000 l it res a day

and this occurred at a t ime when except ional winter weather condit ions

had resulted in groundwater levels being elevated wel l above those

previously recorded. These condit ions consequent ially mobil ised solvent

contaminants known to be present in the local aquifer below the nearby

disused waste site.

Enquires made with Natural Resources Wales (NRW) established that

there was no abstract ion l icence in place for the food factory borehole.

From other information avai lable to the local author ity and the water

company the amount of water used by the food factory was greater than

the threshold (20 cubic meters a day) requir ing an abstract ion l icence to

be appl ied for and granted by NRW. By fail ing to apply for a l icence, the


37

food factory operated the private supply without accessing knowledge held

by NRW about the groundwater quality and the local catchment hazards

thereby fail ing to ensure that water used as an ingre dient in food products

was wholesome. The food factory also fai led to notify the authorit ies in a

t imely manner conducive to al lowing these author it ies to complete the work

necessary to ensure public safety. For example, before use of the private

supply as an ingredient in food products, a food factory should have in

place an ef fect ive, comprehensive and appropr iate Hazard Analysis

Crit ical Control Point (HACCP) procedure as required under food safety

legislat ion.

In order to be able to resume food producti on on site, the food company

needed to acquire a demonstrably wholesome and safe supply of water. To

achieve this, the food factory had to permanently disconnect the

contaminated borehole supply and commission a new connect ion to the

public mains supply. The previously disconnected domestic mains supply

was not of an adequate size to support food product ion on si te therefore a

new larger mains connect ion to water industry standards had to be laid

under the supervis ion of the water company. Addit ional ly the food company

had to clean and reconf igure the internal plumbing arrangements and br ing

the whole water system into compliance with the water f it t ings regulat ions.

Af ter complet ion of all of these works and before the new mains water

supply could be made available for use, the water company through its

own inspection and sampling regime sought and obtained evidence that

water at the point of use was wholesome and the entire water system was

f it t ings regulat ions compliant.

The offences for which the food company and the managing director were

charged and found gui lty subsequent ly were twofold: the abstract ion of

water f rom a source at or above the permitted level without having f irst

obtained a l icense from the relevant statutory body for that abstract ion

and; failure to ensure an adequate supply of wholesome (potable) water

was used ensuring that foodstuffs were not contaminated .

Learning points

This event and the associated prosecution case highl ights the documented

cost impact (£1mill ion) fall ing on a single food premises when it had need

to stop production, cal l back product f rom customers and commission a

new water supply due to a situat ion that arose solely as a consequence of

that business choosing to rely on a pr ivate water supply that did not meet

quali ty standards. The case also shows how the reputat ional damage to a

food business for a single incident far offsets the cost of regulat ion

(£1mill ion for a single incident compared to recurring costs of the order of

£500 a year).


38

This case study highlights a need for systems of food safety assurance to

contain more expl ic it information about potential water -related hazards and

the act ions that need to be embedded in HACCP procedures to identify

and mit igate r isk and secure compliance with both water and food law. The

food company was accredited by the Brit ish Retai l Consort ium (BRC) and

employed persons whose role was to del iver the systems and procedures

needed to maintain this accreditat ion, which provides quality assurance to

the food business to assist in demonstrat ing that safe systems of food

product ion are in place. When invest igating this contaminat ion event the

author it ies found that the BRC audit report was def icient in a number of

ways, in part icular, it failed to ident ify the existence and use of a private

water supply. This revealed a weakness in the Food Standards Agency

(FSA) del ivery model that requires to be remedied by ensur ing in future

that local author ity and private sector auditors ask for details of

abstract ion volume and evidence that the relevant author it ies have been

informed.

This event highl ights the gap in the registrat ion requirements for private

water suppl ies below 20 cubic metres a day (f rom the duty to apply for an

abstract ion l icence) and the absence of effect ive enforcement o f the

requirement for all borehole locat ions deeper than 15m to be notif ied to

the Brit ish Geological Survey (BGS) .This results in s ignif icant gaps in the

information avai lable about borehole locations and usage to those

author it ies charged with responsibi l i ty for securing publ ic safety. A

previous proposal to close this known information gap (by introducing into

the private supply regulat ions a duty on private suppl ies owners and users

to notify the local authority) was not progressed due to legal impedime nts.

However, local authorit ies can require residents in their area to register

new pr ivate suppl ies in their area with them. Fai lure to do so can result in

the serving of a Section 85 Not ice (to provide information to allow a local

author ity to carry out its duties) which is an offence not to comply with.

The business involved was large, serving as a strong reminder to r isk

assessors in the area of both food and water safety, of the need to use

r isk assessment tools and scor ing systems that put adequate we ight on

scrut inis ing and evaluating conf idence in management irrespective of the

size of the business. In this case, the local authority used the Drinking

Water Inspectorate’s private supply r isk assessment tool to update its

original r isk assessment generating a comprehensive assessment of the

whole supply and the associated management arrangements, giving an

act ion plan in which they could have conf idence. For food premises that

use a pr ivate supply, it is recommended that the qual ity assurance

systems rel ied upon by the FSA and BRC in future tr igger such food

businesses to not ify the local author ity . Also, evidence showing that an up

to date r isk assessment using the Inspectorate’s r isk assessment tool is in

place and records are kept demonstrat ing how the identif ied r isk mit igat ion


39

act ions are embedded in HACCP procedures and that they are being

carr ied out ef fect ively.

This event conf irms that water companies have a role in support ing local

author it ies with their food safety role by putt ing in place addi t ional

information sharing arrangements e.g. procedures to not ify a local

author ity of any f it t ings enforcement Notices served on a food premises,

especial ly where there is evidence that a private supply is being used or

mains supply usage has decl ined or ceased but the food factory has not

closed down.

Like many other case studies, the need for good l iaison between dif ferent

departments of a local authority was reinforced , e.g. food and water safety

functions as were the benef its of the more r igorous r isk assessment tool

now avai lable f rom the Inspectorate.

Case study 7 – An outbreak of Escherichia coli 0157 infection amongst

users of a private water supply when staying in holiday

accommodation

This case study relates to the circumstances surrounding i l lne ss suffered

by members of three independent family groups hol idaying at two cottages

served by a private supply in summer 2015. The problem was identif ied by

epidemiological survei l lance. The index case was a seven -year-old male

member of a family group of 22 individuals that had been staying together

in one of the cottages. The boy was admitted to hospital tr iggering

notif icat ion of Publ ic Health England (PHE) on 7 August. A further four

individuals in this family group who were found to be symptomatic,

included two other chi ldren aged seven and nine -years-old. The various

members of this family group had dispersed home across the country with

some returning further af ield to Canada. On 10 August, PHE was not if ied

of another chi ld with a conf irmed E.coli O157 infect ion by Publ ic Health

Scotland. This child was a member of a dif ferent family group of 14

individuals that had stayed at the other cottage on the same private

supply. At least one further member of this family group was symptomat ic.

On 13 August, PHE became aware of a further case of E.col i O157

infect ion in a member of a third family group of 16 individuals that had

hol idayed at this other cottage.

In total the outbreak comprised 22 symptomatic cases of diarrhoea and

vomit ing amongst the 52 individuals making up these three family groups

(42% attack rate). Fourteen of these cases were laboratory conf irmed

infect ions with the same strain of E.coli O157 (phage type 21/28, gene

VT2). Five of the cases were hospitali sed at some point dur ing their

i l lness. Both adults and chi ldren, and both females (13) and males (9)

were af fected. The epidemiological curve based on self -reported f irst


40

symptom onset dates indicated a point source of infect ion ar ising just prior

to 31 July, with the peak of infect ion occur ring on 4 August. Three cases

with later onset dates of 8 and 9 August were probably due to secondary

person-to-person spread among these household groups.

Outbreak control

Tap water samples col lected on 7 August for faecal indic ator tests gave

satisfactory results, however, as the indicator test for E.coli is not capable

of detect ing E.col i O157 , subsequent tap samples were collected on 11

August for pathogen test ing by PHE and these proved to be posit ive for the

outbreak strain of E.col i O157 (phage type 21/28, gene VT2).

Action to prevent further exposure to the private water supply was agreed

by the outbreak control team and put in place by the local authority in the

form of a Regulat ion 18 private water supply Not ice on 13 August. The

Notice prohibited use of the water for drinking, cooking, food preparat ion

and personal washing (hand, bath, shower). Essential ly the use of the

water supply was restr icted at this stage to just toilet f lushing with bott led

water provided for al l other purposes.

Af ter some immediate improvements to the supply further tap samples

col lected on two consecutive days (18 and 19 August) tested negative for

E.col i O157 and in the absence of any new reported cases, this Notice was

revoked and replaced on 27 August with a new Regulat ion 18 Notice,

al lowing water to be used for personal washing as wel l as toi let f lushing

but requir ing water to be boi led before use for drinking and food

preparat ion. This second Notice was required because a sample col lected

on 18 August had demonstrated the presence of E.col i O157 in the spring

source conf irming that contamination of the source had taken place and

longer term risk mit igat ion measures needed to be investigated by the

local author ity. Source monitor ing showed that E.coli O157 remained

detectable in the source water for longer than one month (a posit ive

sample collected on 2 September was fol lowed by negative samples

col lected on 16 and 30 September).

The water supply

The private supply spring source is located in a wooded area of grazing

pasture on hi l ls ide above the premises (see Figure 12).


41

Water is piped from the source holding tank to

f ive storage tanks located at one of the three

premises situated adjacent to one another in a

val ley with land abutt ing a small r iver. The

water is then piped into the treatment room

where it goes into another pre-treatment

holding tank, before passing through a pre -f i l ter

and a UV disinfect ion unit .

Figure 13: Holding tank Figure 14: Storage tanks

Figure 15: Internal untreated

water holding tank

Figure 16: UV treatment

The local authority had carr ied out a r isk assessment of this private wat er

supply in 2012 using the original r isk assessment methodology. This r isk

assessment carr ied out by the local authority did not f lag up any need for

the supply to be improved because, whi le the source was located in

grazing pasture, the l ivestock in quest ion were sheep and there was

Figure 12: Situation of

the source


42

fencing to keep these sheep away from the spring, the water was

disinfected with UV pr ior to use, and there was a maintenance contract in

place for annual servic ing of this equipment. The original r isk assessment

did not require the whole supply (source to tap) to be considered and

hence fel l short of a comprehensive water safety plan appro ach. In

addit ion the previous r isk assessment methodology did not consider

hazards associated with the management and operation of a supply and

the implicat ions on the r isk to health of users.

Immediately following the putt ing in place of the f irst restr ic t ion Not ice, the

owner of the supply who lived in one of the three premises called in the

maintenance engineer. The engineer ’s visit revealed that the dis infect ion

system was operat ing but it was undersized. The equipment was designed

to treat a f low of 9 l i t re/min whereas demand from the three premises when

fully occupied was of the order of 45 l it re/min. The Inspectorate’s r isk

assessment tool guides local authorit ies to consider, where treatment is

already in place, whether it is adequate to treat the cu rrent volume of

water which is being used – i .e. at normal and peak f low per iods. The

engineer identif ied the need for a larger dis infect ion unit sized to treat 60

l it re/min. In addit ion, the pre-treatment in place was a f i l ter of nominal 250

micron size. Such a f i l ter acts only as a coarse screen to remove larger

part ic les, not to achieve the required 1NTU prior to disinfect ion. To

adequately pre-treat water for UV disinfect ion of spring water the pre -

treatment should include a second f iner f i l ter of f ive micron or less and this

should be preceded by a 20 micron f i l ter. Coarse screens should be

located at the source tank. These issues were addressed immediately by

the instal lat ion of new equipment which consisted of a 60 l it re/min UV unit

preceded by two cartr idge f i l ters, the f irst being f ive micron and the

second being one micron nominal pore size.

The equipment was also f it ted with a ‘fail safe auto cut off ’ device to

prevent forward f low of water that may not have been disinfected in the

event of a power failure. Fol lowing these works the pipe network was

chlorinated and f lushed through. A six monthly maintenance contract was

set up with the water treatment engineer and a comprehensive water

safety plan was put in place.

A review of the historic local au thority pr ivate supply records revealed that

annual samples had been col lected f rom a tap in one of the premises in

March 2012, Apri l 2013 and August 2014. While the sample in 2013 (and

another in 2010) had given satisfactory results, Enterococci (1 per 10 0ml)

had been reported in the 2012 sample and the 2014 sample contained

col iforms (40 per 100ml and E.coli 30 per 100ml). Routine water indicator

tests do not detect the pathogen E.coli O157 , however, a posit ive result for

faecal organisms (>1 per 100ml) indicates ingress of animal or human

faecal matter and therefore a heightened r isk of pathogens being present.


43

In a treated water sample, a posit ive result also indicates that any

dis infect ion equipment in place may not be functioning effect ively. The

posit ive sample result obtained in 2014 had been followed up by the local

author ity advising the supply owner to arrange for the treatment equipment

to be serviced. The next sample col lected on 7 August 2015 as part of the

local author ity regulatory compliance monitor ing programme gave a

satisfactory result for the parameters tested. I f the previous posit ive result

had been followed up dif ferently with an investigation based on the

methodology in the Inspectorate’s r isk assessment tool, the defects with

this supply (changes in the catchment, undersized equipment and

inadequate act ive management) could have been ident if ied earlier enabl ing

act ion to be taken that may have prevented the outbreak f rom occurring.

As part of the outbreak investigat ion the local author ity appl ied the

Inspectorate’s r isk assessment tool and consulted with the Environment

Agency. This revealed that the underlying bedrock in the spring location is

f issured l imestone. The general area has some drif t cover of clay but this

was absent in the immediate vic inity of the spring. These natural features

make the source vulnerable to fast surface water in -f lows creating a direct

route for surface contaminants to enter the spring source. I t was also

found that a signif icant change had occurred in the catchment. A new

tenant farmer had commenced grazing of the pasture by catt le, not sheep.

During t imes of inclement weather, including heavy rainfal l in late July, the

catt le had taken to shelter ing in the woodland where the spr ing was

located. The catt le had damaged the fencing and had been defecating in

the immediate proximity of the source. Histor ic maintenance of the supply

had not included inspection and cleaning out of the spring water holding

tank and the tank was not f it ted with either an inlet or o utlet sediment trap.

Figure 17: Fence pushed down by livestock


44

Maintenance of the supply had been l imited to annual servic ing of the UV

disinfect ion equipment and there were no records of other essential act ive

management act ivit ies such as regular visual inspect ions of the source and

its immediate catchment, the condit ion of the tanks or the day-to-day

functionality of the UV lamp and f i l ter.

Based on the updated r isk information, the local author ity was able to work

with the owner of the supply and the tenant farmer to ident ify changes in

land use and supply management that would mit igate the identif ied r isks

and enable the boi l water not ice to be l if ted. On 12 November, the tenant

farmer agreed to instal l a wider perimeter fence preventing catt le f rom

entering a 6,000 square metre area around the spr ing source. In addit ion a

voluntary agreement was made to l imit the grazing density in the wider

area to no greater than one cow per acre. The local authority also required

the supply owner to put in place a water safety plan with act ive

management procedures and record keeping before l i f t ing the boi l water

restr ict ion not ice. Although not required by the local author ity, since the

outbreak, the owner of one of the hol iday cottages has decided to connect

the premises to the local mains water supply.

Learning points

The outbreak occurred through a combination of several factors. Recent

rainfal l mobil ized animal excrement increasing the l ikel ihood of pathogens

entering the spring through surface inf lows; tal l vegetat ion around the

source attracted the animals to shelter f rom rain in the area proximal to

the source; the land use had changed from grazing of sheep to catt le

increasing the l ikel ihood of E.col i O157 being present. The premises

served by the water supply were fully occupied and water demand was f ive

t imes higher than intended for the disinfect ion system design.

This case study provides compell ing evidence of the need for private water

suppl ies to be act ively managed with the design and maintenance regi me

being informed by a comprehensive r isk assessment that is kept under

continuous review and updated in l ight of changed circumstances. Where it

is ident if ied that the manager or owner of a supply is not in direct control

of act ivit ies in the catchment of a spring source then the local authority is

advised to require a water safety plan to be put in place that provides

conf idence that the grazing of catt le in proximity to the source is

restr icted. The r isk assessment should document al l relevant persons as

def ined in Section 80(7) of the Water Industry Act and everyone, including

the owner and manager of land where the source is s ituated, should

contr ibute to and be direct ly involved in the development of the water

safety plan. Such a plan should involve the keeping of records by the

supply owner or manager of regular visual checks that land use


45

agreements regarding l ivestock and the use of chemicals or fert i l izer are in

place and being adhered to.

Catchment measures alone are insuf f icient to safeguard a spr ing supply.

There should be mult iple barr iers in place. Over and beyond catchment

measures, as a minimum, there should be coarse screens on the raw water

holding tank inf low and outf low that are regular ly inspected and kept clean,

combined with a treatment system sized to function ef fect ively at t imes of

maximum demand. The r isk assessment should cr it ical ly evaluate the

maximum daily water use in the context of the maximum design capacity of

the treatment equipment. Al l disinfect ion systems should include p re-

treatment compris ing two f i l ters in series with the second being no greater

in nominal s ize than f ive microns. There should be records kept by the

owner to demonstrate that the condit ion and functionality of the screens,

f i l ters and disinfect ion system are checked no less of ten than weekly.

Such records should also contain detai ls of the act ion taken when checks

indicated the need, as wel l changes made to the system to accommodate a

change in use along with the detai ls of any annual service or maintenanc e

contract.

This case study, l ike many published by the Inspectorate since 2010 , also

demonstrates the need for private supply owners and local authorit ies to

have access to better water engineering advice. The functional ity of all

forms of equipment for water treatment depends crit ical ly on the design

comfortably being able to meet the maximum demand on the system. There

must be safeguards in place also to ensure that rapid changes in source

water qual ity do not result in water with a turbidity of >1 NTU b eing

presented for disinfect ion. At present there is no means by which private

supply owners or local authorit ies can be assured about the equipment and

services on of fer , although many local authorit ies keep l ists of reliable

treatment instal lers.

Through the publ icat ion of this case study, local authorit ies are reminded

of the need to notify the Inspectorate at the ear liest opportunity when

there is a case of E.col i O157 infect ion in a person resident in their area

under investigation as to the exposure source. In such circumstances it is

important to explore the individual ’s recent travel history for any potent ial

exposure to a pr ivate water supply at a location elsewhere and the

national private water supply record held by the Inspectorate enables

ready access to information and knowledge that can enhance

epidemiological survei l lance in relat ion to E.coli O157 and support the

response of any outbreak control team formed.

An important part of this outbreak investigation, beyond the putt ing in

place of appropr iate short and long-term risk mit igat ion measures, was the

need also to establ ish the spring as the source of the pathogen and the


46

l ikely durat ion of the contamination event. Lit t le is known about the

survival of E.coli O157 in raw water sources and the ir catchments so there

was a need to monitor the raw water over t ime. This raw water monitoring

highl ighted that such contamination events may not be short l ived since

E.col i O157 persisted in this spr ing source for several weeks af ter

conf irmation of the contamination event. This invest igation revealed a lack

of water laboratory capacity to test water samples for E.coli O157 , which in

turn highl ighted a need for the Inspectorate to review with the water

industry its capacity to better understand through mo nitor ing the

prevalence of this pathogen in raw waters going forward. Specif ic to

private suppl ies, local authorit ies need ready access to a test ing service

for E.coli O157 in order to verify regulatory r isk assessments of vulnerable

spring sources.

Case study 8 – Risks associated with change of use from a supply for

non-domestic purposes to domestic purposes

This case study i l lustrates some examples of the legacy of historical

def iciencies of the private water suppl ies legislat ion pr ior to the current

legislat ion. This is i l lustrated in relat ion to a regional industr ial group of

Regulat ion 9 suppl ies located in south -east England. These supplies serve

an area of salad growing nurseries, which supply produce to some of the

large supermarket retai l out lets. The suppl ies are fed f rom groundwater

sources f rom boreholes and wel ls. Many of the supply arrangements date

back decades when this local ised industry was at its height, and the

suppl ies were used for irr igat ion. The water f rom these suppl ies is today

used pr imari ly for the domestic needs of workers, the majority of wh om l ive

on site as migrant communit ies in temporary accommodat ion, such as

caravans and mobile homes. The local authority found no evidence to

suggest that the water was being used to wash the crops once it had been

harvested. The source water in most cases was being pumped from a

borehole or wel l to a large elevated steel tank f rom where it was

distr ibuted via a myr iad of pipework and storage facil i t ies, with poor ly

constructed connect ions above and below ground using products, some of

which were potential ly not approved for use on potable water systems.


47

In early 2015 a local authority

contacted the Inspectorate for support

and guidance going forward with their

duties as regulators of these suppl ies.

The deadline for local authorit ies to

complete r isk assessments of private

water suppl ies within the f irst f ive-year

period since the implementation of the

Regulat ions was approaching

(December 31 2015), and they were

concerned that progress to deliver was

being hampered by a number of issues

that were ar is ing as they started to

tackle the task in hand.

On meeting with the local author ity in

June 2015 it became apparent that this

task presented a number of

challenges, not least that previously

unknown suppl ies were emerging al l

the t ime and that the conf igurat ion of

supply systems were, in some cases, complex to r isk assess.

This was in part due to the resistance of site owners to either fully

cooperate with their invest igations, or appreciate that s imple makeshif t

repairs did not const itute adequate mit igat ion of r isk when presented with

act ion plans. In addit ion the pipework arrangements were in most cases

lengthy, poorly constructed and concealed , and of ten shared sites with

pipework providing water derived f rom publ ic supplies, which could not

easily be dif ferentiated f rom those on the private supply. Of those supplies

vis ited by the local authority, al l were described as having a range of r isks

f rom the source to the point of consumption, many of which suggested a

r isk to human health. This included boreholes that were in a state of poor

repair and were not adequately protected from vermin or the elements and

the absence of treatment (or adequate treatment) to mit igate catchment

r isks, such as histor ical landf i l l sites, agricultural farming and animal

husbandry (stables, kennels etc.) pract i ces, unauthorised ‘cottage

industr ies, ’ such as car repair and breaking yards, and where i l legal

discharges were occurring.

The Inspectorate advised that they appeared to have suf f icient evidence

from their vis its to enforce under Regulat ion 18 and should not delay in

serving Notice at the f irst opportunity. Inspectors were invited to

accompany the local authority on site to further advise and examine some

of the suppl ies in question – a visit they duly undertook in October 2015.

Figure 18: Water tower


48

During one of these vis its, the Inspectorate identif ied that a Regulat ion 8

supply had been created on one of the si tes, where a site owner was

further dist r ibut ing water f rom the publ ic supply via his neighbour ’s

premises to provide water to newly constructed bui ldings with bathroom

facil i t ies on his own premises. This apparently i l legal connect ion was later

reported to the local water company by the Inspectorate. On this same site

water was being suppl ied to caravans f rom a borehole located withi n the

growing area of the greenhouses surrounded by crops. This was pumped

to a poor ly constructed elevated steel tank, as is common practi ce on such

nursery sites, and distr ibuted through pipework, in places held together

with standard household tape. The pipes were, in part , la id through open

ditches alongside cluttered working and l iving environments. The water

was fed to a large storage tank located direct ly besid e a hand dug foul

water waste pit covered loosely by wooden boards and receiving site

sewage. From here the sewage was being pumped direct ly onto a

neighbouring f ield, located less than a 200m from the borehole. A

Regulat ion 18 Notice has since been served on the relevant persons to

fully mit igate the r isks to human health.

Figure 19: Waste pit Figure 20: Pipework laid in

ditches

The Inspectorate observed the site and found it was poor ly maintained.

There were disregarded produce heaps in a state of decay, untidy and

messy fuel and other stores, and undesirable localised act ivity in c lose

proximity to water storage areas. Boreholes were seen to be unprotected,

and in one case direct ly adjacent to a neighbouring stable, toi let block and

septic tank. Elsewhere water was being supplied for domestic purposes via

a small service reservoir with no protect ion f rom vandals and wildl ife, with

clear routes of ingress evident.


49

Figure 21: Entry to borehole

shed

Figure 22: Borehole headworks

Figure 23: Headworks for borehole Figure 24: Water storage tank

This case study i l lustrates the number and scale of water qual ity r isks that

can, and as these examples show, have developed over t ime on private

water supply systems through neglect and poor managemen t prior to the

implementat ion of current national legislat ion. Pr ior to 2010 local

author it ies monitored suppl ies according to the f requencies laid down in

the 1991 Regulat ions to determine whether or not a supply was compliant

with standards and therefore safe to consume, or not. A satisfactory

sample result , however, is no guarantee that the supply af fords no publ ic

health r isk at al l t imes, and clear ly as this case study i l lustrates, r isks can

be prevalent and increase with t ime, irrespective of what sam ple results

might indicate. Since 2010 local author it ies have been empowered to

enforce where there is evidence of an unwholesome supply and/or where


50

actual and potent ial r isk to human health has been ident if ied via the r isk

assessments they are required to undertake under Regulat ion 6. The

Inspectorate is aware that in some cases local authorit ies are st i l l reliant

on monitoring to guide their act ions to enforce. Local author i t ies are

encouraged to apply their powers to protect consumers by a t imely

proact ive r isk-based approach.


51

Chapter 4: Summary of research on private water supplies

During the year, the Inspectorate publ ished three research reports specif ic

to private suppl ies and summaries are provided below.

4.1 A review of incidence of outbreaks of diseases associated with

Private Water Supplies from 1970 to 2009 (DWI 70/2/258) .

Background

I t is est imated that 0.5% of the populat ion in England and Wales receive

drinking water f rom private water supplies (PWS), and it is recognised that

these PWS are more vulnerable to contaminat ion compared to larger water

supply systems 5. Studies have also shown that PWS are at a higher r isk of

contamination with E.col i compared to publ ic water suppl ies.

Objectives

The primary object ive of this research was to identify and describe

outbreaks of disease associated with PWS in England and Wales between

2001 and 2009 using the methodology adopted by Said et al . (2003) 6 in

their review of outbreaks between 1970 and 2000. The project included a

number of other object ives including an examination of trends in the

incidence of outbreaks 1970 to 2009, by comparing detai ls before and af ter

the implementat ion of The Private Water Suppl ies Regulat ions 2009 (2010

in Wales).

Key Findings

Between 1970 and 2009 there were found to be 37 outbreaks associated

with PWS. Twenty-f ive occurred up to and including the year 2000 and the

5 Smal l-scale water suppl ies in the pan-European region [ Internet ] . W orld Health

Organisat ion Regional Of f ice for Europe; 2010 p. 57. Avai lable f rom:

ht tp:/ /www.unece.org/f i leadmin/DAM/env/water/publ icat ions/documents

/Smal l_scale_suppl ies_e.pdf

6 Said B, Wright F, Nichols G, Reacher M, Rutter M. Outbreaks of in fect ious

d isease assoc iated wi th pr ivate dr ink ing water suppl ies in England and W ales

1970-2000. Epidemiol Infect. 2003;130:469–79.

Chapter 4:

Summarises the outcome of research specif ic to private

water suppl ies


52

remaining 12 in 2001 and beyond. In this later dozen, f ive occurred in

Wales. Most were found to have occurred in places where consumers

tended to be short-term residents (e.g. mil itary sites, camp sites, hostels) .

The associat ion of the supply and i l lness was general ly possible based on

identif icat ion of water treatment failures in conjunct ion with information of

water-related disease. Fai lures found included contamination by l ivestock,

poor catchment protect ion of the source, inadequate treatment, and poor

maintenance of treatment and supply infrastructure . Pathogens identif ied

included Cryptosporidium, Campylobacter, E.col i O157, Salmonella and

norovirus. I t should be noted that no deaths were reported in relat ion to

these outbreaks, but two chi ldren were admitted to hospital in 2008.

General conclusions

The project identif ied that there were no large changes in the numbers of

outbreaks of gastrointest inal infect ions associated with private water

suppl ies between 1970 and 2009, and reported outbreaks generally only

affected small populat ions. Equal ly, the same problems of poor source

protect ion, animal contaminat ion, inadequate treatment and poor

management have continued to af fect PWS since 1970. The most frequent

pathogens identif ied during outbreaks were Campylobacter spp and E.col i

O157.

The introduction of Regulat ions in 1991, which focused on monitor ing, did

not change this and therefore, there is potential for this to improve

following the implementation of the 2009/2010 Regulat ions with the r isk -

based approach.

I t was a conclusion of the research that outbreaks associated with private

suppl ies continue to represent a r isk to short -term resident populat ions

attending locations such as act ivity centres, while outbreaks l inked to

hol iday accommodation have not occurred since 2001. However, since

complet ion of the research, the Inspectorate has been advised of an

outbreak of E.coli O157 associated with a hol iday let. The learnings from

this outbreak are reported in case study 7 in chapter 3 of this report.

A number of recommendat ions for future work were proposed including

demonstrat ion of associat ion between private supply improvements and

health outcomes (for example, so that impacts of improvements in local

author ity regulat ion of private water suppl ies can be documented) .

4.2 Technical definition of wholesomeness in relation to water used

for toilet flushing in private water supplies (DWI 70/2/203)

Section 218 of the Water Industry Act 1991 states that references to

domestic purposes in the Regulat ions ‘are references to the drinking,


53

washing, cooking, central heating and sanitary purposes for which water

suppl ied to those premises may be used’. While water for toilet f lushing

clearly fal ls within the def init ion of a sanitary purpose, and hence a

domestic purpose, it is logical to propose that the water quality required

might not need to be as high as that for other domestic purposes, provided

the supply f rom natural sources is used solely for toilet f lushing.

Consequently, the Inspectorate commissioned a research project to

document the scient i f ic information required to underpin a technical

def init ion of wholesomeness of water used solely for toi let f lushing in

domestic propert ies, taking into considerat ion publ ic health r isks and

aesthet ic issues.

The aim of this project was to provide the Inspectorate with information on

what water qual ity should underpin a technical def init ion of wholesome in

relat ion to the appl icat ion of the Regulat ions to water f rom natural sources

used only for toi let f lushing in domestic propert ies. More specif ical ly, the

object ives were to:

1. Review avai lable scientif ic l i terature on the qual ity of water used to

f lush toi lets nat ionally and internat ionally .

2. Analyse the approaches adopted by other countr ies to this issue and

examine the rat ionale for any def init ions, guidel ines or standards and

how these have been developed and/or applied.

3. Consider which parameters should be in corporated into a def init ion of

wholesomeness for toi let f lushing water and what l imit should be placed

on the number, amount or concentrat ion of each of the proposed

parameters, with a clear rat ionale for the inclusion of each parameter

and the associated l imit.

Key findings

Objectives 1 and 2 did not result in a consensus regarding a def init ion of

wholesomeness or sett ing of standards. This was part ly due to insuff icient

research and a lack of information. However, there was l it t le agreement on

standards. W ithin greywater/rainwater harvesting systems there was l it t le

consensus on chemical parameters and concentrat ions , although faecal

col iforms tended to be used as m icrobiological standards, but with a broad

range of l imits. Object ive 3 was revised to look at the evaluat ion of the r isk

of using natural sources of water solely for toi let f lushing.

A f ramework was out l ined using a source -pathway-receptor approach and

a f low diagram was developed to evaluate possible systems of f lushing

water and to exclude or advise on certain sources and processes.


54

General conclusions

In order to minimise r isks to human health, water used for f lushing should

exclude surface water sources and sources where the water is potent ially

subject to external faecal contamination. W ater should be suppl ied by a

sealed pipe straight to the cistern, with f ixtures and f it t ings in accordance

with BS6920. The supply should be a permanent sole supply to the toi let

( for example not cross connected with a public or other pr ivate water

supply), with no history of insuff iciency.

Apart f rom the cistern, it is reasonable to have a day’s storage of

f lushwater, but provision must be made for draining the system during

extended per iods of absence. I f a supply is used solely to supply a

handbasin, water fountain or any other feature that could be used for

domestic purposes, then these should be treated as normal under the

private supply regulat ions.

The research carr ied out by DWI related to a private water supply to a

premises used only for toi let f lushing fal l ing under the def init ion of

domestic purposes under the Water Industry Act 1991 (sect ion 218).

However, in 2015, the Building Regulations 2010 were updated to

specif ically deal with the use of water solely for some purposes

including toilet f lush ing, irr igation and laundry. This update to the

Building Regulat ions clar if ies an aspect of private water supply

regulat ion and ensures these uses are covered specif ically under

bui lding legislat ion rather than private water supply regulations. Sect ion

1.6 of the Building Regulations 2010 states that wholesomeness is not

essent ial for water used for toi let f lushing and sect ion 1.13 states that

water f rom alternat ive sources, such as private supplies, “may be used

in dwell ings for sanitary conveniences, wash ing machines and irr igat ion,

provided the appropriate r isk assessment has been carr ied out.”

A risk assessment for the supply should be carr ied out to determine any

health r isks associated with that use, if there are any aesthetic issues

which may affect its acceptabi l ity, or if there is a risk of contaminating

any wholesome supplies. The r isk assessment should be carr ied out by

the system designer and manufacturer (sect ion 1.14) and should also

consider waste, misuse and undue consumption of water. These are

also requirements of the Water Supply (Water Fitt ings) Regulations

1999. If the risk assessment conf irms that there are no signif icant r isks

to health, rout ine monitoring is not required.

4.3 Comparison of Private Water Supply and Public Water Supply

Ultraviolet (UV) Systems (DWI 70/2/306)

The object ive of this study was to understand the dif ferences between UV

technologies used on public and private suppl ies, to review international


55

standards for UV val idat ions and develop a test procedure that could

usefully evaluate a UV system based on dose val idat ion. The project

del ivered guidance for private supply owners to help them select a suitable

UV system and guidance for local author it ies in assessment of exist ing

instal lat ions. This guidance wil l be publ ished at www.dwi.gov.uk

This study involved vis its to a number of UV disinfect ion instal lat ions on

PWS and determined that they usual ly included pre-treatment such as

f i l t rat ion, but were of ten designed based on l imited water qual ity data.

There was l imited monitor ing and control of the systems, although there

were examples where valving was designed to prevent a maximum f lowrate

being exceeded. There were very few instances where UV transmittance

(UVT ) or turbidity was measured, thus making it dif f icult to assess whether

the units operated within their design parameters. Systems were general ly

serviced annual ly, al though a lack of alarms on many systems means that

power cuts or lamp fai lure may go unnoticed for some t ime. The

consultants concluded that the qual ity of design and installat ion varied

considerably.

A number of val idat ion standards exist for UV systems, although the

majority are designed for public suppl ies . A BSI standard exists, but this is

only intended for the condit ioning of mains water in buildings. The Önorm

and DVGW standards are considered the most appropr iate standards,

although the BS:EN 14987 standard has similar requirements to Önorm,

despite not being designed for private suppl ies. The f inal report documents

a recommended test procedure for validat ion of systems for use on PWS.

However, all exist ing standards where UV is instal led for disinfect ion

purposes require instal lat ion of a UVI sensor. These are unl ikely to be

found except on the largest private water supply systems.

The researchers made several key recommendations.

A l icensing or approved contractor scheme should be implemented for

instal lers of equipment for PWS.

Copies of manufacturers’/suppliers’ operating and maintenance

instruct ions should be provided and retained by the supply owner.

A maintenance log should be kept by the owner to record detai ls of

maintenance carr ied out and schedules for future maintenance.

Audible and visual alarms should be more prominent, part icularly where

the UV system is sited away from the user’s premises.

UV systems should include automatic shutdown of the water supply in

the event of power or lamp failure.

The r isk assessment tool developed by the Inspectorate includes many of

these considerat ions in its hazard identif icat ion sect ion f or UV disinfect ion.


56

Chapter 5: Drinking water testing results

Chapter 5:

Descr ibes the progress of local author it ies in providing test results.

Provides details of audits by the Inspectorate of compliance with

sample f requencies.

Summarises the results of private supply test ing.

Reports on work by the Inspectorate and in providing an enquiry

service to local authorit ies and private supply owners .

5.1 Local authority progress in reporting test results

This chapter summarises the information provided by lo cal authorit ies to

the Inspectorate about the results of the test ing of private water suppl ies.

In total, for the calendar year of 2015, there were 188,054 test results

submitted to the Inspectorate by local authorit ies and Figure 25 shows how

this volume of tests compares favourably to the situat ion in previous years

Figure 25: Numbers of test results sent to the Inspectorate 2010–2015


57

5.2 Results of 2015 monitoring

In prepar ing Tables 26 to 29, it should be noted that when pool ing data

f rom local authorit ies, the Inspectorate checked for and corrected any

simple errors ( incorrect units, obvious input errors such as decimal point in

the wrong place) to enable these results to be included in the report.

Where the Inspectorate corrected data, the local authority was contacted,

and the problem and changes explained and agreed. Some of the issues

identif ied with annual returns were:

Analyt ical sample results entered in the wrong units.

There was inappropr iate use of < ( less than) symbols, for example,

nickel reported as <20µg/l when the standard is 20µg/l. This is either a

shortcut being used by local author it ies to speed data entry (saying in

effect the sample did not fail, or that the method is not suf f iciently

sensit ive and that the l imit of detect ion is at the same value as the

standard.

There was inappropr iate use of > (greater than symbols) on chemical

parameters.

Analyt ical data for parameters not contained within the Regulat ions.

Some analyses for taste and odour do not comply with the required

method.

Obvious typos.

Poor correlat ion between samples f lagged as fail ing with those actually

fail ing the standard.

The drinking water standards in the private water supply Regulat ions are

the same as those that apply to publ ic water supplies and most derive f rom

the EU Drinking Water Direct ive. An explanation of the standards can be

found in Annex 5 . In the Regulat ions 7, the standards are set out by

parameter in Schedule 1. Four tables represent this schedule:

Tables 24a–27a cover microbiological standards; Tables 26b-29b and 26c-

29c set out the health-related chemical standards and the nat ional

standards whi le Tables 26d-29d cover the indicator parameters. Regulat ion

9 suppl ies should be monitored at least once per year and so have been

reported for 2015, whi le Regulat ion 10 supplies ( including single domest ic

dwell ings) have to be monitored at least every f ive years and so are

reported for the last f ive complete calendar years (2011 – 2015). For ease

of reference, Tables 26-29 are set out following the Schedule 1 format and

show the following information for each parameter: the standard or

7 The Pr i va te W ater Suppl ies Regula t ions 2009.


58

prescribed concentrat ion; the total number of tests; the number of tests not

meeting the standard or prescr ibed concentrat ion; and the percentage of

samples not meet ing the standard or prescribed concentrat ion.

When comparing the quality of dif ferent types of supply it can be seen

from Tables 26a-29a that there are clear dif ferences in microbiological

quality. In England, 6.2% of samples f rom Regulat ion 9 supplies contained

E.col i (an improvement on 2014), whereas the failure rates for Regulat ion

10 suppl ies and single domestic dwell ings is notably higher at 16.6% and

15.5% respectively. This pattern is ver if ied by the f igures for the other

faecal indicator organism, Enterococci: Regulat ion 9 suppl ies (7.2%),

Regulat ion 10 supplies (15.7%), and single domestic dwell ings (15.0%).


59

England – Regulation 9 – 2015 data – numbers of tests and percentage

not meeting the standard

Table 26a: Schedule 1 Table A – microbiological parameters

Parameter Current s tandard

or speci f ied concentrat ion

Total number of tests

Number of tests not

meeting the standard or

specif icat ion

Percentage of tests not meeting the

standard

Escher ich ia co l i (E.col i ) 0 /100ml 8,888 547 6.2

Enterococc i 0 /100ml 4,573 329 7.2

Table 26b: Schedule 1 Table B – chemical parameters




Number of tests not


specif icat ion


standard

Ant imony 5µg/ l 754 5 0.7

Arsenic 10µg/ l 1 ,532 51 3.3

Benzene 1µg/ l 447 1 0.2

Benzo(a)pyrene 0.01µg/ l 266 0 -

Boron 1mg/ l 612 3 0.5

Bromate 10µg/ l 493 3 0.6

Cadmium 5µg/ l 873 0 -

Chromium 50µg/ l 796 0 -

Copper 2mg/ l 1 ,379 14 1.0

Cyanide 50µg/ l 378 0 -

1-2 Dich loroe thane 3µg/ l 382 0 -

F luor ide 1.5mg/ l 1 ,041 82 7.9

Lead 10µg/ l 2 ,082 85 4.1

Mercury 1µg/ l 391 0 -

Nickel 20µg/ l 1 ,227 36 2.9

Ni t ra te 50µg/ l 4 ,690 397 8.5

Ni t r i te – consumers ’ taps 0 .5µg/ l 3 ,697 41 1.1

Ni t r i te – t reatment works 0.1µg/ l 665 27 4.1

Pest ic ides

A ldr in 0.03µg/ l 261 1 0.4

Die ldr in 0 .03µg/ l 271 0 -

Heptachlor 0 .03µg/ l 261 0 -

Heptachlor Epoxide 0.03µg/ l 257 0 -

Other pest ic ides 0.1µg/ l 10,042 17 0.2

Tota l pest ic ides 0.5µg/ l 272 3 1.1

Polycyc l ic aromat ic hydrocarbons

0.1µg/ l 181 5 2.8

Selenium 10µg/ l 671 11 1.6

Tr ich lo roethene and te t rachloroethene

10µg/ l 340 1 0.3

Tr iha lomethanes 100µg/ l 370 3 0.8

*Standards are not set for a l l d is in fect ion by -p roducts .


60

England – Regulation 9 – 2015 data – numbers of tests and percentage

not meeting the standard

Table 26c: Schedule 1 Table B – national requirements




Number of tests not


specif icat ion


standard

Alumin ium 200µg/ l 3 ,543 48 1.4

Colour 20mg/ l Pt /Co 5,062 86 1.7

I ron 200µg/ l 5 ,068 374 7.4

Manganese 50µg/ l 4 ,858 321 6.6

Odour No abnormal

change 4,579 264 5.8

Sodium 200mg/ l 952 46 4.8

Taste No abnormal

change 3,969 183 4.6

Tet rachloromethane 3µg/ l 413 12 2.9

Turb id i ty 4NTU 5,781 101 1.7

Table 26d: Schedule 1 Table C – indicator parameters




Number of tests not


specif icat ion


standard

Ammonium 0.5mg/ l 5 ,330 170 3.2

Chlor ide 250mg/ l 614 8 1.3

Clostr id ium per f r ingens 0 /100ml 4,175 267 6.4

Col i form bacte r ia ( ind icator)

0 /100ml 8,808 1,283 14.6

Colony Counts Af te r 3 Days At 22°c

No abnormal change

7,107 - -

Colony Counts Af te r 48 Hours At 37°c

No abnormal change

7,005 - -

Conduct i v i t y 2500µS/cm 5,798 7 0.1

Hydrogen ion (pH) ( ind icator)

6 .5 – 9 .5 6.565 621 9.5

Sulphate 250mg/ l 609 18 3.0

Tota l Ind icat i ve dose mSv/year 25 0 -

Tota l organic carbon No abnormal

change 234 0 -

Tr i t ium 100Bq/ l 76 0 -

Turb id i ty (a t t reatment works)

1NTU 752 39 5.2


61

England – Regulation 10 – f ive-year data (2011-2015) – numbers of

tests and percentage not meeting the standard





Number of tests not


specif icat ion


standard

Escher ich ia co l i (E.col i ) 0 /100ml 8,731 1,449 16.6

Enterococc i 0 /100ml 6,432 1,008 15.7





Number of tests not


specif icat ion


standard


Arsenic 10µg/ l 741 23 3.1

Benzene 1µg/ l 95 0 -


Boron 1mg/ l 235 5 2.1


Cadmium 5µg/ l 381 1 0.3


Copper 2mg/ l 1 ,225 70 5.7



F luor ide 1.5mg/ l 279 10 3.6

Lead 10µg/ l 1 ,931 197 10.2

Mercury 1µg/ l 103 1 1.0

Nickel 20µg/ l 480 36 7.5

Ni t ra te 50µg/ l 3 ,932 657 16.7



Pest ic ides

A ldr in 0.03µg/ l 73 0 -

Die ldr in 0 .03µg/ l 68 0 -



Other pest ic ides 0.1µg/ l 2 ,691 11 0.4

Tota l pest ic ides 0.5µg/ l 74 0 -


0.1µg/ l 52 1 1.9

Selenium 10µg/ l 249 1 0.4


10µg/ l 71 1 1.4

Tr iha lomethanes 100µg/ l 70 0 -



62

England – Regulation 10 – f ive-year data (2011-2015) – numbers of

tests and percentage not meeting the standard





Number of tests not


specif icat ion


standard

Alumin ium 200µg/ l 2 ,179 110 5.0

Colour 20mg/ l Pt /Co 2,446 92 3.8

I ron 200µg/ l 3 ,447 360 10.4

Manganese 50µg/ l 3 ,328 413 12.4

Odour No abnormal

change 2,222 302 13.6

Sodium 200mg/ l 353 16 4.5

Taste No abnormal

change 1,575 212 13.5

Tet rachloromethane 3µg/ l 69 0 -

Turb id i ty 4NTU 5,094 272 5.3





Number of tests not


specif icat ion


standard

Ammonium 0.5mg/ l 2 ,631 69 2.6

Chlor ide 250mg/ l 330 6 1.8

Clostr id ium per f r ingens 0 /100ml 2 ,682 322 12.0


0 /100ml 7 ,854 2,505 31.9


No abnormal change

3,584 - -


No abnormal change

3,626 - -



6 .5 – 9 .5 5 ,853 866 14.8

Sulphate 250mg/ l 353 12 3.4



change 164 0 -

Tr i t ium 100Bq/ l 11 0 -


1NTU 715 48 6.7


63

England – Single Domestic Dwellings – f ive-year data (2011-2015) –

numbers of tests and percentage not meeting the standard





Number of tests not


specif icat ion


standard


Enterococc i 0 /100ml 2,269 341 15.0





Number of tests not


specif icat ion


standard


Arsenic 10µg/ l 361 18 5.0



Boron 1mg/ l 78 10 12.8




Copper 2mg/ l 666 26 3.9



F luor ide 1.5mg/ l 161 4 2.5

Lead 10µg/ l 894 60 6.7

Mercury 1µg/ l 46 0 -

Nickel 20µg/ l 202 11 5.4

Ni t ra te 50µg/ l 1 ,604 221 13.8



Pest ic ides

A ldr in 0.03µg/ l 33 0 -

Die ldr in 0 .03µg/ l 33 0 -



Other pest ic ides 0.1µg/ l 0 0 -



0.1µg/ l 21 0 -

Selen ium 10µg/ l 103 0 -


10µg/ l 29 0 -

Tr iha lomethanes 100µg/ l 23 0 -



64

England – Single Domestic Dwellings – f ive-year data (2011-2015) –

numbers of tests and percentage not meeting the standard





Number of tests not


specif icat ion


standard

Alumin ium 200µg/ l 1 ,046 45 4.3

Colour 20mg/ l Pt /Co 1,179 38 3.2

I ron 200µg/ l 1 ,738 191 11.0

Manganese 50µg/ l 1 ,738 288 16.6

Odour No abnormal

change 1,051 191 18.2

Sodium 200mg/ l 168 11 6.5

Taste No abnormal

change 825 130 15.8

Tet rachloromethane 3µg/ l 30 0 -

Turb id i ty 4NTU 1,958 128 6.5





Number of tests not


specif icat ion


standard

Ammonium 0.5mg/ l 1 ,314 39 3.0

Chlor ide 250mg/ l 132 4 3.0

Clostr id ium per f r ingens 0 /100ml 1 ,175 143 12.2


0 /100ml 3 ,330 931 28.0


No abnormal change

1,529 - -


No abnormal change

1,533 - -



6 .5 – 9 .5 2 ,387 361 15.1

Sulphate 250mg/ l 125 10 8.0

Tota l Ind icat i ve dose mSv/year 5 1 20.0


change 31 0 -

Tr i t ium 100Bq/ l 9 0 -


1NTU 400 72 18.0


65

England – Regulation 8 – f ive-year data (2011-2015) – numbers of tests

and percentage not meeting the standard





Number of tests not


specif icat ion


standard


Enterococc i 0 /100ml 838 47 5.6





Number of tests not


specif icat ion


standard


Arsenic 10µg/ l 114 3 2.6


Benzo(a)pyrene 0.01µg/ l 103 8 7.8

Boron 1mg/ l 102 8 7.8

Bromate 10µg/ l 126 0 -



Copper 2mg/ l 192 4 2.1

Cyanide 50µg/ l 80 2 2.5


F luor ide 1.5mg/ l 125 1 0.8

Lead 10µg/ l 250 16 6.4

Mercury 1µg/ l 86 2 2.3

Nickel 20µg/ l 170 4 2.4

Ni t ra te 50µg/ l 564 15 2.7

Ni t r i te – consumers ’ taps 0 .5µg/ l 366 9 2.5


Pest ic ides

A ldr in 0.03µg/ l 67 0 -

Die ldr in 0 .03µg/ l 67 0 -


Heptachlor Epoxide 0.03µg/ l 67 1 1.5

Other pest ic ides 0.1µg/ l 0 0 -



0.1µg/ l 51 1 1.9

Selenium 10µg/ l 83 0 -


10µg/ l 78 1 1.3

Tr iha lomethanes 100µg/ l 74 2 2.7



66

England – Regulation 8 – f ive-year data – numbers of tests and

percentage not meeting the standard





Number of tests not


specif icat ion


standard

Alumin ium 200µg/ l 1 ,043 26 2.5

Colour 20mg/ l Pt /Co 401 6 1.5

I ron 200µg/ l 1 ,333 75 5.6

Manganese 50µg/ l 1 ,140 88 7.7

Odour No abnormal

change 435 53 12.2

Sodium 200mg/ l 445 64 14.4

Taste No abnormal

change 382 38 9.9

Tet rachloromethane 3µg/ l 100 7 7.0

Turb id i ty 4NTU 1,430 38 2.7





Number of tests not


specif icat ion


standard

Ammonium 0.5mg/ l 627 33 5.3

Chlor ide 250mg/ l 384 23 6.0

Clostr id ium per f r ingens 0 /100ml 308 17 5.5


0 /100ml 2 ,616 100 3.8


No abnormal change

2,184 - -


No abnormal change

2,162 - -



6 .5 – 9 .5 1 ,601 50 3.1

Sulphate 250mg/ l 392 32 8.2



change 58 0 -

Tr i t ium 100Bq/ l 52 0 -


1NTU 380 11 2.9


67

The results in Annex 2 demonstrate the extent of non-compliance of

private water supplies with the health -related chemical standards, national

standards and indicator parameters, with 4 ,634 failures of 36 parameters

being recorded in 2015 in England and Wales. Table xx shows that highest

rate of failure of chemical standards associated with Regulat ion 9 suppl ies

in England were of nitrate (8.5% of tests), f luoride (7.9%) and arsenic

(3.3%).

Where there is an exceedance of a health -based parameter, Local

author it ies are reminded it is mandatory to serve a Notice to secure the

protect ion of health. In 2015 there were 65 failures of the arsenic

parameter whi le between 2011 and 2015 there were in total only 19

Notices served for this parameter . Local author it ies when serving a Not ice

should secure a permanent remedy and this may take the form of

prohibit ion, restr ict ion and/or advice on what effect ive act ion is necessary

to mit igate the r isk. The Inspectorate has identif ied instances where act ion

has not been ef fect ive. For example , in 2013, a Notice was served to carry

out remedial measures in respect of arsenic signif icantly above the

standard, but in 2015 this same supply continues to fai l for this parameter.

Arsenic only occurs in drinking water where natural minerals containing

arsenic are present in the local bedrock. In England this is not a frequent

occurrence. Figure 30 shows, for each local author ity area, the highest

recorded sample result in the Inspectorate’s dataset f rom water

companies’ raw water sampling for arsenic in the local author i ty’s area or

f rom samples taken from private water suppl ies by the local authority .

.


68

Figure 30: Maximum arsenic concentration

The results of test ing of Regulat ion 10 supplies have been presented for

the years 2011 to 2015 as they only require monitor ing every f ive years,

unless the r isk assessment shows more f requent monitor ing to be

necessary. In England, the parameters fai l ing in the highest proport ion of

tests were nitrate (16.7%), pH (14.8%) and taste and odour (13.5% and

13.6% respectively). Of the samples which did not meet the standard or

specif icat ion for taste or odour, less than 5% were submitted with a


69

descr iptor. Sample analysed for taste and odour using an accredited

laboratory method should be reported as a di lut ion number, and if that

number if greater than 0, a descr iptor should be provided and reported. Of

those samples reported with a descriptor, around a third of these were

reported as a chlorine taste or odour. The accredited method for taste and

odour analysis requires the sample to be dechlor inated at the earl iest

stage and therefore chlorine tastes or odours should not be detected.

Chapter 6: Legislative updates

Chapter 6:

Highlights work on the revision of the regulat ions and accompanying

guidance.

Reports on collat ion of data on local authority charging for private

water suppl ies act ivi t ies .

6.1 Revised Private Water Supply Regulations 2016

Background

Drinking water qual ity regulat ions In England and Wales transpose the

requirements of the Direct ive 98/83/EC (the Dr inking Water Direct ive)

which came into force on 25 December 2003. Pr ivate water supplies are

regulated by local authorit ies. The Inspectorate has a supervisory role,

and provides technical advice and support on pol icy and strategy to ensure

implementat ion of the Private W ater Supply Regulat ions.

The Private Water Supplies Regulat ions 1991 (SI 1991/ 2790) were

replaced by the Pr ivate Water Suppl ies Regulat ions 2009 in England (SI

2009/3101) and the Private Water Supplies (Wales) Regulat ions 2010 (SI

2010/66 W.16) in Wales, as the original 1991 Regulat ions did not fully

transpose the Dr inking Water Direct ive.

The European Commission approved a proposal for new requirements for

monitor ing of drinking water for radioactive substances in November 2013.

Member States had unti l the 28 November 2015 to transpose the Direct ive

into national legislat ion. Dur ing the revision to the Regulat ions in England

the opportunity was taken to consol idate a small addit ion made through the

Water Supply Regulat ions 2010, and to make some other small

clar if icat ions.


70

Euratom requirements

A parametric value or standard was set for radon in dr inking water (100

Bq/l) with provision for Member States to set a level up to 1 ,000Bq/l

provided water supply is not compromised , i.e. a level of protect ion is

maintained. Minimum frequencies for monitor ing have been specif ied for

monitor ing for tr it ium and indicat ive dose (ID). Monitoring wi l l not be

required if i t can be demonstrated that the radioact ive parameters are not

l ikely to be present or wi l l be at levels wel l below the parametric value.

This demonstrat ion should be based on representa t ive surveys, monitor ing

data or other rel iable information. In addit ion, monitoring for tr it ium is

required only where there is a man-made source.

The new Regulat ion 11 contains the requirements for monitor ing

radioact ive substances. For radon, a represen tat ive survey must be carr ied

out to determine the l ikelihood of a supply fail ing the standard. The

representat ive survey (r isk assessment) for radon should cover the scale

and nature of l ikely exposure to radon from dif ferent sources and wel ls in

dif ferent geological areas; and the impact of geology and hydrology of the

area and radioact ivity of rock and soi l and well type.

For ID, a screening method for gross alpha and gross beta act ivity may be

used and if the tr igger values are exceeded, further analysi s must be

carr ied out for specif ic radionuclides.

The maximum concentrat ions or values or states for radioactivity

parameters are set out in Schedule 1, Part 3, Table D:

Addit ion of a standard for radon [100Bq/l] ,

Addit ion of gross alpha and gross beta ‘ tr igger’ values 0.1Bq/l and

1Bq/l respectively for screening for ID .

A new part to Schedule 3 (Part 3) sets out t he methodologies for

monitor ing for individual radionucl ides. This is currently in guidance, but is

now required to be set out in the legislat i on. The screening method for

gross alpha and gross beta to monitor for ID is described, and the

requirement to monitor for individual radionucl ides when the screening

values are exceeded.

The opportunity was taken in England to consol idate previous amendme nts

and to correct previous transposit ion errors . The exempt ions for water

used for food production purposes has been expanded to allow for a

competent author ity ( in this case, the Food Standards Agency) to conf irm

that it is sat isf ied that the qual ity of water cannot af fect the

wholesomeness of a foodstuff in its f inished form. Regulat ions 6, 9 and 10

have been amended to clar ify that the Regulat ions apply where water is

used as part of a commercial act ivity, not to commercial premises.


71

The Regulat ions are now cal led Private Water Suppl ies (England)

Regulat ions 2016. In Regulat ion 5 (Products or substances in contact with

private suppl ies) the reference to Regulat ion 31 of the Water Supply

(Water Qual ity) Regulat ions 2000 (as amended) has been removed. Thi s is

now a f reestanding provision which sets out the requirements as regards

products or substances used in the treatment or distr ibut ion of private

water suppl ies. This ref lects the existence of a more f lexible approach to

approve products and substances that have been used historical ly in the

treatment and distr ibut ion of private water suppl ies with no detr imental

effect on water quali ty, as wel l as the process for approving products and

substances for publ ic water suppl ies.

In Regulat ion 6, the requirement to carry out a r isk assessment within f ive

years of the Regulat ions coming into force has been removed as it is now

t ime expired. However, the requirement to review and update the r isk

assessment every f ive years has been retained.

A new Regulat ion has been introduced for new suppl ies. Any new suppl ies

or any supply not used for a period of 12 months (except s ingle domestic

dwell ings not used as part of a commercial act ivity or provided to the

public), must be r isk assessed and monitored as soon as the local

author ity becomes aware of its existence. The supply must not be brought

into use unt i l the local authority is sat isf ied that it does not constitute r isk

to health.

Regulat ion 16 has been amended to clar i fy the act ion following

investigations into the cause of a water supply becoming unwholesome. I f

the cause is due to the distr ibut ion system within a domestic premises ( i.e .

the pipework and f it t ings), the local authority must inform the people

concerned and of fer advice on measures to protect health. However, if the

cause is due to the distr ibut ion system within a public building, the local

author ity must inform the people concerned, offer advice on measures to

protect health and ensure appropr iate remedial act ion is taken.

Regulat ion 16 has also been amended, to exclude the provision which had

al lowed local author i t ies to take no act ion where an invest igation has

established that the water is unwholesome. Where a local authority has

carr ied out an invest igation and established the cause of the water being

unwholesome or insuff icient, the relevant person has 28 days to remediate

the situation otherwise the local authority must now serve a Notice under

section 80 of the Water Industry Act 1991.

Guidance

The guidance on the Regulat ions has now been updated. This supercedes

the previous guidance document (October 2010) , and it is now publ ished in

separate information notes for each individual Regulat ion, with an


72

overarching guidance note covering monitoring. These are publ ished on

the Inspectorate’s website and may be subject to individual revis ions and

updates if necessary. Due to the dif ference in t imetable for the revision to

the Regulat ions between England and Wales, separate notes have been

produced for each and these wil l be amended as and when require d.

6.2 Review of local authority published charges

The Private Water Supply Regulat ions 2009 make provisions for local

author it ies to charge the relevant person(s) the cost of conducting their

statutory dut ies. The fees are set out in Schedule 5 of the Regulat ions and

should cover the reasonable cost of conducting the service. The

Inspectorate expects al l local author it ies to make their fees transparent to

the relevant person(s) of a private supply. The maximum fees that can be

charged are out l ined in Table 31.

Table 31: Maximum permitted fees

Service (activity) Maximum fee (£)

Risk assessment (each assessment) 500

Sampling (each vis it ) 1 100

Investigation (each investigat ion) 100

Granting an authorisat ion (each author isat ion) 100

Analysing a sample:

taken under Regulat ion 10 25

taken during check monitor ing 100

taken during audit monitor ing 500 1

No fee is payable where a sample is taken and analysed solely to confirm or clarify the results of the analysis of a previous sample.

In 2011 the Inspectorate completed an audit of charging schemes outl ined

within each local authority’s website and published the conclusions in

Drinking water 2011. While the audit found that one-third of local

author it ies were providing comprehensive information, the Ins pectorate

concluded that many local authorit ies should and could have done more to

provide complete and accurate information to the relevant person(s) and

the general publ ic.

In 2015, following the conclusion of the init ia l f ive-year report ing period,

another review of charges publ ished on local author ity websites was

carr ied out. Dur ing the pre-consultat ion exercise for the revision of the

private water supplies regulat ions, local authorit ies identif ied that they

would l ike the above schedule of charges to be revised. A review was

undertaken to attempt to gather evidence for the just if icat ion.


73

Overview of findings

In total, 279 local authorit ies webpages were audited and Table 32 shows

the general results of the audit in terms of the type of information a vailable

on local authority websites.

Table 32: Summary findings of the 2015 audit of local authority

website content on private water supplies and charges

England Wales

Total in

England

and Wales

% England

and Wales

combined

Ful l charges out l ined wi th reference to max charges

95 3 98 35%

Ful l charges out l ined but no reference to max charges

52 6 58 21%

No charging data but contact deta i ls to obta in emai l for cost quote.

46 10 56 20%

Informat ion on pr ivate water suppl ies but no charging data

13 0 13 5%

No informat ion and no charging data

51 3 54 19%

The f indings revealed around 55% of local authority websites contained

information around the charging structure together with their own fees for

conducting their services. A further 20% outl ined informat ion regarding

charges, but required the relevant person(s) to make contact in order for a

cost to be provided.

This is an improvement f rom the last review and therefore shows the

progress that local authorit ies have made with regard to the information

they provided around private water suppl ies. However , as only 35% of

websites also l isted the maximum charges alongside their own charges the

Inspectorate remains concerned that true transparen cy is st i l l not being

achieved.

The Inspectorate was disappointed to f ind that there was only a slight

reduction in the number of websites that did not contain any information

compared to the orig inal audit . Out of the 54 websites, 37 had less than

ten total regulated supplies, which therefore reiterated the point regardi ng

the number of registered pr ivate supplies that wi l l inf luence decisions

around the publ icat ion of information. Although in contrast , three of these

websites had over 100 regulated suppl ies , but st i l l provided no

information.

The audit also noted whether a reference to the Regulat ions was included

within the text. In most cases, the 2009 Regulat ions (2010 Wales) were


74

referenced with only 38 local authorit ies not including any reference to the

Regulat ions within their text. Seven local author it ies were fou nd to be st i l l

referencing the 1991 Regulat ions and the Inspectorate contacted them to

advise them of the update required.

A transit ional grant scheme was agreed in Wales which compensated local

author it ies for the cost of undertaking r isk assessments for the init ial f ive-

year per iod. However, three local author i t ies in Wales st i l l d id not include

any information regarding private water supplies within their websites.

Charging

The Inspectorate noted that, in most cases, local authorit ies either

charged an hourly rate or a f lat rate when it came to undertaking their

act ivit ies such as r isk assessments, sampling and investigations. I t was of

note that the hourly rate varied considerably f rom £18 to £99 per hour.

While individual local authority pol ic ies and ci rcumstances mean that the

way in which they outl ine their charges wi l l dif fer, the fee charged should

be based on the reasonable cost of providing the service. I f the maximum

fee is charged then this should only be in the cases where the total

amount of t ime (actual t ime on site, conducting the service and related

administrat ion t ime) amounts to (or exceeds) this maximum. Local

author it ies are reminded that they should encourage any person(s)

responsible for a private water supply to compile and maintain su itable

records for the supply including any maintenance of treatment systems or

assets in order that the site vis it aspect of the r isk assessment is carr ied

out in the most cost -effect ive manner. A template is provided on our

website at

http:/ /dwi.defra.gov.uk/private-water-supply/Owner/pwsinfopack.htm

Seven local authorit ies were found to be charging the maximum permitted

fee for all act ivit ies, regardless of the type of sup ply and the parameters

required. This pract ice goes against guidance issued by the Inspectorate

to, where possible, ensure a clear dif ferentiat ion between the type of

supply being assessed.

Some local authority webpages make reference to a fee that is l ist ed

elsewhere in the local authority’s ‘Fees and Charges’ document. In some

cases a separate web search was needed to f ind the information.

One of the main areas of interest was how local author it ies were charging

for their monitoring services, especial ly d ue to the fact that in most cases

this is completed by a contract laboratory, who would in turn have a pr icing

structure to undertake any analysis. For analyt ical act ivit ies, most

recovered any costs up to the maximum. The summary of charges is

outl ined in Table 33.

http://dwi.defra.gov.uk/private-water-supply/Owner/pwsinfopack.htm


75

Table 33: Summary of analysis of monitoring charges

England Wales Total in England

and Wales

% England and Wales combined

Check monitoring

Flat rate including analysis costs 56 6 62 29%

Charge dependent on source water 7 1 8 4%

Charge dependent on parameters 7 0 7 3%

Analysis costs up to maximum 67 2 69 33%

Email for prices 47 10 57 27%

Other* 9 0 9 4%

Audit monitoring

Flat rate including analysis costs 45 4 49 23%

Charge dependent on source water 6 0 6 3%

Charge dependent on parameters 17 2 19 9%



Other* 10 1 11 5%

Regulation 10 monitoring

Flat rate (under £25.00) 17 2 19 9%

Flat rate 54 5 59 28%



Other (Fee not shown /unclear/no charge)

15 0 15 7%

For both check and audit monitor ing there were only a small amount of

local author it ies who actual ly had a dif ferent charging structure dependent

on the source water , whi le a similar number base their charges on the

parameters ident if ied through the r isk assessment. However , in most cases

the charges were in the form of a f lat rate or full cost recovery f rom the

test ing laboratory. The Regulat ions al low for some f lexibil i ty in bo th the

check and audit monitoring suites to al low for individual circumstances.

Check monitor ing can vary f rom 10 to 17 parameters depending on the

source water, treatment chemicals used or if provided in bott les. The audit

monitor ing suite can be adapted to exclude any parameter that can be

demonstrated to be unl ikely to be present above the permitted maximum.

Local authorit ies which publ ish a f lat rate for these services should ensure

that the r isk-based approach to monitoring inherent in the Regulat ions is

being appl ied, and the cost savings passed on to the relevant persons. A

f lat rate charge was found to be the most common type of charge with

regards to Regulat ion 10 suppl ies , however, in most cases the charge was

set at the maximum rate.

General ly, the Inspectorate found l it t le evidence that local authorit ies were

overcharging for monitor ing as a del iberate policy , however, some local

author it ies were found to be charging over the maximum permitted fee for

analysing a Regulat ion 10 supply and the Inspectorate wi l l be contact ing

these local authorit ies to establ ish the reasoning behind this approach.


76

In conclusion. there have been improvements since the last review,

although there is more that can be done to improve the transparency of

charging data.

Pr ivate water supp l i es in Eng land

77

Annex 1 – Numbers of supplies, risk assessments and evidence of monitoring and enforcement.

England and Wales Counci l name Note Counci ls marked with a * did not make a val id return or returned too late to have their data incorporated in 2014 so the latest available data has been used. Where ** is indicated against the est imate of the % of the LA population on the supply, LAs have not provided populat ion data so an est imate has been made on the basis of the volumes supplied.

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Al lerdale Borough Counc i l 267 102 123 42 45 0 Y Y Y

Amber Val ley Borough Counc i l 60 44 1 7 8 100 44 Y Y

Arun Dis tr ic t Counc i l 13 6 3 4 100 100 Y Y Y

Ashf ield Dis tr ic t Counci l 2 1 1 N/A 100 N/A N

Ashford Borough Counci l 7 6 1 N/A 100 N/A N

Aylesbury Vale Dis tr ic t Counci l 35 23 6 6 67 100 Y N Y

Babergh Dis tr ic t Counci l 150 108 1 15 26 100 100 Y Y Y

Bark ing and Dagenham Borough Counc i l 0 1

Barnet Borough Counc i l 1 1 100 N/A Y N/A

Barns ley Borough Counc i l 41 32 4 5 100 100 Y Y

Barrow- in-Furness Borough Counc i l 3 2 1 100 N/A Y N/A

Basingstoke and Deane Borough Counc i l 101 42 1 15 43 100 100 Y Y Y


78


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Bath and Nor th East Somerset Dis tr ic t Counci l

84 57 9 18 100 100 Y Y Y

Bedford Borough Counci l 10 7 2 1 100 100 Y Y 1

Birmingham City Counci l 5 3 2 100 100 Y Y

Blaby Dist r ic t Counc i l 8 7 1 N/A 100 N/A Y

Blackburn wi th Darwen Borough Counc i l 89 65 3 21 100 100 Y N

Blackpool Borough Counc i l 2 2 0 N/A N N/A

Blaenau Gwent County Borough Counc i l 30 26 4 100 N/A Y N/A

Bolsover Distr ic t Counci l 1 1 N/A 100 N/A Y

Bol ton Metropol i tan Borough Counci l 31 13 1 17 0 100 N Y Y 1

Bradford Metropol i tan Dis tr ic t Counc i l 336 167 66 103 100 69 Y Y

Bra intree Dis tr ic t Counc i l 188 143 14 31 100 77 Y Y

Breck land Dis tr ic t Counc i l 1,263 497 79 687 32 4 Y Y

Brentwood Borough Counc i l 3 3 N/A N/A N/A N/A

Br idgend County Borough Counc i l 76 69 6 1 100 100 Y Y Y


79


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Broadland Distr ic t Counc i l 601 442 60 99 100 100 Y Y

Bromley (London Borough of) 3 3 100 N/A Y N/A

Bromsgrove Dis tr ic t Counc i l 29 22 1 6 100 33 Y Y

Broxbourne Borough Counc i l 3 3 N/A N/A N/A N/A

Broxtowe Borough Counc i l 3 1 2 N/A

100 N/A N

Burnley Borough Counci l 53 33 13 7 46 100 N/A N

Bury Metropol i tan Borough Counc i l 68 44 5 7 12 57 65 Y Y

Caerphi l ly County Borough Counc i l 71 57 4 10 100 100 Y Y

Calderdale Metropol i tan Borough Counci l

794 551 38 205 92 98 Y Y

Canterbury Ci ty Counc i l 5 4 1 N/A 100 N/A Y Y

Cardif f Counc i l 24 17 2 5 100 100 Y N

Car l is le Ci ty Counc i l 166 120 27 19 85 89 Y Y 7

Carmarthenshire County Counci l 2,186 2,110 6 60 10 88 44 Y N Y 165


80


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Centra l Bedfordshire Counci l 30 19 9 2 89 100 Y Y

Ceredig ion County Counc i l 1,424 1,266 72 86 100 100 Y Y Y

Charnwood Borough Counc i l 18 14 1 3 100 100 Y N

Chelmsford Borough Counc i l 14 11 1 2 N/A 100 Y N 1

Cheltenham Borough Counci l 21 17 1 3 100 100 Y Y

Cherwel l Distr ic t Counci l 149 110 1 11 27 100 100 Y Y

Cheshire East Counc i l 440 368 55 17 93 94 Y Y Y 1

Cheshire West and Chester Counc i l 66 36 12 18 92 94 Y Y 1

Chichester Distr ic t Counc i l 72 30 5 8 29 100 38 Y Y

Chi l tern Distr ic t Counc i l 21 16 2 3 100 100 Y Y

Chor ley Borough Counci l 18 15 1 2 100 0 Y N

Ci ty of London 0 N/A N/A N/A N/A 2

Colchester Borough Counc i l 44 40 2 2 100 100 Y Y

Conwy County Borough Counc i l 522 421 76 25 99 100 Y Y Y

Copeland Borough Counc i l 215 140 49 26 100 0 Y N


81


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Cornwal l Counc i l 3,761 2.546 10 754 451 34 11 Y Y 2

Cotswold Dis tr ic t Counc i l 225 80 125 20 98 95 Y Y Y

Coventry City Counci l 1 1 100 N/A Y N/A

Craven Distr ic t Counci l 738 366 205 167 98 88 Y Y Y

Dacorum Borough Counc i l 39 22 6 8 3 88 89 Y Y

Dar l ington Borough Counc i l 5 5 100 N/A Y N/A

Daventry Dis tr ic t Counci l 101 86 15 N/A 53 N N 13

Denbighshire County Counci l *2014 data – re fused to send 2015 return

662 476 99 87 95 77 NO

DATA NO

DATA

Derbyshire Dales Dis tr ic t Counc i l 226 156 39 31 95 74 Y Y Y

Doncaster Metropol i tan Borough Counc i l 26 11 4 11 91 25 Y N

Dover Distr ic t Counc i l 3 3 N/A N/A N/A N/A

Dudley Metropol i tan Borough Counci l 2 2 N/A N/A N/A N/A

Durham County Counc i l 277 89 86 102 74 42 Y Y Y

East Cambridgeshire Dis tr ic t Counc i l 38 24 1 12 1 100 50 Y N Y


82


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East Devon Dis tr ic t Counc i l 1,122 824 167 131 92 96 Y Y 2

East Dorset Distr ic t Counc i l 46 24 8 14 100 93 Y N

East Hampshire Dis tr ic t Counci l 54 34 2 10 8 90 90 Y Y Y 2

East Hertfordshire Counc i l 132 94 16 22 75 91 Y Y

East L indsey Dis tr ic t Counci l 189 148 15 26 60 8 Y N

East Northamptonshire Distr ic t Counci l 24 17 1 6 100 50 Y Y 2

East Riding of Yorkshire Counc i l 175 124 37 14 97 100 Y Y 85

East Staf fordshire Borough Counc i l 18 11 7 100 N/A Y N/A

East leigh Borough Counc i l 2 2 N/A N/A N/A N/A

Eden Distr ic t Counc i l 593 251 170 172 66 99 Y Y Y

Elmbridge Borough Counc i l 11 11 N/A N/A N/A N/A

Enf ield (London Borough of) 2 2 100 N/A Y N/A

Epping Forest Dis tr ic t Counci l 73 28 4 29 12 24 25 Y Y Y

Epsom and Ewel l Borough Counc i l 1 1 N/A N/A N/A N/A

Erewash Borough Counc i l 1 1 N/A N/A N/A N/A


83


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Exeter City Counc i l 1 1 100 N/A Y N/A

Fareham Borough Counc i l 1 1 100 N/A Y N/A

Fl intshire County Counc i l 85 79 6 100 N/A Y N/A

Forest Heath Distr ic t Counci l 49 21 13 15 100 93 Y Y

Forest of Dean Distr ic t Counc i l 61 46 11 4 100 100 Y Y Y

Fylde Borough Counc i l 2 1 1 100 N/A Y N/A

Gateshead Metropol i tan Borough Counc i l 1 1 N/A N/A N/A N/A

Gedl ing Borough Counci l 20 15 4 1 50 100 Y Y

Gravesham Borough Counc i l 4 3 1

100 N/A Y N/A

Great Yarmouth Borough Counc i l 53 44 5 4 100 100 Y N

Gui ldford Borough Counc i l 8 6 1 1 0 0 N N

Gwynedd County Counci l 810 478 4 275 53 85 23 Y Y Y 12

Hackney (London Borough of) 1 1 N/A 0 N/A N

Hal ton Borough Counc i l 2 1 1 0 N/A Y N/A

Hambleton Distr ic t Counc i l 268 165 32 71 100 20 Y Y Y 1


84


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Hammersmith and Fulham 1 1 100 N/A Y N/A

Harborough Dis tr ic t Counc i l 38 25 5 8 100 100 Y N

Har low Dis tr ic t Counc i l - *data f rom 2015, no return in 2016

1* 1* No

Data No

Data No

Data No

Data No

Data No

Data

Harrogate Borough Counc i l 588 332 124 132 93 70 Y Y Y

Har t Distr ic t Counci l 11 6 3 2 100 0 Y N

Har t lepool Borough Counc i l 1 1 100 N/A Y N/A

Herefordshire Counc i l 2,496 2,100 1 252 143 96 89 Y Y Y

Her tsmere Borough Counc i l 9 3 2 3 1 100 100 Y Y Y

High Peak Borough Counc i l 294 220 2 20 42 87 45 Y Y

Hi l l ingdon (London Borough of) 1 1 100 N/A Y N/A

Hinck ley and Bosworth Borough Counc i l 56 48 2 6 N/A 88 N/A Y 1

Horsham Dis tr ic t Counci l 13 8 3 2 100 100 Y Y Y 2

Hunt ingdonshire Distr ic t Counci l 10 8 2 100 N/A N N/A

Hyndburn Borough Counc i l 36 30 2 4 50 0 N N


85


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Ipswich Borough Counci l 2 1 1 100 N/A Y N/A

Is le of Anglesey County Counc i l 203 168 25 10 100 100 Y Y

Is le of W ight Counc i l 21 14 5 2 80 50 Y Y Y

Is les of Sc i l l y 60 35 23 2 100 100 N N 5

Kens ington and Chelsea (Royal Borough of )

3 3 100 N/A Y N/A

Ket ter ing Borough Counc i l 2 1 1 100 N/A Y N/A

King's Lynn and W est Norfo lk Borough Counci l

74 42 17 15 100 33 Y Y Y

Kirk lees Counc i l 236 165 18 53 100 100 Y N

Knowsley Metropol i tan Borough Counc i l 2 2 100 N/A Y N/A

Lancaster City Counc i l 192 119 43 30 40 73 Y N Y

Leeds City Counc i l 46 17 18 11 100 100 Y N

Lewes Dis tr ic t Counc i l 14 2 8 4 100 100 N N

L ichf ie ld Distr ic t Counci l 11 7 4 100 N/A Y N/A


86


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Maidstone Borough Counc i l 14 8 2 4 100 100 Y Y

Maldon Dis tr ic t Counc i l 22 15 2 5 100 80 Y Y

Malvern Hil ls Dis tr ic t Counci l 229 205 10 14 100 29 Y Y

Manchester City Counci l 3 3 67 N/A Y N/A

Medway Counc i l 1 1 N/A 100 N/A N

Mel ton Borough Counc i l 15 7 8 100 N/A Y N/A Y

Mendip Dis tr ic t Counc i l 143 76 3 26 38 100 90 Y Y Y

Merthyr Tydf i l County Borough Counc i l 19 18 1 100 N/A Y N/A

Mid Devon Dis tr ic t Counc i l 1,301 1,005 132 164 53 15 Y Y Y

Mid Suf fo lk Distr ic t Counc i l 115 81 15 19 93 100 Y N Y

Mid Sussex Dist r ic t Counc i l 4 2 1 1 100 0 Y N

Mil ton Keynes Counc i l 10 8 1 1 100 100 Y N

Mole Val ley Dis tr ic t Counc i l 8 5 3 N/A 100 N/A Y

Monmouthshire County Counc i l 684 524 49 111 98 97 Y Y Y 7


87


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Neath Por t Talbot County Borough Counci l

178 160 9 9 100 100 Y Y 1

New Forest Dis tr ic t Counc i l 27 17 10 N/A 80 N/A N

Newark and Sherwood Distr ic t Counc i l 14 11 2 1 100 50 N N

Newcast le-under-Lyme Borough Counc i l 30 22 8 N/A 100 N/A Y Y

Newpor t City Counc i l 37 25 4 8 100 100 Y N

Nor th Devon Dis tr ic t Counc i l 1,138 841 1 217 79 87 65 Y Y Y

Nor th Dorset Dis tr ic t Counci l 81 33 15 33 100 97 Y Y Y

Nor th East Derbyshire Distr ic t Counc i l 151 110 15 26 87 35 Y N

Nor th East L incolnshire Counc i l 44 34 8 2 100 100 Y Y

Nor th Her tfordshire Distr ic t Counc i l 58 31 7 20 100 100 Y Y

Nor th Kesteven Dist r ic t Counci l 13 6 4 3 100 100 Y N

Nor th Lincolnshire Counc i l 21 11 5 5 100 100 Y Y 8

Nor th Norfo lk Dis tr ic t Counci l 389 235 100 54 37 2 Y Y Y

Nor th Somerset Dis tr ic t Counci l 12 6 2 3 1 100 67 Y Y


88


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Nor th W arwickshire Borough Counc i l 18 8 7 3 100 33 Y Y 2

Nor thumber land County Counc i l 1,059 436 291 332 99 18 Y Y Y

Norwich Ci ty Counc i l 4 1 3 100 N/A Y N/A

Nott ingham City Counci l 2 2 100 N/A Y N/A

Nor th W est Leicestershire Dis tr ic t Counci l

17 10 2 2 3 100 60 Y N 1

Oldham Metropol i tan Borough Counc i l 187 148 9 30 100 90 N N

Pembrokeshire County Counc i l 972 862 78 32 97 100 Y Y

Pendle Borough Counci l 276 199 13 64 100 100 Y Y Y

Peterborough City Counc i l 10 4 3 3 67 100 Y N

Powys County Counc i l 6,064 5,058 496 510 85 83 Y Y Y 31

Preston Ci ty Counc i l 18 8 7 3 100 100 Y Y

Purbeck Dist r ic t Counci l 64 40 18 6 93 83 Y Y

Reading Borough Counc i l 12 9 2 1 100 100 Y N

Redbr idge Counci l 1 1 100 N/A Y N/A


89


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Redcar and Cleveland Borough Counc i l 41 24 1 4 12 75 92 Y Y

Reddi tch Borough Counc i l 4 4 N/A N/A N/A N/A

Reigate and Banstead Borough Counc i l 1 1 N/A N/A N/A N/A

Rhondda Cynon Taf f County Borough Counci l

89 67 7 15 100 100 N N

Ribble Val ley Borough Counc i l 310 191 39 80 95 71 Y Y Y

Richmondshire Dis tr ic t Counc i l 443 285 68 90 100 36 Y Y

Rochdale Metropol i tan Borough Counc i l 113 58 14 41 100 34 Y N

Rossendale Borough Counci l 457 246 11 200 27 0 N N Y

Rother Dist r ic t Counc i l 29 22 1 3 3 100 75 Y Y 1

Rotherham Metropol i tan Borough Counci l

2 2 100 N/A Y N/A 2

Rugby Borough Counc i l 20 19 1 N/A 0 N/A Y

Runnymede Borough Counc i l 5 3 2 N/A 50 N N/A

Rushc l i f fe Borough Counc i l 4 2 1 1 N/A 50 N/A Y


90


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Rushmoor Borough Counc i l 2 2 N/A 50 N/A Y

Rut land County Counc i l 23 15 1 7 100 100 Y N Y

Ryedale Dist r ic t Counci l 270 153 55 62 96 11 Y Y Y 1

Salford Ci ty Counc i l 2 1 1 100 N/A Y N/A

Scarborough Borough Counci l 322 193 69 60 78 93 Y Y

Sedgmoor Dis tr ic t Counc i l 25 7 14 4 100 100 Y N 2

Selby Dist r ic t Counc i l 39 17 8 14 100 100 Y Y 5

Sevenoaks Dis tr ic t Counc i l 16 5 4 4 3 100 29 Y N Y

Shef f ie ld Ci ty Counc i l 164 160 4 100 N/A Y N/A

Shepway Dis tr ic t Counci l 3 2 1 N/A 100 N/A N

Shropshire Counc i l 2,113 1,632 2 153 326 78 6 N N 1

Slough Borough Counci l N/A N/A N/A N/A 2

Sol ihul l Metropol i tan Borough Counci l 18 15 3 100 N/A Y N/A Y

South Buck inghamshire Distr ic t Counci l 6 3 3 100 N/A Y N/A

South Cambr idgeshire Distr ic t Counc i l 138 109 6 23 100 0 Y N


91


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South Derbyshire Dis tr ic t Counc i l 32 18 8 6 88 17 Y Y Y

South Gloucestershire Counc i l 51 29 9 10 3 100 100 Y Y Y 6

South Hams Distr ic t Counc i l 808 533 122 153 20 9 Y Y

South Hol land Distr ic t Counci l 8 7 1 100 N/A N N/A

South Kesteven Dist r ic t Counci l 49 23 17 9 41 78 Y Y

South Lakeland Distr ic t Counci l 1,705 1,093 3 404 205 50 51 Y Y Y

South Norfo lk Counc i l 275 197 20 58 95 79 Y Y 1

South Nor thamptonshire Counc i l 46 27 12 7 100 100 Y N 1

South Oxfordshire Dis t r ic t Counc i l 146 108 1 30 7 100 100 Y Y Y

South Ribble Borough Counci l 6 4 2 100 N/A Y N/A

South Somerset Dis tr ic t Counci l 429 323 29 77 100 100 Y Y Y 6

South Staf fordshire Distr ic t Counc i l 55 43 4 8 100 100 Y N

South Tyneside Metropol i tan Borough Counci l

1 1 N/A N/A N/A N/A

Spel thorne Borough Counc i l 1 1 100 N/A Y N/A


92


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St Albans Distr ic t Counc i l 56 47 2 7 0 0 Y Y 1

St Edmundsbury Borough Counc i l 93 65 14 14 93 86 Y Y

Staf ford Borough Counc i l 173 142 10 21 90 81 Y Y

Staf fordshire Moorlands Distr ic t Counci l 466 379 54 33 50 39 Y Y

Stockport Metropol i tan Borough Counc i l 39 29 3 7 100 86 Y Y Y

Stockton on Tees Borough Counc i l 3 3 N/A N/A N/A N/A

Stoke-on-Trent Ci ty Counc i l 3 1 2 N/A 0 N/A N

Stratford-on-Avon Dis t r ic t Counc i l 223 134 26 50 13 26 3 N N

Stroud Dis tr ic t Counc i l 168 115 1 31 21 94 100 Y Y 3

Suf folk Coasta l Dis tr ic t Counci l 389 287 2 24 76 96 82 Y Y

Sunder land Ci ty Counci l 1 1 100 N/A Y N/A

Sut ton (London Borough of) 1 1 100 N/A Y N/A

Swale Borough Counci l 15 4 10 1 90 100 Y Y

Swansea Ci ty and Borough Counc i l 101 82 7 12 100 92 Y Y Y

Swindon Borough Counc i l 9 4 3 2 100 100 Y N


93


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Tameside Metropol i tan Borough Counc i l 34 24 3 7 100 100 Y Y Y

Tandr idge Dis tr ic t Counc i l 2 1 1 100 N/A Y N/A

Taunton Deane Borough Counc i l 251 156 31 64 100 91 Y Y Y

Teignbr idge Distr ic t Counc i l 576 384 96 96 38 3 Y Y Y

Telford and Wrek in Counc i l 87 63 10 14 100 100 Y Y Y 1

Tendr ing Dis tr ic t Counci l 126 101 1 8 16 38 12 N N

Test Val ley Borough Counc i l 233 134 43 56 100 100 Y Y Y

Tewkesbury Borough Counci l 107 62 7 12 26 100 82 Y Y 1

Three Rivers Distr ic t Counci l 21 15 3 3 100 100 Y N

Tonbr idge and Mall ing Borough Counc i l 27 20 1 3 3 100 75 Y Y Y 16

Torbay Counc i l 4 1 3 100 N/A Y N/A

Torfaen County Borough Counc i l 65 53 7 5 100 100 Y Y Y

Torr idge Distr ic t Counci l 512 436 53 23 58 4 Y Y 1

Tower Hamlets (London Borough of) 3 3 100 N/A Y N/A

Tunbr idge Wells Borough Counc i l 6 3 3 100 N/A Y N/A


94


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U t t lesford Distr ic t Counc i l 52 28 7 5 12 100 84 Y Y Y

Vale of Glamorgan Counc i l 28 16 6 6 100 100 Y N

Vale of W hite Horse Distr ic t Counc i l 58 32 23 3 100 100 Y Y Y 2

Wakef ield Metropol i tan Distr ic t Counci l 2 1 1 100 N/A Y N/A

Waltham Forest (London Borough of) 1 1 0 N/A N N/A

Wandswor th (London Borough of) 1 1 100 N/A Y N/A

Warr ington Borough Counc i l 2 2 100 N/A Y N/A

Warwick Dist r ic t Counci l 33 25 3 5 100 100 N Y

Watford Borough Counci l 2 1 1 100 N/A N N/A

Waveney Distr ic t Counci l 33 23 4 6 75 33 Y N Y

Waver ley Borough Counc i l 22 12 4 6 100 33 Y Y 4

Wealden Dis tr ic t Counci l 46 29 3 8 6 100 56 Y Y 1

Well ingborough Borough Counc i l 3 3 N/A N/A N/A N/A

Welwyn Hatf ie ld Dis tr ic t Counci l 13 10 3 100 N/A Y N/A

West Berkshire Distr ic t Counci l 184 106 31 47 84 55 Y Y Y 4


95


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West Devon Borough Counci l 982 774 91 109 69 38 Y Y

West Dorset Dist r ic t Counc i l 513 282 91 140 97 51 Y Y Y

West Lancashire Distr ic t Counci l 2 2 N/A N/A N/A N/A

West Lindsey Dis tr ic t Counci l 13 9 3 1 100 100 N N

West Oxfordshire Dist r ic t Counc i l 97 25 62 10 98 100 Y Y Y 3

West Somerset Distr ic t Counci l 711 479 1 120 111 99 96 Y Y Y 1

Westminster City Counc i l 3 2 1 100 N/A Y N/A

Weymouth and Port land Borough Counc i l 1 1 N/A 100 N/A Y

W igan Metropol i tan Borough Counc i l 12 10 1 1 100 100 Y N Y

W iltshire Counci l 582 280 9 213 80 99 100 Y Y Y

W inchester Ci ty Counc i l 163 93 20 50 100 100 Y Y

W indsor and Maidenhead 81 68 1 10 2 100 100 Y Y

W irral Metropol i tan Borough Counc i l 3 3 100 N/A Y N/A

Wokingham Borough Counc i l 112 92 10 10 100 70 Y Y

Wolverhampton City Counc i l 1 1 100 N/A Y N/A


96


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W rexham County Borough Counc i l 189 163 1 9 16 100 100 Y Y

W ychavon Distr ic t Counc i l 105 80 10 15 100 53 Y Y

W ycombe Distr ic t Counc i l 62 48 2 7 5 100 100 Y Y 1

W yre Borough Counc i l 28 12 8 8 100 100 Y Y

W yre Forest Dis tr ic t Counc i l 25 15 2 8 100 50 Y N

York City Counc i l 17 11 2 4 100 100 N N


97

Councils reporting no private water supplies

Basi ldon Dis tr ic t Counci l Har ingey (London Borough of) Oxford City Counci l

Bexley Borough Counc i l Harrow (London Borough of) Plymouth City Counc i l

Boston Borough Counci l Hast ings Borough Counc i l Poole Borough Counc i l

Bournemouth Borough Counc i l Havant Borough Counci l Portsmouth Ci ty Counci l

Bracknel l Forest Borough Counc i l Haver ing (London Borough of) Redbr idge (London Borough of)

Brent (London Borough of) Hounslow (London Borough of) Richmond upon Thames (London Borough of)

Br isto l City Counc i l Hul l City Counc i l Rochford Distr ic t Counci l

Cambr idge Ci ty Counc i l Is l ington (London Borough of) Sandwel l Metropol i tan Borough Counc i l

Camden (London Borough of) Kingston upon Thames (Royal Borough of) Sef ton Metropol i tan Borough Counci l

Cannock Chase Dis tr ic t Counci l Lambeth (London Borough of) Southampton Ci ty Counc i l

Cast le Point Borough Counci l Leicester Ci ty Counci l Southend-on-Sea Borough Counc i l

Chesterf ie ld Borough Counci l Lewisham (London Borough of) Southwark (London Borough of)

Chr is tchurch Borough Counci l L incoln Counc i l St Helens Metropol i tan Borough Counc i l

Corby Borough Counc i l L iverpool Ci ty Counci l Stevenage Borough Counc i l

Crawley Borough Counc i l Luton Borough Counc i l Surrey Heath Borough Counc i l

Croydon (London Borough of) Mansf ie ld Distr ic t Counc i l Tamworth Borough Counc i l

Dar tford Borough Counc i l Merton (London Borough of) Thanet Dis tr ic t Counc i l

Derby City Counc i l Middlesbrough Borough Counc i l Thurrock Counci l

Eal ing (London Borough of) Newcast le-upon-Tyne Ci ty Counc i l Traf ford Metropol i tan Borough Counc i l

Eastbourne Borough Counc i l Newham (London Borough of) Walsal l Metropol i tan Borough Counci l

Fenland Dis tr ic t Counci l Nor thampton Borough Counci l Woking Borough Counci l

Gloucester Ci ty Counc i l Nor th Tyneside Metropoli tan Borough Counc i l Worcester City Counc i l

Gospor t Borough Counc i l Nuneaton and Bedworth Borough Counc i l Worthing Borough Counc i l

Greenwich (Royal Borough of) Oadby and W igston Borough Counci l


98

Annex 2: Summary of test results for 2015 (England and Wales)

Parameter S t a n d ar d Nu m ber o f s am pl e s

Nu m ber o f

f a i l u r e s

P er c e nt a g e o f f a i l u r es

i n 2 01 5

P er c e nt a g e o f f a i l u r es

i n 2 01 4

Escher ich ia co l i 0/100 ml 13,774 1,230 8.9 12.8

Enterococc i 0 /100 ml 8 ,126 829 10.2 13.4

Colony counts af te r 48 hours at 37°C

No abnormal change 10,116

- - -

Colony counts af te r 3 days at 22°C

No abnormal change 9,850

- - -

Col i form bacte r ia ( Ind ica tor) 0 /100 ml 13,257 2,354 17.8 22.2 Clostr id ium per f r ingens 0/100 ml 6 ,108 444 7.3 8.7 Pseudomonas aeruginosa 0/250ml 76 2 2.6 3.1

1 2-Dich loroe thane 3.0µg/ l 439 0 0 0 Alumin ium 200µg/ l 5 ,328 91 1.7 2.6

Ammonium 0.5mg/ l 7 ,280 198 2.7 2.2 Ant imony 5.0µg/ l 1 ,033 5 0.5 0

Arsenic 10µg/ l 2 ,035 65 3.2 3.2 Benzene 1.0µg/ l 521 1 0.2 0

Benzo(a)pyrene 0.01µg/ l 333 0 0 0.3 Boron 1.0µg/ l 757 4 0.5 0.4

Bromate 10µg/ l 577 3 0.5 0.9 Cadmium 5.0µg/ l 1 ,235 1 0.1 0.2

Chlor ide 250mg/ l 783 10 1.3 1.4 Chromium 50µg/ l 1 ,078 0 0 0.1

Colour 20mg/ l Pt /Co 7,004 114 1.6 1.6

Conduct i v i t y 2500 µS/cm at 20°C 9,058 10 0.1

0.1

Copper 2.0mg/ l 2 ,597 44 1.7 1.6

Cyanide 50µg/ l 463 0 0 0.2 F luor ide 1.5mg/ l 1 ,281 89 6.9 2.9

Hydrogen ion (pH) ( Ind icator) 6 .5 – 9 .5 9,948 1,131 11.4 13.8 I ron 200µg/ l 7 ,452 532 7.1 7.5

Lead 10µg/ l 3 ,483 137 3.9 10.9 Manganese 50µg/ l 7 ,198 581 8.1 8.7

Mercury 1.0µg/ l 471 0 0 0 Nickel 20µg/ l 1 ,614 45 2.8 2.2

Ni t ra te 50µg/ l 6 ,267 603 9.6 10.1 Ni t r i te – consumers ’ taps 0 .5µg/ l 4 ,909 51 1.0 0.5

Ni t r i te – t reatment works 0.1µg/ l 809 27 3.3 2.3

Odour No abnormal change 5,716 338 5.9

5.9

Polycyc l ic Aromat ic Hydrocarbons

0.1µg/ l 211 5 2.4

1.3

Selenium 10µg/ l 844 11 1.3 0.2

Sodium 200mg/ l 1 ,199 53 4.4 3.2 Sulphate 250mg/ l 792 22 2.8 3.2

Taste No abnormal change 4,890 219 4.5

4.2

Tet rachloromethane 3.0µg/ l 471 12 2.5 0

Tota l ind icat i ve dose 0.1mS/year 25 0 .0 0

Tota l organic carbon No abnormal change 276

0

Tr ich lo roethene and Tet rachloroethene

10µg/ l 380 2 0.5

3.1

Tr iha lomethanes 100µg/ l 415 3 0.7 0.6

Tr i t ium 100 Bq/ l 98 0 .0 0

Turb id i ty a t tap 4NTU 945 53 5.6 2.6

Turb id i ty a t works 1NTU 9,020 192 2.1 9.1


99

Annex 2: continued

Parameter S t a n d ar d Nu m ber o f

s am pl e s Nu m ber o f

f a i l u r e s

P er c e nt a g e o f f a i l u r e s i n 2 01 5

P er c e nt a g e o f f a i l u r e s i n 2 01 4

Pest ic ides

A ldr in 0.03µg/ l 305 1 0.3 0.3

Die ldr in 0 .03µg/ l 315 0 .0 0

Heptachlor 0 .03µg/ l 306 0 .0 0

Heptachlor Epoxide 0.03µg/ l 301 0 .0 0.3

Other pest ic ides* 0.1µg/ l 12,660 20 0.2 0.5

Tota l pest ic ides 0.5µg/ l 314 3 1.0 0.6

To ta l 184,743 9,535 5.2 6.4

The data set repor ted th is year had a smal l number (588) of samples removed

where they were taken at an inappropr iate locat ion, for example, the source and

there was evidence that a sample had been taken on the same day f rom the

correct locat ion ( for example, k i tchen tap) , or the supply was not being used or

had not been commissioned.


100

Annex 2.1: Pesticide detections – England and Wales 2015

Pesticide

Number of samples

Number of fa i lures

Percentage of fa i lures

1,1,1- t r ich lo ro-2,2-ethane pp ' -DDT ’ 132 1 0.8

1,1-d ich loro-2,2-b is -ethane pp ' -DDE ’ 66 0

2 4-D 233 0

2 4-DB 163 0

2 ,3,6-Tba 75 0

2 ,4,5-T 189 0

Alachlor 2 0

Alpha-HCH 92 0

Ametryn 23 0

Asulam 49 0

Atrazine 289 2 0.7

Azinphos methyl 86 0

Azoxystrob in 27 0

Benazol in 58 0

Bendiocarb 4 0

Bentazone 227 2 0.9

Beta-HCH 54 0

Boscal id 22 0

Bromaci l 54 0

Bromoxyni l 188 0

Carbaryl 32 0

Carbendazim 120 0

Carbetamide 151 0

Carbofuran 1 0

Carbophenoth ion 52 0

Chlorbufam 31 0

Chlordane 13 0

Chlordane-Alpha 26 0

Chlor fenvinphos 27 0

Chlor idazon 60 0

Chlormequat 12 0

Chlorothalon i l 133 0

Chlorpropham 36 0

Chlorpyr i fos 91 0

Chlorpyr iphos Methyl 38 0

Chlor tha l 2 0

Chlor to luron 254 0

Clomazone 17 0

Clopyra l id 166 0

Cyanazine 105 0

Cyf lu thr in 54 0

Cypermethr in 53 0

Cyproconazole 104 0

Cyprodin i l 1 0

Cyromazine 1 0

Del ta-HCH 71 0

Del tamethr in 47 0


101

Pesticide

Number of samples



Demeton 4 0

Demeton-S-Methyl 11 0

Desethylat razine 71 3 4.2

Desmetryn 3 0

Diazinon 127 0

Dicamba 238 0

Dich lobeni l 173 0

Dich lorodiphenyld ich lore thanePp' -DDD TDE 40 0

Dich lorodiphenyld ich loroethyle op ' -DDE 60 0

Dich lorprop 210 0

Dich lorvos 315 0

Di fenconazole 14 0

Di f lu fen ican 36 0

Dimethoate 79 0

Disu l fo ton 16 0

Diuron 255 7 2.7

Endosul fan A 99 0

Endosul fan B 93 0

Endosul fan Tota l 42 0

Endr in 140 0

Epoxyconazole 109 0

Eps i lon-HCH 3 0

EPTC 58 0

Eth ion 7 0

Ethofumersate 18 0

Fenchlorphos 3 0

Feni t ro th ion 39 0

Fenoprop 76 0

Fenpropid in 17 0

Fenpropimorph 48 0

Fenth ion 8 0

Fenuron 1 0

Fenvalerate 45 0

F lu fenacet 18 0

F luroxypyr 199 0

F lur tamone 17 0

F lus i lazo le 106 0

F lu t r ia fo l 125 1 0.8

Fonofos 17 0

Gamma-HCH 235 0

Glyphosate 301 0

Heptenophos 65 0

Hexachlo robenzene 120 0

Hexachlo robutadiene 64 0

Hexachlo rocyc lohexane 3 0

Imazapyr 92 0

Ioxyni l 139 0

Iprodione 4 0

Isodr in 75 0


102

Isoproturon 257 0

Pesticide

Number of samples



Kresoxim-methyl 32 0

Lenac i l 2 0

L inuron 266 0

Malath ion 87 0

MCPA 253 0

MCPB 215 0

MCPP 215 0

Mecoprop -P 46 0

Mesosul furon -methyl 2 0

Meta laxy l 38 0

Meta ldehyde 121 0

Metami t ron 47 0

Metazachlor 134 2 1.5

Methabenzth iazuron 92 0

Meth iocarb 16 0

Methoxychlor 63 0

Metoxuron 20 0

Metr ibuzin 30 0

Mevinphos 23 0

Monol inuron 28 0

Monuron 92 0

Napropamide 29 0

op ' -DDD (TDE) 50 0

Oxadixyl 109 1 0.9

Parath ion 26 0

Parath ion-methyl 7 0

PCB - Tota l 7 0

PCB Congener 101 46 0







PCT 3 0

Pendimethal in 135 0

Pentachlorobenzene 18 0

Pentachlorophenol 76 0

Permethr in 7 0

Permethr in -c is 64 0

Permethr in - t rans 57 0

Phorate 43 0

Phosalone 16 0

Pic loram 38 0

Pi r imicarb 30 0

Pi r imiphos Ethyl 5 0

Pi r imiphos Methyl 20 0

Prochloraz 3 0


103

Pesticide

Number of samples



Prometryne 139 0

Propachlor 39 0

Propamocarb 1 0

Propazine 152 0

Propetamphos 24 0

Propham 30 0

Propiconazole 41 0

Propyzamide 209 0

Prosul focarb 10 0

Proth ioconazole 1 0

Quinmerac 70 0

Quintozene 10 0

Simazine 287 1 0.3

Tebuconazole 94 0

Tebuth iuron 1 0

Tecnazene 97 0

Terbuthylazine 66 0

Terbutryn 184 0

Tr iad imefon 24 0

Tr i -a l la te 171 0

Tr iazophos 18 0

Tr ich lo ro-2(2chlo rophenyl )2eth op ' -DDT 69 0

Tr ich lo robenzene 32 0

Tr ic lopyr 231 0

Tr ie tazine 151 0

Tr i f loxyst rob in 1 0

Tr i f lura l in 105 0

Tr i for ine 6 0

Vinc lozol in 3 0

Tota l 13,179 20 0.2


104

Annex 3: Guidance and technical advice

The fol lowing advice and guidance was published in 2015 for the

attention of local authorit ies

June 2015 Manual on treatment for small water supply systems

October 2015 Information Letter 04/2016

New Drinking Water Quality Legislation (2016)

October 2015 Q and A document on radon


105

Annex 4: Enquiries about private water supplies handled by the Drinking Water Inspectorate

Numbers of enquir ies received 2008–2015 for England

2008 2009 2010 2011 2012 2013 2014 2015

Enquir ies f rom local author i t ies

10 42 133 306 290 97 348 269

Enquir ies f rom owners of pr ivate suppl ies

6 9 22 35 23 9 41 50

Enquir ies about pr ivate water suppl ies – general

11 25 40 50 58 19 75 65

Total 27 76 195 391 371 125 464 384

Number of enquiries received from 2008–2015 indicating the origin of

the enquiry – England


106

Annex 5: Glossary and description of standards

Aluminium occurs natural ly in some source waters. I t is removed from

drinking water by convent ional water treatment (coagulat ion and f i l t rat ion).

The standard is 200µg Al/ l.

Ammonium salts are naturally present in trace amounts in most waters.

Their presence might indicate contaminat ion of sanitary signif icance and

they interfere with the operat ion of the disinfect ion process. The guide

value is 0.5mg NH4 / l .

Antimony is rarely found in dr inking water. Trace amounts can be derived

f rom brass tap f it t ings and solders. The standard is 5 µg Sb/ l.

Arsenic occurs natural ly in only a few sources of groundwater. Specif ic

water treatment is required to remove it . The standard is 10 µg As/l.

Benzene is present in petrol. I t is not found in drinking water , but it can

migrate through underground plast ic water pipes if pe trol is spi lt in the

vic inity. Some bott led waters and sof t drinks which include sodium

benzoate as an ingredient have been reported as containing benzene.

The standard is 1µg/l.

Benzo(a)pyrene is one of several compounds known as polycycl ic

aromatic hydrocarbons (PAHs). Their source in dr inking water is as a

result of the deteriorat ion of coal tar which was used to l ine water pipes up

unti l the early 1970s. The standard is 0.01µg/l.

Boron in surface water sources comes from industr ial discharges or f rom

detergents in treated sewage ef f luents. I t can be present in part ially

desal inated seawater when this is used to supplement drinking water

suppl ies. Concentrat ions found in dr inking waters are general ly very low.

The standard is 1mg B/l.

Bromate can be formed during dis infect ion of drinking water as a result

of a reaction between naturally occurr ing bromide and strong oxidants

(usually ozone). I t may be generated in the manufacture of sodium

hypochlorite dis infectant. I t can also arise f rom using an inappropriate

grade of sodium hypochlorite for water treatment. Exceptional ly,

groundwater beneath an industr ial site can become contaminated with

bromate. The standard is 10µg BrO3 / l .

Cadmium is rarely detected in dr inking water and trace amounts are

usual ly due to the dissolut ion of impurit ies f rom plumb ing f it t ings. The

standard is 5µg Cd/ l.

Chloride is a component of common salt . I t may occur in water natural ly ,

but it may also be present due to local use of de -icing salt or sal ine

intrusion. The guide value is 250mg Cl/ l.


107

Clostridium perfringens is a spore-forming bacter ium that is present

in the gut of warm-blooded animals. The spores can survive dis infect ion.

The presence of spores in dr inking water in the absence of E.col i and

Enterococci indicates histor ic or remote faecal contamination that requires

investigation. The standard is 0 per 100ml.

Chromium in dr inking water comes from the coat ings on some taps and

plumbing f it t ings. The standard is 50µg Cr/ l.

Coliform bacteria are widely distr ibuted in the environment of ten as a

result of human or animal act ivity, but some grow on plant matter. Their

presence in a water supply indicates a need to invest igate the integrity of

the water supply system. The standard is 0 per 100ml.

Colony counts are general techniques for detect ing a wide range of

bacteria, the types and numbers being dependent on the condit ions of

the test. These counts, if done regularly, can help to inform water

management, but they have no direct health signif icance. The standard

is ‘no abnormal change ’.

Colour occurs natural ly in upland water sources and is caused by natural

organics which are character ist ic of these catchments . Colour can be the

cause of elevated disinfect ion byproducts where chlorine is used for

dis infect ion. The standard is 20mg/l on the Pt/Co scale.

Conductivity is a non-specif ic measure of the amount of natural dissolved

inorganic substances in source waters. The guide value is 2 ,500µS/cm.

Copper in drinking water comes mostly f rom copper pipes and f it t ings in

households. In general, water sources are not aggressive towards copper ,

but problems very occasional ly occur in new installat ions. These ‘blue

water ’ events can be avoided by good plumbing pract ices. The standard

is 2mg Cu/l.

Cyanide is not normally present in drinking water, but could be present

in surface water as a result of a specif ic i ndustr ial contaminat ion incident.

The standard is 50µg CN/l.

1,2-Dicholoroethane is a solvent that may be found in groundwater in the

vic inity of industr ial sites. Where necessar y it can be removed by special

water treatment. The standard is 3µg/l.

Escherichia coli (E.coli) and Enterococci are bacter ia present in the gut

of warm-blooded animals. They should not be present in dr inking water

and, if found, immediate act ion is requir ed to identify and remove any

source of faecal contaminat ion that is found. The standard is 0 per 100ml.


108

Fluoride occurs natural ly in many water sources , especial ly groundwater.

I t cannot be removed by convent ional water treatment , so high levels must

be reduced by blending with another low f luor ide water source. The

standard is 1.5mg F/l.

Hydrogen ion (pH) gives an indicat ion of the degree of acidity of the

water. A pH of 7 is neutral; values below 7 are acidic and values above 7

are alkaline. A low pH water may result in pipe corrosion. This is corrected

by adding an alkal i during water treatment. The guide value is a range

between 6.5 and 9.5.

Iron is present natural ly in many water sources. However, the most

common source of iron in drinking water is co rrosion of iron water mains.

The standard is 200µg Fe/l.

Lead very occasionally occurs natural ly in raw waters , but the usual

reason for its presence in dr inking water is lead plumbing in older

propert ies. The permanent remedy is for householders to remove lead

pipes and f it t ings. The standard is 10µg Pb/l.

Mercury is not normally found in sources of drinking water in the UK. The

standard is 1µg Hg/l.

Nickel occurs naturally in some groundwater and , where necessary,

special treatment can be installed to rem ove it . Another source of nickel in

drinking water is the coatings on modern taps and other plumbing f it t ings.

The standard is 20µg Ni/ l.

Nitrate occurs natural ly in all source waters although higher

concentrat ions tend to occur where fert i l isers are used on the land. Nitrate

can be removed by ion exchange water treatment or through blending with

other low nitrate sources. The standard is 50mg NO3 / l .

Nitrite may occur where ammonia is present in the source and chlorine is

used for dis infect ion. Careful operat ion of the dis infect ion process ensures

that levels of nitr ite are below the standards of 0.1 mg NO2 / l in water

leaving water treatment works and 0.5mg NO2 / l at consumers’ taps.

Odour and taste can arise as a consequence of natural substances in

surface waters, part icularly between late spring through to ear ly autumn.

The standard is described as acceptable to consumers and no abnormal

change in odour or taste.

Pesticides – organochlorine compounds (aldrin, dieldrin, heptachlor,

heptachlor epoxide) are no longer used in the UK because they are

persistent in the environment. They are very unl ikely to be found in

drinking water. The standard for each compound is 0.03 µg/l.


109

Pesticides – other than organochlorine compounds are a diverse and

large group of organic compounds used as weed ki l lers, insecticides and

fungicides. Many water sources contain traces of one or more pestic ide s

as a result of both agricultural uses mainly on crops and non-agricultural

uses, mainly for weed control on highways and in gardens. The standard

is 0.1µg/l for each individual substance and 0.5µg/l for the total of all

pestic ides.

Polycyclic aromatic hydrocarbons is a group name for several

substances present in petroleum-based products such as coal tar. The

standard is 0.1µg/l for the sum of all the substances (see Benzo(a)pyrene

l isted above for more information).

Selenium is an essential element and a necessary dietary component.

Amounts in dr inking water are usually well below the standard of 10 µg

Se/l.

Sodium is a component of common salt (sodium chloride). I t is present

in seawater and brackish groundwater. Some water treatment chemicals

contain sodium. Concentrat ions in dr inking water are extremely low , but

some water sof teners can add signif icant amounts where they are instal l ed

in homes or factories. The standard is 200mg Na/l.

Sulphate occurs natural ly in all waters and cannot be removed by

treatment. The guide value is 250mg SO4 / l .

Tetrachloroethane and trichloroethene are solvents that may occur in

groundwater in the vic ini ty of industr ial si tes. Where necessary they are

removed by special ist treatment. The standard is 10 µg/l for the sum of

both substances.

Trihalomethanes are formed during dis infect ion of water by a reaction

between chlor ine and naturally occurr ing organic substances. Their

product ion is minimised by good operat ional pract ice. The standard is

100µg/l.

Vinyl chloride may be present in plast ic pipes as a residual of the

manufacturing process of polyvinyl chlor ide (PVC) water pipes. I ts

presence in drinking water is control led by product specif icat ion.

The standard is 0.5µg/l.

Tetrachloromethane is a solvent that may occur in groundwater in the

vic inity of industr ial sites. Where necessary it is removed by specialist

water treatment. The standard is 3µg/l.

Total indicative dose is a measure of the effect ive dose of radiat ion the

body wi l l receive f rom consumption of the water. I t is calculated only when

screening values for gross alpha or gross beta (radiat ion) are exceeded.

The guide value is 0.10mSv/year.


110

Total organic carbon represents the total amount of organic matter

present in water. The guide value is ‘no abnormal change ’.

Tritium is a radioactive isotope of hydrogen. Discharges to the

environment are str ict ly control led and there is a nat ional programm e

of monitoring surface waters. The guide value for drinking water sources

is 100Bq/l.

Turbidity measurement is an important non-specif ic water qual ity control

parameter at water treatment works because it can be monitored

continuously on l ine and alarms set to alert operators to deteriorat ion in

raw water qual ity or the need to optimise water treatment. The standard

at treatment works is 1NTU. Turbidity can also ar ise at consumers’ taps

following disturbance of sediment within water mains ; the standard at

consumers ’ taps is 4NTU.

Drinking water2013Private water supplies in EnglandJuly 2014A report by the Chief Inspector of Drinking Water

Drinking Water Inspectorate | Nobel House, 17 Smith Square | London | SW1P 3JR | Tel: 0300 068 6400

www.dwi.gov.uk

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Drinking water 2015