Page 4: Guidance For Providing Safe Drinking Water in Areas of Federal Jurisdiction – Version 2

Introduction

In Canada, the responsibility for providing clean, safe and reliable drinking water to the public generally lies with the provincial and territorial governments. Health Canada plays a key role by leading the development of the Guidelines for Canadian Drinking Water Quality (GCDWQ) and by providing scientific and technical expertise to the provinces and territories through the Federal-Provincial-Territorial Committee on Drinking Water (CDW).

The federal government also has or shares responsibility for ensuring the safety of drinking water supplies on federal lands, in federal facilities, and in First Nations communities. While most supplies and facilities are located on Canadian soil, others such as military vessels and Canadian diplomatic missions may lie outside of Canada's physical borders. Specific requirements are established in federal acts and regulations. Some departments have responsibilities for drinking water right from the source through to the tap, whereas others are only responsible for the quality of drinking water after it enters a federal building or facility and until it reaches the consumer.

Departments demonstrate the safety and reliability of their supplies through their monitoring programs, developed through and complemented by periodic sanitary surveys, vulnerabilities assessments and baseline chemical analyses. Departments and other authorities responsible for treating their own water will have to develop more comprehensive quality management programs than those that receive treated water from a well-regulated outside agency (e.g., municipality). In locations where the quality of tap water is unreliable or consistently unsafe for consumption, a department or responsible authority may choose to provide additional localised treatment through the use of point-of-entry or point-of-use devices, or by providing an alternative to consumers, such as bottled water.

This document recognizes that federal government drinking water purveyors face a number of challenges in carrying out their duties, including:

  • The size and location of drinking water systems: Most federal drinking water systems are very small, serving 500 or fewer people. In addition, many of these systems are located in remote areas, in countries where water supplies may be unreliableFootnote 2, or on-board airplanes and ships, including Coast Guard and military vessels. In some of these locations, drinking water may need to be hauled by truck. In other cases, the only practical water supply may be bottled water.
  • Jurisdiction(s) responsible for water: In most situations, the water source falls under the jurisdiction of a provincial government and/or the drinking water treatment plant is operated by a public or municipal utility. In some cases, the lines of responsibility may not be clear.
  • Cost of infrastructure: Because the number of people served by the federal government in each location is often very small, the per capita cost of installing, operating and maintaining the necessary infrastructure is extremely high. This cost increases further with remote locations.
  • Cost of water quality monitoring: The costs associated with water quality monitoring are based on the number of samples and the type and frequency of tests conducted, and not generally directly on the number of people served by a water system. Because of the number of federal systems and the relatively small number of people served by each one, the relative costs for water quality monitoring are high.
  • Funding: In order to ensure that federal drinking water systems are properly designed, constructed, operated and maintained, departments need to have adequate funds and program management controls in place. On-going funding is also required to cover employee training and infrastructure maintenance and upgrades. For the majority of departments for whom the provision of drinking water is not part of their mandate, funding may be considered as part of their department's overhead and more difficult to obtain.

Purpose

The purpose of this document is to give clear, consistent guidance on how to implement the GCDWQ. Guidance is directed to federal civil servants and other responsible authorities whose jobs relate, either directly or indirectly, to ensuring the safety of drinking water on federal lands, in federal facilities and/or in First Nations communities. It is written for employees who make decisions at the policy and management levels, as well as for those who run drinking water systems on a day-to-day basis, such as treatment plant operators or drinking water monitors.

Detailed information is provided to assist federal departments and responsible authorities meet the GCDWQ and drinking water-related regulations. Meeting these requirements will ensure a more consistent approach to managing drinking water systems across areas of federal jurisdiction. For issues or concerns specific to a given contaminant, the appropriate guideline technical documents should be consulted.

All affected departments and authorities are encouraged to strive to meet the guidance set out in this document in order to protect the health of the people who consume the water provided. In some cases, it may be preferable for a department to meet more stringent objectives than those detailed in this document. This decision is under the authority of each department or responsible authority.

It is recognized that departments operating unique facilities, such as those in remote locations or in locations beyond Canadian borders, may face challenges that prevent them from meeting all the guidance contained in this document. In such cases, these departments are encouraged to strive to meet the guidance to the best of their ability and to focus on a continuous improvement process.

Scope

This document relates to the management of drinking water supplies on federal lands and in federal government facilities. These supplies include those serving:

  • Federal government employees working in Canada, as well as Canadian Coast Guard, Canadian Forces personnel, and federal government Canadian diplomatic mission staff working abroad;
  • Inmates, staff, and visitors to federal correctional facilities;
  • Visitors to federal lands and facilities; and
  • Residents of First Nations communities.

The guidance in this document applies to facilities owned by or leased to the federal government. It outlines considerations regarding the design, operation and maintenance of treatment and distribution systems, and describes the requirements for conducting assessments and for setting up, running, and evaluating monitoring programs. Departments may have, or wish to develop, more detailed protocols for their staff which address their department's unique circumstances or requirements. This federal guidance document is meant to provide a framework to complement such efforts.

Given that the majority of federal water systems supply drinking water to 500 or fewer people, the guidance contained in this document relates primarily to very small drinking water systems and micro-systems. While this document recognizes the importance of managing drinking water from source to tap, source water issues are touched on only briefly. Wastewater issues are considered to be beyond the scope of this document. The focus is on drinking water quality from intake to tap.

Organization

Part 1: The Federal Framework

Chapter 1: Setting the stage provides details about the multi-barrier approach to safe drinking water and key jurisdictional issues related to drinking water in Canada. The multi-barrier approach is the overarching concept which ties together each of the individual commitments and tasks outlined in the subsequent chapters.

Chapter 2: Federal legislation and policies outlines the federal government's legislated and policy-based responsibilities as a purveyor of drinking water on federal lands and in First Nations communities, as well as in facilities owned or leased by the federal government.

Part 2: Application of the Federal Framework

Chapter 3: Developing a monitoring program outlines the steps involved in developing a monitoring program for microbiological and chemical contaminants, including choosing source water and conducting vulnerabilities assessments, sanitary surveys and baseline chemical analyses.

Chapter 4: Microbiological considerations and monitoring provides detailed guidance on microbiological indicators (E. coli and total coliforms) and related operational parameters (turbidity, chlorine residuals). It includes monitoring frequency, sampling locations and the interpretation of results.

Chapter 5: Treatment and distribution systems outlines various issues related to the treatment and distribution of drinking water, including system design and assessment, distribution of drinking water within buildings (i.e., plumbing systems), corrosion control, chlorine residual, drinking water materials and special circumstances (i.e., trucked water, alternative sources of drinking water).

Chapter 6: Operational requirements provides guidance on a range of issues, including operational planning, operator certification, monitoring requirements, record-keeping, incident and emergency response planning, and compliance verification and reporting.

Chapter 7: Information and resources provides readers with further resources.

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