Page 6: Guidance For Providing Safe Drinking Water in Areas of Federal Jurisdiction – Version 2

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Part 2 - Application of the Federal Framework

The multi-barrier approach incorporates the principle of sound quality management. Federal departments have the responsibility to ensure treatment programs, facilities and distribution systems are designed and maintained to perform consistently and reliably, and that they are operated by appropriately trained personnel.

A comprehensive review and approval process for new or upgraded water systems is essential to ensure all project proposals are reviewed and commented on at their various stages of development and to ensure that relevant standards and requirements are met. An effective and coordinated review and evaluation of project proposals will result in the overall reduction of potential health hazards in the new or upgraded water system.

3.0 Developing a monitoring program

The monitoring program for all federal drinking water systems should be developed based on a sanitary survey in combination with a vulnerabilities assessment and a baseline chemical analysis. Each of these steps should be conducted by a competent expert in the appropriate field.

At minimum, an initial sanitary survey, vulnerabilities assessment, and baseline chemical analysis should be conducted within five years for an existing system and before a new system is put into service. They should continue to be conducted every five years, or when there are significant changes to the treatment system, land use, or other conditions which may adversely affect water quality.

Although the survey/assessment/analysis may only be done every five years, departments should endeavour to be aware on an on-going basis of any changes at a site that could impact water quality. This will help to determine if changes are required to the monitoring program. See Section 3.5 for specific guidance in cases where the frequency of the baseline chemical analysis may be reduced.

These steps apply to all systems, new or existing. However, case-specific guidance for a number of scenarios, including groundwater supplies and municipally supplied systems, is provided in Section 3.7.

3.1 Selecting a source for drinking water

For new systems, the selection of a source water must take into consideration whether:

• The source water is of high enough quality that it can be rendered safe for human consumption.
• The quantity of water available is suitable for the number of people who will be using it over the long term, the types and duration of activities they will use it for, and water demands for other uses (e.g., industrial or recreational).

When selecting a source for drinking water, more than one water source should be evaluated, where feasible. Doing so will help determine whether a better source exists or if an alternative source is available that can be used as a back-up in cases where the chosen water supply becomes contaminated or otherwise unsuitable.

3.2 Vulnerabilities assessment

The first step in assessing the drinking water supply is to assess the quality and quantity of the source water. The vulnerabilities assessment is a comprehensive assessment of the vulnerability of the source water in the environment. The results of the vulnerabilities assessment help determine the extent of treatment or other management actions required. Drinking water supplies may originate from surface water or ground water sources. Microbiological risks differ depending on the type of source. Surface water is defined as water open to the atmosphere or subject to surface run-off. It is vulnerable to contamination, including microbiological, and must be treated.

Groundwater is defined as either under the direct influence of surface water (GUDI) or less vulnerable to fecal contamination. GUDI carries the same risks to health as surface water and is dealt with in the same way. It is defined as any water beneath the surface of the ground with (i) occurrence of insects or other microorganisms, algae, organic debris, or large-diameter pathogens such as Giardia lamblia or Cryptosporidium, or (ii) significant fluctuations in water characteristics such as turbidity, temperature, conductivity, or pH which may closely correlate to climatological or surface water conditions.

Groundwater (as opposed to GUDI) is from an aquifer where microbiological contamination is unlikely to occur because of the formation of the rock which protects it. It is typically determined by a hydrogeologist or other well specialist. That said, all groundwaters may be at some risk of contamination, particularly from enteric viruses.

As part of the overall assessment, an evaluation of demands on water quantity is also required.

3.2.1 Delineation of watersheds and aquifers

The land area that contributes water and potential contaminants to the water supply should be defined and mapped (delineated) in order for drinking water managers to focus their efforts within a defined area and respond appropriately to incidents or emergencies.

This component of the vulnerabilities assessment should include characterizing the water source, geology, and features of the surrounding area to determine what may be in the water and what could become a concern in the treated drinking water (e.g., bromide in humic acid in the source water could react with chlorine or other chlorinated disinfectants to form brominated disinfection by-products at the tap).

Many methods exist to delineate watersheds and aquifers, ranging from simplistic terrain mapping to complex mathematical models requiring significant amounts of field data. The decision about which method is required will depend on source water characteristics and the relative risk of contamination.

3.2.2 Identifying source water hazards

The next step is to identify the potential hazards to the water source within the delineated area. Hazards can be identified in a number of ways such as inventories of land uses and contaminant sources, evaluations of watershed and/or aquifer characteristics, and monitoring data related to source water quality and quantity.

The level of effort expended on identifying hazards will depend on available resources. However, the goal should be to collect as much data as feasible on contaminants (including their sources and concentrations), pressures on water quantity, and to fill knowledge gaps with new information from public consultations and/or field studies.

In the vulnerabilities assessment, it is essential to identify hazards since they influence the type of treatment required and any response required in the watershed or aquifer. For instance, a watershed where the primary hazards come from industrial effluent will be managed differently than one where the main threat to water quality is nutrient enrichment.

3.2.3 Susceptibility to contamination

Once the hazards have been identified within a delineated area, the vulnerability of the source to the hazards needs to be determined. The potential impact of the hazards on human health also needs to be determined. The results of these assessments influence the treatment required to ensure the water is safe and aesthetically-pleasing for human consumption. They also guide integrated watershed/aquifer protection efforts by identifying the quantity and quality of the water and its potential vulnerability to degradation. Assessment results may be extremely useful to other agencies and stakeholders who share common interests.

In assessing vulnerability or risk, the data from the identification of hazards needs to be complemented with monitoring data to get an idea of the concentration at which the contaminant is found in the source water and whether this concentration fluctuates over time. Fluctuations in physical parameters should also be noted. These types of data are gathered through long-term monitoring programs. While concentrations can be modelled, it is preferable to obtain real-time, site-specific monitoring data.

3.3 Sanitary survey

A sanitary survey is an on-site review, from intake to tap, of the specific raw water quality, facilities, equipment, operations, and maintenance records for the purpose of evaluating the system's ability to adequately treat source water in order to produce and deliver safe drinking water. The sanitary survey will vary depending upon the type and complexity of the system, but will include the elements outlined in figure 3.1:

Variations in the quality of water supplies can help in detecting contamination problems, and in determining whether they have arisen at the source, during water treatment, or in the distribution system. However, it may often not be possible to take more than a few samples. Consequently, the results of any analysis may not be representative of the water-supply system as a whole.

Sanitary surveys, while they cannot replace water quality analyses, are an essential complement to such analyses as part of water quality control programmes. They allow for an overall appraisal of the many factors associated with a water supply system, including the waterworks and the distribution system.

Sanitary surveys are intended to provide a range of information and to locate potential problems. The data obtained may identify failures, anomalies, operator errors, and any deviations from normal conditions that may affect the production and distribution of safe drinking water.

3.4 Microbiological quality

Since the most significant health risk from drinking water supplies is the presence of disease-causing microorganisms, the most important goal of drinking water treatment is to reduce microbiological risk in the treated water to an acceptable level. The most appropriate type and level of treatment should take into account the potential fluctuations in the source water quality, including short-term water quality degradation, and variability in treatment performance.

For this reason, it is important that federal water quality management systems address any existing and potential microbiological quality concerns at the site (e.g., level of treatment, historical testing results, surface and groundwater vulnerabilities, potential water quality risks, user activities, and local trends), prior to establishing a routine monitoring regimen. A full discussion of microbiological considerations is provided in Chapter 4.

3.5 Baseline chemical analysis

The GCDWQ lists many chemical and physical parameters of concern in Canadian drinking water supplies. Many of these, though, are only a concern in certain parts of the country due to site-specific geology or industrial or agricultural activity. For this reason, it is recommended that a baseline chemical analysis of all drinking water supplies be conducted to determine which substances should be monitored as part of the monitoring program.

A baseline chemical analysis is an analysis of all chemical parameters with Maximum Acceptable Concentrations (MACs) in the GCDWQ. The analysis includes screening for radiological parameters where testing is feasible or warranted. Departments may also choose to look at parameters with aesthetic and/or operational values. Pesticides are generally tested in a suite. However, there may be no need to test for some pesticides (e.g., those not used in a particular watershed). A water quality professional should make this determination.

The department does not have to conduct the baseline chemical analysis if it can access the same data from a reliable third party source (e.g., an accredited laboratory or a municipality). Note: monitoring at the tap is still required for some contaminants originating in plumbing systems (e.g., lead).

As a safeguard, it is recommended that a baseline chemical analysis be conducted every five years, unless a sanitary survey or vulnerabilities assessment indicates that this type of analysis should be done more or less frequently. If particular substances are consistently absent from a water system, the frequency of sampling for those substances can be reduced. As well, where water supplies are obtained from sources that are not likely to be contaminated by industrial and agricultural wastes, a baseline chemical analysis may be needed only to help select new drinking water sources and then only occasionally thereafter.

For drinking water supplied by a municipality, the baseline chemical analysis would include an analysis of the water received to determine if there are any concerns with the supply that require further treatment or whether an alternative source should be used. Federal departments and First Nations communities should request water quality testing results from the municipality. This information will indicate which substances are being tested for and analysed.

3.6 Establishing a monitoring program

It is recommended that monitoring programs for identified chemical contaminants include, at minimum, annual monitoring for surface water sources, and monitoring every two years for groundwater sources, unless otherwise specified in the GCDWQ. Microbiological monitoring should be implemented as per the guidance in Chapter 4 of this document.

3.6.1 Disinfection by-products

For systems using chemical disinfection, monitoring of disinfection by-products (DBPs) should be conducted more frequently, in some cases every three months, to meet the requirements of the GCDWQ. For example, the MACs for trihalomethanes (THMs) and haloacetic acids (HAAs), which are DBPs linked to the use of chlorine as a disinfectant, are established as locational running annual average of quarterly samples.

3.7 Case-specific guidance

3.7.1 Groundwater supplies

The risks associated with groundwater contamination vary with the type of activities on the property, the surrounding land use, soil type, and the type and condition of the wellhead or wellfield. A vulnerabilities assessment report for all existing groundwater systems should include a description of the facility and surrounding land use, the direction and rate of groundwater flow, capacities of the selected water source, the radius of influence, hazards associated with the water source, and protection measures that are either in place or needed.

The sanitary survey for groundwater should also include a review of previous sampling results, identify whether further treatment is required, investigate the type of well in place (or proposed), and lay out requirements for wellhead protection. It should recommend improvements and upgrades where needed, and identify any compliance and enforcement issues. Federal staff and, in First Nations communities, managers and/or operators of facilities and the water treatment plant operator, will then be able to regularly update well records (CDW and CCME, 2004).

The amount of effort and resources expended on assessing the groundwater supply will depend on factors such as its size, use, and location. A sample Well Assessment Form is provided in Appendix D.

Suitable sealing, capping, filling or removal of wells to be abandoned is important to ensure the safety of the aquifer and the environment and to protect against future hazards. (Note: Listing relevant guidelines for abandoning wells is beyond the scope of this document.)

3.7.2 Municipally-supplied drinking water systems

Often the source of potable water for facilities owned and operated by the federal government is the local municipality. The quality of this water is the responsibility of the system owner.

In order to ensure the water received is of acceptable quality, water quality managers and/or technical support staff should be in regular contact with the municipality. Maintaining solid relationships with key contacts in the municipality's drinking water program is important in order to be kept informed of any water quality or quantity issues that could affect the health of consumers. Staff should periodically review the municipality's reports describing water sampling results in order to keep informed of the water's changing characteristics and to understand the quality of drinking water entering the facility's distribution system or building plumbing.

Sanitary surveys should be conducted every five years for all systems. Sanitary surveys are needed to verify a number of factors (fully described in other sections), which include the condition of the plumbing, the type of materials, and the state of the connections, including cross-connection control, within the building.

Where a federal department receives municipally-treated drinking water, a vulnerabilities assessment may not be practical or necessary. In its place, the information normally gathered through the vulnerabilities assessment should be obtained through a complete assessment of the water received from the municipality. This could be based on the municipality's reports describing water sampling results.

In cases where water is received from a municipality, it may be possible to negotiate to have the federal building designated as a routine municipal water sampling location. If this is not possible, water samples may need to be collected for some water quality parameters (e.g., lead). Samples should be collected at the point closest to the intake of municipal water to the building in order to establish a baseline understanding of the water quality. Additional samples taken from points within the building will indicate whether water quality is deteriorating within the building. Information specific to microbiological monitoring is found in Chapter 4.

3.7.3 Staff quarters

The need to provide potable water to staff quarters is determined on a department-by-department basis.

4.0 Microbiological considerations and monitoring

Given the sheer number of federal drinking water systems and the wide variety in system size, location, and site-specific concerns, the guidance in this document is designed to be flexible. For the purpose of this document, drinking water systems have been categorized as large, small, very small, and micro-systems depending on the size of the population served (see Section 1.3 and the glossary for definitions).

Microbiological monitoring programs should include the indicator organisms E. coli and total coliforms. Turbidity and chlorine residuals should also be monitored in order to ensure the microbiological integrity of the water, even though these are not microbiological parameters. System operators may also choose to test for heterotrophic plate count bacteria in order to better understand the general bacteriological quality of the drinking water and changes in water quality in distribution systems.

Generally, minimum treatment of supplies derived from surface water sources or groundwater under the influence of surface water should include adequate filtration (or the use of equivalent technologies) and disinfection (primary disinfection). Where there is a distribution system, a disinfectant residual (either chlorine or chloramine) should be maintained throughout the distribution system at all times (secondary disinfection). Very small systems or micro-systems where there is little or no distribution system do not require a disinfectant residual. Commonly used disinfectants include chlorine (primary and/or secondary disinfection), chloramine (primary and/or secondary disinfection), chlorine dioxide (primary disinfection), ultraviolet radiation (UV – primary disinfection) and ozone (primary disinfection).

It is important to note that all chemical disinfectants used in drinking water can be expected to form di¬sinfection by-products, which may affect human health. Current scientific data show that the benefits of disinfecting drinking water (reduced rates of infectious illness) are much greater than any health risks from disinfection by-products. While every effort should be made to reduce concentrations of disinfection by-products, any method of control must not compromise the effectiveness of disinfection.

4.1 Monitoring frequency

Note: For facilities that receive municipally supplied drinking water, additional guidance is provided in Section 4.3.

For departments and other responsible authorities who produce/treat their own drinking water, the recommended monitoring frequency for microbiological parameters depends on a number of factors, including the size of the population served, the monitoring history, type and quality of the source water, and the presence and type of treatment used.

Some guidance on monitoring frequency is provided in the GCDWQ. Monitoring frequencies at the facility or system level should be established by the appropriate department or responsible authority, with proper guidance and due consideration of the above factors and any regulatory requirements.

Generally, for all systems serving up to and including 5,000 people, bacteriological samples should be collected at a minimum four times per month at regular intervals as shown in Table 4.1. Sampling could be scheduled to match provincial guidelines or regulations where these are more stringent. It is recommended that chlorine residuals be tested when bacteriological samples are taken. Ideally, each monitoring event for E. coli and total coliforms should include samples at both the treatment plant and in the distribution system.

Table 4.1 lists the default monitoring frequencies that should be followed (unless conditions are met for reduced monitoring as per Section 4.1.1, Box 4.1 and tables 4.2 through 4.5) by departments and other responsible authorities who produce/treat their own drinking water. (See Section 4.3 for guidance for facilities that receive municipal drinking water).

Table 4.1 Default monitoring frequency and locations

For routine sampling, an effort should be made to collect and analyse samples when the risk of contamination is highest and there is a potential public health risk (e.g., spring thaw, heavy rains, dry periods, and/or when there is a noticeable deterioration in water quality).

During high risk events (e.g., flooding, extreme or unusual weather events), there may be a need for additional monitoring. Additional monitoring should also be done when alterations are made to treatment, plumbing, or distribution systems). In addition, new or renovated wells should be sampled and analysed at start-up to confirm acceptable bacteriological quality (Health Canada, 2012a).

Where the finished water is expected to come into contact with a distribution system, a storage tank, or a trucked (hauled) water container, a chlorine residual should be maintained at all times (throughout the distribution system and/or in the storage tank or trucked (hauled) water container. If a very small system or micro-system has little or no distribution system, no chlorine residual is required.

Both surface water and GUDI systems require filtration in addition to disinfection, unless systems meet criteria for excluding filtration as outlined in the guideline technical document on turbidity (Health Canada, 2013).

4.1.1 Conditions for reducing monitoring frequency

There is no flexibility provided for small systems (i.e., serving 501 to 5000 people) to reduce monitoring frequencies. In some cases, for very small systems and micro-systems, it may be possible to reduce the number of samples taken and analysed.

Box 4.1 and tables 4.2 through 4.5 define the conditions for reduced monitoring frequency, once an acceptable history has been established. Box 4.1 and the tables must be read together. The department must default to four samples per month for systems serving 500 or fewer people if the conditions identified in Box 4.1 and tables 4.2 through 4.5 are not met.

Box 4.1: Conditions for reduced monitoring frequencies in very small and micro systems

4.2 Sampling locations

Samples should be taken at the point where the water enters the system (to eliminate the source water as the cause of the adverse water quality), in the treatment plant after each filter (if applicable) and from representative points throughout the network, although not necessarily the same points on each occasion. Samples should also be taken in any other locations identified in the sanitary survey as areas of concern. For very small systems where there is little or no distribution system, samples should be taken at the first point where water is taken for drinking.

If the water supply is obtained from more than one source, the location of sampling points in the distribution system should ensure that water from each source is periodically sampled. The majority of samples should be taken in potential problem areas: low-pressure zones, reservoirs, dead ends, areas at the periphery of the system farthest from the treatment plant and areas with a poor previous record.

4.3 Facilities that receive municipal drinking water

Facilities that receive municipal water (in Canada) should be receiving microbiologically safe water. However, it is the responsibility of the department to ensure they have the appropriate documentation (e.g., vulnerabilities assessment, third party reliable data) to verify that the incoming water is microbiologically safe. In this case, these facilities do not need to routinely collect bacteriological samples to verify the quality of the water entering the facility. Note that bacteriological sampling would still be needed in situations where the sanitary survey has identified potential risks (e.g., absence of a cross-connection control program). It may also be needed to respond to consumer complaints.

Where the quality of the municipally supplied water does not meet the microbiological parameters in the GCDWQ or is uncertain (e.g., no vulnerabilities assessment, absence of third party reliable data, inadequate chlorine residual levels), the system should be considered to be an untreated supply and steps taken to ensure public health is protected. The guidance in the whole of this document will help departments fulfill their responsibility to provide safe drinking water to their employees.

Facilities receiving municipal drinking water that requires bacteriological monitoring should collect samples at the main or at the point of entry to the building (where applicable), in the building's plumbing system (i.e., dead ends), and in other locations identified in the sanitary survey.

4.4 Interpreting results

4.4.1 Indicator organisms

As part of a "source to tap" approach, testing for E. coli and total coliforms should be used to verify the microbiological quality of the water. The GCDWQ have separate guideline technical documents for each of these parameters. Information regarding sample analysis and laboratory accreditation can be found in Section 6.3.3.

E. coli

E. coli is a member of the total coliform group and the only one found exclusively in the faeces of humans and other animals. The GCDWQ state that the MAC of E. coli in a drinking water system is none detectable per 100 mL. The presence of E. coli indicates recent faecal contamination and the possible presence of enteric pathogens that may adversely affect human health. If E. coli is detected, the appropriate agencies should be notified, and corrective actions taken, including re-sampling. A boil water advisory should be issued when the presence of E. coli is either detected or confirmed.

Total coliforms

Total coliforms, while not a reliable indicator of faecal contamination, are a good indicator of general microbiological water quality, and therefore are measured as well. For total coliform bacteria, the GCDWQ recommend:

• In water leaving a treatment plant, the MAC of total coliforms is none detectable per 100 mL.
• In distribution systems where fewer than 10 samples are collected in a given sampling period, no sample should contain total coliform bacteria. In distribution systems where greater than 10 samples are collected in a given sampling period, no consecutive samples from the same site or not more than 10% of samples should show the presence of total coliform bacteria.

While E. coli is the only member of the total coliform group that is found exclusively in faeces, other members of the group are found naturally in water, soil and vegetation, as well as in faeces. Total coliform bacteria are easily destroyed during disinfection. Therefore, their presence in water leaving a treatment plant indicates a serious treatment failure and should lead to the immediate issuance of a boil water advisory and to corrective actions being taken.

The presence of total coliforms in the distribution system (but not in water leaving the treatment plant) indicates that the distribution system may be vulnerable to contamination or may simply be experiencing bacterial regrowth. It does not necessarily mean a boil water advisory must immediately be issued; however, the source of the problem should be determined and corrective actions taken (Health Canada, 2012b).

In well water, the presence of total coliform bacteria in the absence of E. coli indicates the well may be prone to surface water infiltration and is therefore at risk of faecal contamination, or may indicate the presence of biofilm in the well or plumbing system (Health Canada, 2012b). A biofilm is a community of micro-organisms attached to a solid surface in an aquatic environment, for example the inside wall of a pipe. Even though the biofilm itself is not a health concern, it could interfere with analytical testing. Also, it could eventually impede water flow, potentially leading to the deterioration of aesthetic water quality and ultimately to taste and odour problems.

If total coliforms are found in the absence of E. coli, in a non-disinfected groundwater system, necessary action will vary depending on the source of the total coliforms and the size and history of the system. A boil water advisory may not need to be issued immediately. However, for very small systems and micro-systems, it is recommended that boil water advisories be issued—or an alternative safe source of drinking water used—if the presence of total coliforms has been confirmed in the groundwater system. Regardless of whether a boil water advisory was issued, corrective actions should be implemented.

Corrective actions could include shock chlorination (the addition of a strong solution of liquid chlorine into a drinking water system to reduce the presence of microbiological contaminants) and flushing of the well and/or distribution system.

A recommended approach to shock chlorinating wells can be found in Health Canada's "Water Talk: What's In Your Well? - A Guide To Well Water Treatment And Maintenance".

It is recommended that a boil water advisory be used only as a temporary measure while problems are being identified and remediated. In certain circumstances, boil water advisories may be in place for a longer period of time. More information on issuing and rescinding boil water advisories is provided in section 6.6 and on the website.

4.4.2 Heterotrophic plate count

Heterotrophic plate count (HPC) bacteria are not a suitable indicator of the microbiological safety of water, but can provide an indication of the general bacteriological quality. For example, increases in HPC bacteria above normal baseline levels can indicate changes in raw water quality, problems such as bacterial regrowth in the distribution system or plumbing, or problems with drinking water treatment.

Effective treatment can reduce concentrations of HPC bacteria to fewer than ten colony forming units per 100 mL of water. These counts can be used for quality control in water treatment plants and as a measure of quality deterioration in wells, distribution lines, and reservoirs.

A sudden rise of HPC or background colonies in drinking water collected from a site that has traditionally had low counts should give rise to concern. If a sample contains greater than usual levels of HPC or background colonies, the site should be re-sampled and the chlorine residual verified (if applicable). If the repeat sample still indicates an elevated HPC, the system should be inspected to determine the cause, and if necessary, remedial action should be taken (Health Canada, 2012c).

4.4.3 Turbidity

Federal facilities and facilities in First Nations communities that treat and supply their own drinking water should monitor their water for turbidity as it is a strong indicator of water quality. It is also an important indicator of treatment efficiency and filter performance in particular (Health Canada, 2013).

Generally, minimum treatment of supplies derived from surface water and GUDI sources should include adequate filtration (or technologies providing an equivalent log reduction credit) and disinfection. Filtration is an important barrier for removing particles that cause turbidity. Microorganisms, in addition to being particles themselves, can become attached to soil and waste particles in the environment and can aggregate or attach to inorganic or other particles during treatment. Effective removal of microbial pathogens is best achieved when water of low turbidity is produced and effective inactivation of microbial pathogens is best achieved when low-turbidity water is disinfected.

The most important consideration when dealing with turbidity is the need to reduce it to a level as low as reasonably achievable and to minimize fluctuation. Optimizing treatment performance for turbidity reduction and particle removal also generally optimizes pathogen removal and subsequent disinfection while reducing the potential formation of undesirable disinfection by-products.

Health-based treatment limits (HBTL) for turbidity have been established for the different filtration technologies to help ensure that systems are meeting the minimum levels of pathogen removal (log removal credits) provided in the enteric protozoa guideline technical document. The HBTL are achievable by most filtration systems. However, filtration systems should be designed and operated to reduce turbidity levels as low as reasonably achievable and strive to achieve a treated water turbidity target from individual filters of less than 0.1 NTU.

Where filtration is not required to meet pathogen removal goals, it is best practice to keep turbidity levels below 1.0 NTU to minimize the potential for interference with disinfection. In addition, to mimimize particulate loading and effectively operate the distribution system, it is also good practice to ensure that water entering the distribution system has turbidity levels below 1.0 NTU. Turbidity should be measured at each individual filter, and can be measured by on-line turbidity meters, a laboratory, or by using a test kit.

Turbidity monitoring is also recommended for systems using groundwater that is less vulnerable to fecal contamination (with the exception of serving 25 people or less, i.e., micro-systems). Turbidity levels in groundwater should be relatively constant. Changes in turbidity outside the normal range for a groundwater system indicate changes in groundwater quality or changes in the integrity of the well that need to be investigated. For systems that use groundwater that is not under the direct influence of surface water, which are considered less vulnerable to faecal contamination, turbidity should generally be below 1.0 NTU.

Turbidity sampling should take place in accordance with tables 4.1 through 4.5. The daily source water turbidity level can be based on either a single grab sample measurement or the arithmetic average of all the source water turbidity measurements taken in one calendar day (ADI Ltd., 2002b). In systems where turbidity monitoring is not continuous, turbidity samples should be taken during times of poorest source water quality, such as after heavy rains, and during spring run-off (when possible).

4.5 Disinfection targets

Barring system-specific exemptions (as described below), all drinking water supplies should be disinfected to ensure the safety of the drinking water leaving the treatment plant. The effectiveness of disinfection can be predicted based on a knowledge of the residual concentration of disinfectant, temperature, pH (for chlorine), and the time between the moment the disinfectant is added to the water and the moment the water arrives to the first customer. This relationship is commonly referred to as the "contact time" or "CT" concept. CT is the product of C (the residual concentration of disinfectant, measured in mg/L) and T (the disinfectant contact time, measured in minutes). This calculation is used by large drinking water systems as a tool for ensuring adequate inactivation of organisms during disinfection (Health Canada, 2012a,b).

In the case of a groundwater source that is less vulnerable to fecal contamination, primary disinfection may not be necessary for very small systems and micro-systems provided an annual sanitary survey / vulnerabilities assessment are conducted to ensure that the source is not subject to contamination, that conditions have not changed, and that routine monitoring and appropriate system maintenance is in place. A vulnerabilities assessment may not be required for micro-systems if conditions described in box 4.1 are met. In addition, if a comprehensive sanitary survey is conducted following the elements described it table 3.1, its frequency may be reduced to once every three to five years, as appropriate.

Where disinfection is practised, a residual of an acceptable disinfectant, typically chlorine, should be present at all times in the distribution system (see section 5.3 for further information on chlorine residuals). Free and/or total chlorine residuals should be tested when bacteriological samples are taken, as identified above, as well as independently. Chlorine residuals can be verified by a laboratory or by using an acceptable test kit (addressed in section 6.3.3). Additional testing of chlorine residuals could also be done to routinely monitor the integrity of the distribution system.

Note: Even in cases where a sanitary survey or vulnerabilities assessment suggests that disinfection is not required, periodic disinfection may become necessary in situations where the microbiological quality of the water deteriorates. For this reason, it is recommended that disinfection equipment and supplies, or an equivalent incident response mechanism (such as an alternative source or boil water advisory), be available to deal with potential occurrences.

5.0 Treatment and distribution systems

The properties of the treated water will be affected by the quality of the source water, treatment components and design, treatment processes and chemicals used, treatment efficiency, and distribution system characteristics.

5.1 Design of drinking water treatment systems

Treatment systems should be designed based on the site-specific raw water quality and quantity and should take into account seasonal variations. Because of the complexity of assessing the level of risk associated with drinking water hazards, as well as the need to properly design a water treatment system, the evaluation of the source water and the design and construction of the treatment facility should be performed by appropriately qualified specialists (e.g., registered professional engineers).

5.1.1 Continuous monitoring and automated systems

When considering the construction of a new treatment plant or upgrading an existing plant, it is recommended that the design include an automated, continuous monitoring system that allows an operator to control and monitor processes from a central location. When a plant does not have an operator present 24 hours per day, 7 days per week, such systems are capable of calling a designated location if there is a process failure during silent hours (DND, 2007). In addition, the use of some remote monitoring technologies, such as Supervisory Control And Data Acquisition (SCADA) or similar, allows the operator to make operational adjustments from a remote location. These products should be secure from accidental or deliberate interference.

Automation is advantageous in situations where an operator's duties are shared between different systems or different roles (i.e., not just drinking water) and when it is not possible for the operator to physically check equipment every day (including weekends). It can be used for any size of system; however, the utility of automation in a very small system would have to be assessed in terms of the costs and benefits related to the level of risk the water system represents to the users. The costs associated with the operator's time need to be assessed against the cost of the suggested equipment.

For very small systems, less sophisticated automated notification systems can be used to communicate alarms to an offsite location, such as a pager or phone, when a water quality parameter is out of compliance.

5.1.2 Surface water intakes

A surface water source requires an intake structure for drawing water into the water treatment plant. The main purpose of the intake structure is to draw in water while preventing leaves and other debris from clogging or damaging pumps, pipes, and other pieces of equipment in the treatment plant. The location of the water intake structure can greatly affect the quality of the water withdrawn. Ideally, the intake would be located upstream of any potential source of contamination or, if that is not possible, sufficiently downstream to minimize impact (Earth Tech, 2002). It should also be located deep enough under water to ensure that the water around it does not freeze in the winter, thereby ensuring water can be drawn year round, but far enough from the bottom of the water body to avoid sediments and mud.

Proper design, maintenance, and operation are essential to prevent partial or complete shut-down of the entire drinking water system^{Footnote 4}. Screens should be cleaned regularly to prevent blockage. Each spring, the lake or river intake pipe and screen should be inspected by divers to ensure no damage has occurred over the winter (DND, 2007).

5.1.3 Treatment options

The treatment process selected should address all potential hazards identified in the source assessment (Health Canada, 2001). Minimum treatment of all supplies derived from surface water sources and groundwater under the influence of surface waters should include disinfection and filtration (Health Canada, 2012a). For detailed information on water treatment technologies, see Holden (2001) and DND (2007).

5.2 Distribution systems

Drinking water distribution systems are made up of components that connect the water treatment plant to buildings, such as treated water reservoirs, water mains (distribution system pipes), service lines to individual buildings, backflow preventers, valves, hydrants, and, if required, pipe insulation and heating cables.

In general, the distribution system does not include in-home plumbing, point-of-entry or point-of-use treatment devices. However, in some situations, such as non-residential buildings and staff quarters, the plumbing may be considered part of the distribution system.

When a water source is provided by a municipality, the municipality's responsibility for the quality of the water generally ends at the curb or the point where the water enters the building's plumbing system. When a federal facility or First Nations community uses municipal drinking water as its supply, the beginning of the facility or community's supply system marks the end of municipal responsibility. For instance, facilities in First Nations communities that receive water from the local municipality are responsible for properly maintaining a community water supply pipe and for monitoring the quality of water in that pipe. Should this pipe deteriorate, the water quality would suffer.

Regardless of the jurisdiction over the water source, all federal purveyors of drinking water, or, in the case of First Nations communities, Chief and Council, are responsible for ensuring the water in drinking water supply systems is tested to ensure contamination events are detected as soon as possible and can be appropriately addressed. The department or facility's responsibilities include routine maintenance of the facility's plumbing system and analysis to determine if a change in water quality is occurring within the building. The plumbing systems in federal facilities must meet the National Plumbing Code of Canada and CSA Standard B64.10.01.

Federal facilities or First Nations communities that supply their own drinking water have to consider the distribution system from the water supply to the building or to the curb stop before the house (this may include water delivered by trucks) and then within the building to consumers. Other facilities may receive their water from municipal sources, but must still concern themselves with the distribution through the plumbing system within the building. First Nations communities are responsible for the routine maintenance of the plumbing in their homes.

A routine maintenance schedule for plumbing systems should include the following elements: inspecting the building's plumbing for cross-connections, pressure testing, flushing water lines (when warranted) and hydrants, regular disinfection of bottled water coolers and drinking fountains, and monitoring water quality. See section 6.3 for further information on monitoring.

In order to keep track of the infrastructure as it was built and changes made over time, it is important to keep up-to-date drawings on hand. These drawings should include notes describing all work and observations over time.

5.2.1 Design and assessment

Distribution systems, including treated water reservoirs, should be designed to take the following into account: public access, access by wildlife, system capacity, emergency water storage (including fire flow capacity), contact time required for disinfection, the minimization or elimination of dead ends, and cross-connection control. They should also be designed and constructed to comply with all local or provincial by-laws and regulations and take into account best management practices.

Portions of the infrastructure that are accessible to the public and/or animals should be secured, where applicable. Treated water reservoirs should be covered, watertight, and secured to prevent contamination.

When assessing the condition of water distribution systems, a two-phase approach is suggested. The first phase involves a preliminary assessment of the structural condition, hydraulic capacity, leakage and water quality on a system-wide basis using existing data. The second phase involves a more detailed investigation of specific problems based on findings of the preliminary assessment.

The most effective way to investigate the condition of a water distribution system is through regular analysis of readily available data. A preliminary assessment of this data should be conducted every three to five years to identify trends and to determine the need for more detailed investigations. If the preliminary assessment indicates that a more detailed investigation is needed, experts in distribution system analysis should do the work.

Descriptions of the components of the distribution system and guidance for investigating water distribution systems are found in Appendix E. Table E.1 summarizes the type of data that should be used to complete a preliminary assessment of each of the four common types of problems that can occur in water distribution systems.

For more information on the disinfection of water storage facilities, see AWWA's C650 series of manuals.

5.2.2 Corrosion control

If not properly maintained, many water distribution system components (including plumbing) could lead to contamination of the water supply. Corrosion is a key issue, and can cause deterioration of water distribution systems in the following ways:

Internal corrosion

• Impaired/poor water quality due to internal corrosion of unlined metallic components, biofilm build-up and/or poor maintenance practices.
• Reduced hydraulic capacity due to internal corrosion of unlined metallic components or calcium carbonate precipitation (e.g., scaling).

External corrosion

• High leakage rate due to external corrosion of the infrastructure, through holes in pipe walls and/or deteriorating joints.
• Frequent breaks due to external corrosion, material degradation, poor installation practices, manufacturing defects and operating conditions (InfraGuide, 2002).

Health Canada and the CDW have developed guidance on corrosion control in drinking water systems. Further information can be found on Health Canada's website.

5.2.3 Watermains

The condition of critical watermains should be monitored to minimize failures. Critical mains are typically those which serve as a trunk line to the smaller water lines. It is also important to monitor the condition of non-critical water mains. Failures should be "managed" to minimize operational and maintenance costs (InfraGuide, 2002).

Watermains may need to be replaced, or a structural liner may need to be used, if they fail because of high rates of breakage or excessive leakage. If hydraulic capacity or water quality are a concern, rehabilitation might be more cost-effective than replacement.

5.2.4 Cross-connection control

Cross-connections are physical links in the distribution system through which contaminants can enter the drinking water supply. This can happen when the pressure in a plumbing component connected to the distribution system is higher than that of the distribution system, an event commonly called back siphonage or backflow. When conducting a sanitary survey of a water system, it is important to include cross-connection control to ensure risks of contaminants entering the water system through backflow are identified.

The National Plumbing Code (NPC) is the over-riding code for cross-connection control and backflow prevention requirements. It stipulates the need to comply with the most recent version of the CSA B64 standard. Most jurisdictions have adopted the NPC. Purveyors may also have to meet additional requirements for their jurisdiction. The NPC applies from the property line into the facility. When a municipality is responsible for meters, valves, or other fittings within the property line, municipal codes or other by-laws may also apply.

Cross-connection control programs should be in place in order to prevent contamination. Such programs include (Holden, 2001; U.S. EPA, 2003; DND, 2007):

• Surveying existing buildings to rank the connections based on the degree of hazard that they present to the water supply. (Note: where a cross-connection can be classified at different degrees of hazard, purveyors should classify at the highest degree of hazard);
• Preparing a list of all testable backflow devices in the building's water system;
• Assessing new construction plans for cross-connection hazards;
• Installing proper backflow preventers;
• Instituting a tamper policy;
• Testing, inspecting, and maintaining devices;
• Setting out the qualifications required for a person to be allowed to perform a building's cross-connection control survey;
• Training and educating staff; and
• Establishing protocols for notifying the building owner or responsible party to test devices.

A cross-connection control survey, as well as testing backflow prevention or cross-connection control devices, should be conducted by a certified cross-connection control specialist or other qualified professional who has expertise in this area.

Devices used in the prevention of cross-connections and backflow may also deteriorate over time without regular maintenance and inspection, potentially allowing contaminants to enter the water system. Consequently, testing, inspecting, and maintaining cross-connection control devices must be done following manufacturers' instructions with guidance from CSA B64. For more detailed information on cross-connection control, the AWWA Standard (M14, listed below) can provide additional guidance. You may also wish to consult your local Canadian section of AWWA for additional information relevant to the Canadian situation. The InfraGuide document, "Methodology for Setting a Cross-Connection Control Program," outlines the differences between the CSA B64 and AWWA documents, which could be helpful in selecting the most appropriate approach. The CSA B64 Standard can be purchased online through CSA.

Additional guidance is provided in other documents such as:

• AWWA Manual "Recommended Practice for Backflow Prevention and Cross-Connection Control (M14), Third Edition".
• AWWA Standard "C510-07: Double Check Valve Backflow-Prevention Assembly".
• AWWA Standard "C511-07: Reduced-Pressure Principle Backflow Prevention Assembly".
• AWWA's "Distribution Valves: Selection, Installation, Field Testing, and Maintenance (M44), Second Edition".
• InfraGuide. "Methodology for Setting a Cross-Connection Control Program".
• U.S. EPA. "Cross-Connection Control Manual".

Individual jurisdictions may have their own guidance manuals as well.

5.2.5 Dead ends and loops

Dead ends and loops within plumbing and distribution systems result in water remaining in pipes for an extended period of time. As the water stagnates, metal concentrations may increase as a result of the pipes leaching metals into the water. Bacteriological growth in stagnant areas is also a concern.

Problems may also arise as the result of low water use or water sitting in pipes overnight (or on weekends) when no one is at the facility. As it is not possible to eliminate these times of low use, it is advisable to allow for several minutes, or other appropriate length of time, of flushing when using water the morning following weekends or other periods of low usage. Automatic flushing hydrants are available to improve water quality at the end of lines.

The appropriate flushing frequency may be determined through a sanitary survey/vulnerabilities assessment process.

As part of a sanitary survey/vulnerabilities assessment process, facility managers should work to identify any dead ends or loops in the system and measure chlorine residual. They should give special attention to dead ends and loops in flushing and monitoring schedules. Generally speaking, it is a good idea to practice uni-directional flushing, create a written plan including valve-opening and closing sequences, and record turbidity levels and flow volumes and rates. In northern areas, it is necessary to have looped water networks designed to ensure the continuous flow of water. This serves as a means of anti-freeze protection.

5.2.6 Routine flushing of the plumbing system

Routine maintenance should include flushing water lines within a building. A minimum flushing regimen should be put into place, with flushing frequency based on the sanitary survey and vulnerabilities assessment. At minimum, it is suggested that water be flushed through the lines every 6 to 8 weeks in all inactive areas of the plumbing system (e.g., water fountains that are used infrequently, areas with dead ends or loops). The entire system should be flushed once a year. The sanitary survey and vulnerabilities assessment may identify site-specific problems that require more, or less, frequent attention.

5.2.7 Drinking water fountains

Drinking water fountains should be disinfected to ensure contamination does not occur at the spigot. Current industry standards recommend that fountains be disinfected a minimum of once every two months and at an increased frequency if heavily used. They should also be maintained according to the manufacturer's recommendations.

5.2.8 Recording and tracking maintenance issues

Main Breaks

Federal facilities and facilities in First Nations communities should record the location and details of water main breaks. Appendix F includes a form that summarizes the data that should be recorded for each break occurrence. The total number of breaks in a year should be compiled and reviewed to identify any trends (InfraGuide, 2002).

Low Pressure

The distribution system should be pressure-tested on a regular basis to ensure that flow pressure conforms to section 6.3 of the most recent version of the NPC (NRC, 2010). Low-pressure complaints should be recorded. If the number of complaints increases over time, it may suggest the hydraulic capacity of the system is deteriorating. A visual or camera inspection of the interior of water mains can help indicate the degree of flow restriction from corrosion. The inferior condition can also be determined by visually inspecting the water when a water main is flushed (InfraGuide, 2002).

A complete cross-connection control program includes training and education for staff. Employees who will administer the program need to be competent in the use of backflow testers, surveys, and device repair (U.S. EPA, 2003). Each department's training plan should address these needs.

5.2.9 Water quality complaints

A preliminary assessment of the water quality in a distribution system can be completed using routine water quality monitoring data, complemented by water quality complaint records. The water quality complaint records should be recorded and tracked in a manner similar to that for low-pressure complaints or breaks. Water quality complaints related to construction and maintenance activities (e.g., flushing, repairs, new construction) should be excluded from the analysis to properly reflect the condition of the system but should be reviewed to determine if operational changes are necessary.

On-going analysis of water quality data will indicate if the water quality is changing through the distribution system, both spatially and over time. Low chlorine residuals in some parts of a system, in combination with increased colour, high turbidity, increased iron, increased HPC, or drops in pressure or flow may demonstrate that the mains in these areas are deteriorating. Low chlorine residuals could also indicate deteriorating water quality. Similarly, the concentration of iron in the water may denote the degree of internal corrosion of unlined mains (InfraGuide, 2002).

5.3 Chlorine residuals

Disinfection is critical to ensuring the safety of the drinking water supply in the treatment plant. In addition to this primary disinfection, free and/or total chlorine is used in residual amounts to ensure continued disinfection throughout the distribution system (secondary disinfection) and to protect the water from re-contamination. Where there is a distribution system, a disinfectant residual (either chlorine or chloramine) should be maintained throughout the system at all times. The chlorine residual is the concentration of chlorine species present in water after the oxidant demand has been satisfied.

Tests of chlorine residuals at the drinking water treatment plant and in the distribution system are needed to determine chlorine dosage levels and to monitor water quality. A disinfectant residual should be detectable at all points in a distribution system. Maintenance of an adequate free chlorine residual will minimize bacterial regrowth in the distribution system and provide a measurable level of chlorine; therefore, a rapid drop in free chlorine concentrations suggesting unexpected changes in water quality can be more quickly detected.

A free chlorine residual of 0.2 mg/L is considered a desirable minimum level throughout the distribution system for control of bacterial regrowth. In the provinces and territories, specific requirements for chlorine residual concentrations are set by the regulatory authority and may vary between jurisdictions. Further information on chlorine residual can be found in the guideline technical document for chlorine (Health Canada, 2009c).

In the case of a very small system or micro-system that obtains its water from a groundwater source, and has little or no distribution system, no chlorine residual is needed.

More information on disinfection, including for groundwater issues, is found in Section 4.5.

5.4 Drinking water materials

Drinking water materials are materials that come into contact with drinking water for its treatment or distribution, from its intake at the source through the treatment plant and the distribution system and all the way to the consumer's tap (and beyond). These materials fall into three general categories: treatment devices (such as filters and reverse osmosis systems and their components), treatment additives (such as alum and chlorine) and system components (such as pipes and faucets). Drinking water quality concerns from these materials are generally related to:

• Leaching of contaminants from the material into the drinking water;
• Treatment devices not meeting manufacturers' claims of efficiency for removing specific contaminants.

Health Canada does not recommend specific brands of drinking water treatment devices, but it strongly recommends that consumers look for a mark or label indicating that the device has been certified by an accredited certification body as meeting the appropriate NSF International (NSF)/American National Standards Institute (ANSI) health-based performance standards. These standards have been designed to safeguard drinking water by helping to ensure the material safety and performance of products that come into contact with drinking water. Certification organizations provide assurance that a product conforms to applicable standards and must be accredited by the Standards Council of Canada (SCC). An up-to-date list of accredited certification organizations can be obtained from the SCC.

NSF standards are widely accepted in North America. They reference and incorporate other relevant standards and protocols as appropriate. The NSF website has information about both health-based and performance standards related to drinking water treatment devices. Standards exist for most drinking water treatment devices. The two key standards with respect to health effects are NSF/ANSI Standard 60: Drinking water treatment chemicals-health effects (which addresses treatment chemicals/additives; NSF, 2012a) and NSF/ANSI Standard 61: Drinking water system components-health effects (which addresses leaching from products that come into contact with drinking water, including pipes, fittings and coatings such as water storage tank liners; NSF, 2012b).

Plumbing systems (internal building distribution systems) within federal buildings and in First Nations communities must be designed and constructed to meet the National Plumbing Code of Canada (NPC). The NPC requires that plumbing products, at the time of installation, comply with a number of standards but in particular, Canadian Standards Association (CSA) standards for plumbing fittings, fixtures and backflow prevention. Many of the CSA standards are currently being harmonized with equivalent US standards. NSF/ANSI Standard 61 is incorporated in these standards, where applicable, to ensure that the plumbing components also meet minimum health effects requirements. Meeting the NPC may not be possible in places such as Canadian diplomatic missions in other countries. In these situations, minimum sanitary engineering practices should be met.

Any chemicals (additives) used in drinking water treatment processes and/or the distribution system must meet the applicable health-based standards established by NSF, namely NSF/ANSI Standard 60 (NSF, 2012). The NSF/ANSI standard ensures that treatment chemicals meet purity and performance requirements for drinking water applications but does not include product performance requirements. These are currently addressed in standards established by the American Water Works Association (AWWA). Because these AWWA standards complement NSF/ANSI 60, regulators generally recommend that products also meet the appropriate requirements specified in the AWWA standards.

Other international standards do exist (e.g., British Standards International) but do not currently address the health-based issues related to materials that come into contact with drinking water and therefore should not be considered equivalent.

5.5 Special circumstances

5.5.1 Alternative sources of drinking water

Departments may need to provide an alternative source of drinking water under certain circumstances, such as:

• If the water supply has become contaminated or is otherwise considered unacceptable;
• If there are problems in the distribution system or plumbing; or
• Simply for convenience.

One option departments may consider is to provide bottled water, including water from water coolers and/or dispensers. Although bottled water may be safe when it is delivered, precautions should be taken to ensure it does not become contaminated at the dispenser. See Appendix H for details on how to maintain water coolers and dispensers.

Outside of Canada, for example in Canadian diplomatic missions in foreign countries, the bottled water available is not necessarily safe. In foreign jurisdictions where no water quality results are available from the manufacturer, departments should ensure the safety of bottled water by conducting tests as per their own policies. For example, the Department of Foreign Affairs and International Trade requires that, for each bottled water provider, at least five samples from five different water bottles be collected and analysed (DFAIT, 2007).

5.5.2 Trucked (hauled) water

Remote locations, or those that do not have easy access to a reliable drinking water source, may have to rely on drinking water hauled to the site. No federal regulations relate to hauling potable water. Some provinces/territories have specific requirements for trucked water, and the guidance in this document is based mainly on these guidelines/standards. Hauled water to be used as a drinking water supply must meet the GCDWQ. The original source of the hauled water should be a water system whose treatment provides a disinfectant residual before being delivered to the truck (ADI Ltd., 2002a).

The sanitary condition of the transportation equipment is very important. The tank or container used to carry potable water and pumps, hoses, and other equipment used in the supply or delivery of the potable water should be maintained and operated in a clean and sanitary condition (Province of Alberta, 2003), and must be free of contaminants. The tank/container must not be used to transport other materials likely to contaminate that water (e.g., milk) (ADI Ltd., 2002a; Ministère du Développement durable, de l'Environnement et des Parcs du Québec, 2005), and must not have been used previously to transport a noxious, hazardous or toxic substance. The container should be constructed of materials that meet NSF/ANSI Standard 61 NSF, 2012b), and should allow easy access for cleaning. The tank/container used to transport the water should be disinfected on at least a weekly basis. When the container is filled or emptied, precautions must be in place to prevent backflow or back siphonage (e.g., through an air gap or double check valve assembly).

For information on disinfection of water storage containers, see the AWWA C650 series of manuals.

The outlet connections at filling points must be constructed and protected so contaminants cannot enter the water supply and so their nozzles are kept free of ice build-up during the winter. These inlets should be closed except when filling or cleaning the tank. Receiving tanks or cisterns should also be maintained in a clean and sanitary condition and should not be used for any other purpose (ADI Ltd., 2002a; Quebec Ministry of Environment, 2005). Receiving tanks or cisterns must be cleaned and disinfected before they are put into use and when the system or any of its parts are dismantled for repair, maintenance or replacement. Cisterns should be monitored for bacteriological parameters at least four times per year (Health Canada, 2007).

A disinfectant residual of at least 1.0 mg/L of total chlorine or 0.2 mg/L free chlorine should be present in the water at the time of delivery. The quantity of free chlorine residual should be measured once per day, in a water sample collected at the outlet of the tank truck. All data should be recorded in a register containing the data and results of the measurements and the name of the person who took them (ADI Ltd., 2002a; Quebec Ministry of Environment, 2005).

For an example of guidelines for ensuring the safety of trucked water, see the Quebec government's regulations in this area.

6.0 Operational requirements

Federal departments and First Nations may benefit from the use of a quality management framework to manage their drinking water systems. A framework can help in coordinating existing or new operational activities, setting priorities and making decisions. It can provide a mechanism to identify and manage risks, apply and introduce measures for prevention, and achieve continuous improvement.

6.1 Operational plans

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

Operational plans should be specific to each individual drinking water system, and prepared for each drinking water system or facility. Generic plans could be developed at a departmental level for office buildings serviced by municipal water. For leased buildings and/or office space, the department would need to negotiate with the other party to determine who is responsible for developing the plan. This responsibility should be clearly laid out in the lease. The operational plan for each facility should include detailed guidance or instructions related to monitoring, as well as for reporting and record-keeping. It should be developed in consultation with the system designer. In addition, operational plans should include:

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

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

6.2 Training and certification

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

Management should support initial and on-going training and provide a training budget. Federal departments and First Nations communities should provide opportunities for their operators to participate in approved training. Many well-recognized training programs are available for drinking water treatment operators. Training sessions can range in rigour from educational seminars to certification courses with written examinations.

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

All operators are encouraged to participate in on-going training in an organized, continuing education setting by qualified instructors. This training may include formal classroom training, conferences, online and interactive presentations, seminars or hands-on workshops or training sessions. It can include training on new or revised operating procedures, reviews of existing operating processes, safety training, computer training and/or training in related environmental or technical areas (DND, 2007).

In the case of less complex treatment systems (i.e., a liquid chlorinator with no further treatment), operators may participate in system-specific training which would provide a site-specific equivalent to a certification for this role only. Such a certificate would not be recognized as valid at other facilities. It is especially important for operators of very small systems to meet one another and develop network contacts amongst their peers. These relationships can facilitate the use of best practices and encourage continuous improvement (ADI Ltd., 2002b).

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

6.3 Monitoring

Monitoring the treated water helps assess the effectiveness of the treatment and determine the presence and concentration of disinfection by-products. Operational monitoring will help ensure the plant is operated effectively, while compliance monitoring ensures the water leaving the plant and distribution system meets the established requirements, typically the GCDWQ. Sampling at various points in the distribution system indicates the quality of water reaching consumers at the tap and identifies problems which may arise due to faults with the distribution system (Health Canada, 2001; CDW and CCME, 2002). Specific guidance regarding monitoring frequencies, locations, and the interpretation of results is found throughout Chapter 4.

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

6.3.1 Operational monitoring

Operational monitoring practices focus on critical control points in the drinking water system to ensure the system is being operated as required. This type of monitoring allows the operator to detect changes in water quality and adjust the treatment process accordingly. In addition, increased monitoring during extreme conditions yields important information on the ability of the system to cope, and helps identify required improvements. Where feasible, continuous monitoring at plants is recommended for some parameters (e.g., chlorine residual, turbidity). Tests for operational monitoring do not need to go to an accredited lab.

Operational monitoring strategies should:

• be system-specific;
• be developed in the operational plan;
• facilitate more comprehensive documentation of the system; and
• foster due diligence.

6.3.2 Compliance monitoring

Compliance monitoring ensures drinking water reaching consumers meets established requirements. Every facility will need to develop its monitoring program based on the results of the vulnerabilities assessment, sanitary survey and baseline chemical analysis as discussed in Chapter 3. In addition, many federal departments and First Nations communities have their own documents and/or directives that provide guidance on monitoring frequency and related monitoring issues. The guidance in this document is meant to complement existing protocols.

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

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

Collection and preservation of any other samples should follow procedures (collection, preservation, storage and shipment) recommended by the accredited laboratory analysing the samples.

6.3.3 Laboratory accreditation

Accreditation is the best mechanism to provide assurance to customers on the quality and competence of the laboratory. When testing and analysing water samples (with the possible exception of E. coli and total coliforms under the conditions outlined below), federal departments or, in the case of First Nations communities, managers and operators of facilities and technical support personnel, should use a laboratory accredited by one of the following: Canadian Association for Laboratory Accreditation (CALA), the Standards Council of Canada (SCC) or, in Quebec, the Bureau de normalisation du Québec (BNQ). Accreditation is awarded to a laboratory for each individual test (e.g., the analysis of pesticides in drinking water). A list of SCC accredited labs is available on-line.

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

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

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

6.4 Operation of groundwater systems

Operating a groundwater system consists mainly of taking necessary measurements, maintaining yield, and preventing contamination. In general, wells should be pumped within specific pumping rates. When there is more than one well, they should be operated in rotation, if possible, to equalize wear on pumping equipment. If specified pumping rates are exceeded, sand and silt may pack in and around the well screen and clog it or may fill the voids in gravel-wall wells, reducing yield. Frequent starting and stopping of a well pump causes agitation in the aquifer around the well and may wash out sand or gravel, causing clogging or cave-ins that will reduce the yield. Any requirement for altering pump operation methods can be determined from well performance records and the quality of water produced (DND, 2007).

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

6.5 Records and record-keeping

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

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

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

All records, including "as built" construction records, should be maintained. Records related to policy and procedures must be retained for a minimum of five years and all other "routine" records must be maintained for two years (Library and Archives Canada, 2007). Records to be kept include:

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

6.6 Incident and emergency response plans

Federal purveyors of drinking water and, in First Nations communities, Chief and Council, should prepare and maintain written emergency and incident response plans to deal with events which occur outside of normal operating conditions. Such plans should also identify potential events. The water purveyor's response and remediation strategy will depend on the type of event affecting the water system (ADI Ltd., 2002b). Events that should be considered include extreme or unusual weather events, natural disasters, unplanned human activities, line breaks, valve replacements, or extended electrical power outages.

To address cases of a suspected/confirmed event of microbiological contamination (see Chapter 4), the plan should include the possibility that a boil water advisory may need to be issued. For extreme events where a significant chemical/radiological contamination has or is expected to occur, drinking water avoidance advisories may be issued. Details about boil water advisories and drinking water avoidance advisories are given in Box 6.1.

Incident response protocols should be established with the understanding that notification and reporting should be compatible with existing provincial / territorial approaches. These reporting relationships should be established well in advance and are fundamental to public health protection and due diligence. This type of integrated information sharing is typically the trigger for implementing appropriate response and keeps all agencies properly informed whether the incident originates at a federal facility or municipal supply.

One of the tools available to drinking water purveyors is a real time, Web-based alert and reporting system for drinking water advisories. It was developed collaboratively between Health Canada and the Public Health Agency of Canada (PHAC), and is a component of the Canadian Network of Public Health Intelligence (CNPHI), an interactive, web-based platform created by PHAC. The drinking water advisories module provides a means of real-time notification and information sharing regarding drinking water advisories. It is now available for use by agencies across Canada at no cost. See appendix G for further information.

Box 6.1: Incident response: Drinking water advisories

6.7 Compliance verification and reporting

Compliance verification and reporting activities are an essential part of any quality management approach. They provide an opportunity to evaluate performance related to each component of the federal framework identified in this document. They can also serve to identify issues and determine appropriate corrective measures in a timely fashion.

Such a process should be undertaken on a regular basis, to ensure the safety of drinking water is maintained through the risk management activities described in this document, and to be able to report on any progress or concerns.

In addition to routine compliance verification and reporting activities, internal or external audits should be undertaken at regular intervals (e.g., every five years) to ensure that:

• Policies and procedures are current and are being implemented as intended;
• A process for continuous improvement supports drinking water activities; and
• Responsible authorities can demonstrate at the headquarters, regional or site level how they meet the requirements and expectations outlined in this document.

An audit or verification is normally completed in three phases:

1. Planning: The objective of the pre-audit planning is to define the scope of the audit and identify specific activities to be conducted as part of the audit. The pre-audit file review should generate a list of items to be verified, and a list of questions or lines of inquiry. Activities may include a combination of interviews with managers or operational personnel and a review of documents such as engineering studies, monitoring records, policies or procedures.
2. Conducting the audit/verification: This process should be collaborative, transparent and non-adversarial, explain the scope and goals, provide an opportunity to raise questions and concerns, and allow reasonable flexibility in terms of timelines. It should follow the established scope and lines of inquiry to verify that observed operational activities and procedures are consistent with written policies and procedures, and identify inconsistencies as a deficiency. These should be brought to the attention of the appropriate personnel, together with a discussion of suggested corrective measures, prior to writing the final report.
3. Final reporting: The final report should include the timelines of the process, the scope, verification goals and lines of inquiry, the names and titles of participants, the findings of the process, as well as recommended corrective measures and timelines to address identified deficiencies.

6.7.1 Site level compliance verification

This level of audit activity is aimed to verify that operations and procedures at a given site are implemented as intended by the responsible authority. Site level verification goals will generally seek to confirm that the drinking water system is operated and managed in a manner consistent with the site operational plan and that issues have been documented and resolved with appropriate and timely corrective measures. This verification should confirm that aspects of drinking water management described throughout this document are being maintained in a manner appropriate to site characteristics.

Section 6.5 on records and record-keeping provides an overview of the types of documentation that should be maintained at the site. Auditors will want to confirm that site records are present and accurately reflect operations. This can be facilitated by making observations on-site, or by interviewing site personnel, for example.

As a general guide, lines of inquiry for the site level compliance verification may seek to confirm that:

• The operational plan is maintained and accessible;
• An appropriate vulnerabilities assessment has been carried out and is sufficiently current;
• The drinking water system design remains relevant and offers acceptable performance;
• Sanitary surveys have been completed with appropriate frequency and related preventive maintenance has been carried out;
• Monitoring activities and related corrective measures are carried out as required;
• An incident or emergency response plan is in place and properly maintained;
• Site personnel have received training appropriate to their roles; and
• Recommendations from previous compliance verifications have been addressed.

6.7.2 Corporate roll up

Findings and recommendations developed at the site levels should be rolled up at the corporate level. This allows departments to maintain a global understanding of the state of their drinking water systems and related priorities and to help inform responsible authorities to focus improvements in areas of greatest benefits, either to a specific site or to address departmental-wide gaps or issues (e.g., training, equipment upgrades).

Verification goals at the corporate level may seek to confirm that organizational drinking water policies and procedures are being implemented consistently across their sites and that progress on addressing broader organizational priorities can be demonstrated and evaluated.

6.7.3 Core federal reporting on drinking water management

Core reporting is important to ensure transparency at the federal level, and to allow departments to respond consistently to requests for compliance information from central agencies, the Commissioner of the Environment and Sustainable Development (CESD, Office of the Auditor General of Canada), senior management or the Canadian public. Core reporting should reflect the main activities that comprise drinking water risk management.

Core reporting will allow the federal government to demonstrate due diligence at the jurisdictional level, characterize priority areas and contribute to federal, provincial, territorial drinking water protection initiatives. The most important outcome of federal core reporting to agencies such as CESD will be an improved understanding of key risks and vulnerabilities across all areas of federal responsibility, which in turn will help central agencies to make informed decisions around funding and other resource priorities.

Based on Chapter 4 of the 2005 CESD Report, Safety of Drinking Water: Federal Responsibilities, core federal reporting should reflect how drinking water related risks are assessed and managed. Reporting should incorporate the following information:

• Water source (municipally supplied, surface or groundwater);
• Size and location of water treatment systems (accessible or remote);
• Water treatment system design and performance (disinfection, filtration);
• Distribution system design and status (age, condition, complexity); and
• Operational requirements (monitoring, testing, maintenance and training).

7.0 Information and resources

A number of federal programs and documents exist to support departments in carrying out their duties related to drinking water issues.

7.1 Health Canada

CDW and GCDWQ

Health Canada's Water and Air Quality Bureau plays a key role in the safety of drinking water by working with the provinces and territories, through the CDW, to establish the GCDWQ. The GCDWQ are used by every jurisdiction in Canada as the basis for their own enforceable drinking water quality requirements.

The role of the Water and Air Quality Bureau is one of scientific expertise and leadership. Following the priorities established by the CDW, it leads the development of health risk assessments for drinking water contaminants. These assessments can be presented either as guideline technical documents or as guidance documents. All these documents undergo public consultations.

All current documents, including the guideline Summary Table, guideline technical documents and guidance documents are available.

Guideline technical documents

Guideline technical documents present the scientific and technical information that forms the basis for the establishment of a numerical guideline. They are developed for contaminants that meet all of the following criteria:

• Exposure to the contaminant could lead to adverse health effects;
• The contaminant is frequently detected or could be expected to be found in a large number of drinking water supplies throughout Canada; and
• The contaminant is detected, or could be expected to be detected, at a level that is of possible health significance.

The process remains flexible. Guideline technical documents may be developed for some parameters which do not meet all criteria (e.g., chlorine, ammonia), at the request of the CDW.

Guidance documents

The role of the CDW has evolved over the years, and new methodologies and approaches have led the CDW to develop a new type of document—guidance documents—to provide advice and guidance on issues related to drinking water quality for parameters that do not require a formal drinking water guideline.

If a contaminant of interest does not meet all the criteria for developing a guideline technical document, the CDW may choose to develop a guidance document. The CDW may choose to develop guidance documents in two instances. The first would be to provide operational or management guidance related to specific drinking water related issues (such as boil water advisories), in which case the documents would provide only limited scientific information or health risk assessment. The second instance would be to make risk assessment information available when a guideline is not deemed necessary.

Guidance documents undergo a similar development process to guideline technical documents, including public consultations through the Health Canada website. They are offered as information for drinking water authorities and, in some cases, to help provide guidance in spill or other emergency situations.

Federal role

The Bureau also plays a coordinating role at the federal level, to help ensure a consistent federal approach to drinking water quality. It provides the secretariat function and scientific expertise to the IWGDW, coordinating the update and publication of this federal guidance document.

Other activities

In order to help ensure the quality of drinking water nationally, and thereby protecting public health, the Bureau:

• Shares expertise and scientific advice with other government departments and organizations interested in drinking water issues, and with the public;
• Conducts scientific health assessments related to the GCDWQ;
• Participates in the development of standards for materials that come into contact with drinking water; and
• Provides advice and assists in emergencies such as chemical spills, on request.

Drinking water guidance values

Health Canada can develop a drinking water guidance value (DWGV) at the request of a federal department, a province, or territory, usually as a result of a spill or unexpected contamination. It is not based on thorough research of all existing studies; rather, it is developed for use within the department or government that has made the request. A DWGV is based on the scientific information available at the time of the request.

DWGVs are not subject to a review as detailed as the GCDWQ, which undergo internal peer review and public consultation before approval by the CDW and subsequent approval by the Federal-Provincial-Territorial Committee on Health and the Environment.

7.2 Interdepartmental Water Quality Training Board

The Training Board has focused its efforts in developing and disseminating training tools aimed at very small and micro-systems, filing a documented gap in resources and tools. This has been possible through the amalgamation of resources and expertise from all members. In recognition of this amazing collaboration between federal departments, the Training Board received in 2013 the Public Service Award of Excellence in the area of innovation.

The Training Board has developed the following documents and videos, which are all available in English, French and Spanish:

• Safe Drinking Water – Your Responsibility
• Water Sampling in Federal Facilities
• Ultraviolet & Reverse Osmosis for Micro-Systems
• Drinking Water Storage Tanks
• Bottled Water: Selection & Application in Federal Facilities
• Water Wells for Micro-Systems
• Water Filtration and Ion Exchange for Micro-Systems
• Disinfection for Micro-Systems
• Advice for the Operation of Potable Water Field Test Equipment
• Water Quality 101: Potable Water Micro-System Fundamentals (a course consisting of 10 modules and a supporting workbook, which may count as a half-credit in some certification programs).
• The training materials from the Training Board are publically available through the Walkerton Clean Water Centre.

7.3 InfraGuide

InfraGuide operated from 2001 to 2007 as a partnership between the Federation of Canadian Municipalities, the National Research Council and Infrastructure Canada. The program developed a series of how-to manuals, which address innovations and best practices related to drinking water quality, including treatment and distribution systems. Further information.

8.0 References

• ADI Ltd (2002a). First Nations water and sewer infrastructure standards and regulations study.
• ADI Ltd (2002b). Technical document - Guidance for safe drinking water in Canada: drinking water quality management. Contract for Health Canada.
• AWWA (2000). The drinking water dictionary. Edited by J.M. Symons, L.C. Bradley, Jr., T.C. Cleveland.
• Canada Customs and Revenue Agency (2002). Well assessment form. Personal communication from B. Gray.
• CDW and CCME (2002). From source to tap: The multi-barrier approach to safe drinking water. Federal-Provincial-Territorial Committee on Drinking Water and Canadian Council of Ministers of the Environment.
• CDW and CCME (2004). From source to tap : Guidance on the multi-barrier approach to safe drinking water. Federal-Provincial-Territorial Committee on Drinking Water and Canadian Council of Ministers of the Environment.
• DFAIT (2007). Drinking water guidelines for Canadian diplomatic missions abroad. Drinking Water Management System. Department of Foreign Affairs and International Trade. August. O/Ref.:033-P005073-0101-000-EN-001-00
• DND (2007). Canadian forces construction engineering technical order C-98-15W-002/MG-010- Water Supply and Distribution Systems - Operations and Maintenance - Part 3, para 1 (page 3-1). Department of National Defence.
• GOC (2008). Drinking water awareness program. Module 1 - Canada Labour Code and Due Diligence. Government of Canada.
• Health Canada (2001). Guidance for safe drinking water in Canada: From intake to tap. Federal-Provincial-Territorial Committee on Drinking Water.
• Health Canada (2007). Procedure manual for safe drinking water in First Nations communities south of 60o. First Nations and Inuit Health Branch.
• Health Canada (2008). What's in your well? A guide to well water treatment and maintenance. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario.
• Health Canada (2009a). Guidance for issuing and rescinding boil water advisories. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario.
• Health Canada (2009b). Guidance for issuing and rescinding drinking water avoidance advisories in emergency situations. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario.
• Health Canada (2009c). Guidelines for Canadian drinking water quality: Guideline technical document — Chlorine. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario. (Catalogue No. H128-1/09-588E).
• Health Canada (2012a). Guidelines for Canadian drinking water quality: Guideline technical document — Escherichia coli. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario.
• Health Canada (2012b). Guidelines for Canadian drinking water quality: Guideline technical document — Total coliforms. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario.
• Health Canada (2012c). Guidance on the use of heterotrophic plate counts in Canadian drinking water supplies. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario (Catalogue No. H144-6/2013E-PDF).
• Health Canada (2013). Guidelines for Canadian drinking water quality: Guideline technical document — Turbidity. Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada, Ottawa, Ontario.
• Holden, R. (2001). Drinking water due diligence framework on federal lands. Occupational Health and Safety Agency, Health Canada.
• Library and Archives Canada (2007). Retention guidelines for common administrative records of the Government of Canada. Section 1, Part 1, Section 2. https://www.collectionscanada.gc.ca/obj/007002/f2/007002-3000.1-e.pdf 
• Malcolm Pirnie Inc. and HDR Engineering Inc. (1990). Guidance manual for compliance with the filtration and disinfection requirements for public water systems using surface water sources. Prepared for Science and Technology Branch, Criteria and Standards Division, Office of Drinking Water, U.S. EPA, Washington, D.C., Contract # 68-01-6989, Section K, Sanitary Survey. October. https://www.epa.gov/sites/production/files/2015-10/documents/guidance_manual_for_compliance_with_the_filtration_and_disinfection_requirements.pdf
• NJC (2011). Occupational health and safety directive. National Joint Council. January. http://www.njc-cnm.gc.ca/directive/oshd-dsst/index-eng.php
• InfraGuide (2002). Best practices: deterioration and inspection of water distribution systems. From: National guide to sustainable municipal infrastructure - innovations and best practices. September. http://www.fcm.ca/Documents/reports/Infraguide/Deterioration_and_Inspection_of_Water_Distribution_Systems_EN.pdf
• NRC (2010). National Plumbing Code of Canada 2010. National Research Council of Canada, Ottawa, Ontario. http://www.nrc-cnrc.gc.ca/eng/publications/codes_centre/2010_national_plumbing_code.html
• NSF (2008). Survey of ASDWA members use of NSF standards and ETV reports. http://www.nsf.org/business/water_distribution/pdf/ASDWA_Survey.pdf
• NSF (2012a). NSF/ANSI Standard 60 -- Drinking water treatment chemicals-health effects
• NSF (2012b). NSF/ANSI Standard 61 -- Drinking water system components-health effects
• U.S. EPA (2003). Cross-connection control manual. Office of Water, U.S. Environmental Protection Agency (EPA816-R-03-002). http://water.epa.gov/infrastructure/drinkingwater/pws/crossconnectioncontrol/crossconnectioncontrol_manual.cfm

9.0 Relevant legislation and policies

9.1 Titles

• Canada Labour Code. R.S. 1985, c. L-2. Part II: Occupational Health and Safety, ss. 125(1)(j) and 125(1)(z.11).
• Canada Occupational Health and Safety Regulations. SOR/86-304, Part IX - Sanitation. s. 9.24 - 9.29.
• Aviation Occupational Safety and Health Regulations. SOR/2011-87, Part IV - Sanitation. s.4.9 - 4.12.
• Maritime Occupational Health and Safety Regulations. SOR/2010-120, Part 4 – Sanitation. s.73-79.
• On-Board Trains Occupational Safety and Health Regulations. SOR/95-105, Part VI - Sanitation. ss. 6.9 - 6.24.
• Oil and Gas Occupational Safety and Health Regulations. SOR/87-612. Part X - Sanitation. s. 10.19.

Corrections and Conditional Release Act

• Corrections and Conditional Release Regulations (SOR/92-620) Section 83 (1) - Living Conditions.

Food and Drugs Act (R.S.C., 1985, c. F-27)

• Food and Drug Regulations (C.R.C., c. 870), Division 12, Prepackaged Water and Ice,.

National Joint Council Occupational Health and Safety Directive

• National Joint Council Occupational Health and Safety Directive

9.2 Excerpts

Excerpts of relevant texts are provided below, for information. It is important to note that these excerpts are included for information only and that the reader should refer to the official version.

Canada Labour Code

Part II -- Occupational Health and Safety

• 125. (1) Without restricting the generality of section 124, every employer shall, in respect of every work place controlled by the employer and, in respect of every work activity carried out by an employee in a work place that is not controlled by the employer, to the extent that the employer controls the activity,
  • (j) provide, in accordance with prescribed standards, potable water;
  • (z.11) provide to the policy committee, if any, and to the work place committee or the health and safety representative, a copy of any report on hazards in the work place, including an assessment of those hazards;

Canada Occupational Health and Safety Regulations (SOR/86-304)

• 9.24 Every employer shall provide potable water for drinking, personal washing and food preparation that meets the standards set out in the Guidelines for Canadian Drinking Water Quality 1978, published by authority of the Minister of National Health and Welfare.
• 9.25 Where it is necessary to transport water for drinking, personal washing or food preparation, only sanitary portable water containers shall be used.
• 9.26 Where a portable storage container for drinking water is used,
  1. the container shall be securely covered and closed;
  2. the container shall be used only for the purpose of storing potable water;
  3. the container shall not be stored in a toilet room; and
  4. the water shall be drawn from the container by
     1. a tap,
     2. a ladle used only for the purpose of drawing water from the container, or
     3. any other means that precludes the contamination of the water.
• 9.27 Except where drinking water is supplied by a drinking fountain, sanitary single-use drinking cups shall be provided.
• 9.28 Any ice that is added to drinking water or used for the contact refrigeration of foodstuffs shall
  1. be made from potable water; and
  2. be so stored and handled as to prevent contamination.
• 9.29 Where drinking water is supplied by a drinking fountain, the fountain shall meet the standards set out in ARI Standard 1010-82, Standard for Drinking-Fountains and Self-Contained, Mechanically-Refrigerated Drinking-Water Coolers, dated 1982.

Aviation Occupational Safety and Health Regulations (SOR/2011-87)

• 4.10
  1. Every employer shall ensure that employees are provided with potable water in sufficient quantity for drinking, personal washing and food preparation.
  2. The potable water shall meet the microbiological quality guidelines set out in the Guidelines for Canadian Drinking Water Quality, prepared by the Federal-Provincial-Territorial Committee on Drinking Water and published by the Department of Health.
• 4.11 If a portable storage container for potable water is used,
  1. the container shall be equipped with an airtight cover that can be securely closed;
  2. the container shall be used only for the purpose of storing potable water;
  3. the container shall not be stored in a washroom; and
  4. the water shall be drawn from the container by a tap, a ladle used only for the purpose of drawing water from the container or any other means that precludes the contamination of the water.
• 4.12 If potable water is not supplied by a drinking fountain the employer shall provide sanitary single-use drinking cups or bottled water.
• 4.13 Any ice that is added to potable water or used for the contact refrigeration of foodstuffs shall be
  1. made from potable water; and
  2. stored and handled in a manner that prevents contamination.

Maritime Occupational Health and Safety Regulations (SOR/2010-120)

• 73.
  1. Every employer must ensure that employees are provided with potable water for drinking, personal washing and food preparation.
  2. The potable water must
     1. be in sufficient quantity to meet the purposes set out in subsection (1); and
     2. meet the quality guidelines set out in the most recent edition of Guidelines for Canadian Drinking Water Quality, prepared by the Federal-Provincial-Territorial Committee on Drinking Water and published by the Department of Health.
  3. Potable water for drinking must be available at all times for the use of every employee working on the vessel.
• 74.
  1. Every employer must develop a potable water management program that sets out the testing procedures and frequency and the measures to be taken to prevent contamination.
  2. The potable water management program must be made readily available for inspection.
• 75.
  1. Every vessel of 300 gross tonnage or more that is not a day vessel must have on board a supply of water that is available for all wash basins, tubs and showers and is sufficient to provide at least 68 l of water for each employee on the vessel for each day that the employee spends on that vessel.
  2. A day vessel must have on board at least 22.7 l of water for each employee on the vessel for each day that the employee spends on that vessel.
• 76. If it is necessary to transport water for drinking, personal washing or food preparation, only sanitary portable water containers must be used.
• 77. If a portable storage container for drinking water is used,
  1. the container must be securely closed;
  2. the container must be used only for storing potable water;
  3. the container must not be stored in a sanitary facility; and
  4. the water must be drawn from the container by
     1. a tap,
     2. a ladle used only for the purpose of drawing water from the container, or
     3. any other means that precludes the contamination of the water.
• 78. Any ice that is added to drinking water or used for the contact refrigeration of foodstuffs must be made from potable water, and stored and handled so as to prevent contamination.
• 79. If drinking water is supplied by a drinking fountain,
  1. the fountain must meet the standards set out in the Air-Conditioning and Refrigeration Institute (ARI) of the United States ARI 1010-2002, Self-Contained, Mechanically-Refrigerated Drinking-Water Coolers; and
  2. the fountain must not be installed in a sanitary facility.

On Board Trains Occupational Safety and Health Regulations (SOR/87-184)

• 6.19
  1. Subject to subsection (2), every employer shall provide employees with potable water for drinking, personal washing and food preparation that meets the standards set out in the publication entitled Guidelines for Canadian Drinking Water Quality, 1978, as amended in March 1990, published under the authority of the Minister of National Health and Welfare.
  2. An employer is not required to provide potable water for personal washing if waterless hand cleaning supplies are provided.
• 6.20 Where it is necessary to transport water for drinking, personal washing or food preparation, only sanitary portable water containers shall be used.
• 6.21 Where a portable storage container for drinking water is used,
  1. the container shall be securely covered and closed;
  2. the container shall be used only for the purpose of storing potable water;
  3. the container shall not be stored in a toilet room; and
  4. where the container is not a single-use storage container, water shall be drawn from it by
     1. a tap,
     2. a ladle used only for the purpose of drawing water from the container, or
     3. any other means that precludes the contamination of the water.
• 6.22 Except where drinking water is supplied by a drinking fountain or a single-use portable storage container, sanitary single-use drinking cups shall be provided.
• 6.23 Any ice that is added to drinking water or used for the contact refrigeration of foodstuffs shall be
  1. made from potable water; and
  2. stored and handled in a manner that prevents contamination.
• 6.24 Where drinking water is supplied by a drinking fountain, the fountain shall meet the standards set out in ARI Standard 1010-82, Standard for Drinking-Fountains and Self-Contained, Mechanically-Refrigerated Drinking-Water Coolers, dated 1982.

Oil and Gas Occupational Safety and Health Regulations (SOR/87-612)

• 10.19 Every employer shall provide potable water for drinking, personal washing and food preparation that meets the standards set out in the Guidelines for Canadian Drinking Water Quality, 1978, published by authority of the Minister of National Health and Welfare.
• 10.20 Where water is transported for drinking, personal washing or food preparation, only sanitary water containers shall be used.
• 10.21 Where a storage container for drinking water is used,
  1. the container shall be securely covered and labelled that it contains potable water;
  2. the container shall be used only for the purpose of storing potable water; and
  3. the water shall be drawn from the container by
     1. a tap,
     2. a ladle used only for the purpose of drawing water from the container, or
     3. any other means that precludes the contamination of the water.
• 10.22 Except where drinking water is supplied by a drinking fountain, sanitary single-use drinking cups shall be provided.
• 10.23 Any ice that is added to drinking water or used for the contact refrigeration of foodstuffs shall
  1. be made from potable water; and
  2. be so stored and handled as to prevent contamination.
• 10.24 Where drinking water is supplied by a drinking fountain, the fountain shall meet the standards set out in ARI Standard 1010-82, Standard for Drinking-Fountains and Self-Contained, Mechanically-Refrigerated Drinking-Water Coolers, dated 1982.

Occupational Health and Safety Directive

This directive, hosted by the National Joint Council, was co-developed by participating bargaining agents and public service employers.

Part IX – Sanitation of the Directive enhances and supplements Part IX (Sanitation) of the Canada Occupational Health and Safety Regulations (SOR/86-304) and should be read in that context.

Scope: This part applies in all government-owned buildings. However, where employees occupy buildings not owned by the federal government, this part shall apply to the maximum extent that is reasonably practicable.

• 9.2 Care of Premises
  • 9.2.3 With the advice of a qualified person and in consultation with the appropriate health and safety committee, departments shall establish contingency procedures for cases in which there is a temporary interruption in the supply of drinking water or to the water used to remove water-borne waste.
• 9.4 Water Quality
  • 9.4.1 The employer will adhere, as a minimum, to the Guidelines for Canadian Drinking Water Quality, or to any other federally, provincially or territorially appropriate standards and any existing guidelines that provide the higher level of protection to workers.
• 9.4.2 Any storage container for drinking water shall be disinfected in a manner approved by a qualified person at least once a week while in use, and before the container is used following storage.
• 9.4.3 A fountain supplying drinking water shall not be installed in a personal service room containing a toilet.

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