General
Under the Private Water Supplies Regulations 2016 the District Council has a duty to ensure that the location of all private water supplies is recorded, and those that serve commercial businesses or more than one domestic property are monitored to ensure that they are of sufficiently high quality to protect the health of consumers.
Water supplies not provided by the public water supply (mains water) can be from a borehole, spring, well or originate from ground run-off. Each supply requires its own unique protection and treatment. Those supplies which fall within the scope of the regulations are risk assessed and improvements recommended. If there is a risk to public health improvements will be enforced in accordance with the Regulations.
To check the effectiveness of any protection or treatment on the supply, a programme of sampling is carried out in accordance with the Regulations and the results of the risk assessment. Both bacteriological and chemical parameters are tested to monitor if the supply complies with standards laid out in the Regulations.
The District Council also has a duty to risk assess and monitor private distribution systems where mains water is provided to the boundary of a site and then distributed to buildings within that site. This includes caravan and camping sites.
Fees
The charges associated with sampling, risk assessments and any investigations are set annually by the District Council in accordance with the Regulations.
Risk assessment for both Regulation 9 and 10 supplies - £465.80
Desktop risk assessment of well managed supplies - £193.60
Sampling visit and administration - £63.60
Investigation - £102.05
Granting an authorisation - £48.30
Analysing a sample under regulation 10 - Laboratory charge
Analysing of Group A parameters - Laboratory charge
Analysing of group B parameters - Laboratory charge
The District Council is happy to advise anyone who has, or is planning to have, a private water supply on how best to protect their supply, sample the water for quality and advise how best to plan any treatment that may be needed to ensure the safety of the drinking water.
Food business
Environmental Health has a programme of risk assessments and reviews under the Private Water Supply Regulations 2016 "the Regulations" for all private water supplies serving commercial businesses or more than one domestic property.
Regulation (EC) No. 852/2004
Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs lays down specific rules regarding water supplies utilised by food businesses. Chapter 7, 1(a) in particular states that: 'There is to be an adequate supply of potable water, which is to be used whenever necessary to ensure that foodstuffs are not contaminated'. 'Potable water' means, in this instance, water meeting the minimum requirements laid down in Council Directive 98/83/EC (as amended by Regulation (EC) No. 1882/2003) on the quality of water intended for human consumption.
Failure to assure a consistent safe supply of water could potentially pose a risk to health not only via consumption, but indirectly via contaminated foodstuffs.
Food Safety Management System
Any documented food safety management system should include the necessary control measures, monitoring procedures, contingency plans etc. for a private water supply.
Any documented HACCP (hazard analysis critical control point) based system should include an assessment of the necessary control measures, monitoring procedures (e.g. daily checks that the treatment is fully functional), contingency plans etc. to ensure a consistent, safe supply of water is provided as part of the food operation.
Water Safety Plan (WSP)
A water safety plan considers the risks to a private water supply, the treatment facilities, the distribution infrastructure including pipes, reservoirs or tanks, and the internal pipe work within premises, and measures to prevent or control contamination from 'catchment to tap'. One of the key elements of a water safety plan is the identification of the hazards and the risks associated with those hazards. This element is described as a 'risk assessment' and is undertaken by the District Council on a five yearly cycle.
We recommend that a WSP includes:
- The risk assessment report/letter
- Site plan
- Details of water treatment and maintenance schedule
- Checks and Maintenance records
- Sampling results
- List of contact details for servicing/repair
- Emergency procedure in the event of a sampling failure or loss of supply
It is not mandatory to have a WSP, but it is strongly recommended that a food business with a private water supply has one. If a food business does not have a WSP which includes an emergency procedure in the event of a sampling failure, there should be a similar document in the Food Safety Management System.
Sampling frequency
A food business on a supply shared with dwelling houses or another business will not always be sampled as part of the sampling programme implemented following a risk assessment, as sampling can be undertaken at different outlets on the supply. A food business may, therefore, wish to undertake additional sampling.
Treatment at a food business
Standard recommendation for microbiological treatment is:
- A pre-filter (UV will not work well if there is particulate matter in the water)
- UV treatment
- Failsafe system (An audible or visual alarm and a shut off valve that prevents water entering the system if the UV treatment is not functioning.)
A food business should seek professional advice from a Water Consultant regarding the most appropriate chemical and biological treatment for their business.
Risk assessments
Under the Private Water Supplies Regulations 2016, local authorities have a duty to carry out risk assessments on all private water supplies other than those that supply single, non-commercial premises. The risk assessment aims to identify actual or potential causes of contamination so that suitable actions can be taken to prevent or control problems, and to ensure that the quality of the drinking water is as good as it can be.
A risk assessment is a useful exercise for anyone on a private water supply to do, not just those people who have a supply for multiple dwellings or commercial premises and are therefore required to have a risk assessment undertaken. An action plan of improvements is drawn up as necessary, and the results help dictate how often and for what parameters future sampling is carried out. The District Council will charge for this report. Details on how costs are apportioned between different outlets on a supply are detailed in our document Apportioning costs 2018
Undertaking a risk assessment is a statutory duty on all but single domestic supplies and must be done every five years. High risk supplies will be fully risk assessed again and charged.
Private Distribution Systems
The Regulations also require risk assessments to be carried out on private distribution systems. Where water originally supplied by a water undertaker (e.g. Severn Trent Water) to the boundary of a property is then further distributed through a private distribution network to buildings/properties on the site. For example, a caravan or camping site could be a private distribution system. The risk assessment will dictate a programme of sampling of the system.
Sampling
The Private Water Supplies Regulations 2016 require that the Local Authority monitor all private water supplies in its area in accordance with the size of the supply, its use and any risk assessment that has been carried out. The District Council does not have to routinely monitor supplies to single dwellings unless requested to do so by the home owner.
Supplies are categorised as large, small or single dwellings. Large supplies that serve either over 50 persons, or where the water is used for a commercial activity or to supply a public premises have two types of monitoring. Check monitoring is undertaken frequently for a few important parameters, and audit monitoring that is undertaken infrequently for any other relevant parameters. The frequency of sampling is in relation to the volume of water used and the risk assessment for the supply. Details on how costs are apportioned between different outlets is detailed in our Apportioning costs 2018 policy.
Small supplies that serve less than 50 persons and are used only for domestic purposes require limited monitoring at least once every 5 years, and more frequently if the risk assessment highlights particular problems until the problems have been addressed and the supply categorised as low risk.
Examples of biological parameters tested are Escherichia coli (E. coli), coliforms, enterococci and Clostridium perfringens. Examples of chemical parameters tested are hydrogen iron (pH), turbidity, aluminium, iron, manganese and arsenic.
The purpose of sampling is to determine compliance with The Private Water Supplies Regulations 2016, and to monitor the effectiveness of any treatment or disinfection of the water. Sampling also helps to determine the effectiveness of any control measures on the supply network and that these are working satisfactorily.
Any failures on the supply need to be investigated and if necessary a Notice served on the relevant person requiring prohibition or restriction to ensure the safety of consumers, who will be kept informed and given advice.
Further information on private water supplies is available on the Central Government private water supplies website and from the Drinking Water Inspectorate.
Treatment
It is recommended that all private water supplies have some form of water treatment, especially if the supply is used for a commercial business that involves supplying food or drink to members of the public. To ensure that the correct treatment is installed it is recommended the person responsible for the supply consults a water treatment consultant who has good knowledge and experience of dealing with private supplies.
An initial assessment of the water quality needs to be undertaken; this can be as a result of the District Council carrying out a risk assessment and routine sampling of the supply under The Private Water Supplies Regulations 2016.
From the results of testing it can be seen what, if any, chemical treatment needs to be installed. It is recommended that on all spring supplies biological treatment is installed as a matter of course as spring water can change with rainfall levels and throughout the seasons. Bacteria such as E Coli and coliforms can be treated successfully by installing the correct equipment, which will eradicate any contamination. It is recommended that this is done by a suitably qualified or experienced water consultant who can install the correct equipment to match the flow and use of the supply. The consultant should also check if the pressure on the supply is sufficient to serve its purpose and recommend what equipment needs to be installed to ensure a steady flow of water.
If you would like any further advice please contact Environmental Health.
