The Municipal Drinking Water Licence and the Drinking Water Quality Management Standard

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The Municipal Drinking Water Licence and the
Drinking Water Quality Management Standard A
New Approvals Framework for Drinking Water
Systems
Ministry of the Environment
Indra R. Prashad, P.Eng. Manager, Approvals
Licensing Safe Drinking Water Branch, Drinking
Water Management Division OWWA/OMWA Annual
Conference Blue Mountain, Collingwood May 7,
2007
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Thank You to

• The following municipalities/organizations and
  their representatives
• Dryden Barry Hardy and Ron Maylen
• Durham Bernie Kuslikis (MEA)
• Lake Huron Andrew Henry
• Machin Greg Penner
• Napanee Max Christie (OMWA), Todd Harvey and
  Meaghan Lewis
• North Middlesex Joe Adams and Sherry Maguire
• Peterborough Wayne Stiver (OWWA)
• Sudbury Brad Johns
• Toronto Patrick Newland
• Waterloo Thomas Schmidt (RPWC) and Nancy
  Kodusek
• and to the numerous stakeholders who have
  provided comments to us during this development
  period

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Program Status

• Development and Implementation of the Licensing
  Program will enable the Ministry to fulfill a
  number of recommendations from the Walkerton
  Inquiry Part II report
• The Ministry is moving forward with proclaiming
  all sections of the SDWA related to Licensing, as
  well as with a Regulation prescribing the
  mandatory submission dates for all municipalities
• The Ministry is developing comprehensive guidance
  materials along with an outreach strategy to
  assist owners/operating authorities

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Municipal Drinking Water Licence approval to
operate a municipal residential drinking-water
system
The following elements must be in place to be
issued a Licence
Financial Plan (under development)

• Drinking Water Works Permit a permit to
  establish or alter a drinking-water system will
  replace the current CofA
• Permit to Take Water requirements as outlined
  in the OWRA
• Financial Plan requirements are under
  development
• Operational Plan documents an Operating
  Authoritys Quality Management System
• Accredited Operating Authority third party
  verification that the operating authoritys
  quality management system meets the DWQMS

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The Financial Plan

• The proposed financial plan regulation and
  supporting guidance document serve as a first
  step in the governments long term strategy to
  promote financial sustainability of water systems
  
• The proposed regulation under the Safe Drinking
  Water Act (SDWA) will put in place requirements
  for all municipal residential drinking water
  systems to prepare financial plans as part of
  their municipal drinking-water licence.
• A financial plan guideline is also being prepared
  to assist municipalities in meeting their
  obligations under the proposed regulation.  It
  sets out broad principles and provides practical
  advice that may assist municipalities in moving
  toward long-term financial sustainability of
  their drinking-water systems
• In winter 2007, a working group composed of
  interested stakeholders from the water sector
  (including the OWWA and OMWA) and the
  municipal/financial sector was established to
  provide feedback to the province on this
  initiative
• MOE posted the draft Regulation and Guideline on
  the EBR on May 4th, 2007.
• Regional consultation sessions will begin mid-May
  and last until mid-June
• Contact Bev Tuazon 416-326-0468 or John Sanderson
  416-314-7991

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EBR Postings on Licensing Oct. 30/06 to Dec.
29/06

• Drinking Water Quality Management Standard
• Final version
• Proposed Prescribed Dates Regulation
• Outlines dates for submission of the Operational
  Plan and applications for a Licence and DWWP
• Proposed Directors Direction
• Provides direction for content of the Operational
  Plan and submission options for the Operational
  Plan, i.e. full or partial implementation of the
  DWQMS
• Proposed Accreditation Protocol
• Outlines the roles and responsibilities of the
  Accreditation Body, the MOE, the Owner and the
  Operating Authority
• Proposed Guidance Document
• Contains guidance on how to write an operational
  plan, how to implement a quality management
  system and provides examples of operational plans
  and procedures

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Licensing of Municipal Drinking-Water Systems
Regulation

• The program will be phased in over 18 months
  starting January 1, 2009. Extension of 6 months
  provided based on stakeholder feedback
• Large municipalities start first over two months,
  then medium municipalities moving from the
  southwest to the southeast to the north, followed
  by small municipalities (population 1,000 and
  under) in the same geographic pattern
• Submissions by the Owner to the Ministry, to
  include the Operational Plan along with
  applications for a Licence and a Drinking Water
  Works Permit
• Operating Authorities are required to separately
  submit their Operational Plan to the
  Accreditation Body to schedule a document review
  and on-site audit, depending upon the Operational
  Plan Submission option

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Director's Direction for Operational Plan
Submissions

• Once the Directors Direction is finalized
  (Summer 2007) the Owner must indicate to the
  Ministry, within six months, the option selected
  for Operational Plan submission
• Proposed Options
• Option 1 Partial Implementation 12 elements of
  the DWQMS would be documented and implemented
• Option 2 Document Review Operational Plan will
  document the planning requirements of the entire
  DWQMS. No requirement for implementation
• Option 3 Full Implementation all sections of
  the DWQMS will be documented and implemented.

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Owner and Operating Authority - Responsibilities

• OWNER
• Submit applications for a Licence and Drinking
  Water Works Permit
• Endorse and submit Operational Plan to the
  Ministry
• Develop a Financial Plan as per the prescribed
  requirements
• Ensure the system is being operated by an
  Accredited Operating Authority
• Ensure compliance with the Safe Drinking Water
  Act
• OPERATING AUTHORITY
• Work with the Owner to develop and implement the
  QMS ensure endorsement of the Operational Plan
• Submit endorsed Operational Plan to the
  Accreditation Body
• Ensure compliance with the Safe Drinking Water
  Act
• AUDITOR
• Audit the Operational Plan and the QMS to ensure
  conformance with the requirements of the Drinking
  Water Quality Management Standard
• ACCREDITATION BODY
• Accredit the Operating Authority as per the
  auditors recommendations
• Forward status of accreditation to Ministry
• MINISTRY APPROVALS COMPLIANCE
• Receive, review and approve all documentation
  relating to Safe Drinking Water Act
• Ensure compliance with all regulatory
  requirements through the Compliance program

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Things to Consider

• It is strongly recommended that owners and their
  operating authorities start the planning process
  as soon as possible
• Options 1 and 2 from the Directors Direction
  will require that two separate audits be
  completed and this must be included in the work
  plan
• Training is critical to ensure that all staff are
  aware of their responsibilities with respect to
  the DWQMS

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Things to Consider

• Program initiatives that should be included in
  any upcoming planning/budget process
• Implementation of DWQMS and Preparation of
  Operational Plans impact will depend on current
  status of management processes and procedures,
  records management, etc
• Accreditation of Operating Authority ensure
  available resources/budget for the document
  review and on-site audit

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Other Information for Owners

• The Licence will facilitate the ability of the
  Owners to meet some of the requirements of the
  Standard of Care provision
• In part, these provisions require that those
  persons with oversight responsibilities for a
  municipal drinking water system exercise a level
  of care, diligence and skill that a reasonably
  prudent person would be expected to take in a
  similar situation (s. 19, SDWA)
• These standard of care provisions will come into
  effect after the Province has issued Licences to
  all Owners

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Municipal Drinking Water Licence

• When proclaimed, if the accredited Operating
  Authority is not the Owner, then the two shall
  enter into an agreement that contains certain
  elements (s. 14, SDWA)
• Description of the system for which the operating
  authority is responsible
• Description of respective responsibilities to
  ensure conditions of the drinking water works
  permit, licence and the Act and related
  regulations are met
• Description of responsibilities in the event of a
  deficiency or if an emergency exists
• Description of the responsibilities to ensure
  that operational plans are reviewed and revised
  as appropriate and that all parties are informed
  of modifications
• This section of the SDWA will come into effect
  once Licences have been issued to all Owners

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What are typical QMS benefits?

• Provides consistency to operations and management
  to support the production of safe drinking water
• Provides procedures to reduce errors due to
  interpretation
• Improves teamwork and communications
• Facilitates community confidence in drinking
  water supply
• Helps to fulfill the needs and expectations of
  consumers

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Key Steps to becoming Accredited

• Prepare for Implementation
• Complete a Gap Analysis
• Establish the QMS and Implement
• Plan for and Conduct Internal Audits (annually)
• Plan for and Conduct Management Review (annually)
• Check and Improve QMS based on Internal Audits
  and Management Reviews
• Obtain Third-Party Accreditation
• Submit information to the Ministry and the
  Accreditation Body as required

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Accreditation of Operating Authorities

• MOE to enter into an agreement with a third-party
  organization to provide accreditation services
• Accreditation body will hire and train all
  auditors
• Qualifications will require they have familiarity
  with drinking-water systems
• Focus is on management processes and procedures
  not on the operations of the drinking-water
  system
• Auditors conformance with the Drinking Water
  Quality Management Standard
• Not a review of compliance with regulatory or
  legislative requirements

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Accreditation of Operating Authorities
Management Committee (OWWA/OMWA/Accreditation
Body/MOE)
2nd Level of Appeal
1st Level of Appeal
Accreditation Body Retains and Trains
Auditors Reviews Auditor Recommendations
Accredits Operating Authority
Operating Authority Implements Quality Management
System Develops Operational Plan
Auditors
Audit of QMS
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Audit Cycle after Start-up

• A three-year cycle, based on ISO industry
  standards
• Initiated when you receive a Certificate of
  Accreditation (Full Scope)
• Year 1 Surveillance audit
• Option being considered to have this audit as a
  desktop review only, no on-site visit required
• Year 2 Surveillance audit
• Same as above
• Year 3 Re-accreditation Audit

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Guidance Material for DWQMS and Operational Plans

• Guidance Documentation includes the following
• Part I - Guidance on how to implement the DWQMS
  and how to prepare an Operational Plan
• Part 2 - Templates on management procedures and
  processes.
• Part 3 - Model Operational Plans for various
  drinking water systems
• Note Based on stakeholder feedback from the EBR
  Registry posting of the draft materials, the
  Ministry is also developing a Quick Reference
  Guide for the DWQMS

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Proposed Outreach and Education Strategy

• Provide fact sheets, brochures and guidance
  documents to all owners and operating authorities
  Summer/Fall 2007
• Provide information on the Ministrys website
  related to the Licensing Program Summer 2007
• Undertake workshops across the Province on how to
  implement the DWQMS and how to prepare an
  Operational Plan Fall 2007
• Develop additional guidance materials as required
• Ministry is working with stakeholders to develop
  a Peer Support Program to assist municipalities,
  particularly small ones, in implementing the DWQMS

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• We would like to thank the many stakeholders that
  have provided their feedback during this
  development phase and we encourage you to
  continue participating as we move forward with
  implementation.
• Please contact Ms. Indra R. Prashad, P.Eng.
  Manager, Approvals Licensing, Safe Drinking
  Water Branch, Drinking Water Management Division
  at [phone] or indra.prashad_at_ontario.ca