Directives: small drinking water systems
A “directive” is a document that outlines the operational requirements that must be carried out by the owner or operator of a small drinking water system. It is issued by a public health inspector on completion of a site-specific risk assessment or other inspection process.
Public health inspectors inspect small drinking water systems to ensure owners and operators of small drinking water systems comply with their directive and Ontario Regulation 319 (Small Drinking Water Systems) at all times.
Public Health Sudbury & Districts publicly discloses a summary report on each routine and complaint based inspection, and drinking water advisories of small drinking water systems. Reports are posted for four years. Inspection reports and drinking water advisories can be accessed by visiting our disclosure website, Check Before You Go!
How do public health inspectors know what operational requirements are necessary for your small drinking water system?
Since there are many types of small drinking water systems, a public health inspector will conduct a site-specific risk assessment of your system to determine potential risks to users associated with its operation. This is done by:
- using a risk categorization (RCat) tool to identify and assess potential risks to users
- applying a multi-barrier approach to determine any potential risk that may affect the safety of the drinking water if left uncorrected
Following the site-specific risk assessment, basic operating requirements are set to assist you to adequately maintain and supervise the provision of drinking water to your users. These operating requirements will be provided to you as a written “directive” that specifically applies to your small drinking water system. The items listed in the directive are in addition to the requirements listed in Ontario Regulation 319/08 – Small Drinking Water Systems.
How is the risk level of a small drinking water system categorized?
A risk categorization (RCat) tool was developed by the Ministry of Health and Long-Term Care (MOHLTC) for site-specific risk assessments of small drinking water systems. This tool assesses all parts of the system, from source water to water available at the tap, by applying the steps of a multi-barrier approach to protect drinking water.
At the end of the risk assessment, your small drinking water system will be assigned one of the following risk categories for the system as a whole:
- high = significant level of risk
- moderate = medium level of risk
- low = negligible level of risk
What are some of the actions or requirements that are included in a directive?
Your public health inspector will issue a directive which may have components related to:
- the need for treatment and treatment equipment
- your water sampling and testing frequency, location, and method
- the types of samples to be taken
- operational checks
- record maintenance
- posting of warning signs
- training requirements for owner/operators
See below for more details.
Provision of treatment and treatment equipment
Ontario Regulation 319/08 – Small Drinking Water Systems requires that water be treated if the system gets water from a raw water supply that is surface water (for example, lakes, rivers, or streams).
Your directive may have additional components that require you to install treatment equipment on the small drinking water system that may include any combination of the following:
- filtration
- primary disinfection
- secondary disinfection
Sampling and testing frequency, location and method of sampling
Ontario Regulation 319/08 – Small Drinking Water Systems requires that as the operator of a small drinking water system you must sample and test your water at a minimum frequency through a laboratory licensed by the Ministry of the Environment, Conservation and Parks. The public health inspector will consider other factors to determine any additional sampling and testing that may be required. Factors include:
- risks identified by the RCat tool during the site-specific risk assessment of your system
- the provision of treatment to your system
- the protection of the source of water or distribution system
Depending on the inspection findings, the public health inspector’s directive may establish:
- your sampling frequency, which may vary depending on the risks and complexity of your system
- the location(s) in the drinking water system from which samples must be collected (for example at the tap or in the distribution system)
- the sampling techniques to use (for example, a grab sample or continuous monitoring for testing of chlorine residual)
Refer to Sampling, Monitoring and Testing Requirements for advice on maintenance and proper water sampling techniques.
Types of samples to be taken
All small drinking water system owners or operators will be required to collect samples for the following microbiological agents: Escherichia coli (E.coli) and total coliforms. Based on the site-specific risk assessments, some owners or operators may also be required to collect samples and test the water for other parameters, such as:
- chemical (fluoride, lead, or nitrate)
- radiological contaminants (uranium)
- any other parameters (viruses, parasites, or specific chemicals)
Performance of operational checks
The directive may also require you to perform specific operational tests. For example, you may be required to:
- conduct turbidity tests
- measure disinfectant levels
Record maintenance
The public health inspector may require that you maintain records of operational and maintenance tests and related issues for your small drinking water system. For example, you may be required to maintain records of:
- test results for microbiological (E.coli), chemical (nitrate) or radiological (uranium) parameters
- free available chlorine residual readings for primary and/or secondary disinfection
- turbidity levels
- equipment failures
- corrective actions taken to respond to any adverse test results or adverse observations
Posting of warning signs
In certain cases, a small drinking water system may be allowed to post warning signs advising the public not to consume the water. The directive will specify the location of these warning signs. Posting is only permitted if access to the water system is sufficiently restricted, and the risk to the users of the system is acceptable.
Training requirements for owners or operators
As the owner or operator of a small drinking water system, you should be trained in the operation of the system for which you are responsible. The public health inspector will determine whether the type of training you have is appropriate and may recommend that you obtain additional training.
What can you do if you disagree with the requirements issued in a directive?
After you have been issued a directive or an amendment to a directive, you have 7 days to request a review by the Medical Officer of Health (MOH). If you have a disagreement about the requirements issued in a directive, you should first discuss the matter with your public health inspector. If you are not satisfied with the outcome of this consultation, then the small drinking water system owner may request a review in writing to the local MOH. The request must include the following:
- the portions of the directive or the amendment to a directive that you want to be reviewed;
- any submission that you would like the MOH to consider in the review; and
- a current mailing address so the MOH can provide you with their decision.
If you are considering seeking a review, you should refer to Ontario Regulation 319 – Small Drinking Water Systems for the complete details of the review process.
Requests for review must be sent to the Medical Officer of Health directly. The request must be made in writing and filed, by way of personal service, service by fax or service by pre-paid registered mail on the medical officer of health.
What happens to the directive if ownership changes?
If the small drinking water system transfers in ownership, it must be noted that the directive is site-specific and therefore belongs to the site. The new owner should contact Public Health Sudbury & Districts and advise a public health inspector of the change in ownership.
Remember, if you are uncertain of what actions to take, immediately contact Public Health Sudbury & Districts and speak with a public health inspector at 705.522.9200, ext. 464 (toll-free 1.866.522.9200).
This item was last modified on August 27, 2018