By Stanley Rayfield and Lydia Newman
Imagine this – your organisation has had minor plumbing works carried out. The first job included repairing a waste pipe behind a WC and the second was an alteration to a cold tap at the tea point.
The same hacksaw was used, but the plumber had limited understanding of the water supply regulations and as a result, introduced the bug E.coli into drinking water supply.
Issues such as disinfection, flushing and correct selection of water fittings are critical to reduce the risk of contamination and to control the growth of legionella.
What might seem a simple mistake may have severe and long lasting consequences – it’s a disturbing point to note but many defects that lead to bacteria growth in water systems such as Legionella are often introduced by the plumber at either design or installation stage.
Your ISO 14001 consultant will be able to advise when the Water Supply Regulations 1999 should be included within your organisation’s compliance obligations register. For organisations that have responsibilities to control the growth of legionella in particular, it is difficult to fulfil those responsibilities without understanding, and carrying out internal auditing of how the water supply regulations have been applied.
The regulations are a national requirement for the design, installation, and maintenance of plumbing systems. They have been put in place for the purpose of ensuring the contamination of drinking water is prevented and the efficient usage of water is optimised.
When did they come into force?
Although there is often a lack of awareness amongst installers, the Regulations came into force on the 1st of July 1999, and Scotland followed with Byelaws on the 4th of April 2000. All stages of plumbing systems, water fittings and water-using appliances are accounted for, from design stage, through to installation and maintenance.
Internal audits
An ISO 14001 internal audit of the water supply regulations focuses strongly on both competence and risk category. During the audit it will be determined which works may have triggered requirements under these regulations and objective evidence sought that the correct arrangements or type of device for water system have been put in place. The regulations use Fluid Risk Categories which are defined by contaminants in water flow, often as a consequence of backflow, where the water direction can oppose the designed flow.
Who has to comply?
The regulations place a legal duty on users, owners or occupiers and anyone who installs plumbing systems. If your organisation hires someone, using a member of a water Industry Approved Plumbers’ Scheme (WIAPS) will give peace of mind that all will be executed correctly. It should be noted that a plumber that has WIAPS membership and a traditional plumber are often found not to be the same thing and as a result, will have demonstrated different levels of competence.
Water fitting regulations do not apply to premises that do not have a public water supply connection.
Which type of work require consent?
Some works have requirements of consent needed before the works can begin. Consent must be given via water undertakers before work is carried out on the following:
“ 1. The erection of any new building or structure
2. The extension or alteration of the water system in any premises except a domestic dwelling.
3. The material change in use of any premises
4. The installation of:
(a) A bath larger than 230 litres (measured to the centre of the overflow);
(b) A bidet with an ascending spray or flexible hose;
(c) A shower unit of a type specified by the Regulator (none are currently specified);
(d) A pump or booster drawing more than 12 litres per minute;
(e) A reverse osmosis unit;
(f) A water treatment unit producing a waste water discharge or requiring water for regeneration or cleaning;
(g) A reduced pressure zone (RPZ) valve or other mechanical device for protection against backflow in fluid category 4 or 5;
(h) A garden watering system unless designed to be hand- operated;
(i) Any water system laid outside a building and either less than 750mm or more than 1350mm below ground level;
5. Construction of an automatically-replenished pond or swimming pool of more than 10,000 litres. “
Be aware that in Scotland and Northern Island there are additional types of work that require notification.
However, The Water Fitting Regulations do not cover wastewater pipework such as from bidets, sinks, WCs, showers, washbasins and baths, and requirements should be alternatively found in building regulations documentation instead.
What are the fluid risk categories?
There are five fluid risk categories with the regulations. Plumbing fittings that are used for each fluid category are typically WRAS rated and meet the requirements of each category:
Fluid category 1
Wholesome water supplied by a water undertaker and complying with the requirements of water regulations
Fluid category 2
Water in fluid category 1 whose aesthetic quality is impaired owing to–
(a)a change in its temperature, or
(b)the presence of substances or organisms causing a change in its taste, odour or appearance,
including water in a hot water distribution system.
Fluid category 3
Fluid which represents a slight health hazard because of the concentration of substances of low toxicity, including any fluid which contains–
(a)ethylene glycol, copper sulphate solution or similar chemical additives, or
(b)sodium hypochlorite (chloros and common disinfectants).
Fluid category 4
Fluid which represents a significant health hazard because of the concentration of toxic substances, including any fluid which contains–
(a)chemical, carcinogenic substances or pesticides (including insecticides and herbicides), or
(b)environmental organisms of potential health significance.
Fluid category 5
Fluid represents a serious health hazard because of the concentration of pathogenic organisms, radioactive or very toxic substances, including any fluid which contains–
(a)faecal material or other human waste;
(b)butchery or other animal waste; or
(c)pathogens from any other source.
It is a criminal offence to contravene the regulations?
If regulations are breached then offenders may be prosecuted as it is a criminal offence, consequences may include a fine and a criminal record.
To avoid this, if water undertakers identify that any regulations have been neglected, then amendments must be made as soon as practically possible. Furthermore, if regulations are not complied with and threaten the health of users, or water is being adversely wasted, then an immediate disconnection of water supply to the premises may occur. If you do not receive consent within 10 working days of your Notice, then one must assume permission has been granted.
Before purchasing a fitting or appliance, be confident that it is suitable. Selling unsuitable items is legal, but installing one would not be. Appropriate standards for water fixtures and materials can be found in the regulations and WRAS provides a list of a variety of current items that conform to requirements if installed and used properly.
