1. Regulatory Perspective on Development of
Water Safety
Conference 2010
Regulatory Perspective on Development of
Piped Drinking Water Safety Plan
in Singapore
Good morning everyone, I'd like to start by introducing myself. My name is Lam Chun Hsiang. I am from the National Environment Agency in Singapore. Today I would like to share with you our experiences on the development of piped drinking water safety plan in Singapore.
Lam Chun Hsiang
Drinking Water Unit (DWU)
National Environment Agency, Singapore

2. New Regulatory Framework Water Safety Plans
Background
Singapore, Regulatory Authorities, Water Suppliers
New Regulatory Framework
Objectives, Technical Committee, Regulations, Legislative Requirements
Water Safety Plans
Preparation of Plans, Framework for Monitoring and Assessment
The presentation is divided into 4parts. What I would like to do first is to provide some background information on the regulatory framework in Singapore, before moving on the preparation of the plans and finally to talk about our experiences encountered with the suppliers on the development of the plans.
Challenges and Learning Points

3. Background: Singapore
Population: ~ 5 million
Mean daily temp: ~ 26.8 °C
Mean annual rainfall: ~ 2300 mm
High humidity: ~ 84%
With a land area of 707 km2, Singapore has a population of around 5 million. On average, we receive about 2300mm of rain annually.

4. Background: Regulatory authorities
Ministry of the Environment and Water Resources
PUB
National water authority
National Environment Agency
Environmental / Public health authority
Ministry
Statutory boards
Role
The National Environment Agency is the public health and environment protection authority in Singapore. Along with PUB, we report directly to the Ministry of the Environment and Water Resources.

5. Background : Water Suppliers
The major supplier of piped drinking water in Singapore is PUB. The smaller water suppliers are mainly located on the off shore islands.
Off-shore islands
Land Area = 707 km2

6. Background : Water Suppliers
PUB: Major supplier in Singapore
Small suppliers: Usually supply
< 1000 m3 of water per day
(Employ traditional or desalination
technology)
The smaller suppliers cater mainly to transient customers. For example, campers who are there for less than a week and or visiotrs who are there for less than a day. These supplier usually produce water in small-scale batches ……maybe <1000m3 of water per day..

7. New Regulatory Framework Water Safety Plans
Background
Singapore, Regulatory Authorities, Water Suppliers
New Regulatory Framework
Objectives, Technical Committee, Regulations, Legislative Requirements
Water Safety Plans
Preparation of Plans, Framework for Monitoring and Assessment
In line with Singapore’s move towards water sustainability, the government decided to introduce new regulations to regulate the quality of piped drinking water.
Challenges and Learning points

8. New Regulatory Framework
Objectives
Need to establish a common set of standards for piped drinking water suppliers
b)Inculcate preventive risk management practices amongst piped drinking water suppliers
New regulations were needed so as to provide a common set of standards for the piped drinking water suppliers to comply with. Specific requirements had to be included within the regulations so as to promote preventive risk management practices among the suppliers.

9. New Regulatory framework
Technical Committee on National Drinking Water Quality Standards
Formed to advise NEA on drinking water quality standards and related issues.
Consists of 11 local and 2 overseas experts
NEA, PUB, MOH, AVA
Educational Institutions - NUS, NTU
Prof. Michael Rouse from UK
Dr. Joseph Cotruvo from USA
Expertise of committee lends credence to standards for both the industry as well as the public
In the early stages of developing the framework, a Technical Committee was formed to review the international standards and to develop national standards for subsequent adoption by NEA. The Committee includes local experts from various organizations such as the Ministry of Health and the National University of Singapore . These selected members cover various fields including water research, medicine, communicable diseases, microbiology, food safety and environmental law, amongst others. We are also very pleased to have 2 two overseas experts on our committee Prof Michael Rouse, and Dr Joseph Cotruvo.
Even after the development of the national standards, the Committee has continued to serve as NEA’s advisors on various issues (identifying emerging trends and provide independent assessments on water quality issues). They have been instrumental in building up NEA’s capabilities as an independent regulator of drinking water quality

10. Environmental Public Health (Quality of Piped Drinking Water)
New Regulatory Framework
Environmental Public Health
(Quality of Piped Drinking Water)
Regulations
2008
With their help, the Environmental Public Health (Quality of Piped Drinking Water) Regulations were introduced and came into operation on August 2008.
Available for download from NEA’s website:

11. New Regulatory Framework
Legislative requirements
a) Compliance with the water quality standards
b) Preparation of water safety and sampling plans & periodic review
c) Approval of these plans by NEA
Under the Regulations, our supplier would have to –
Comply with the standards set out in the Schedule
They would have to prepare and submit a water safety and sampling plans for approval before they are allowed to supply water.
Based on the approved sampling plan, the supplier would then have to monitor and submit the test results to us.
If portable test kits are being used for monitoring purposes, suppliers must ensure that the test kits be well maintained and checked for accuracy.
Water suppliers are required to keep records of the results relating to any chemical parameter for a minimum period of 10 years from the date of the test.
d) Monitoring of water quality and submission of test results to NEA
e) Calibration and maintenance of test equipment
f) 24-hour notification
g) Documentation and record keeping

12. New Regulatory Framework Water Safety Plans
Background
Singapore, Regulatory Authorities, Water Suppliers
New Regulatory Framework
Objectives, Technical Committee, Regulations, Legislative Requirements
Water Safety Plans
Preparation of Plans, Framework for Monitoring and Assessment
the smaller water suppliers especially had found it challenging to prepare the water safety plans.
Challenges and Learning Points

13. Water Safety Plans Preparation of water safety plans
a) Code of Practice on Piped Drinking Water Safety and Sampling plans
Available for download from NEA’s website at:
b) Templates for preparation of water safety plans

14. Water Safety Plans Key components of water safety plans
Based on WHO Guidelines:
Formation of Water Safety Team
Documentation of the system
Hazard assessment and risk characterization
Sanitary inspection of the raw water/supply
Control measures and operational monitoring
Management procedures
According to WHO guidelines, the key components of the water safety plans are –
Formation of the water safety team
Documentation of the system
Hazard assessment and risk characterization
Sanitary inspection
Control measures and operation monitoring
And management procedures
DWU worked with suppliers’ internal departments, consultant(s) and contractor(s). We would engaged with them in the thinking process where we go step by step , ensuring that the take into account
Raw water source
Site-specific conditions
Type of the water treatment processes employed
Etc.

15. Water Safety Plans
Provides a basis for preparation of water sampling plans
WSP provide a basis for the preparation of water sampling plans

16. Water Safety Plans Framework for monitoring and assessment
Desktop Audit
Water safety and sampling plans
> 100,000 test results per year
Results are checked for compliance with regulatory standards and water safety and sampling plans
Site Inspections
Check if water safety plans are being implemented
Identify risk /shortcomings and make suggestions for improvement
As part of the framework for monitoring, suppliers are required to submit the test results report to us every month. And we would review the results for compliance with the regulatory standards.
We would conduct periodic sites inspections at the water treatment plant to ensure that the water safety plans are being implemented. We would also identify areas which we think can be improved and would advise the suppliers accordingly.

17. New Regulatory Framework Water Safety Plans
Background
Singapore, Regulatory Authorities, Water Suppliers
New Regulatory Framework
Objectives, Technical Committee, Regulations, Legislative Requirements
Water Safety Plans
Preparation of Plans, Framework for Monitoring and Assessment
Moving on to the last portion of my presentation, I would like to talk about our experiences that we had encountered while enforcing our piped drinking water regulations.
Challenges and Learning points

18. Challenges and Learning Points
Main challenge:
To ensure that all relevant hazards are identified, and their risk characterization is carried out in a meaningful way to establish the high-risk scenarios.
One of the main challenges that my unit faced while reviewing the plans for approval was to identify the relevant hazards and the risk characterization.
WE realized that if was important for us to built up our expertise and to carry out comprehensive review of the WSPs to ensure that certain risks are not overlooked. .

19. Challenges and Learning Points
Certain members in the water safety team may choose to have a greater flexibility in highlighting the hazard, resulting in conflict of view between members on the extent of risk.
May make generic statements such as “All applicable parameters should be controlled to prevent the hazard”, without specifying the type of the parameters and their degree of control
One of the things we have noticed is that the supplier is familiar with the ISO9001 system, they may not be able to fully address the various hazards in the WSP as the approach is different. .

20. Challenges and Learning Points
May choose not to highlight certain hazards, thinking that the regulatory agency may raise questions on the control of those hazards.
May document inadequate or even erroneous description of the hazards, especially those who are not academically inclined .
When the members of the water safety team are aware that the plans are actually regulatory documents, they would try not to highlight certain hazards or even try to downplay them because they did not want us to question them further on their operational issues.
Some members would try to make generic statements in the safety plan. And again, this would risk making the process a paper exercise and would not benefit anyone.
That being said, there were some suppliers who are not academically inclined or have the technical expertise…so they are not aware of the hazards or understand the extent of the consequences of such hazards.

21. Challenges and Learning Points
How various challenges were addressed:
DWU built up the necessary expertise
Reviewed the draft plans prepared by the suppliers
Discussed the details with the WSP team members
Conducted site audits
Revised the plans where required, before seeking the management approval
To built up our expertise, we tried to find actual cases/studies
With regards to the water safety team, it was important to include key staffs who are involved in day to day operations. Not only that they should also have the authority to implement the upgrading initiative, identified during the preparation of the water safety plan. Because if we do not include these people in the initial stages while drafting the plan, the preparation of the plans would risk becoming just a paper exercise and would not have helped the suppliers like it was intended to.

22. Challenges and Learning Points
Lessons learnt:
If the requirement for preparation of water safety is not prescribed under the regulations-
Suppliers may not invest their efforts and time in preparing such plans; and
even if they do, the plans may not be adequate in substance.
On hindsight, while working with the suppliers to develop the plans, we realized that it was crucial to include the requirement to prepare the plans within the regulations. As mentioned earlier, we had spent a lot of effort in working together with the suppliers  making multiple visits to the sites  discussing with them what should and should not be included within the plans.  If the requirement was not stated in the regulations, most likely the suppliers would not have spent their time and efforts to develop such plans.

23. Challenges and Learning Points
Lessons learnt:
Even though water suppliers’ staff may be familiar with ISO 9001 system, they may not be able to adequately address various hazards in the WSP due to the difference in methodology used to identify and characterize the hazards.
On hindsight, while working with the suppliers to develop the plans, we realized that it was crucial to include the requirement to prepare the plans within the regulations. As mentioned earlier, we had spent a lot of effort in working together with the suppliers  making multiple visits to the sites  discussing with them what should and should not be included within the plans.  If the requirement was not stated in the regulations, most likely the suppliers would not have spent their time and efforts to develop such plans.

24. Conclusion Legislation and Code of Practice Administrative controls
Singapore’s Approach
Legislation and Code of Practice
Administrative controls
Communication
with suppliers
Risk-based management system

25. “
With the new regulatory regime in place, Singapore’s growing population will continue to enjoy safe piped drinking water

26. Mr. Ramnath Vaidyanathan
Co-authors
Dr. Pranav S. Joshi
Mr. Ramnath Vaidyanathan
Mr. S. Satish Appoo

27. www.nea.gov.sg E-mail Topics – Drinking Water Unit
For more details
Topics – Drinking Water Unit

28. Thank you