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FOREWORD
• It provides a framework upon which inspections of
Adoption of a risk assessment and risk management WSP activities can be implemented;
approach will contribute to water suppliers meeting
their requirements to consistently ensure the • It provides a robust approach to ensure that all
wholesomeness and acceptability of drinking water water company risk assessments carried out
supplies. Drinking water suppliers are obliged to use against Regulation 9 and Regulation 27 of the
BS EN 15975-2:2013 (Security of drinking water Regulations can be used as a basis to justify a risk
supply - Guidelines for risk and crisis management, based approach to sampling frequency. The
Part 2: Risk management) as their specification for the regulatory reporting requirements for WSP are
assessment and management of risks associated with included in Regulation 28 (Regulations 28 and 29
the security of drinking water supplies. respectively in Wales) of the Regulations.
The approach described within BS EN 15975-2:2013 The references provided were current at the time of
is consistent with the Water Safety Plan (WSP) writing this Water Industry Specification.
approach advocated by the World Health Organisation
(WHO Water Safety Plan manual (WSP manual): Compliance with this specification does not itself
Step-by-step risk management for drinking-water confer immunity from legal obligations.
suppliers). It also aligns with the requirements of the
current Water Supply (Water Quality) Regulations This specification does not purport to include all the
2016 (and equivalent regulations in Wales). necessary provisions of a contract. Users of this
specification are responsible for its correct application.
Note that BS EN 15975-2:2013 consists of two parts. Reference to a British Standard, Water Industry
This specification relates exclusively to Part 2: Risk Specification or any other specification applies equally
management. Part 1: Crisis management is outside to any equivalent specification. It refers only to
the scope of this specification. technical suitability and does not absolve the user
from legal obligations relating to health and safety at
This specification has been prepared by the Water UK any stage.
Task and Finish Group for Risk Assessment
Certification under the direction of the Water UK An inspection process to ensure compliance with this
Standards Board and it addresses the following specification will be performed by a UKAS accredited
objectives: certification Inspection Body meeting the requirement
of ISO/IEC 17020: 2012.
• It recognises the use of BS EN 15975-2:2013 and
aligns risk assessment and risk management It has been assumed in the drafting of this
requirements with that standard to provide specification that the execution of its provisions is
compatibility; entrusted to appropriately competent people.
• It provides additional detail regarding current UK Information contained in this specification is given in
practice in relation to WSP activities; good faith but Water UK cannot accept any
responsibility for actions taken by others as a result.
Water UK 2018
This document has been prepared on behalf of the Water UK Standards Board. Technical queries should be addressed to the Standards Board c/o The Technical
Secretary on e-mail:mikeshepherd@thamesinternet.com. For further copies please visit http://www.water.org.uk/publications/WIS-IGN.
WIS 4-01-04
March 2018: Issue 1
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This document specifies the principles of the risk The risk assessments shall:
assessment and risk management process that is
undertaken by drinking water suppliers to ensure the • Follow the principles of the WHO WSP process
integrity of the drinking water supply system. The risk and requirements of BSEN 15975-2:2013.
assessment process is undertaken from source to
consumers’ taps and includes protection of sources • Cover catchment, abstraction, treatment,
(catchment), water abstraction, treatment, storage, storage, distribution and within building plumbing
distribution and up to the consumers’ tap. systems up to the consumer’s tap.
It is based on the British Standard EN 15975-2:2013 • Include risks to be assessed for each
(hereafter referred to as the Standard), the principles hazard/hazardous event using a scoring system
of the holistic Water Safety Plans (WSP) approach of based on likelihood and consequence criteria
the World Health Organisation, the Drinking Water
Inspectorate’s water safety planning guidance • Assess risk both before and after taking into
(October 2005) and takes into account experience and consideration any control measures. The
evolution of Drinking Water Safety Plan (WSP) risk methodology shall be capable of identifying
assessments since their introduction into the UK residual risks where further mitigation measures
Water industry over 10 years ago. (additional control measures) are required.
The scope of the document is restricted to the WSP • Be documented and the summary report be
risk assessment process and governance thereof as provided to the Drinking Water Inspectorate as
required under the Regulations. Dynamic risk detailed in the Water Suppliers’ (Information
assessment processes e.g. discoloured water risk Direction) 2017.
assessments for planned and unplanned work are out
of scope of this document; they are considered as • Take into account any monitoring carried out
control measures (mitigation activities) within the WSP under Article 7(i) and Article 8 of the Water
process. Framework Directive.
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Table 1: Terms and definitions extracted from the BS EN 15975-2:2013, WHO WSP Manual and the DWI
WSP Guidance document.
The probability of an
adverse effect in an
organism, system, or (sub)
population caused under
specified circumstances by
exposure to an agent
(WHO 2004).
Failure / deviation Failure Deviation Deviation
deviation from normal operating Failure to meet a critical Failure to meet a critical
conditions characterised by its limit. limit (WHO/IWA 2009).
cause and the extent
Validation Obtain evidence, assessment Obtaining evidence that Obtaining evidence that the
and approval of the capability of the elements of the WSP elements of the Water
the current or proposed control can effectively meet the Safety Plan can effectively
measures water quality targets.
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Terms BS EN 15975-2:2013 WHO WSP Manual DWI WSP Guidance
Glossary (WHO Lexicon)
meet the water quality
targets (WHO/IWA 2009).
Verification Routine confirmation, through The application of The application of
the provision of objective methods, procedures, methods, procedures, tests
evidence, that the drinking water tests and other and other evaluations, to
supply system is delivering evaluations, to determine determine compliance with
water in accordance with the set compliance with the the Water Safety Plan
objectives and that the risk WSP, i.e. checking (WHO/IWA 2009).
management approach is whether the system is
effective delivering water of the
desired quality and
whether the WSP is
being implemented in
practice.
• Consider risks to meeting defined water quality assessment methodology and management approach
standards with regards to wholesomeness of shall be available and documented.
water to consumers.
A WSP is essentially a framework of hazard and
• Consider the multiple barrier approach and, hazardous event identification, risk assessment, risk
where practicable, control measures shall be management including; the control measures,
identified throughout all stages in the supply corrective actions/additional or enhanced control
system to mitigate risk to water quality. measures and verification with the associated
documentation for each stage in the water supply
• Be kept under continuous review. The supplier chain. This approach comprises elements shown in
shall have documented processes in place to Figure 1.
incorporate new information, changes to risk
scores and mechanisms for feeding into
Company processes for agreeing and prioritising 4.2 Interdisciplinary group for risk
actions. management approach
Due to the extent of the source to tap supply system, The responsibility for the preparation of a Company’s
it may be necessary to involve third parties in the risk WSP shall be held by a senior manager. All stages of
assessment process. Third parties should be the process require teamwork and the involvement of
encouraged to cooperate fully to ensure risks to the key stakeholders from relevant departments from
drinking water supply are adequately assessed with within the Company and in some cases from third
appropriate controls in place. The drinking water parties.
supplier is the responsible body for producing a WSP
but other organisations, for example the Environment The multi-disciplinary team will vary depending on the
Agency or catchment landowners have significant supply system but can typically include:
roles in supplying data. Engagement with third parties
shall be documented. • Operational Water Quality Scientists
• Public Health advisors
Other drivers may be incorporated into the risk • Catchment Officers
assessment process, for example, pressure. These
• Operational Network staff
service objectives are checked and audited by other
• Operational Production Staff
water industry processes.
• Maintenance Engineers
• Design Engineers
• Asset Management
4. RISK MANAGEMENT
APPROACH Although members of the WSP team are fundamental
to the process of developing the plans, there may
4.1 General often only be a limited requirement for the physical
assembling of the team. Team members shall be
competent for their role. A Drinking Water Supplier’s
A WSP is a comprehensive risk assessment and risk
specific approach to the development of the
management approach for all the steps in a water
interdisciplinary group, their respective roles and
supply chain from catchment to consumer. The risk competence required shall be documented in their
Water UK 2018
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methodology. Examples of Company structures can 4.3 Drinking water supply system description
be found in Appendix B.
A ‘Supply System’ is defined as a group of assets that
are connected from catchments through to Water
Supply Zones to indicate the transfer of water from
source to tap for a discreet area of the drinking water
supplier’s water network (Figure 2).
1.
Describe the characteristics, components and assets
of the catchment, abstraction, treatment works, supply
point, service reservoir, water supply zone and
customer property.
2.
Construct flow diagram of supply system
10.
Review according to Risk
Review Procedure
3.
Conduct hazard and hazardous event assessment and
assign likelihood and consequence scores
4.
Identify control measures
9.
Verification of DWSP
5.
Calculate Pre-Control and Post-Control risk scores
6.
8.
Establish the parameters monitored and monitoring
records Categorise risks and
summarise
7.
Review ongoing validation procedures
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WIS 4-01-04
March 2018: Issue 1
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An asset can appear in multiple supply systems which The identification of hazards and hazardous events
demonstrates the interconnectivity of the water shall include each element of the water supply system
network. The supply systems shall be uniquely (in Figure 2) where there are potential sources of
identified and contain all assets that can form part of contamination, potential for water to become
the supply system. unwholesome or where there could be a potential
significant impact on the sufficiency of supply. The
The assets referred to in the ‘Supply System’ shall be review shall identify whether the hazards identified
referenced according to the Information Direction present a risk in terms of likelihood and severity for
2017 ‘Details Table’ which is submitted to the Drinking that stage of the water supply system.
Water Inspectorate on at least an annual frequency.
Supply system descriptions may include flow charts, In order to apply for a waiver hazards must be reported
geographic representation or tables. individually. Typically a list of potential hazards might
include those parameters monitored under the
For each drinking water supplier there are several Regulations and should additionally include any
different types of WSP risk assessment to cover the specific supply system hazards identified through the
main stages of the Supply System. Additional assets risk assessment process or through previous
to those included in Figure 2, may be required to fulfil experience or knowledge. The individual company
the requirement from DWI that a risk assessment shall approach shall be documented within their
be produced for each asset, for example those methodology.
companies with bulk supply inputs or concessionary
4.5 Risk assessment
supplies.
6
All risks across all water supply systems shall be
4.5.2 Risk analysis compared, categorised and prioritised with regard to
their likely impact on the delivery of safe and
Risk analysis shall be carried out by the WSP group wholesome water to the consumers’ taps and on
as described in (Figure 2). This shall be a systematic human health. This process will help determine the
approach working through the hazards and/or risk exposure within the water supply system and
hazardous events identified at each stage of the allow for the prioritisation of control measures.
supply system.
A mechanism shall be in place to review the resulting
Each hazard or hazardous event shall be assessed for residual risks to inform priorities for where additional
likelihood of it occurring and the consequence of the control measures, or enhancements to existing control
resulting risk. This risk analysis shall score each risk measures are required. High priority risks are typically
individually to allow categorisation and prioritization for those that are deemed undesirable in terms of their
action. potential impact on human health and/or
wholesomeness. These risks often require
Risk = Likelihood x Consequence improvements to be made to the system to achieve
regulatory and/or health based targets. The
Different types of risk may require different risk improvement plan may include short, medium and/or
analysis approaches. To ensure a consistent long term measures. In addition, companies may
approach is taken the risk analysis criteria shall be consider having additional actions identified to
clearly documented in the methodology including how improve robustness or resilience of existing control
the risk is calculated. measures.
The likelihood of the hazard or hazardous event Lower priority risks will not necessarily require
occurring could be described qualitatively in terms improvement action but shall be kept under review.
such as almost certain, likely, moderately likely, The process of reassessing and prioritising risks shall
unlikely or rarely or by a quantitative scoring method take place post the validation of control measures. A
such as probability or frequency over a given consistent approach to reassessing and prioritising
timeframe which shall be documented. risks shall be maintained.
The consequences of the hazard, particularly the New risks that are identified which cannot be
potential effect on human health, and meeting health controlled effectively and could lead to risk to human
based standards or indicator parameter values shall health, should be considered under crisis
be assessed. Again this assessment could be management. This falls outside the scope of this
described qualitatively in terms such as catastrophic, document. These are subject to the requirements of
major, moderate, minor or insignificant or by a BSEN 15975-1:2013 and are audited through
quantitative or semi-quantitative scoring method. separate processes.
The risk shall then be determined by combining the
likelihood and consequence according to the drinking
water supplier methodology. 4.6 Risk control
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The effectiveness of these control measures shall be 4.6.3 Validation of risk control measures
validated against drinking water supplier and/or
industry specifications or procedures. The effectiveness of the control measures shall be
validated individually or in combination at different
stages. Validation is concerned with actively obtaining
4.6.2 Identification of risk control measures evidence that existing or new measures are suitable
to control a specific risk and to perform effectively
Control measures shall be identified at each stage of under a range of conditions. Actively obtaining
the water supply system. The multi barrier approach evidence regarding the performance of control
is applicable in many source to tap supply systems to measures can take a number of forms including both
minimise the risk to water quality. A control measure direct and indirect evidence. Examples are provided in
applied at an ‘upstream’ stage might reduce, but not Table 2.
eliminate, the risk. The risk might be further mitigated
or removed at a ‘downstream’ stage. For example, Validation data shall be reviewed periodically and
catchment management might reduce the risk of a reflected in the WSP’s risk prioritisation. The supplier
pesticide being present in the raw water, while shall ensure that earlier assumptions on the efficacy
Granular Activated Carbon treatment might remove of control measures remain valid and up to date. Risk
the pesticide such that the risk is eliminated. Risk assessments shall be reviewed as improved
control measures can be either preventative and/or knowledge is acquired (Figure 1).
reactive. Examples of control measures applicable to
each stage of the risk assessment are provided in
Appendix D.
Manufacturer validation of the process e.g. UV Industry and regulatory published guidance
disinfection validation documents
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4.6.4 Implementation of additional risk control Once corrective action has been implemented the risk
measures shall be reviewed (Figure 1).
Following the implementation of additional risk control Internal audits which form part of a quality system shall
measures, the relevant risks shall be reviewed to be used as part of the verification process of the
facilitate re-prioritisation of remaining significant risks. drinking water supplier’s WSP. The audit process
shall ensure that implementation of the risk
The details of the company’s approach to management process has been completed as
implementation of control measures shall be detailed described and is consistently applied.
in the company methodology and/or strategy.
It should be noted that the risk management cycle is
4.6.5 Operational monitoring of risk control continuous and a risk assessment process should
measures never be considered to have been completed. Both
audits and improvement reviews shall be formally fed
Risk control measures shall be monitored by the back into the WSP review process. They shall
preparation of a routine monitoring programme. This document which management measures have been
shall include what is monitored and the frequency, to verified.
check that the WSP is effective and the risks
adequately controlled.
4.8 Documentation
Monitoring may include regulatory and/or operational
sampling with a frequency applicable to the risk The drinking water supplier’s methodology for their
identified, visual inspection (physical checks), on-line WSP shall be documented.
monitoring, routine servicing and maintenance, and/or
compliance with standard operating procedures. WSP risk assessments shall be recorded
electronically so that they may be submitted in the
Procedures shall be in place to ensure that any format and frequency required by the Regulator and
deviations from expected values or observations are subject to any interim updates that meet the relevant
acted upon in a timely manner to initiate corrective triggers.
action.
Audit trails shall be in place to record changes in risk
4.6.6 Corrective action and to demonstrate that the methodology is being
followed. The documentation shall also cover the
Procedures shall be in place to identify anomalous governance of the WSP process within the drinking
situations, deviations from expected values or water supplier’s operation.
observations so that action can be taken in a timely
manner to mitigate the risk. Corrective actions shall
be documented.
Water UK 2018
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4.9 Review in the field of water policy http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSL
The WSP risk assessments for individual supply EG:2000L0060:20011216:EN:PDF Accessed 21
systems shall be kept under review to ensure that they August 2017
remain valid and fit for purpose.
Water Supply (Water Quality) Regulations (Wales)
The review process shall be specific for each drinking (2010)
water supplier WSP. The methodology shall state the http://www.dwi.gov.uk/stakeholders/legislation/wsr20
target frequency for review and set out the triggers for 10wales.pdf
an interim review. These triggers may include:
Water Supply (Water Quality) Regulations (2016)
• Changes to the supply system e.g. the http://www.legislation.gov.uk/uksi/2016/614/contents/
introduction of new sources or rezoning of water made
to bring water from a neighbouring area.
Water Supply (Water Quality) (Amendment)
• Legal and / or regulatory changes. Regulations (2016)
http://www.legislation.gov.uk/wsi/2016/410/introductio
• In response to a failure of a control measure. n/made
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APPENDIX A – GLOSSARY OF TERMS
DWI Category Classification used by the Drinking Water Inspectorate on the nature of the risk
e.g. Category A – adequately controlled.
Gross Risk Also known as uncontrolled risk or pre risk. This is the risk score (likelihood x
consequence) for a particular hazard with none of the existing control measures
taken into account.
Likelihood The probability of a hazard or a hazardous event being present or occurring,
whether defined measured or determined objectively or subjectively,
qualitatively or quantitatively, and described using general terms or
mathematically
Residual risk Also known as post control risk. This is the risk score (likelihood x consequence)
for a particular hazard with all of the existing control measures taken into
account.
Supply System Group of assets that are connected from catchments through to Water Supply
Zones to indicate the transfer of water from source to tap for a discreet area of
the drinking water supplier’s water network
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APPENDIX B – CURRENT EXAMPLES OF ESTABLISHED TEAMS WITHIN DRINKING WATER SUPPLIERS
UNDERTAKING WSPS
Managing
Director Level Sign-off of risk Director of
assessments
Water Services
INTERNAL
REVIEW
Day to day
updating of risk Catchment Production Quality
assessments
Scientists Coordinators Technicians
Example A
Example B
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APPENDIX C – EXAMPLES OF RISK MATRICES
Consequence Type
No
Compliance Aesthetic Regulatory Public Health
Detectable
Impact Impact Impact Impact
Likelihood Impact
0-1 years 5 10 15 20 25
1-3 years 4 8 12 16 20
3-10 years 3 6 9 12 15
10-30 years 2 4 6 8 10
>30 years 1 2 3 4 5
Example C
Example D
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Severity
Very low Low Moderate High Very high
Likelihood Score 1 2 3 4 5
Very low 1 1 2 3 4 5
Low 2 2 4 6 8 10
Medium 3 3 6 9 12 15
High 4 4 8 12 16 20
Very high 5 5 10 15 20 25
Definitions
Example E
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APPENDIX D – EXAMPLES OF CONTROL MEASURES
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