Standards play a major role in Walkerton inquiry recommendations

2002-07-16

A public inquiry investigating the contamination of Walkerton, Ontario's water system has recommended that standards and conformity assessment should play a greater role in protecting the safety of drinking water. The inquiry's report calls for standards-related improvements in several areas, including the management of municipal water systems, treatment and distribution, water quality monitoring and personnel certification.

A public inquiry investigating the contamination of Walkerton, Ontario's water system has recommended that standards and conformity assessment should play a greater role in protecting the safety of drinking water. The inquiry's report calls for standards-related improvements in several areas, including the management of municipal water systems, treatment and distribution, water quality monitoring and personnel certification.

Walkerton's municipal water system became contaminated with a deadly strain of E. coli bacteria in May 2002. As a result of the contamination, seven people died and more than 2,300 became ill. The provincial government established the public inquiry, headed by Ontario appeal court justice Dennis O'Connor (http://www.walkertoninquiry.com/commissioner/index.html), to determine the causes of the outbreak and advise how to prevent such incidents from happening in the future.

The inquiry's first report (http://www.attorneygeneral.jus.gov.on.ca/html/cad/walkertonrpt1.htm), published in January 2002, focused on the circumstances leading up to the outbreak. The second report (http://www.attorneygeneral.jus.gov.on.ca/html/cad/walkertonrpt2.htm), published in May 2002, examines how to better protect the safety of drinking water in Ontario. The second report includes 93 recommendations, several of which involve standards or conformity assessment systems. That means that the Standards Council of Canada and the National Standards System will likely be involved in their implementation.

The report calls for standards-related improvements in four principal areas.

1. The distribution system

The provincial government should encourage the federal government, working with the Standards Council of Canada and with advice from municipalities, the water industry, and other stakeholders, to develop standards for materials, including piping, valves, storage tanks, and bulk chemicals, that come into contact with drinking water.
(Recommendation 34)

The report notes that materials standards help to protect against contamination by ensuring that only materials that are known to be safe are used in water systems. It recommends using existing standards wherever possible, and developing new ones only when they're required.

If new standards are needed, the report calls for them to be developed and incorporated into building and plumbing codes through the National Research Council of Canada (NRC). The NRC already has an extensive research and development program for building codes.

2. Laboratories

The provincial government should phase in the mandatory accreditation of laboratories for all testing parameters, and all drinking water testing should be performed only by accredited facilities.
(Recommendation 41)

The Ministry of the Environment should licence and periodically inspect, as required, environmental laboratories that offer drinking water testing; as with water treatment operations, continuing accreditation should be a condition of licence.
(Recommendation 42)

The results of laboratory accreditation audits should be provided to the Ministry of the Environment and should be publicly available.
(Recommendation 43)

Accreditation is the independent verification of a laboratory's competence to carry out specific tests accurately and reliably. The Standards Council of Canada operates the Program for the Accreditation of Laboratories - Canada (PALCAN) , which has accredited more than 325 laboratories in a variety of specialty areas. Environmental laboratories, including those that test drinking water, are accredited in partnership with the Canadian Association for Environmental Analytical Laboratories (CAEAL). Justice O'Connor comments about this program in his report, saying , "I was impressed by the thoroughness of the verification process and the capacity to identify areas for improvement at individual laboratories."

In the wake of the Walkerton incident, the Ontario government began to require all laboratories performing certain tests on drinking water to be accredited by PALCAN or a recognized equivalent (http://www.ene.gov.on.ca/envision/WaterReg/WaterReg.htm). The inquiry's recommendation goes farther, calling for all water tests to require accreditation.

The report also suggests that accreditation should apply to more of the testing process than just the actual analysis, such as sample collecting and handling and the analysis of results. That's something that the International Organization for Standardization (ISO), which developed the rules underlying PALCAN's accreditation procedures, is looking into.

The inquiry report recommends that accreditation be just one element in an oversight regime that also includes licensing and possibly inspection by the provincial environment ministry.

The report calls for the results of laboratory audits to be available to the public. That's not possible under PALCAN's current rules, which treat this as confidential information. But in their testimony before the inquiry last September, Don Wilson, then the director of the Standards Council's conformity assessment branch, and Rick Wilson, CAEAL's executive director, agreed that those rules could be changed if new government regulations require this information to be reported.

3. Quality management

The provincial government should require all owners of municipal water systems, as condition of their licence (see Recommendation 71), to have an accredited operating agency, whether internal or external to the municipality.
(Recommendation 51)

Accreditation should be based on an independent audit and a periodic review by a certified accrediting body.
(Recommendation 52)

The Ministry of the Environment should initiate the development of a drinking water quality management standard for Ontario. Municipalities, the water industry, and other relevant stakeholders should be actively recruited to take part in the development of the standard. The water industry is recognized as an essential participant in this initiative.
(Recommendation 53)

(The inquiry report uses the terms "accreditation" and "certification" in reverse fashion to the way they're traditionally used in quality management circles. "Certification" or "registration" would normally be used where the word "accreditation" appears in the recommendations quoted above, and vice versa.)

According to the inquiry's first report, the Walkerton incident was caused in part by the local water utility's failure to consistently follow proper procedures for monitoring and ensuring water quality, and by the lack of effective procedures for dealing with emergencies.

That might not have been the case if the utility had had an effective quality management system in place. A quality management system is a structure for documenting and evaluating an organization's policies and procedures. Used consistently, such a system can help an organization to achieve greater consistency and improved results.

Thanks to standards such as ISO 9000, quality management has become an important aspect of trade and regulation around the world.

Recognizing the effectiveness of quality management systems, the Walkerton inquiry calls on the provincial government to make them mandatory for municipal water systems. Water systems would be required to develop a quality management system, based on a standard tailored to the needs of the water industry. That system would be audited and registered by a registration body that is in turn accredited by an accreditation body such as the Standards Council.

The report cites ISO 9000 as a general management system model, and comments on the sector specific applications that have been developed in industries such as aerospace, automobile manufacturing, and telecommunications. It recommends the development of a similar quality management framework specifically designed for the water industry.

While it doesn't specifically recommend that the water industry model be based on ISO 9000, this might be a desirable approach since consistency with ISO 9000 could simplify implementation, auditing and registration for those organizations applying it.

ISO has established a new technical committee that is planning to develop quality criteria for drinking water and wastewater treatment (ISO TC 224). The inquiry report doesn't recommend waiting for work to be completed in other jurisdictions, however, and calls for the provincial government to begin work on such as standard as soon as possible. It suggests that the development work should be managed by an "appropriate body" such as the Canadian Standards Association.

Finally, the report recommends that the development of a quality management standard by completed by the end of 2003, and that all municipal water systems have a registered quality system in place by the end of 2006. It notes, however, that these deadlines may not be realistic.

4. Personnel certification

The Ministry of the Environment should continue to require the mandatory certification of persons who perform operational work in water treatment and distribution facilities. Education, examination, and experience are essential components of ensuring competence.
(Recommendation 59)

The Standards Council is in the process of developing an accreditation program for organizations that certify people on the basis of their skills and qualifications. This program will be based on ISO/IEC 17024, General requirements for bodies operating certification schemes for persons, a new international standard, and will replace the current accreditation programs for auditor trainers and certifiers.

The new program could be applied to organizations that certify water treatment personnel, as suggested in the above recommendation.

The recommendations of the Walkerton inquiry can be expected to play a significant role in the way drinking water treatment is managed in the future, not only in Ontario, but across Canada. The inquiry's emphasis on standards and conformity assessment as solutions may lead to an increased regulatory focus on standardization, something the Standards Council has long been working to promote.