Tavares Group Blog

DWQMS Version 2.0 Update

The long awaited, and much anticipated, revisions to Ontario’s Drinking Water Quality Management Standard (DWQMS) were released in early April 2017. The new DWQMS Version 2.0, in addition to the Ministry of the Environment and Climate Change’s (MOECC) Potential Hazardous Events for Municipal Residential Drinking Water Systems to Consider in the DWQMS Risk Assessment, are both available on the Environmental Registry. While some of the revisions to the Standard have been administrative, resulting in very little impact to existing Drinking Water Quality Management Systems (Drinking Water QMSs), other changes will require Operating Authorities (OAs) to take a closer look at their existing processes and make substantial adjustments. The significant changes to DWQMS Version 2.0 and insight into how they will affect your QMS have been detailed below. For more context on the DWQMS and the originally proposed changes, read our blog Proposed Changes to the DWQMS.

Significant Changes

1. Timeline-bound requirement clarification
Timeline-bound requirements within the standard have been clarified to require various activities (related to Elements 7, 14, 15 [new – see number 3 below], 19, and 20) to be completed ‘once a calendar year’. The DWQMS Version 2.0 has defined a calendar year as “a period of one year beginning and ending with the dates conventionally accepted as marking the beginning and end of a year (January 1st to December 31st).” This change to the Standard will allow for greater ease of flexibility and do away with audit findings when a timeline-bound requirement has been missed by a few weeks. However, there are potential downsides with this change. OAs could wait up to almost 24 months (in the most extreme case: January calendar-year 1 to December calendar-year 2) between performing these activities that the previous version of the Standard required to be completed every 12 months. While an OA choosing to do this would still meet the requirements of the DWQMS, implementing the QMS in this manner is not ideal. A greater lag-time in between these activities will not only increase the amount of data to be reviewed, but timely communication is essential in ensuring effectiveness of the entire QMS, especially when it comes to items such as ensuring the risk assessment is valid and current, reviewing long-term forecasts, communicating the status of the QMS with the Owner, etc. Ultimately, finding an appropriate timeline for these activities will vary from OA to OA, and will depend on variables such as risk (size and complexity of the subject system) and availability of resources (including personnel).
NOTE: Until you have upgraded to DWQMS Version 2.0, you must conform with the existing timeline requirements in DWQMS 2006.

2. MOECC Mandatory Risk Assessment Requirements
The MOECC has released a list of potential hazardous events that are required to be assessed as part of an OA’s risk assessment, dependant upon the type of drinking-water system (i.e. all systems, distribution, distribution providing secondary disinfection, treatment, and treatment using surface water). While some mandatory hazardous events/hazards are straight forward (e.g. backflow etc.), some are broad and open to interpretation. For example, ‘water supply shortfall’, ‘sustained pressure loss’, and their risk and risk mitigation strategies are heavily dependant on the OA’s interpretation of the terms ‘shortfall’ and ‘sustained’. Like all Management Systems, the DWQMS, and in this case the Potential Hazardous Events for Municipal Residential Drinking Water Systems to Consider in the DWQMS Risk Assessment, identify requirements, but do not specify how the requirements are to be implemented. OAs will have to draw on knowledge of their specific subject system to interpret these broad hazardous events and should ask themselves questions like “what do we consider a water supply shortfall” or “how could climate change impact our system in the long term?”. OAs should also be prepared to explain how they interpreted these broad hazardous events (i.e. to an auditor) and could benefit from keeping meeting minutes of their risk assessments or even documenting their interpretation in their risk assessment procedure, or the risk assessment itself.

3. Infrastructure review and long-term planning
Element 14 (Review and Provision of Infrastructure) has been revised to require OAs to update their existing infrastructure review procedures to now also include consideration of the outcomes of their risk assessment. The inclusion of climate change considerations in the mandatory risk assessment hazards now means that OAs will keep the potential risks to their system associated with climate change top of mind and, consider them in their infrastructure planning once a calendar year. Changes to Element 15 (Infrastructure Maintenance, Rehabilitation and Renewal) will see long term forecasts of major infrastructure maintenance, rehabilitation and renewal activities to be documented as part of the Operational Plan; ‘long term’ and ‘major’ are other broad terms that OAs and Owners will need to interpret. OAs are also required to review the long term forecast once a calendar year. These processes are likely already occurring through Municipal capital planning and OAs may benefit from integrating those processes within the Operational Plan, rather than duplicating information.

4. Continual Improvement
Element 21 (Continual Improvement) has by-far seen the greatest change with this revision. OAs will now be required to ‘track and measure’ continual improvement of its QMS. Processes to identify, manage, and implement corrective and preventive action are to be documented and implemented. OAs will also be required to review and consider applicable (again, another broad term the OA will need to interpret) best management practices (BMPs), including those issued by the MOECC, at least once every thirty-six months.

Next Steps

1. Perform a Gap-Analysis
Perform a gap analysis comparing your existing Drinking Water QMS and the revised DWQMS Version 2.0 to clearly pinpoint what needs to be updated.

2. Understand your transition timelines and develop a plan (including gaps, actions, timelines, and responsibilities)
The MOECC has announced that Elements 7 and 8 (Risk assessment and outcomes) will need to meet the requirements of DWQMS Version 2.0 prior to an OA’s next 36-month risk assessment. This means that if your OA is due to complete a 36 month risk assessment in 2018, it must consider the MOECC’s Potential Hazardous Events for Municipal Residential Drinking Water Systems to Consider in the DWQMS Risk Assessment. OAs will be expected to make all other changes to meet the new requirements of the Standard in time for their first audit in 2019; this includes an internal audit and management review to DWQMS 2.0! Developing a plan that identifies gaps, actions to be taken, timelines and responsibilities will keep your transition on track. Additionally, it should be noted that upgrading to DWQMS Version 2.0 will not result in an on-site audit, unless you are due for re-accreditation.

3. Keep in touch with your certification body
Transitioning to the new Standard before 2019 is an option; OAs should consult with their
accreditation body.

With MOECC and Walkerton Clean Water Center (WCWC) -hosted DWQMS training just around the corner, stay tuned to our blog for more updates on how DWQMS 2.0 will affect your drinking water system’s QMS! Since the inception of the Drinking Water Quality Management Standard (DWQMS) program, Tavares Group Consulting Inc. has conducted both off-site (systems / surveillance) and on-site (internal, initial and re-accreditation) audits for over 50 municipalities located throughout the province of Ontario, dealing with various Operating Authorities. We are also experienced in the development and delivery of Operating Authority specific DWQMS awareness training sessions and DWQMS-specific consulting services. Our variety of DWQMS services are scalable to our client’s business needs in order to support successful implementation of the QMS. To learn more about how we’ve helped Operating Authorities across Ontario, click here.