Tavares Group Blog

Proposed Changes to the DWQMS

Ontario’s mandated Drinking Water Quality Management Standard (DWQMS) was specifically designed and developed for Ontario drinking water systems as a result of Justice Dennis O’Connor’s Report of the Walkerton Inquiry.  As recently mentioned in our e-mail newsletter to subscribers, the Ministry of Environment and Climate Change (MOECC) has proposed revisions to the DWQMS.  While the revisions to the DWQMS are mainly administrative in nature, they also serve the purpose of clarifying existing requirements and to ensure enough consideration is given to the potential impact of climate change when assessing the risks to drinking water systems.  The proposed revisions have been highlighted below, organized by element number. Pay special attention to Elements 7 and 21, which have several new requirements.

Element 2 – Quality Management System Policy
The requirement to ensure the Quality Management System (QMS) Policy is appropriate for the size and type of subject system has been removed. 

Element 6 – Drinking-Water System
Element 6 has been revised to provide specific requirements for the Operational Plan depending if the subject system includes or does not include equipment that provides Primary or Secondary Disinfection. Additionally, if the subject system is connected to one of more other Drinking Water Systems (DWS) owned by different Owners, the Operational Plan must document which of those systems that the Subject System relies upon to ensure the provision of safe drinking water.

Element 7 – Risk Assessment
Element 7 has been updated to require the consideration of potential hazardous events and associated hazards as identified in the MOECC document Potential Hazardous Event for Municipal Residential Drinking Water Systems within the subject systems Risk Assessment.  Additionally, the requirement to verify the currency and validity of the assumption used “once a year”, has been clarified to state “once every calendar year”. Finally, terminology regarding the 36 month requirement has been changed to “ensures that the risks are assessed at least once every thirty-six months”.

Element 10 – Competencies
Only a slight editorial edit has been made to this section, resulting in PLAN b) being changed to “activities to develop and/or maintain”.

Element 12 – Communications
The proposed changes require the Operational Plan to document a procedure for communications that describes how the relevant aspects of the QMS are communicated between Top Management and “suppliers that have been identified as essential under PLAN a) of Element 13”.

Element 14 – Review and Provision of Infrastructure
Element 14 is proposed to be changed by requiring the procedure for reviewing the adequacy of infrastructure to consider the outcomes of the risk assessment (Element 8) and ensure the adequacy of infrastructure is reviewed at least once every calendar year.

Element 15 – Infrastructure Maintenance, Rehabilitation and Renewal

As proposed within this element, Operational Plans will be required to document a long term forecast of infrastructure maintenance, rehabilitation and renewal activities and ensure that it is reviewed once every calendar year.

Element 16 – Sampling, Testing and Monitoring
The changes within this section of the DWQMS are editorial in nature only, and do not alter the intent of the existing requirement.

Element 20 – Management Review
The changes within this section have been proposed to clarify the frequency at which Management Review is to take place as “once every calendar year”.

Element 21 – Continual Improvement
Quite possibly the proposed change with the most impact on the QMS and the Operational Plan, the proposed changes to the DWQMS would require Operating Authorities to develop a procedure to track and measure continual improvement of the QMS by:

a) Reviewing and considering best management practices (including those published by the MOECC) at least once every 36 months.

b) Documenting a process for identification and management of QMS Corrective actions including:

i. Investigating causes (i.e. root cause analysis)
ii. Documenting action that will be taken to correct and prevent the non-conformity from re-occurring, and
iii. Reviewing the actions to correct the non-conformity to verify that they are implemented and effective in correcting and preventing the re-occurrence of the non-conformity (i.e. verification of effectiveness)

c) Documenting processes for identifying and implementing preventive actions to eliminate the cause of potential non-conformities including:

i. Reviewing potential non-conformities to determine if preventive actions are necessary
ii. Documenting the outcome of the review, including resulting actions that will be taken to prevent non-conformities from occurring, and
iii. Reviewing the actions taken to verify that they are implemented and are effective in preventing the non-conformity.

It should be noted that the proposed changes do not state that the Operational Plan document the aforementioned, only that the Operating Authority develop, implement, and conform to it.

Next Steps
The comment period for the proposed changes closed December 24, 2015.  Stay tuned to our blog or sign-up for our Newsletter to stay up-to-date! Looking for an internal DWQMS audit or gap analysis once the new standard has been released? Contact us! Our team of certified auditors is here to help.