y now most of you are probably aware that the regulation of private drinking water systems in our industry has moved away from the Ministry of Environment and into the Ministry of Health and Long Term Care. MOE Regulation 252 has been replaced by two new regulations under the Ministry of Health, Reg. 318 and 319, which are administered by inspectors from your local health unit.
Reg. 318 came into effect late in 2008 and it simply took the old Reg. 252 and moved it to a different ministry. Whatever you were doing under 252 remained in effect, whether that was testing at the prescribed intervals with an approved lab or posting your water as untested. The change from 318 to 319 occurs when you receive a visit from a local health inspector who will conduct an assessment of your system. After the assessment, the inspector will indicate what needs to be done to remedy any shortcomings and what ongoing action, such as testing frequency and training will be needed to maintain compliance.
Many operators are wondering if their drinking water systems will require significant upgrades to comply with the new regulations, even if they were showing good test results during the time they operated under Reg. 252.
Unfortunately, the answer to that question is not always simple. The reason for this has to do with how the approach in the new regulations is very different from how MOE approached things.
The original MOE regulation that impacted our industry was Reg. 170, which is still in place for municipal waterworks and certain other systems. This regulation is very detailed and prescriptive. The approach being taken in the new regulations under the Ministry of Health is designed to be much more responsive to individual circumstances and works by trying to reduce risk to an acceptable level while controlling cost and providing flexibility. Rather than being guided by hard rules, inspectors are expected to analyze risk based on established principles and scientific knowledge.
In practice, most established principles and approaches will not change. For example, water from a properly constructed drilled well that has a history of clean test results will often not require further treatment. Surface water will generally require filtration followed by approved disinfection. These are generally accepted principles and do not change with the change of regulation.
Some other areas are not so clear at the moment. Some have asked if posting will continue to be permitted. Under the old MOE regulations, posting was to be permitted only in facilities “not served by electricity”, and a part-time generator counts as electricity. The new regulation gives health units the option of allowing posting if “the risk is acceptable”. How this will be interpreted by local health units is not clear to us at this time.
We have been asked by many operators whether chlorination will be required. The short answer is no, but the full answer is a bit more complicated. In order to understand when chlorination may be required, you need to understand the difference between primary and secondary disinfection. A given system may require either primary or secondary disinfection or both.
Sometimes one system performs both functions, but there are cases where it is advantageous to perform these two functions separately.
If the source water has a high risk of containing disease causing organisms, primary disinfection is required. Surface water, or groundwater that may become contaminated with surface water must be disinfected. This primary disinfection can be carried out by irradiating the water with ultraviolet light or by chemically treating the water with a disinfecting agent, usually chlorine. Filtration is usually required, as well, before either form of treatment.
Secondary disinfection, on the other hand, is intended to provide an additional layer of protection against re-contamination of water if a distribution system is compromised. Generally, a distribution system refers to plumbing that runs outside the building where the water supply originates that has multiple connections. The concern is that a break in one of these pipes could allow contaminants to enter the system, particularly if there is a loss of pressure.
Secondary disinfection is provided by adding chlorine so that a prescribed minimum level is maintained and can be measured at the end of the distribution piping. Some have suggested that the real value of chlorine residual in a distribution system is as an indicator rather than as an effective means of disinfection. Any contamination in the system will consume the available chlorine and cause the level to fall. The required daily chlorine testing would detect this and trigger remedial action.
Ultraviolet treatment and chlorine are both acceptable methods of primary disinfection. Where the answer becomes less clear is the issue of a “distribution system”. Under the old MOE rules, secondary disinfection was required almost any time water was distributed outside the building where the treatment equipment was located. The new guidelines suggest that chlorination should be considered for systems over 10 service connections, such as lines to individual cottages. However, this is not a hard rule, and specifics of the system could lower or raise the risk.
Many operators are under the impression that the fact that they have a distribution system means that they must use chlorine both for primary disinfection and secondary treatment. This is not necessarily the case, and several other options can be considered. Chlorination systems are typically more complex than UV disinfection and require more ongoing care and maintenance. They must also be designed to insure adequate contact time, which often results in having to install additional holding tanks. Furthermore, chlorine is not effective against Giardia and Cryptosporidium, so you are dependent on the filtration system to remove these organisms.
Because ultraviolet systems are highly effective and reliable, you could opt to use UV for primary disinfection and then add a chlorinator to inject enough chlorine to maintain the appropriate residual in the distribution system. Another option would be to disinfect with UV and request permission to post in the cabins and encourage guests to obtain treated water at the main lodge or boil water in the cabins before use. Although it is not clear at this point how health units would respond to such a request, I can see nothing in the regulation to prevent this.
Although we still have some unanswered questions about the new regulations, we believe the move of drinking water back to local health units was the correct approach. We have questions, at this point, because the approach of Reg. 319 is flexible and provides a great deal of latitude to health inspectors – unlike the old MOE regulations which were inflexible and highly prescriptive. Now we have to hope that the training and direction health units are being provided by the Ministry of Health gives inspectors the confidence to use their discretion appropriately.
This article was taken from pages 12 & 13 of NOTO's "The Outfitter" publication, Fall 2009 Issue