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Part 3 Section 7 : boil water advisory protocol (BWAP) Grover, Renuka; Copes, Ray; Mavinic, Don; Teschke, Kay 2012-03-01

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12 PART 3 SECTION 7 BOIL WATER ADVISORY PROTOCOL (BWAP) Authors: Renuka Grover (School of Population and Public Health, University of British Columbia), Ray Copes (Public Health Ontario), Don Mavinic (Civil Engineering, University of British Columbia) and Kay Teschke (School of Population and Public Health, University of British Columbia). With grateful thanks to Dr. Diana Allen (Simon Fraser University), Mr. Barry Boettger (BC Ministry of Health), Paul Froese (Ontario Ministry of the Environment) and Dr. Judith Isaac-Renton (BC Cen- tre for Disease Control) for their comments and input. WATER SECURITY GUIDANCE DOCUMENTW ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 3 ABSTRACT A step-by-step guide for government regulatory ocials and water suppliers involved in the decision to issue and rescind boil water advisories. This protocol is based on the thesis “Boil, Boil, Toil and Trouble: The Trouble with Boil Water Advisories in British Columbia” by Renuka Grover. The full thesis is available at: hp://hdl.handle.net/2429/33790.  4 Background: Key Issues and Context Purpose of the Protocol Intended Users Description of Protocol A Step-by-Step Guide to Applying the Protocol The Three Main Types of Public Notications Part 1: Issuing and Removing BWAs:  A GUIDE FOR GOVERNMENT REGULATORY OFFICIALS  Step 1 – Identify threat to the Drinking Water Supply that may require a BWA  Step 2 – Initiate Communication with Water Supplier and Required Personnel  Step 3 – Review Water System File and Assess Risk  Step 4 – Conduct Site Inspection  Step 5 – Consult and Communicate to Reach a Decision  Step 6 – Issue BWA  Step 7 – Conrm Issuance of BWA  Step 8 – Develop Removal Criteria  Step 9 – Keep Everyone in the Loop  Step 10 – Meet Removal Criteria  Step 11 – Rescind BWA  Step 12 – Review BWA Part 2: Issuing and Removing BWAs: A GUIDE FOR WATER SUPPLIERS  Step 1 – Identify threat to the Drinking Water Supply that may require a BWA  Step 2 – Initiate Communication with Regulatory Ocial and Required Personnel  Step 3 – Assess Risk  Step 4 – Consult and Communicate to Reach a Decision  Step 5 – Issue BWA  Step 6 – Develop Removal Criteria  Step 7 – Keep Everyone in the Loop  Step 8 – Meet Removal Criteria  Step 9 – Rescind BWA  Step 10 – Review BWA Checklists  Checklist A: Water System Risk Assessment  Checklist B: Creating the BWA Message  Checklist C: Ways to Disseminate the BWA Message  Checklist D: BWA Removal Criteria  Checklist E: Creating the BWA Removal Message Recommendations and Further Areas for Research Useful Web Links Bibliography 5 5 5 6 6 6 8 14 22 24 25 9 10 10 10 10 10 11 12 12 12 12 13 14 15 15 16 16 16 17 17 17 17 18 20 21 21 22 WATER SECURITY GUIDANCE DOCUMENT TABLE OF CONTENTS, 3.7 March 2012W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 5 BACKGROUND: KEY ISSUES AND CONTEXT Boil water advisories (BWAs) are public notications of drinking water qual- ity and are used as temporary, precautionary measures to protect the public from possible waterborne illnesses. In many Canadian jurisdictions, BWAs have been in place for months to years, leading to the concern that their use can be a substitute to the action needed for their removal. With lengthy or on-again-o-again BWAs, there is concern that the public will become com- placent and not comply with the BWA. Research on BWAs is scarce, and lile evidence is available to support practical decision-making by the two groups of key players responsible for BWA management – government regulatory of- cials and water suppliers. The decision-making process has been found to be inconsistent from one de- cision-maker to the next, both within and across regulatory authorities. BWAs are handled on a case-by-case basis for the most part. This approach has both advantages and disadvantages.  The management of each BWA case within the context of the water system’s unique circumstances allows decision-makers to consider what is likely best for the specic water system in question. Treating all water systems the same way would be a rigid approach; there needs to be some sensitivity to context. However, at present some of the diversity of approaches is not because of dif- ferences between systems but rather dierences between decision-makers. Some decision-makers issue BWAs as a precaution and others only as last resort. Some consider numerous factors before making decisions; others do not. Some have years of experience in issuing BWAs and with specic water systems; others do not. There is the potential for such personal preferences and experiences (or the lack thereo) to aect sound decision-making. Inconsistent approaches can therefore be problematic from a fairness perspec- tive.  This concern was raised in the Ombudsman’s report on drinking water in British Columbia (Oce of the Ombudsman 2008). The public should be able to rest assured that their drinking water is being managed in the best possible way, regardless of the type or size of their water system or where they live.  PURPOSE OF THE PROTOCOL Part III of this Guidance Document focuses on managing risks to water secu- rity. The purpose of this protocol is to guide the overall management of boil water advisories, by acting as an information resource and by introducing a basis for consistency. It includes steps to take and factors to consider taking into account when deciding to issue and rescind boil water advisories.  INTENDED USERS This tool is primarily intended for regulatory ocials and water suppliers in- volved in the management of boil water advisories.   W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 6 DESCRIPTION OF PROTOCOL The BWA protocol denes and describes the three main types of public noti- cations, and the circumstances in which each should be issued. It also recom- mends steps for regulatory ocials and water suppliers to take for issuing and removing BWAs. This protocol functions to support decision-makers with adaptive procedures such that decisions to issue and rescind BWAs can be structured across rough- ly similar yet unique situations. The protocol may be used together with other related and jurisdiction-specic policies, regulations and guidance material; however, this protocol is subsidiary to any provincial/territorial and federal laws, directives, policies or regulations based on the management of BWAs. For information on what regulations apply in specic jurisdictions, the appro- priate regulatory authority should be consulted. The contents of the protocol have been partially adapted from resource mate- rials from the local/regional authority, provincial and federal levels: •	 Guideline for Issuing and Rescinding a Drinking Water Public Notice (2007). Health Protection, Environmental Health Services, Fraser Health Au- thority. •	 BC Drinking Water Ocer’s Guide (2007). Drinking Water Leadership Council, Ministry of Health Services, Province of British Columbia. •	 Guideline for Boil Water Notice Decision Process (2009). Public Health Pro- tection Management Team, Northern Health Authority. •	 Guidance for Issuing and Rescinding Boil Water Advisories (2009). Federal- Provincial-Territorial Commiee on Drinking Water, Federal-Provin- cial-Territorial Commiee on Health and the Environment, Health Canada. •	 Issue Paper: Drinking Water Public Notication Policy and Guideline Rec- ommendation (2005). Zibin S., Sigalet, E., Interior Health Authority.  Although the protocol materials and resources are specic to BWAs, the in- formation could be extended to other forms of public notications on drinking water quality.   A STEP-BY-STEP GUIDE TO APPLYING THE PROTOCOL THE THREE MAIN TYPES OF PUBLIC NOTIFICATIONS Knowing when to issue a BWA - or any type of public notication - rst re- quires awareness of the dierent types of public notices.  For consistency in terminology, it is recommended that decision-makers in each province/territory adopt terms dened in relevant provincial policies and legislation.  For instance, the terms used in the BC Drinking Water Of- cer’s Guide should be used in BC (as shown in bold in Table 1). W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 7 Table 1: Relevant terminology used for issuing public notices Do not drink advisories (Do not use water notices, Do not use, Do not use advisories) Boil water notices (Boil water advisories, Boil water orders) Water quality advisories (Drinking water advisories, Water quality notications, Drinking water notications) When to issue? When there is a risk that cannot be adequately ad- dressed by issuing a water quality advisory or by boiling the water (and in some cases, boiling would worsen the water quality); the water is not safe for domestic use. When there is a known or potential threat to drinking water that is microbio- logical (bacterial, viral or parasitic) in nature. The risk can be adequately addressed by boiling the water as a short-term form of treatment. A boil water order is a legal wrien order and formalized version of a boil water advisory requiring water supplier to operate under boil water condi- tions. When there is some level of threat particularly af- fecting a subset of the general population (sus- ceptible individuals) and not necessarily everyone; the threat is not signicant enough to require a boil water advisory or do not drink advisory. Common rea- sons to issue •	 Chemical contamina- tion or exceedances (such as unacceptable levels of naturally oc- curring nitrates, lead or arsenic) •	 Accidents – such as chemical spills •	 Acts of vandalism, sabotage or bioterror- ism that may aect water supply •	 Natural disasters, such as earthquakes or mudslides •	 For precautionary purposes when there is some unknown threat that will require time to deter- mine. •	 Waterborne outbreak conditions •	 Bacteriological qual- ity of water is below the accepted standard (presence of E.coli in water and/or repeated trends of total coli- form) •	 No treatment in place at water system •	 Water system treat- ment breakdown •	 Inadequate disinfec- tion at water system •	 High turbidity •	 Chemical exceed- ances (such as high sodium or high iron levels, which may af- fect individuals  on a sodium-restricted diet or infants, respec- tively) •	 Water is not aestheti- cally pleasing (colour, odour) •	 Medium-to-high turbidityW ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 8 PART 1: ISSUING AND REMOVING BWAS: A GUIDE FOR GOVERNMENT REGULATORY OFFICIALS Table 2: Summary table outlining the recommended steps to the decision, issuing and removing of BWAs for regulatory ocials 1 Step 1 Identify Threat to the Drinking Water Supply that May Require a BWA 2 Initiate Communication with Water Supplier and Required Per- sonnel 3 Review Water System File and Assess Risk *Checklist A 4 Conduct Site Inspection 5 Consult and Communicate to Reach a Decision 6 Issue BWA *Checklist B and C 7 Conrm Issuance of BWA 8 Develop Removal Criteria 9 Keep Everyone in the Loop 10 Meet Removal Criteria *Checklist D 11 Rescind BWA *Checklist E 12 Review BWA *  See the Checklist section of this document (page 17) to view the checklists      referenced in the table above and in the text below. Note: Especially in events where time is of the essence, steps 1 – 5, which take place prior to the actual issuing of the BWA, should be aempted promptly so as to not unintentionally delay the issuing of the advisory.  The amount of time spent on each step and whether the completion of one step is necessary before proceeding linearly onto the next step is discretionary and dependent on the type of threat and situation on hand. 1 The information provided in this section primarily used the Fraser Health Authority’s Guideline for Issuing and Rescinding a Drinking Water Public Notice (2007) as a guide, but has been adapted specifically for BWAs, rather than for all public drinking water notif ications. W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 9 STEP 1 – IDENTIFY THREAT TO THE DRINKING WATER SUPPLY THAT MAY REQUIRE A BWA Determine whether there is a potential or conrmed threat to the drinking water supply. The threat can be any situation, condition, or thing that renders the water unsafe for consumption. Awareness of a threat may occur via noti- cation from the laboratory, from the water supplier, from a member of the public, or by an on-site water system inspection, for instance. Threats may include: •	 A drinking water sample is not in compliance with relevant provincial or territorial legislation; •	 There is no water treatment and/or disinfection in place at the water sys- tem or the treatment system is malfunctioning due to mechanical failure; •	 Unexpected and unacceptable changes to water quality are observed, such as high turbidity; •	 The water system is not being properly maintained. This could be when a new or previously un-permied water system is discovered and there is no water supplier or no trained or competent water supplier onsite to maintain daily water system operations (e.g. water quality monitoring); •	 There is epidemiological evidence indicating water from the system as a possible source of a waterborne disease outbreak. Moderate to high-risk, time-sensitive events may require decision-makers to proceed towards a course of action more quickly than low-risk events. Moder- ate to high-risk events include: •	 waterborne disease outbreaks; •	 laboratory reports of E.coli in multiple water samples collected from dif- ferent locations with no evidence of sampling error; •	 interruption or loss of water treatment; •	 unltered surface water systems with unacceptable raw water turbidity; •	 zero or negative pressure due to water main break or loss of source; and •	 tampering and introduction of a harmful substance into the water system. Low-risk events - primarily from inconclusive water bacteriological results – include: •	 the potential for sampler error; •	 no evidence of operational and maintenance issues or loss of disinfectant residual at the time of water sampling; •	 a water system with no history of poor water quality; and •	 no evidential change to water quality (e.g., turbidity or colour).W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 10 STEP 2 – INITIATE COMMUNICATION WITH  WATER SUPPLIER AND REQUIRED PERSONNEL Make contact with the water supplier to inform him/her about the identied potential risk to drinking water, possible causes, and to initiate dialogue on next steps. Review the water supplier’s water sampling protocol and arrange to have follow-up water samples taken immediately by the water supplier for conrmatory testing. Inform appropriate managers, the medical ocer of health and any other required personnel about the threat to the drinking wa- ter system. Having an incident response team established prior to and in preparation for such events, as recommended by the Federal-Provincial-Territorial Commit- tee on Drinking Water, would expedite the eective exchange of information. Such a team may include professionals experienced in water quality monitor- ing, drinking water regulation, source water protection, treatment plant op- eration, water distribution, and public health surveillance.  STEP 3 – REVIEW WATER SYSTEM FILE AND ASSESS RISK Collect and compile risk assessment information about the water system. Consider what is known and unknown about the situation. Refer to Checklist A: Water System Risk Assessment.  STEP 4 – CONDUCT SITE INSPECTION  If additional or conrmatory information is needed for risk assessment, you may conduct an onsite water system inspection, if there is sucient time.  STEP 5 – CONSULT AND COMMUNICATE TO REACH A DECISION Once sucient information about the water system and the risk posed to wa- ter users has been compiled, consult with the manager, medical ocer of health, and other colleagues, as appropriate.  Discuss the situation with the water supplier.  Given that the main purpose of a BWA is to protect public health from a con- rmed or possible microbiological threat to drinking water – where boiling the water is sucient to render the water potable – decide whether issuing of a BWA would be the correct action to take, and not some other form of public notication.   STEP 6 – ISSUE BWA Review proposed course of action and request the water supplier to initiate action immediately. The water supplier should be notied of the issuing of a BWA by the best means (wrien notice, email, telephone, fax or in-person). In the case of noncompliance, issue a formal boil water order to the water sup- plier. W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 11 In communication with the water supplier, the regulatory ocial should in- dicate how to inform the water users about the BWA and what specic infor- mation or instructions they should be given. Direct the water supplier to pre- pare the BWA notice and submit a copy to the regulatory authority for review prior to disseminating. The water supplier should conrm by what means the BWA will be communicated to the water users.  Alternatively, clearly and directly indicate to the water supplier what the BWA message should include. This may especially be required in the case of small water systems, where the water suppliers may not have the experience, resources, and know-how to develop an eective strategy and message to communicate the BWA to water users.  Refer to Checklist B: Creating the BWA Message. Prohibit the use of language that nullies or defeats the purpose of the notice. Ensure the language is not too technical and encourages broad understanding of the BWA message. Decide on the best means to disseminate the information to the all water users and the general public, according to the water system in question.  The use of multiple methods is recommended. Refer to Checklist C: Ways to Disseminate the BWA message. Inform support sta and agencies aected by the BWA, such as other health unit facilities, Nurse lines, etc. The regulatory authority’s website should be immediately updated with information about the BWA. It is recommended that at least the following information be provided online on the regulatory authority’s website: •	 Name and location of water system •	 Date the BWA is issued/eective •	 Why the BWA was issued (the reason, the threat) •	 What specic actions will determine when the BWA can be lied (the criteria for removal) •	 Up-to-date information regarding the current status of the BWA (updated as soon as new information is available or progress is made)  STEP 7 – CONFIRM ISSUANCE OF BWA Verify with water supplier that the BWA has been communicated to the water users. Furthermore, verify that the issuance has been clearly communicated by checking media reports, directly contacting select water users, onsite visits, or other means.  If there is any reason to believe that the water supplier has not adequately complied with the requirement to inform the water users of the BWA, initiate action to inform the water users yourself. If you need to implement further compliance activity, take appropriate action as per relevant legislation.  W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 12 STEP 8 – DEVELOP REMOVAL CRITERIA Once a sound rationale for issuing a BWA has been developed, and the BWA is communicated in a timely manner, formulate removal criteria and develop a timeline by which required corrective actions should be taken and the BWA lied. The timeline should be realistic and created in conjunction with the water supplier and with consideration of the water system’s unique circum- stances. Note: A BWA should not be removed without approval of the appropriate regulatory authority.  STEP 9 – KEEP EVERYONE IN THE LOOP Arrange to discuss the BWA and progress made with the water supplier on a regular basis. Schedule the next follow-up phone call at each meeting.  Main- tain a set minimum frequency of follow-up and communication to ensure pro- gress in addressing the BWA is made. Ensure the water supplier is reminding the water users about the BWA fre- quently and informing them of progress/updates since the issuance. Keep public postings updated and refresh them as needed. Ensure that the regulatory authority’s website has up-to-date information about the BWA at all times.  STEP 10 – MEET REMOVAL CRITERIA To ensure progress towards the BWA’s removal is maintained, it is important to follow the timeline that indicates what steps need to be taken by the water supplier to remove the BWA. Once the water supplier has informed you that the threat has been eliminated or corrected, review the removal criteria and decide whether the BWA can be lied. Refer to Checklist D: BWA Removal Criteria.  STEP 11 – RESCIND BWA Compile information indicating that the risk to drinking water is no longer in place. Consult with managers, medical ocers of health and other required personnel to discuss removal of BWA. Authorize water supplier to remove the BWA and inform water users. Have the water supplier develop and submit the BWA removal message for your review. Alternatively, clearly and directly indicate to the water supplier what the BWA removal message should include. This may be required especially in the case of small water systems, where the water suppliers may not have the experience, resources and know-how to develop an eective strategy and no-W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 13 tice communicating the removal of the BWA to water users. Once an approved message has been created, the water supplier should immediately inform the water users in the most appropriate means.  Refer to Checklist E: Creating the BWA Removal Message. Notify support sta and agencies of the BWA’s removal, and update the regu- latory authority’s website.  STEP 12 – REVIEW BWA Complete a full review or record of the BWA event.  Determine if any changes in approach to the management of the water system are needed. Make neces- sary improvements to the water system’s emergency response plan as need- ed. This is a key component of an adaptive management and governance ap- proach (see Part III, Section 6, Fostering Good Governance Practices).  W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 14 PART 2: ISSUING AND REMOVING BWAS:  A GUIDE FOR WATER SUPPLIERS 2 Table 3: Summary table outlining the recommended steps to the decision, issuing and removing of BWAs Step 1 Identify Threat to the Drinking Water Supply that May Require a BWA 2 Initiate Communication with Regulatory Ocial and Required Personnel 3 Assess Risk *Checklist A 4 Consult and Communicate to Reach a Decision 5 Issue BWA *Checklist B and C 6 Develop Removal Criteria 7 Keep Everyone in the Loop 8 Meet Removal Criteria *Checklist D 9 Rescind BWA *Checklist E 10 Review BWA * Refer to the Checklist section of this document (page 18) to view the checklists ref- erenced in the table above and in the text below. Note: Especially in events where time is of the essence, steps 1 – 4, which take place prior to the actual issuing of the BWA, should be aempted promptly so as to not unintentionally delay the issuing of the advisory.  The amount of time spent on each step and whether the completion of one step is necessary before proceeding linearly onto the next step is discretionary and dependent on the type of threat and situation on hand.  STEP 1 – IDENTIFY THREAT TO THE DRINKING WATER SUPPLY THAT MAY REQUIRE A BWA Determine whether there is a potential or conrmed threat to the drinking water supply. The threat can be any situation, condition or thing that renders the water unsafe to drink. You may come to know about a threat to drinking water via notication from the laboratory, from the regulatory authority, from a water user or from your own observations of the water system. 2 The information provided in this section primarily used the Fraser Health Authority’s Guideline for Issuing and Rescinding a Drinking Water Public Notice (2007) as a guide, but has been adapted specifically for BWAs, rather than for all public drinking water notif ications. W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 15 A threat to drinking water may include the following situations: •	 A drinking water sample is not in compliance with relevant legislation in your province or territory; •	 There is no water treatment and/or disinfection in place at the water sys- tem or the treatment system is malfunctioning due to mechanical failure. •	 Unexpected and unacceptable changes to water quality are observed, such as high turbidity; •	 The water system is not being properly maintained. This could be if your water system is new or was previously un-permied and was recently discovered by the local health authority. A well-maintained water system requires a trained and certied water supplier on site to maintain daily water system operations – such as water quality monitoring. If you lack training or are unsure how to manage the water system, your water sys- tem may not be considered well maintained and drinking water from the system may not be safe for consumption; •	 There is epidemiological evidence indicating water from the system as a possible source of a waterborne disease outbreak.  STEP 2 – INITIATE COMMUNICATION WITH REGULATORY  OFFICIAL AND REQUIRED PERSONNEL Once you identify or become aware of a potential risk to the drinking water, contact your designated regulatory ocial to inform him/her about the threat, possible causes, and to initiate dialogue on next steps. Review your water sam- pling protocol with the regulatory ocial and arrange to have follow-up water samples taken immediately for conrmatory testing.  Inform required personnel, following your emergency response and contin- gency plan, such as managers, supervisors, community water system Presi- dent, as deemed appropriate.  STEP 3 – ASSESS RISK Collect and compile risk assessment information about the water system for consideration into the decision on whether issuing a BWA would be the best course of action to take. Consider what is known and unknown about the situ- ation to develop rationale.  Refer to Checklist A: Water System Risk Assessment. If the regulatory ocial requests additional or conrmatory information about the water system, you may need to conduct a complete risk assessment of the water system. If the regulatory ocial plans to conduct an onsite water system inspection, make yourself readily available for the visit and provide as much detailed information and assistance as you can.W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 16 STEP 4 – CONSULT AND COMMUNICATE TO REACH A DECISION Once sucient information about the water system and the risk posed to wa- ter users has been compiled, inform the regulatory ocial and discuss what actions to take. Given that main purpose of a BWA is to protect public health from a con- rmed or possible microbiological threat to drinking water – where boiling the water is sucient to render the water potable – decide whether issuing of a BWA would be the correct action to take, and not some other form of public notication.  STEP 5 – ISSUE BWA Review proposed course of action with the regulatory ocial. The regulatory ocial may request that you issue a BWA.  As per jurisdictional legislation, water suppliers are required to provide pub- lic notice to water users (with or without request from the regulatory ocial) when an immediate reporting standard is not met or when there is some threat to the drinking water. The failure of water suppliers to do so will result in the issuing of a boil water order by regulatory ocials. Further negligence in complying with the issuing of a BWA and failure to communicate the BWA to water users may result in legal enforcement by regulatory ocials. Activate the water system’s emergency response and contingency plan. The BWA should not be removed without approval of the regulatory ocial. In communication with the regulatory ocial, indicate how you will inform the water users about the BWA and what specic information or instructions they will provide. Prepare the BWA notice as will be communicated to the water users and submit a copy to the regulatory authority for review prior to disseminating. Inform the regulatory ocial how you plan to communicate the BWA to all water users. Refer to Checklist B: Creating the BWA Message. Be careful of the language and tone by which you convey the BWA message to the water users. Prohibit the use of language that defeats the purpose of the notice. Ensure the language is not too technical and encourages broad under- standing of the BWA message. Decide on the best means to disseminate the information to the all water users and the general public, according to the water system in question. The use of multiple methods is recommended.  Refer to Checklist C: Ways to Disseminate the BWA Message.  STEP 6 – DEVELOP REMOVAL CRITERIA Once a sound rationale for issuing a BWA has been developed, and the BWA is communicated in a timely manner, formulate removal criteria and develop a timeline by which required corrective actions should be taken and the BWA lied. The timeline should be realistic and created in conjunction with the W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 17 regulatory ocial and with consideration of the water system’s unique cir- cumstances. Note: A BWA should not be removed without approval of the appropriate regulatory authority.  STEP 7 – KEEP EVERYONE IN THE LOOP Arrange to discuss the BWA and progress made with the regulatory ocial on a regular basis.  Schedule the next follow-up phone call at each meeting. Maintain a set minimum frequency of follow-up and communication to en- sure progress in addressing the BWA is made. Inform the regulatory ocial when any progress is made, of any updates, questions or concerns. Ensure that you are reminding the water users about the BWA frequently and informing them of progress and updates since the issuance. Keep public post- ings updated and refresh them as needed.  STEP 8 – MEET REMOVAL CRITERIA To ensure progress towards the BWA’s removal is maintained, it is important to follow the timeline that indicates what steps need to be taken to remove the BWA. Once the threat has been eliminated or corrected, inform the regulatory of- cial and proceed towards reviewing the removal criteria and decide whether the BWA can be lied. Refer to Checklist D: BWA Removal Criteria.  STEP 9 – RESCIND BWA Once authorized by the regulatory ocial in writing, remove the BWA and inform water users. Develop and submit the BWA removal message for review and approval by the regulatory ocial. Once an approved message has been created, immediately inform the water users by the most appropriate means. Refer to Checklist E: Creating the BWA Removal Message. Notify support sta and personnel with a need to know about the BWA re- moval.   STEP 10 – REVIEW BWA Complete a full review/record of the BWA event. Determine if any changes in approach to the management of the water system are needed. Make improve- ments to the water system’s emergency response plan as needed.W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 18 CHECKLISTS CHECKLIST A: WATER SYSTEM RISK ASSESSMENT 3 When deciding to issue a BWA, consider the following: Water system characteristics:  ‡ What is the source of the water system?  ‡ Is the water source protected?  ‡ How old is the water system infrastructure?  Is it well maintained?  ‡ What is the size of the system? How many connections does it have?  ‡ What type of water system is it?  What is the system’s purpose?  ‡ What type of population is served water from this system? Does the popu- lation include high-risk groups, such as elderly, children and/or infants?  ‡ Does the system run year-round or only seasonally?  ‡ Is there any water treatment (ltration, disinfection) in place?  Is treat- ment at point of use/entry or centralized at the water system? Sampling Information:  ‡ Where was the last water sample taken?  ‡ What was the sampling procedure?  ‡ How many samples were taken?  How many sample results are available?  ‡ If water sample(s) were positive for E.coli or total coliform, were the counts low (example: 1 count E.coli or 10 counts total coliform per 100 mL) or high (example: over 10 counts per 100 mL)? With low counts, sampling error needs to be ruled out.  ‡ Has the system been ushed, disinfected and re-sampled for conrmatory testing?  What are the results?  ‡ Was the sample shipped appropriately (within required time-frame)?  ‡ How much condence do you have in the lab results?  ‡ Was the lab fully capable and certied?  ‡ Have the results been interpreted correctly? Monitoring Data:  ‡ What monitoring data are available? 	 •	 Chlorine	residual	records 	 •	 Turbidity	records 	 •	 Past	bacteriological	lab	results,	trends  ‡ Have there been any public complaints about water quality?  ‡ Is there a known communicable disease outbreak in the community?  ‡ Is there any recent raw water quality events?  ‡ When was the last water system inspection done? By whom? Operational Factors:  ‡ Is the water supplier certied and/or trained and competent in running the water system?  ‡ What is the history of the water system operations?  ‡ Has this system been on BWA(s) in the past? For what reason(s)?  ‡ Is there a cross connection control program in place?  ‡ Is there an approved Emergency Response and Contingency Plan in place at the water system? 3 The list of factors was heavily influenced by the risk evaluation checklist that included in BC Drinking Water Officer’s Guide  (Drinking Water Leadership Coun- cil, Province of British Columbia, Ministry of Health Services; 2007), but was further refined with respect to BWAs.W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 19 Environmental Factors:  ‡ Were there any recent weather events that may have aected  water quality? Other things to think about:  ‡ Are there any other legislative requirements on this system? Systems linked to institutions or businesses may be subject to regulations other than those specic to drinking water (e.g., food handling regulations for restaurants).  ‡ Is potential liability a concern?  ‡ What would be the possible consequences if a BWA is not issued?  ‡ Are concerns over expense or inconvenience to water supplier and/or wa- ter users aecting the decision to issue a BWA? Regulatory Ocials should consider factors relevant to their work- ing relationship and history with the water supplier that may inuence decision-making:  ‡ From past communication and experience, is the water supplier gener- ally cooperative and compliant?  ‡ If this is the rst time dealing with this water system or with the wa- ter supplier, could the lack of experience or information be aecting your decision?W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 20 CHECKLIST B: CREATING THE BWA MESSAGE In creating the BWA message, consider including the following information:  ‡ Name of water system and jurisdiction/regional health authority  ‡ Date BWA issued/eective   ‡ Reason why the advisory is being issued; what the water quality problem or threat is  ‡ What the associated health risks are  ‡ Who is at risk  ‡ What to do to avoid health risk •	 Bring tap water to 1 min of rolling boil before use  •	 Use boled water in place of tap water •	 Treat tap water with household bleach before use  •	 Use other household water treatment  •	 Use boiled, boled, or treated water for washing fruits and vegetables •	 Use boiled, boled, or treated water for food and beverage preparation •	 Use boiled, boled, or treated water for washing dishes •	 Use boiled, boled, or treated water for brushing teeth •	 Use boiled, boled, or treated water for making ice •	 Give pets boiled, boled, or treated water for consumption  ‡ What corrective action is being taken to end the advisory  ‡ Who to contact for more information and where to get more information  ‡ Additional information for susceptible populations, such as infants and the elderly   ‡ How long the advisory is anticipated to last  ‡ How the water users will be notied of advisory removal  ‡ Any special instructions for landlords with tenants, retail food establish- ments, day care facilities, schools, hotels, restaurants, spas, swimming pools, etc.  W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 21 CHECKLIST C: WAYS TO DISSEMINATE THE BWA MESSAGE  ‡ Press release: television, radio, newspaper  ‡ Internet: the local government jurisdiction’s website, the water system’s website, e-mail, social utility websites (Facebook, Twier)  ‡ Telephone, short message services (SMS)  ‡ Posting of signs or print notices in clearly visible public locations  ‡ Door to door canvassing of houses/units to verbally and personally inform water users and/or distribute print notices or leers  ‡ Announcements in community meetings  CHECKLIST D: BWA REMOVAL CRITERIA 4  ‡ The following should be considered when deciding to li the BWA:  ‡ The threat to the drinking water and its source has been identied and resolved  ‡ The water quality results are in compliance with relevant drinking water legislations in your province/territory  ‡ Conrmatory water sample testing has been done and the results are sat- isfactory  ‡ The water system has been returned to normal operating conditions  ‡ Distribution system has been ushed to displace any aected or contami- nated water  ‡ Water system operating procedures have been reviewed  ‡ Turbidity and/or heavy run-o events have resolved  ‡ Water treatment has been installed  ‡ There is a trained and certied water supplier on site to operate system  ‡ Water quality surveillance and monitoring is in place  ‡ An approved emergency response plan, with directives on the issuing and removing of BWAs, has been developed  ‡ Full site inspection of the water system has been conducted  ‡ The waterborne outbreak event has ended, as supported by epidemiologic surveillance data 4 This list was based on the risk evaluation checklist that was included in the Interior Health Author- ity’s Issue Paper: Drinking Water Public Notification Policy & Guideline Recommendation (2005)W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 22 CHECKLIST E: CREATING THE BWA REMOVAL MESSAGE When creating the BWA removal message, consider including the following information:  ‡ Name of water system and jurisdiction/regional health authority  ‡ BWA removal date   ‡ How the water quality problem or threat was resolved  ‡ What to do to before using tap water 	 •	 Flush	all	water-using	fixtures	for	1	minute 	 •	 Run	cold	water	faucets	and	drinking	fountains	for	1	min 	 •	 Drain	and	flush	all	ice-making	machines 	 •	 Drain	and	refill	hot	water	heater  ‡ Who to contact for more information or where to get more information  RECOMMENDATIONS AND FURTHER AREAS FOR RESEARCH A water system will be beer managed if the relationship between the regula- tory ocial and water supplier is based on mutual understanding and con- cern for public health; a relationship in which a regulatory oce can convince, rather than force, a water supplier to issue a BWA. Therefore, there are many benets to maintaining a healthy working relationship involving communica- tion and trust between the regulatory ocial and water supplier – whether a BWA is in place or not. The challenge in decision-making comes in determining whether or not ac- tion is truly needed. Ideally, we want to avoid outcomes where a decision was made not to issue a BWA when it was truly needed or a decision was made to issue a BWA when it was not truly needed.  Failure to act - or issue a BWA - could lead to disastrous consequences, as was evident from the infamous Walkerton, Ontario tragedy. It is, therefore, generally thought valid for deci- sion-makers to take the precautionary approach to public health decisions in order to avoid such severe consequences. However, there are inevitable con- sequences to taking action when not required either. The disadvantages to is- suing BWAs - or liberally issuing BWAs - include: message fatigue and loss of compliance, creating unnecessary panic among the public, the potential for the public to lose condence in their water system, and increasing the risk of burn injuries among the public from boiling water. On the other hand, BWAs may enhance the public’s awareness of their water supply and water system, serving as a catalyst that triggers further remedial action and improvements to the water system. Further studies are needed to help provide empirical evidence for the best means by which decisions to issue BWAs should be made. At present, no W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 23 study has investigated the decision-making process behind issuing BWAs in a large sample and across all of Canada. As many water systems have long- standing BWAs in place in lieu of more permanent upgrades to the water sys- tem’s infrastructure, it may also be of value to collect information on what specic upgrades or actions are eective in improving water systems.  Such data and any lessons learned could be used to guide future actions and deci- sions regarding water system upgrades that work.W ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 24 USEFUL WEB LINKS Health Canada: Boil Water Advisories and Boil Water Orders hp://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/boil-ebullition-eng.php Health Canada: Canadian Drinking Water Guidelines: hp://www.hc-sc.gc.ca/ewh-semt/water-eau/drink-potab/guide/index-eng. php Health Canada: Guidance for Issuing and Rescinding Boil Water Advisories: http://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/boil_water-eau_ebulli- tion/index-eng.php Health Canada: Water Quality – Reports and Publications: hp://www.hc-sc.gc.ca/ewh-semt/pubs/water-eau/index-eng.phpW ATER SECURITY GUI D ANCE DOCUMEN T PART 3 SECTION 7 B O IL W ATE R  A D V ISO RY  PR O TO CO L ( BW AP ) 25 BIBLIOGRAPHY Drinking Water Leadership Council. (2007). Drinking Water Ocer’s Guide. Province of British Columbia, Ministry of Health Services. hp://www. health.gov.bc.ca/protect/dwoguide_updated_approved%202007.pdf Fraser Health Authority. (2007). Guideline: Issuing and Rescinding a Drinking Water public notice. Fraser Health Authority, Environmental Health Services, Health Protection. Health Canada (Federal-Provincial-Territorial Commiee on Drinking Water, Federal-Provincial-Territorial Commiee on Health and the Environment). (2009). Guidance for Issuing and Rescinding Boil Water Advisories. Oawa, Ontario: Water, Air and Climate Change Bureau, Healthy Environments and Consumer Safety Branch, Health Canada. hp://www.hc-sc.gc.ca/ewh-semt/alt_formats/hecs-sesc/pdf/pubs/water- eau/boil_water-eau_ebullition/boil_water-ebul_eau-eng.pdf Drinking Water Protection Act, (2001a): hp://www.bclaws.ca/EPLibraries/ bclaws_new/document/ID/freeside/00_01009_01 (accessed February 20, 2011). Drinking Water Protection Regulation, (2001b): hp://www.bclaws.ca/ EPLibraries/bclaws_new/document/ID/freeside/10_200_2003 (accessed February 20, 2011). Oce of the Ombudsman. (2008). Fit to Drink: Challenges in Providing Safe Drinking Water in British Columbia. Special Report no. 32 to the Legislative Assembly of British Columbia hp://www.ombudsman.bc.ca/images/resources/reports/Special_Reports/ Special%20Report%20No%20-%2032.pdf Public Health Protection Management Team, Northern Health Authority. (2009). Guideline for Boil Water Notice Decision Process. Zibin, S., Sigalet, E., and Interior Health Authority. (2005). Issue Paper: Drinking Water Public Notication Policy And Guideline Recommendation. 

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