HSE Submission to the Joint Oireachtas Committee on the Future Funding of Domestic Water Services HSE's current role in relation to water quality: Under the Drinking Water Regulations 2014 (S.I. 122 of 2014), and its predecessor S.I. 278 of 2007, the HSE has an important statutory role in relation to protection of human health. Included in this, is a requirement that the HSE be consulted and the agreement of the HSE obtained regarding actions to be taken to protect human health where a potential danger to human health exists. Before Irish Water came into being each local authority was the ‘water services authority’ for its functional area and consultation with the HSE was at local office level (as described in the ‘Management of Initial Notification of a Drinking Water Incident’ ( July 2016) document). This remains the de facto liaison route, notwithstanding the establishment of Irish Water. Nevertheless it was recognised by the HSE that the 2007 regulations necessitated harmonisation of HSE procedures and provision of guidelines for HSE staff The HSE National Drinking Water Group was set up in 2008 to harmonise national drinking water procedures and guidelines and review resource issues and training needs. A summary of the role, membership and activities of the group is set out in appendix 1 below. We wish to recognise the significant improvement in the management of drinking water supplies and quality since the coming into being of both the EPA and Irish Water. The ability to bring together and create/enhance expertise and skills is very beneficial and brought obvious improvements to our public drinking water supplies. Whilst the HSE has made every effort to match this new impetus it has proved difficult as initially 2007 onwards it coincided with financial constraints on the relevant HSE services and then it has proved more difficult as IW, in particular, has geared up appreciably in recent years. We fully recognise that there is more we can do to support the improvement of the quality of Drinking water but it is obvious we are not resourced to fully do so. Another key point to note is that the debate on Drinking Water in Ireland invariably focuses on Public Supplies yet 15-17% of the population receive their water from private supplies (from Group Water to private domestic wells). These are where the majority and persistent sources of poor quality drinking water are found giving rise year on year to many many cases of water related diseases. Ireland has one of the highest rates of drinking water related disease in Europe best evidenced bt the rate of VTEC E.Coli which is a virulent stomach problem that can causes renal damage and even death in a proportion of those afflicted. Ireland has nearly 800 cases a year often in young children who are most vulnerable. Indeed the Irish rate is 5-10 times that of most European Countries. As much if not more emphasis is required on these sources and the obvious public health solution is they are absorbed into and replaced by an appropriate public scheme. Our views in relation to the quality and improvement of domestic water Table 3 of appendix 1 sets out examples of a number of areas in which the HSE National Drinking Water Group has developed position papers, participated in external consultation processes and liaison. The issue of lead in drinking water has been an area of particular concern. We have been involved in a significant degree of liaison with Irish Water and Government Departments in relation to a national strategy and on the Irish Water remediation plan. Appendix 2 below lists various position papers and information documents produced by the HSE National Drinking Water Group and includes weblinks on document locations. All of these are of relevance to the heading above. Appendices 3 and 4 below are also pertinent to this heading. We also wish to highlight our concerns regarding ‘unregulated’ water supplies i.e. those supplies exempt from the regulations. These are typically private domestic wells. Given that approximately11% of the 1 population of Ireland is served by such supplies, together with the very high prevalence rate of STEC e. coli infection in this country, it is probable that contaminated well water is a contributory factor to ill-health. Proposal regarding how the HSE can support continuous water quality for the public We believe that local liaison arrangements on drinking water issues should continue and that decisions on HSE health advice on local incidents / issues are best made by personnel familiar with local water supplies and population health. Nevertheless it is recognised that consistency of approach, where appropriate, needs to be enhanced and promoted and this would necessitate oversight, training and access to technical support and advice at a level that the current HSE National Drinking Water Group is not equipped to deliver. This is because all of the members of the group have full-time day jobs, with no protected time for work associated with the Drinking Water Group. The HSENDWG, as currently constituted is also significantly constrained in delivery of a proactive work plan, as reactive work has dominated activities in recent years. Irish Water, EPA and Government Departments have all drawn significantly on the time of the group in responding to requests for meetings, responses to submissions, consultative processes, policy development etc., frequently with extremely short response time-frames. Ireland’s high dependence on surface water sources and small-scale water supplies due to its dispersed population pattern makes us particularly vulnerable to pollution challenges such as pesticides, disinfection by-products, STEC and cryptosporidium. This is further exacerbated by increasingly intensive agricultural practice. In several of these aspects Ireland is a European outlier of concern. Local HSE offices have been greatly assisted by position papers and other documents developed by the HSEDNDWG but the sheer range of drinking water parameters and topics means that there is a large body of work yet to be done. Rather than ‘re-invent the wheel’ in different locations around the country, it would be more productive if the HSENDWG were given the resources to further develop its work in this area. It is clear to meet the challenges outlined above a dedicated unit needs to be established appropriately funded. Such a Unit could be created with the recruitment of 5 full-time posts (2 Public Health; 2 Environmental Health; 1 admin / research post) which would form a core part of a reconstituted HSE National Drinking Water response alongside pre-existing regional services. Recommendation regarding how an effective and coordinated method can be implemented in relation the inspection of water in the best interest of the public. 1. We would suggest that the advent of Irish Water, with an overall national remit for public drinking water quality has led to a more integrated analysis of the challenges and solutions (see appendix 3 below). It has highlighted, among other matters, the need for investment in infrastructure. 2. The allocation to the Environmental Protection Agency of a supervisory authority role was also a driver for improvement in drinking water quality. This needs to include all drinking water supplies. 3. The HSE is more and more being asked to comment at national level on health aspects of Irish Water policies and procedures, as the latter organisation does not have internal health expertise. There needs to be a National Drinking Water and Health Unit (see above). 4. Irish Water should have statutory responsibility for water supply catchments. In many cases, e.g. pesticide or microbiological contamination, the issue arises in the catchment area, rather than the treatment plant 5. The present level of private supplies is an obvious threat to Public Health there should be explicit policy to reduce the dependence on Private sources. 2 APPENDIX 1 Role and Structure of HSE National Drinking Water Group 1. Background The Terms of reference of the HSE Drinking Water Group were initially defined in 2008 when the group was first established following the enactment of the 2007 Drinking Water Legislation. They were subsequently updated in 2010 and again in 2013. with a review date of 2016. . Table 1 – HSE Drinking Water Group Revised Terms of Reference March 2013 2. Governance and Infrastructure - HSE Drinking Water Group 1. To support best practice and promote competence among HSE personnel who have a role in the protection of public health in relation to drinking water by; a. reviewing evidence, developing guidance, standardising responses and updating drinking water and health guidance and materials as necessary b. assessing and addressing the training needs of the group c. monitoring new and emerging issues d. sharing drinking water incidents and experiences 2. To review communications within the HSE and between the HSE and other agencies in relation to drinking water and health 3. To act as the HSE expert group and resource on drinking water and health issues Oversight of the group is provided by the Assistant National Directors ( ANDs) Public Health and Environmental Health who were responsible for establishing the group in 2008 within the Population Health Directorate of the HSE. The role of chair of the HSE Drinking Water Group has rotated between the Public Health and Environmental Health membership of the group as shown in Table 2. In 2013 the 2 ANDs were realigned to the Health and WellBeing Division of the HSE which is now responsible for the remit of the group. The HSE Drinking Water Group does not have a central secretariat nor a budget to cover materials, travel expenses, training , development/dissemination of materials /guidance etc . The chair is responsible for : ensuring that minutes are taken( usually allocating the task to a group member) circulation of documentation for meetings communication to ANDs for Public Health and Environmental Health prioritising the resources within the group to fulfil the agreed workplan and to respond to requests for unplanned work identifying new/replacement membership of group to replace retiring staff or to fill new needs acting as a communications hub for other agencies( EPA,CER, FSAI, CCMA etc) , bodies ( DECLG, DES, Irish Water, Expert Committee on Fluoridation etc) ) and other HSE services( Estates etc) who correspond with the HSE Drinking Water Group Identifying appropriate representation from within group for external and HSE Working Groups etc when requested by ANDs 3 Membership is drawn from the local Environmental Health Officer Services and Regional Public Health Departments with a nominated representative from the Clinical Microbiologists , the Public Analyst s and HPSC . When members are moved or seconded to other roles there may be no replacement. Members are part of this group in addition to their full-time substantive posts (as outlined in the membership list) i.e. there is no protected time allocated for participation in the work of the group. Meeting frequency has increased from 6 meetings/year in 2008-9 to 8 meetings/year since 2013 The HSE Drinking Water Group meetings take place usually at HPSC , or occasionally at NIO( National Immunisation Office) Table 2 – Current Membership (February 2017) of HSE Drinking Water Group Current Membership Mr. Ray Parle Dr. Tessa Greally Dr. Margaret O’Sullivan Dr. Patricia McDonald Dr. Anthony Breslin Mr. Andrew Curtin Mr. Paul McGuinness Dr Una Fallon Ms Gemma Leane Dr Helena Murray Dr Julie Heslin Dr Melissa Canny Prof Martin Cormican Dr Fred Davidson Mr. Shane Keane Ms. Siobhan Byrne Ms. Sara Doohan Ms Catherine Cosgrove Dr. Paul McKeown Dr. Lois O’Connor PEHO HSE South (Chair) CPHM HSE West (MW) CPHM HSE South (Cork/Kerry) CPHM HSE Dublin CPHM HSE West (NW) PEHO HSE West PEHO Dublin Mid-Leinster CPHM HSE DML(Midlands) Research Officer, PH Dept, HSE SE CPHM HSE East CPHM HSE South(SE) CPHM HSE West Consultant Microbiologist, NUI Galway Public Analyst, HSE South PEHO HSE West SEHO HSE West(NW) EHO HSE West Regional Chief Chief EHO, HSE South CPHM HPSC HPSC The HSE Drinking Water Group has provided input to external processes under the following headings : Table 3 – HSE DW Group inputs to external processes Consultations Examples: Q1 2014 Guideline for the Prevention of Representing HSE on external groups Training Publications Conference presentations and media interviews Examples: Examples: 2010 – National training workshops organised by HSE Drinking Water Group in 4 areas to introduce and Examples: Examples: Home haemodialysis working group Pesticides Working Group 4 Drinking Water and Public Health 2010 Precautions SAFEFOOD 2008 EPA Annual Conference Infection from Water Systems in Healthcare Facilities Q3 2013 HARVES T 2020 IRC2 Consultati on on the preparatio n of the Irish Water Investmen t Plan(2015 -2016) COUNCIL DIRECTIV E 2013/51/E URATOM2015 implementa tion seminar Sustainable Water Manageme nt Initiative (SWIMI) Abstractions & Impoundments Working Group (AIWG) Water Framework Directive Tier 1 Water Policy Advisory Committee Catchment Management Network Workshop Expert Group on Fluoridation EPA Private wells campaign 2014 Irish Water Multi-agency lead communications group ( currently holds fortnightly teleconferences) Dept. of Environment, Community and Local Government Lead strategy group Input to CER process on affordability of water provide training on “ Drinking Water and Public Health” 2016 -– National training workshops organised by HSE Drinking Water Group in 4 areas to introduce and provide training on HSE Management of Initial notifications of Drinking Water Incidents Lead in Water systems in Public Buildings (HSE)Estates Procurement Group 2016 5 and advice for reducing the risk of infection from WELL WATER SUPPLIES Joint Position Statements - Nitrates -Lead, -THMs Rural Water Conference Ear to the Ground APPENDIX 2 HSE DRINKING WATER GUIDANCE AND POSITION PAPERS INCIDENT MANAGEMENT DOCUMENTS Management of Initial Notification of Drinking Water Issues of Potential Danger to Human Health Author: HSE National Drinking Water Group Date: July 2016 Available at http://www.lenus.ie/hse/handle/10147/618917 Drinking Water and Health: a review and guide for population health Author: HSE Population Health Water Group Date: Dec 2008 Available at http://www.lenus.ie/hse/handle/10147/110534 HSE WATER INTERNET www.hse.ie/water LEAD (Pb) Available at http://www.hse.ie/eng/health/hl/water/drinkingwater/lead/Lead.html Lead in Drinking Water FAQs Author: HSE National Drinking Water Group Date: May 2015 HSE advice for Schools and Crèches regarding Lead (Pb) in Drinking Water Author: HSE National Drinking Water Group Date: July 2015 Drinking Water Consumer Advice Note No. 1 – Lead (Pb) Author: EPA and HSE National Drinking Water Group Date: May 2015 Joint Position Paper Lead (Pb) in Drinking Water Author: HSE National Drinking Water Group and EPA Date: Dec 2013 TRIHALOMETHANES (THMs) Available at http://www.hse.ie/eng/health/hl/water/drinkingwater/trihalomethanes/trihalomethanes.html Trihalomethanes in Drinking Water – Information for Consumers Author: HSE National Drinking Water Group and EPA Date: Sept 2016 Joint Position Statement Trihalomethanes in Drinking Water Author: HSE National Drinking Water Group and EPA Date: Nov 2011 PESTICIDES Protecting Drinking Water from Pesticides Leaflets Author: National Pesticides Working Group (HSE was a member) Available at http://www.hse.ie/eng/health/hl/water/drinkingwater/ Date: 2014 PRIVATE WELL WATER Available at http://www.hse.ie/eng/health/hl/water/drinkingwater/well_water.html Risk of illness for well water Author: HSE National Drinking Water Group Date: Jun 2013 6 Health risks associated with switching from a public to a private water supply Author: HSE National Drinking Water Group Date: Feb 2011 CRYPTOSPORIDIOSIS Drinking Water Supplies, Cryptosporidiosis and Severely Immunocompromised Patients Author: HSE Consultants in Public Health Medicine Date: May 2014 Available at http://www.hpsc.ie/A-Z/Gastroenteric/Cryptosporidiosis/Publications/File,14628,en.pdf NITRATES Joint Position Paper Nitrates in Drinking Water Author: HSE Date: Apr 2010 Available at http://www.lenus.ie/hse/bitstream/10147/281453/1/HSE_EPA%20joint%20position%20paper%20Nitrates% 20in%20drinking%20water%20Apr10.pdf 7 APPENDIX 3 HSE NATIONAL DRINKING WATER GROUP SUBMISION ON IRISH WATER CONSULTATION DOCUMENT ON THE EMERGING INVESTMENT PLAN 2017-2021 10th FEBRUARY 2016 The January 2016 draft of the above document was circulated to the members of the group for comment. The response below is based on comments received back. The HSE DWG welcomes the opportunity to comment. Mindful of the scope of our group, our comments are confined to health-related drinking water quality issues. The proposed rationalisation of smaller supplies is welcomed as it can provide the following advantages in support of public health policy; - Efficiencies of scale supporting the application of multiple barriers and higher grade treatment systems in a greater proportion of public water supplies which will also assist in THM precursor reduction. - freeing up water treatment plant personnel. -The extension of fluoridation to a greater proportion of public water supplies. We would however caution that reduction of the number of water treatment plants may, in some situations, also pose challenges in relation to water abstraction and source water quality. A smaller number of water supplies will necessitate larger volume water sources. This will most likely require increased abstraction from lowland surface water sources. Such changes in source profile may increase risk of contamination from, for example, pathogenic species of cryptosporidium, oil spillages or inappropriate pesticide usage. In response to this it would be worthwhile considering the inclusion within the Emerging Investment portfolio of such as the following: -Hydrocarbon alarms for intake points of vulnerable public surface water supplies -Treatment upgrades to support pesticide removal where continuing problems have not been addressed through catchment protection and other elements of a national pesticide strategy. We would also have a positive view of the commitment to a increased differential between supply capacity and demand (‘headroom’ page 18) and minimum 24 hour treated water storage (page 45). Improved treated water storage capacity will significantly enhance chlorine contact time. Taken together with pH correction this should optimise the disinfection process and may even allow scope for reduction in chlorine concentration where THM formation is an issue (balanced, of course, with the desirability of maintaining a free chlorine residual in the distribution system). In addition, we would suggest that there should be a commitment in the emerging investment portfolio to maximising the treated water storage capacity to the greatest extent feasible. The rationale for this is that climate change models suggest that Ireland may in future experience more extreme rainfall events. There is evidence from other countries (ch. 3 WHO 2009, Risk Assessment of Cryptosporidium in Drinking Water, WHO/HSE/WSH 09.04) that extreme weather events have led to water-borne cryptosporidiosis outbreaks even where cryptosporidium barrier treatment had been in place. Timely suspension of water intake could have avoided the overwhelming of the treatment systems. Increased treated water storage capacity would also have advantages in drought situations and provide greater buffering in the event of a transient source pollution or contamination incident (as described above) or temporary treatment failure. The situation would of course be enhanced by hoped-for improvements in water conservation and reduction in leakage. The measures outlined on page 49 relating to data capture and planned maintenance programme are also laudable - timely identification of incidents and reaction to same have presented difficulties in the past in 8 case of small treatment plants with no staff on site for much of the time. While use of telemetry has been increasing in recent years it should be universal. Pages 24-25, under the heading ‘Other Challenges for Irish Water’ refer to take-over / taking in charge of the following private water supply networks provided with public water : - Group Water Schemes (take over passed from Local Authorities to IW) -Developer Provided Infrastructure ( i.e.take over water services infrastructure located in residential developments, including developer built networks and treatment systems). Although the GW schemes taking in charge is included in the list of national programmes, both are developments which the HSE would support as a priority because of the unsustainable governance arrangement in place for many of these networks leading to potential public health risk. Appendix B gives an “Indicative Listing of Programmes and Projects in the Emerging Investment Portfolio” . A ranking or prioritisation formula, which includes population served, reasons of inclusion on list including crypto risk scores if applicable and summary of proposed enhancements would be helpful to allow the HSE to understand potential timelines and advise on any health related issues. A “Plan Balancing Tool” is mentioned and the values used in the ranking formula for this tool would also be of value in understanding how prioritisation has been applied. As an example from the Mid-West, there are projects such as Thurles WTP and Shannon WWTP, about which the HSE has had ongoing contact with Irish Water in support of prioritisation of upgrading works because of identified health risks. Stakeholder acceptability is one of the bullet points under the ‘Business Decision Making’ heading (page 41). We presume that communication with customers and the general public will be an important component of the implementation of the investment plan. As health protection may be a factor in much of the investment e.g. cryptosporidium barriers, THM reduction, lead remediation, the anticipated extent of involvement expected of the HSE in ongoing communications or information packages will require discussion. 9 APPENDIX 4 HSE NATIONAL DRINKING WATER GROUP SUBMISION ON WATER CHARGES AND AFFORDABILITY Oct 15th 2013 Dear Ms Graham, I have been in touch with Deirdre Mason who requested input from the HSE regarding water charges and affordability for an inter-departmental meeting on Wednesday October 16th 2013. We have made the following points for the group’s consideration. General comment on affordability Until now quantity has rarely been an issue in Ireland for domestic consumers. However as water charges are introduced it is paramount that water quantity is adequate for the protection of public health for both the general population and specific vulnerable groups. The free allowance must be adequate to maintain health for those who will have difficulty paying and consideration should be given to people who have medical conditions which require additional water. The requirement to provide potable water must always take precedence over water charges and legislation should clarify specifically that any potential risk to public health should override price control considerations. Specific groups requiring large volumes of water Home Haemodialysis patients Home Haemodialysis (HHD) is a cost-effective treatment (€29,000 annually compared to €60,000 in a hospital renal unit). Studies suggest better clinical outcomes and the patient’s quality of life is significantly improved especially for those who would otherwise have to travel long distances. HHD is increasingly being used in the Republic of Ireland. Baxter Healthcare was awarded the National Home Haemodialysis tender in 2011. In 2011 there were 20 patients on HHD. This increased to 28 in December 2012 and was 33 in June 2013. The National Renal Office (NRO) anticipates an increase in HHD numbers of up to 80 patients by the end of 2014. Once this threshold is reached an approximate increase of 14 patients per year is expected. Currently, most patients on HHD are in Dublin, Cork, and the South East and more recently in the Galway area. However, those who benefit most are likely to live outside these urban areas and the service is likely to expand to less densely populated areas in the coming years. A large volume of potable water is required for HHD. This varies by frequency and type of dialysis. Our current best estimate is that including the volume of water required for disinfection, day-time dialysis patients will use 46,800-52,000 litres per year and nocturnal dialysis patients will use 91,000 – 117,000. At maximum, a patient undertaking nocturnal dialysis seven days a week would use an estimate of 163,800 litres of water per year. (Please see attached paper). As this is considerably more than the average water consumption per person per year, this group of patients needs special consideration in terms of water charges. We would request that the benefits of this new effective treatment modality should not be undermined by personal affordability issues. In addition we would request that, however this group is accommodated, because the water requirement for HHD can vary so much and change with time, an individual patient can make a case to the Water Services Authority for their personal needs regarding water volume usage. Other groups We agree that those with desquamating or weeping skin conditions, those with urinary and faecal incontinence and those with inflammatory bowel disease as outlined in the UK Water Sure list of eligible 10 medical conditions require larger than usual volumes of water. However, it is very difficult to be comprehensive on all medical conditions that may have an additional requirement. We recommend that there be a process whereby a person can identify themselves and justify a significant additional water requirement based on their medical condition. This is particularly relevant for conditions where hygiene is important, including frequent hand-washing, such as wound dressing or the preparation of tube feeds. This list is not exhaustive. Infection Control Hand hygiene Hand hygiene is the cornerstone of infection control in domestic, non-domestic and health-care settings. Public Health advice for the control of infectious diseases always includes paying attention to hand hygiene in particular hand washing. Person-to-person spread of serious infectious gastroenteritis, such as VTEC, Salmonella and Cryptosporidiosis as well as simple childhood viral illnesses can be prevented by simple hand washing. However, hand washing requires running water. It is not desirable that individuals would refrain from washing their hands properly to save money while increasing the risk of infection which ultimately could cost both themselves and the State. The introduction of domestic water charges and the formation of Irish Water may eventually impact on the current cost of water for nondomestic customers such as hospitals and long-stay residential homes. The use of running water for hand washing and infection control is paramount in this setting. In addition, preventing the spread of infectious disease is a key task in preventing antibiotic resistance. Anti-biotic resistance is an ultimate cost to the State. The feasibility of hand washing with running water, a simple but critical measure in infection control, should not be compromised by water charges. Consequences Switching The inter-departmental affordability group should be aware that a possible health consequence of introducing domestic water charges is that customers may switch from a public water supply to a preexisting well. We have experienced this in the commercial sector where the risks and responsibilities associated with such a step have not been appreciated by the owner. In the summer of 2012, there was unprecedented environmental contamination resulting in serious cases of VTEC around the country, many of which were associated with private domestic household wells. Considering the risks to health, water charges should not be so prohibitive as to encourage people to seek out and re-activate old private wells as an alternative to a public water supply. Mixing In addition, there have been instances where contaminated private wells have been inadvertently connected to public supplies and instances where grey-water was mixed with drinking water. This is usually as a result of faulty non-return valves or indeed no valve at all. Again, prohibitive charges may unwittingly encourage this and consideration of affordability and pricing should take these risks into account. Flushing Flushing or running off volumes of stagnant water is often used in the control of both chemical and microbiological parameters. For instance it may be a simple solution for a household where the lead(Pb) parameter is elevated. It is used in hospital and residential care settings as an adjuvant in the control of Legionella and Pseudomonas. It may also be part of mitigation in copper(Cu) exceedances. Water charges may make flushing - a health-associated control measure - prohibitively expensive. The affordability of flushing or alternative control measures in these situations need to be considered. Individual fluid needs 11 While the volume of water consumed or drank by an individual or household is small relative to the volumes used in showers and washing machines etc, it is essential that people understand the importance of keeping themselves hydrated with frequent drinks. An effective public information campaign should emphasise that people, particularly the elderly, should not forego drinking tap water and keeping hydrated to keep their water costs down. We are happy to give any further information or assistance as required. 12
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