HSE Submission to the Joint Oireachtas Committee on the Future

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
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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.
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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
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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
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

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
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
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
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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
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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
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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.
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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
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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
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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.
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