Southern Water Services Limited – Network Water Quality and Operating Procedures, Policies and Management

Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)

Reference: SRN-2024-00003

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Southern Water Services Limited, with registered number 02366670 (hereinafter called ‘the Company’).

Assets Affected:

• All distribution systems in the Southern Water area.

Details of this Notice:

1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a regulation 28(1) report of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company dated 22 June 2022, which states that there is or has been a significant risk of supplying water to all water supply zones (WSZ) (and associated assets as applicable) that could constitute a potential danger to human health or could be unwholesome.
2. Consequently, this Notice is served on the Company by the Inspectorate on behalf of the Secretary of State, under regulation 28(4) for the assets listed above, for risks associated with:

Description of Risk	Hazard/ Hazardous Event/ Parameter	Hazard I D
Ingress and/or contamination as a result of network activity	Biological	For example: 28467
Loss of supply as a result of network activity	No Supply	For example: 28469, 28470, 28471
Physio Chemical change as a result of network activity	Physio Chemical	For example: 28468
Discolouration of water as a result of network activity.	Turbidity	For example: 69585
Aesthetic change as a result of network activity	Taste	For example: 28461
Aesthetic change as a result of network activity	Odour	For example: 28462

Table 1: Table of the hazards, hazardous events, and/or parameters covered by this Notice, including the Hazard I D numbers and the description of risks.

3. The Company are required to satisfy the following requirements.

The date given is that until or by which the requirements must be maintained or satisfied, as appropriate.

Requirements:

(a) To maintain the following measures for the period specified in each case:

1. All company staff and third-party contractors involved in the operation of the water network (at all levels) to have clearly defined roles and be trained in accordance with current company procedures.
   Date: Ongoing for the duration of this Notice
2. Network and Water Quality manuals and working procedures, defining normal operation, triggers, responses and contingency plans to be kept up to date at all times.
   Date: Ongoing for the duration of this Notice
3. All company staff and third-party contractors involved in the operation of the water network are kept up to date on policy and procedural changes and appropriate competency signed off within 1 month of changes being incorporated.
   Date: Ongoing for the duration of this Notice
4. All company staff and third-party contractors involved in the operation of the water network to follow the procedures in the Water Distribution Manual.
   Date: Ongoing for the duration of this Notice.
5. Carry out the risk assessment process for all planned works on the water supply network using the current risk assessment methodology.
   Date: Ongoing for the duration of this Notice.
6. Keep the water network risk assessment process under continuous review and make any necessary changes to the process to ensure the process is fit for purpose, useable and that the roles and responsibilities of those involved are clearly defined.
   Date: Ongoing for the duration of this Notice.
7. Keep under continuous review the training and competency requirements for each role in the water network risk assessment process.
   Date: Ongoing for the duration of this Notice.
8. Ensure all company staff and third-party contractors involved in the operation of the water network (at all levels) are trained to the appropriate required competency within 12 months of starting their role.
   Date: Ongoing for the duration of the Notice

(b) To review, revise or make operational the following measures, by the dates specified in each case:

1. Culture:

a) Deliver the Water Quality and Public Health awareness programme, including initial company rollout of workshops, Water Quality Mandate and Water Quality Visa.
Date: 31 August 2024

b) Deliver regular Water Quality briefings for all company staff and third-party contractors involved in the operation of the water network.
Date: 31 August 2024 and then ongoing for the duration of the Notice

c) Embed water quality metrics, as defined in the audit strategy, and reporting into hubs and team meetings to raise awareness of performance.
Date: 31 August 2024

d) Deliver the Water Quality and Public Health awareness programme to Repair and Maintain (R&M) contractor staff.
Date: 31 December 2025 and then ongoing for duration of notice thereafter.

2. Training and Competency:

a) Develop competency assessment criteria and methodology for the Networks team.
Date: 30 June 2024

b) Commence competency reviews as identified in b(2)a for the Networks team and define future review frequency.
Date: 31 August 2024

c) Put in place an updated process to ensure all lessons learnt identified from water quality events and compliance are incorporated into training to all relevant personnel.
Date: 31 August 2024

d) Develop network focussed training material for water network controllers and rollout training to include Water Quality Risk assessment.
Date: 31 August 2024

e) Develop an internal network ‘Licence to Operate’ process to ensure all company staff involved in the operation of the water network are competent in the roles they are required to complete, before undertaking work.
Date: 31 December 2024

f) Develop and deliver practical networks training to include “Calm networks” training to all company staff involved in the operation of the water network.
Date: 31 December 2026

3. Procedures and standards:

a) Define which network procedures are, high, medium and low priority.
Date: 30 June 2024

b) Develop toolbox talks for high priority networks procedures and deliver these to all company staff and third party contractors involved in the operation of the water network.
Date: 31 May 2025

c) Develop toolbox talks for medium priority networks procedures and deliver these to all company staff and third party contractors involved in the operation of the water network.
Date: 30 June 2025

d) Review and update of network procedures covering water quality risk assessments (WM-D 360), mains repairs (WM-D 323) and tanker operations (WM-D 338).
Date: 31 August 2024

e) Review and update all remaining procedures associated with network interventions and maintenance.
Date: 31 March 2026

4. Controls, risk assessments and assurance:

a) Introduce a point of work water quality risk assessment tool to prompt compliance with networks procedures and capture evidence.
Date: 30 June 2024

b) Develop and implement root cause analysis to ensure water quality issues arising from network activity are investigated and actions are taken to prevent likelihood of reoccurrence.
Date: 30 June 2024

c) Implement second line assurance audits of network operations on a risk-based criteria.
Date: 31 August 2024

d Implement the revised Safe Control of Operations (SCO) process for planned network activity to ensure the delivery of wholesome water.
Date: 31 August 2024

e) Develop and implement a network unplanned work risk assessment, to incorporate mitigation for potential consequences on water quality.
Date: 31 August 2024

f) Embed point of work water quality risk assessment tool into business as usual practices to implement assurance programme of network inspector activity.
Date: 30 September 2024

g) Develop and implement a plan for next iteration of internal assurance process.
Date: 30 September 2025

h) Develop and implement a plan for enhanced SCO process to integrate with GIS and valve tagging.
Date: 30 September 2025

5. Contractor Management:

a) Introduce a “letter of governance” to be completed by Repair and Maintain (R&M) contract partners to assure first line controls and ensure management of any non—compliance.
Date: 30 June 2024

b) Award and implement an enhanced R&M contract for AMP8 which will include adherence to updated company procedures, water quality related KPI’s, robust audit and assurance processes and enable improvements to work management processes.
Date: 31 March 2025

c) Develop and implement a new connections process.
Date 31 March 2025

d) Develop a “licence to operate” training and competency plan for R&M contract partners in AMP 8.
Date: 31 March 2025

e) Develop and implement a plan for contractor assurance.
Date: 30 September 2025

f) Complete “licence to operate” training for R&M contract partners in AMP 8.
Date: 31 January 2026 and then ongoing for duration of the notice

6. Asset maintenance and operational plans:

a) Develop emergency network rezone plans for water supply systems to be enacted in case of site outage.
Date: 31 March 2025

b) Design and implement a trunk main walkover plan in all regions to identify and assess assets. Confirm future return frequency.
Date: 31 March 2025

c) Asset condition data to be collected from burst repairs and recorded in an asset system to better assess network risk.
Date: 31 March 2026

d) Create methodology, identify, and define critical air valves and implement risk-based maintenance of critical air valves.
Date: 31 December 2026

7. Customer:

a) Review and update Customer advice and information on Company website.
Date: 31 August 2024

b) Design a competency framework for the management of water quality customer related queries.
Date: 31 August 2024

c) Implement the new framework in (b)7b.
Date: 31 March 2025

(c) To audit whether the measures have been effective by the following means:

1. Define an audit strategy to monitor the effectiveness of the measures specified in sections (a) and (b).
   Date: 30 July 2024
2. Implement, and keep under continuous review, the audit strategy defined in measure (c)1.
   Date: Following completion of measure (c)1. onwards.

(d) Not to supply water for regulation 4(1) purposes from all distribution systems in the Southern Water area, or not to so supply unless the specified conditions below are satisfied:

1. Not Applicable

(e) To provide the following information in the time and manner specified below to enable monitoring of progress towards the mitigation of the risks:

1. Provide a bi-annual report covering progress and evidence of completion where available across all (b) measures.
   Date: by 30 April and 31 October each year for the duration of this notice.
2. Provide a report to confirm completion of all steps in (b)1. Culture.
   Date: 31 January 2026
3. Provide a report to confirm completion of all steps in (b)2. Training and Competency.
   Date: 31 January 2027
4. Provide a report to confirm completion of all steps in (b)3. Procedures and Standards.
   Date: 30 April 2026
5. Provide a report to confirm completion of all steps in (b)4. Controls, Risk Assessments and Assurance.
   Date: 31 October 2025
6. Provide a report to confirm completion of all steps in (b)5. Contractor Management.
   Date: 31 January 2026
7. Provide a report to confirm completion of all steps in (b)6. Asset Maintenance and Operational Plans
   Date: 31 January 2027
8. Provide a report to confirm completion of all steps in (b)7. Customer.
   Date: 30 April 2025
9. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
   Date: 31 August 2024
10. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
11. Submit a report in the event that any completed measures of this Notice need to be altered in any way, for any reason.
    Date: Ongoing for the duration of this Notice.
12. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 30 June 2027

Further Details of this Notice:

4. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
5. Under regulation 28(6) the Inspectorate, on behalf of the Secretary of State, may by notice served on the Company, revoke or vary this Notice.
6. Failure by the Company to comply with this Notice may result in enforcement proceedings under section 18 of the Water Industry Act 1991 (as amended).

Signed

Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
6 June 2024
Reference: SRN-2024-00003 v1