Notice of Regulation: Thames Water – Procedures and Documentation
NOTICE UNDER REGULATION 28(4) OF THE WATER SUPPLY (WATER QUALITY) REGULATIONS 2016 (AS AMENDED)
Thames Water Utilities Limited: Procedures and Documentation
Reference: TMS-2020-00001
Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Thames Water Utilities Limited, with registered number 02366661 (hereinafter called ‘the Company’).
Assets affected:
All catchments, water treatment works, service reservoirs and zones in the Company’s supply region.
- The Drinking Water Inspectorate (‘the Inspectorate’) has on 19th October 2017 received multiple regulation 28(1) reports of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company, which state that there is or has been a significant risk of supplying water from all catchments, water treatment works, service reservoirs and zones in the Company’s supply region that could constitute a potential danger to human health or could be unwholesome.
- 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:
For risks associated with:
- Adequacy of Company’s procedures
- Suitability of asset maintenance plans, maintenance task specifications and identification process
- Adequacy of response times to alarms
- Adequacy of Site Operating Manuals (SOM)
- Adequacy of site schematics
- The Company are required to satisfy the following:
Requirements
(a) to maintain the following measures for the period specified in each case:
- Up-to-date Site Operating Manual (SOM), defining normal operating ranges, triggers, response and contingency procedures, with controlled update and review programmes. Internal waiver process is followed where deviation from SOM is required.
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:
- a) Complete a critical review of the Company’s procedures to identify any deficiencies or where procedures may be missing.
Date: Complete - b) Identify any measures required to address the findings of the critical review completed under measure (b)1.a) above.
Date: Complete - c) Implement any required measures identified under measure (b)1.b) above.
Date: 31 March 2022
- a) Complete a critical review of the Company’s procedures to identify any deficiencies or where procedures may be missing.
- a) Review the suitability of the Company’s asset maintenance plans, maintenance task specifications and the maintenance tasks identification process to ensure maintenance of assets is conducted at an appropriate frequency.
Date: Complete - b) Identify any measures required to address the findings of the critical review completed under measure (b)2.a).
Date: Complete - c) Implement any required measures identified under measure (b)2.b) above.
Date: 31 August 2022
- a) Review the suitability of the Company’s asset maintenance plans, maintenance task specifications and the maintenance tasks identification process to ensure maintenance of assets is conducted at an appropriate frequency.
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- a) Complete a critical review of response times to alarms based on risk to human health and regulatory compliance.
Date: Complete - b) Identify any measures required to address the findings of the critical review completed under measure (b)3.a) above. This must include the implementation of a fit for purpose system to log and appropriately justify operator responses to high priority alarms as well as response times.
Date: Complete - c) Implement any required measures identified under measure (b)3.b) above.
Date: Complete
- a) Complete a critical review of response times to alarms based on risk to human health and regulatory compliance.
- a) Identify all assets without SOMs.
Date: Complete - b) Implement SOMs for all assets identified in (b)4.a) above.
Date: Complete
- a) Identify all assets without SOMs.
- a) Complete a critical review of all SOMs currently in place.
Date: Complete - b) Identify any measures required to address the findings of the critical review completed under measure (b)5.a).
Date: Complete - c) Implement any required measures identified under measure (b)5.b) above.
Date: 31 March 2023
- a) Complete a critical review of all SOMs currently in place.
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- a) Complete a review of all site schematics to ensure they are fit for purpose.
Date: Complete - b) Identify any measures required to address the findings of the critical review completed under measure (b)6.a).
Date: Complete - c) Implement any required measures identified under measure (b)6.b) above.
Date: 31 March 2022
- a) Complete a review of all site schematics to ensure they are fit for purpose.
(c) to audit whether the measures have been effective by the following means:
- Define an audit strategy to monitor the effectiveness of the measures specified in section (a) and (b).
Date: Complete - 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 multiple sites, or not to so supply unless the specified conditions below are satisfied:
- 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:
- Provide a progress report annually by 31 January and against the following milestones:
Date: Annually by 31 January- a) Report outlining the measures implemented under measure (b)1.c).
Date: 30 April 2022 - b) Report outlining the measures implemented under measure (b)2.c).
Date: 30 September 2022 - c) Report outlining the measures implemented under measure (b)5.c).
Date: 30 April 2023 - d) Report outlining the measures implemented under measure (b)6.c).
Date: 30 April 2022
- a) Report outlining the measures implemented under measure (b)1.c).
- Submit the strategy for auditing the effectiveness of the measures, as specified in (c)1.
Date: Complete (30 October 2020) - Submit any revisions of the audit strategy produced under measure (c)2.
Date: Within 1 month of a revision - Submit a report in the event that any completed measure of this Notice needs to be altered in any way for any reason.
Date: Ongoing for the duration of this Notice - Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
Date: 30 April 2024
- Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
- 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.
- 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
Laura Moss
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
17 August 2021
Reference: TMS-2020-00001
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