Dwr Cymru Cyfyngedig – Governance, Accountability, Procedures and Record Keeping
Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2018 (as amended)
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Dwr Cymru Cyfyngedig, with registered number 02366777 (hereinafter called ‘the Company’).
Assets Affected:
- Whole company
Details of this Notice:
- The Drinking Water Inspectorate (‘the Inspectorate’) has received a set of regulation 28(1) reports of the Water Supply (Water Quality) Regulations 2018 (‘the Regulations’) from the Company dated 13 October 2023, which states that there is or has been a significant risk of supplying water from multiple sites (and associated assets as applicable) 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 Welsh Ministers, under regulation 28(4) for the assets listed above, for risks associated with:
|
Description of Risk |
Regulation 28(1) Control Measure |
Hazard I D |
|---|---|---|
|
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health. |
Procedures |
Multiple e.g. D78282 |
|
Risk assessment |
Multiple e.g. D126770 |
- 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:
- All Water Quality, Network, Production, Control and Operational personnel (at all levels) to have clearly defined roles and responsibilities, and be trained in accordance with Company procedures.
Date: Ongoing for the duration of this Notice - Works operating manuals and procedures relating to water supply, defining normal operating ranges, triggers, response and contingency plans are to be kept up to date, at all times. Scheduled dates to be defined for their review and clear criteria to be defined and briefed to all relevant staff specifying when interim reviews are required or may be triggered.
Date: Ongoing for the duration of this Notice - Operational staff are kept up to date on strategy and procedural changes
Date: Ongoing for the duration of this Notice - Staff with authority or accountability within the Company’s water quality and sufficiency governance framework, exercise those responsibilities in accordance with the framework.
Date: Ongoing for the duration of this Notice - Deliver the Water Quality First Programme.
Date: Ongoing for the duration of this Notice
(b) To review, revise or make operational the following measures, by the dates specified in each case:
Governance and Accountability
- Review the company’s governance framework for water quality and sufficiency.
- Implement any improvements identified in (b)1 to ensure the governance framework for water quality.
Date: 31 May 2026
Procedures
- Complete a critical review of the company policy, procedure and documentation management system hierarchy and control process, including the review process of all strategies and procedures.
Date: 31 August 2025 - Implement improvement measures to address (b)3
Date: 31 May 2026 - Evaluate all water quality strategies and operational procedures to identify gaps, weaknesses and opportunities for operational risk reduction and reissue where required;
- Include measuring impact of changes to ensure any changes are effective.
- Include process confirmation of new/updated procedures to ensure new control measures are embedded.
- Include commissioning and de-commissioning of assets/component procedures
Date: 30 September 2027
- Review the process of learning from incidents and near misses; including tracking of actions to completion and dissemination of those learnings to the wider teams that would benefit from it.
Date: 30 April 2025 - Implement any improvements as identified in measure (b)6.
Date: 31 August 2025 - Conduct a gap analysis of the water supply and network planned and unplanned risk assessments, to incorporate mitigation for potential consequences on water quality, appropriate senior level sign off and inclusion of on-site findings and field test results to support the developing risk assessment.
Date: 31 August 2025 - Implement any improvements as identified in measure (b)8.
Date: 30 April 2026 - Complete a critical review of the internal audit process of the company policy, procedure and documentation management system.
Date: 31 August 2025 - Implement any improvements as identified in measure (b)10
Date: 31 December 2025
(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 sections (a) and (b).
Date: 28 February 2025 - 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 assets, 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.
Date: by 31 January each year. - Provide a report on the governance framework review, as described in (b)1.
Date: 30 September 2025 - Confirm completion of all improvements, as described in (b)2.
Date: 30 June 2026 - Provide a report on the critical review as described in (b)3.
Date: 30 September 2025 - Confirm completion of all improvements, as described in (b)4.
Date: 30 June 2026 - Provide a report as described in (b)5, including evidence of updated procedures, evidence of staff briefing of changes and evidence of process confirmation checks.
Date: 31 October 2027 - Provide a report on the review, as described in (b)6.
Date: 31 May 2025 - Confirm completion of all improvements, as described in (b)7.
Date: 30 September 2025 - Provide a report on the gap analysis of planned and unplanned risk assessments as described in (b)8.
Date: 30 September 2025 - Confirm completion of all improvements, as described in (b)9.
Date: 31 May 2026 - Provide a report on the critical review, as described in (b)10.
Date: 31 May 2025 - Confirm completion of all improvements, as described in (b)11.
Date: 31 January 2026 - Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
Date: 31 March 2025 - 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 measures of this Notice need 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: 31 October 2028
Further Details of this Notice:
- 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 Welsh Ministers, 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
Nicholas Adjei
Deputy Chief Inspector, on behalf of the Welsh Ministers
18 December 2024
Reference: DWR-2024-00006