Independent Water Networks Limited: All assets risk assessment review and methodology update
Notice under regulation 27(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)
Reference: IWN-2024-00001
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Independent Water Networks Limited, with registered number 05776438 (hereinafter called ‘the Company’).
Assets affected:
All water quality zones listed in Annex 1.
Details of this Notice:
- This Notice is served on the Company by the Drinking Water Inspectorate on behalf of the Secretary of State, under regulation 27(4) of the Water Supply (Water Quality) Regulations 2016 (as amended) for the assets listed above, for risks associated with:
- Drinking water safety plan processes, procedures and documentation that do not provide confidence that the World Health Organisation (WHO) approach has been fully adopted.
- The significant number of risks classified, according to the company’s methodology, as “Very High Risk” with no control measures in place.
- Inadequate and generic control measures, and the validation of these measures, relating to company and incumbent controls.
- Integrity issues with company and incumbent data.
- The company’s approach to obtaining information/data from incumbent companies.
Requirements:
- The Company is required to satisfy the following:
(a) Review of risk assessment:
- Conduct a review of the methodology used by the company to carry out risk assessments as required by regulation 27(2) and in accordance with the WHO approach. This will include:
Review of the WHO approach and compare against the Company’s current DWSP methodology.
Date: 31 July 2024
Undertake a gap analysis of the WHO approach and the Company’s DWSP methodology, including planning for improvement.
Date: 30 September 2024
Develop and update the Company’s DWSP methodology using the gap analysis and make alterations to the methodology where applicable. This will also include developing current methods on auditing, risk management, new hazardous events and associated hazards, new supply zones, Regulation 31 risks, risk scoring and profiling, incumbent risks, risk categories and escalation.
Date: 31 December 2024
Provide training to team members on all changes to the methodology and reporting tool.
Date: 31 August 2025 - Complete a review of the control measures employed to mitigate risks identified, as well as their associated validation measures. This will consider both company and incumbent control measures and will address the risks classified as “Very High Risk” with no control measures in place. This will include:
Review of the Company’s current control measures and associated validation measures post-gap analysis of WHO and the Company’s methodology.
Date: 31 January 2025
Develop and update the methodology with the new control measures and validation measures. This will address the risks which are classified as “Very High Risk” as well as risks which originate upstream.
Date: 31 March 2025
Post-database creation, create a visualisation of incumbent high risks and control measures by Company zone. Develop a visualisation tool of incumbent risks which change once an incumbent’s risk update is added to the database.
Date: 31 July 2025
Review of all incumbent high risks and control measures using the visualisation tool. Use incumbent high risk visualisation tool in incumbent liaison meetings. Provide training to team members on all changes to the methodology and process.
Date: 31 August 2025
Alter and develop internal guidance on proactive communication with the incumbent regarding significant incumbent risk changes. Develop methodology for a control measure or comment for incumbent high risks which are discussed with the incumbent. Consider and document additional control measures that the Company may be required to implement should the incumbent controls be considered inadequate or not sufficiently timely in delivery. Provide training to team members on all changes to the methodology. Update the methodology to include any new processes or adjustments to the risk assessments.
Date: 30 September 2025
Update risks to include new control measures or comments regarding communication with incumbents on their high risks. Date: 21 October 2025 - Carry out a review of all risk assessments submitted to the Inspectorate under regulation 28(1), for the assets listed in Annex 1. This will include:
Review of current regulation 28’s held by the Inspectorate and identify risk lines which require updates, including those which need to be changed to an X category. Submit an update to the Inspectorate.
Date: 21 October 2024
Post-upload of the last three years of the Company’s risk into the database, create a visualisation tool to monitor and track trends of the Company’s risks; this will include risk categories and changes to risk. In addition, link zones which are no longer in commission to the visualisation tool.
Date: 31 July 2025
For future submissions, use the visualisation tool to review zones which are no longer in commission and compare them to the information held on the database, specifically relating to X risk categories.
Date: 30 August 2025
Review of risk categories held on the database and amend risk lines.
Date: 30 September 2025 - Conduct a review of the company and incumbent data and information/ documentation held by the company in relation to risk assessments and implement controls regarding data integrity. This will include:
Create a database which contains incumbent data used for the Company’s risk assessments. Upload the Company’s risk assessments from the previous three years into a database.
Date: 31 October 2024
Develop a system which links the Company’s data used for the risk assessments. Create or convert the Company’s data and link to the database; this includes the water supply zone and incident database. Create an automated system which uses the Company’s and incumbent data/information to form the risk assessments to ensure that the data used is robust. Develop a tool which ensures that the risks are exportable in DWI reportable format by zone.
Date: 30 April 2025
Create a visualisation tool of the risk assessments held in the database.
Date: 31 July 2025
Update the methodology to include the database and visualisation tool. Provide training to team members on all changes to the methodology.
Date: 31 August 2025 - Carry out a review of the company’s approach to obtaining information/data from incumbent companies. This will include:
A review of current incumbent contact information.
Date: 31 July 2024
A review of the Company’s approach to liaison to ensure that it obtains the necessary information to understand incumbent risks and any mitigation measures being delivered (including timescales). Include this information within methodology document.
Date: 31 August 2024
Convert incumbent data request tracker to SharePoint™ and create a visualisation tool to ensure that requests outside of Service Level Agreement (SLA) are flagged.
Date: 31 August 2024
Post-creation of the visualisation tool of the risk assessments held in the database, review incumbent risk categories for upstream risks and review how these risk categories are used for PFAS.
Date: 30 September 2025
(b) Reporting:
- Submit the revised or new risk assessments (as appropriate) as outlined in section (a), accompanied by a Board level Director sign-off.
Date: 21 October 2025 - Submit the new methodology and updated risk lines which have been impacted by methodology changes, to the DWI.
Date: Completion of final action no later than 21 October 2025
Signed
Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
18 June 2024
Reference: IWN-2024-00001
Annex 1 – Assets affected:
|
Site Reference |
Site Name |
|---|---|
|
ZAF0102 |
Folkestone Hythe |
|
ZAF0202 |
Stort Bourne |
|
ZAF0302 |
Houghton Regis |
|
ZAF0401 |
Affinity Thames |
|
ZAF0501 |
Tendring Underground |
|
ZAF0701 |
Sawbridgeworth |
|
ZAF0801 |
Adeyfield |
|
ZAF0901 |
Hart Lane |
|
ZAF1001 |
Buckland Drellingore |
|
ZAF1102 |
Sibley’s Uttlesford |
|
ZAF1201 |
Codicote |
|
ZAF1301 |
Slip End |
|
ZAF1401 |
Whitehall |
|
ZAW0106 |
Rutland Grafham |
|
ZAW0301 |
Elsham |
|
ZAW0401 |
Mousehold Lakenham |
|
ZAW0501 |
Ipswich |
|
ZAW0601 |
Colchester Bures |
|
ZAW0701 |
Hartlepool |
|
ZAW0801 |
Stanton |
|
ZAW0901 |
Meppershall |
|
ZAW1001 |
Gringley |
|
ZAW1101 |
Bow Brickhill |
|
ZAW1201 |
Warren Hill |
|
ZAW1301 |
Covenham |
|
ZAW1401 |
Saltersford Clayhill |
|
ZAW1501 |
West Bradenham |
|
ZAW1601 |
Bracebridge Heath |
|
ZAW1701 |
Great Cornard |
|
ZAW1801 |
Langham and Layer |
|
ZAW1901 |
Earls Colne |
|
ZAW2001 |
Marham Stoke Ferry |
|
ZAW2101 |
Burnham |
|
ZAW2201 |
Melton |
|
ZBM0101 |
Alderney |
|
ZBW0102 |
Banwell |
|
ZBW0201 |
Barrow |
|
ZBW0301 |
Purton |
|
ZCW0101 |
Cambridge |
|
ZES0101 |
Chelmer Blackwater |
|
ZES0301 |
Chigwell |
|
ZNW0102 |
Tyneside |
|
ZNW0202 |
Wearside |
|
ZNW0301 |
Teesside |
|
ZNW0401 |
Wansbeck |
|
ZNW0601 |
South Durham |
|
ZNW0702 |
Mosswood |
|
ZNW0801 |
Syleham |
|
ZNW0901 |
Redgrave |
|
ZPW0101 |
Portsmouth |
|
ZPW0201 |
Chichester |
|
ZPW0301 |
Bognor |
|
ZPW0401 |
Racton |
|
ZSE0102 |
East Kent Wells |
|
ZSE0301 |
North Kent Wells |
|
ZSE0401 |
Surrey Hills |
|
ZSE0502 |
Horsted Keynes |
|
ZSE0601 |
West Ham |
|
ZSE0701 |
Cuckmere Friston |
|
ZSE0801 |
Hockers |
|
ZSE0901 |
Lasham |
|
ZSE1001 |
Poverty |
|
ZSE1101 |
Ditton |
|
ZSS0101 |
Sedgley |
|
ZSS0201 |
Hopwas |
|
ZSS0301 |
Blithfield |
|
ZST0202 |
Northfield |
|
ZST0302 |
Warwickshire Rugby Stratford |
|
ZST0401 |
Derby City |
|
ZST0501 |
Stoke |
|
ZST0601 |
Kidderminster |
|
ZST0701 |
Telford |
|
ZST0801 |
Mitcheldean |
|
ZST0901 |
Leicestershire South |
|
ZST1001 |
Nottingham Central |
|
ZST1101 |
Trimpley |
|
ZST1201 |
Wolverhampton North |
|
ZST1301 |
Chequer House |
|
ZST1401 |
Ogston |
|
ZST1501 |
Shelton |
|
ZST1601 |
Boughton |
|
ZST1701 |
Draycote |
|
ZST1801 |
Braybrook |
|
ZST1901 |
Melbourne |
|
ZST2001 |
Caunton Ompton |
|
ZST2101 |
Hatton Warks |
|
ZST2201 |
Mythe |
|
ZST2301 |
Uckington |
|
ZST2401 |
Oakham |
|
ZSW0102 |
Sussex North |
|
ZSW0202 |
Hampshire South |
|
ZSW0301 |
Medway East |
|
ZSW0401 |
Broadstairs |
|
ZSW0501 |
Burham |
|
ZSW0701 |
Hardham |
|
ZSW0801 |
Beauport |
|
ZSW0901 |
Overton |
|
ZSW1001 |
Burpham Batworth |
|
ZSWE0101 |
Capel Lane |
|
ZSWE0201 |
Prewley |
|
ZSWE0301 |
Woodgreen |
|
ZSWE0401 |
Allers |
|
ZSWE0501 |
Delank |
|
ZSWE0601 |
Avon |
|
ZTW0102 |
Kent Wells |
|
ZTW0203 |
TWRM |
|
ZTW0302 |
Aylesbury |
|
ZTW0601 |
Coppermills |
|
ZTW0701 |
Cleeve |
|
ZTW0801 |
Netley |
|
ZTW0901 |
Baunton |
|
ZTW1001 |
Axford |
|
ZUU0101 |
Woodgate Hill |
|
ZUU0201 |
Lostock |
|
ZUU0301 |
Lightshaw |
|
ZUU0401 |
Ridgaling |
|
ZUU0501 |
Franklaw Fishmoor |
|
ZUU0601 |
Fishmoor |
|
ZUU0701 |
Cornhow Williamsgate |
|
ZUU0801 |
Sutton Hall |
|
ZWW0101 |
Yeovil |
|
ZWW0501 |
Purbeck |
|
ZWW1101 |
Trowbridge |
|
ZWW1301 |
Dorchester |
|
ZWW1601 |
Minehead |
|
ZWW2001 |
Dewlish |
|
ZYW0102 |
Derwent |
|
ZYW0202 |
Chellow |
|
ZYW0301 |
Yorkshire Wolds BHs |
|
ZYW0401 |
Harrogate |
|
ZYW0501 |
Selby |
|
ZYW0601 |
Leeds |
|
ZYW0701 |
Nutfield Hatfield |
|
ZYW0801 |
Scarborough |
|
ZYW0901 |
Northallerton |
|
ZYW1001 |
Wetherby |
|
ZYW1101 |
Halifax |
|
ZYW1201 |
Embsay |
|
ZYW1302 |
Acomb |
|
ZYW1401 |
Haisthorpe |
|
ZYW1501 |
East Ness |