United Utilities Water Limited – Policy, Procedures, Standards and Training

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

Reference: UUT-2021-00006

Version Number: 4

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): United Utilities Water Limited, with registered number 02366678 (hereinafter called ‘the Company’).

Assets Affected:

• Whole Company Procedures and Training

Details of this Notice:

1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a set of reports, under regulation 28(1) of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company submitted on 21 October 2021, which state that there is or has been a significant risk of supplying water from all water treatment works and the connected supply systems in the United Utilities Water Limited supply region that could constitute a potential danger to human health and 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 reported regulation 28(1) Hazardous Events where the control measures include:

Description of associated risk	Regulation 28(1) Control Measure
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Company Water Quality Procedures
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Standard Operating Procedure
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Network Operating Procedure
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Network Operator Training
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Licenced Operator Training
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Management of Contractors on Site
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Procedures Refresher for Contractors
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Liaison with External Stakeholders
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Alarm Response and Procedure
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Discolouration Risk Assessment
If not correctly controlled or applied, could cause a risk to wholesomeness and constitute a potential danger to human health.	Site Specific Disinfection Policy

Table 1: Table of the control measures listed in the company’s reported regulation 28(1) Hazardous Events and the associated risk.

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 Water Quality, Network, Production, Control and Operational Contact Centre personnel (at all levels) to have clearly defined roles and be trained in accordance with Company procedures.
   Date: Ongoing for the duration of this Notice
2. Works operating manuals and works procedures, 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.
   Date: Ongoing for the duration of this Notice
3. Operational staff are kept up to date on policy and procedural changes and competency signed off within 1 month of changes being incorporated.
   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:

Implement the following “Water Quality First” (a United Utilities Water Limited initiative setting out strategic purpose, objectives and success measures in order to provide customers with industry leading water quality) water quality awareness and education initiatives to upskill all Company employees and delivery partners;

• Water quality Education Programme
• Integrated Comms and Engagement

1. Develop and implement an ongoing communication strategy for the Company’s ‘Water Quality First’ programme for all United Utilities employees and delivery partners.
   Date: Complete (31 March 2023)
2. Define all personnel that are relevant to the supply of water for regulation 26 and regulation 4 (1) purposes. Put in place and implement an action plan to ensure they are all aware of the importance of water quality and how their roles contribute to the supply of water presented for disinfection and wholesome water to consumers.
   Date: Complete (31 March 2023)

Implement the following Water Quality First training and competency initiatives across the Company.

• Annual Learning and Development
• Network Knowledge Review
• Process Knowledge Review
• Licence to Operate

3. Complete a critical review of competency across the roles that are relevant to the supply of water for regulation 26 and regulation 4 (1) purposes to establish that relevant competencies are matched to defined roles. This review must include:

• A targeted gap analysis of current competency levels for all Water Quality, Network, Production, Monitoring and Control teams both at technical and management levels who are responsible for asset decisions and operation.
• A review of the Company’s competency assessment procedure.
• A review of how to ensure staff are competent in performing their tasks; and
• A review of the Company’s ‘Licence to Operate’ process and its effectiveness to ensure staff are competent in the roles they are required to complete, before undertaking work.
• Incorporate evaluation of appropriate competency review frequency and when refresher training is suitable for the relevant role.
  Date: Complete (28 February 2023)

4. Identify any measures required to address the findings of the critical review completed under measure (b) 3. above.
   Date: Complete (31 March 2023)
5. Implement any required measures identified under measure (b) 4. above.
   Date: Complete (30 September 2023)

Implement the following Water Quality First policy and procedural review and update initiatives to ensure documentation is fit for purpose.

• Quality Assurance Compliance

6. Company to continue benchmarking exercise to enable Company standards to be aligned with industry good practice. The Company should be an engaged participant in industry forums to facilitate continuous benchmarking of Company standards against other water companies and industry good practice. This must include understanding industry sampling operations and the use of water fittings inspections to support Regulation 18 investigations.
   Date: Complete (30 September 2022)
7. Complete a gap analysis of all water quality response and investigation procedures. Consideration must be given to; benchmarking exercise for Regulation 18 compliance including timely and appropriate parameter sampling (including manual sampling for verification and event sampling to determine the extent).
   Date: 31 August 2024
8. Review the systems and processes that support the above procedures, ensuring robust communication of failures, handover of associated actions and checks on progress through to completion.
   Date: Complete (28 February 2024)
9. Ensure all relevant teams are trained in the new ways of working and any further changes procedures.
   Date: 30 November 2024
10. Carry out an audit to confirm successful implementation of the processes covered by steps 8 and 9 above, with consequential improvements in ongoing compliance with regulation 18.
    Date: 28 February 2025
11. Complete a gap analysis of the water supply process and network planned and unplanned work 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. Consideration should be given to water quality change risk assessments and the use of proactive network flushing during planned and unplanned works and the use of network modelling and manual field readings to inform flushing teams.
    Date: Complete (30 November 2022)
12. Implement any required measures identified under measure (b) 6, 7, and 11. above for procedures, documentation and risk assessment improvements to ensure the delivery of wholesome water in planned and unplanned situations.
    Date: Complete (31 March 2023)

Implement the following Water Quality First root cause analysis initiatives to ensure failure causes are identified and actions are taken to prevent likelihood of reoccurrence.

• Continuous improvement upskilling
• Lessons Learnt
• Infringement Process

13. Develop, put in place and deploy a thorough and efficient root cause analysis process within the Company across Water Quality, Network, Production, Monitoring and Control teams to identify failure causes and resolution actions.
    Date: 30 November 2024
14. Obtain independent verification of the new root cause analysis process being implemented within the Company. Embedding any feedback gained into the new process.
    Date: 28 February 2025
15. Put in place systems and procedures to ensure all lessons learnt identified through root cause analysis (for events, compliance, complaints and audits (both internal and external)) are rolled out to all relevant personnel.
    Date: Complete (31 March 2024)

(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: Complete (30 June 2022)
2. Review and revise (where necessary) the audit strategy defined in measure (c)1, to include the new measures (b)8, 9 and 10, added to this notice at version 4.
   Date: Complete
3. Implement, and keep under continuous review, the audit strategy defined in measures (c)1 and (c)2.
   Date: Following completion of measure (c)1 and (c)2 onwards.

(d) Not to supply water for regulation 4(1) purposes, 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 6 monthly progress reports outlining the progress of section (b) measures, including the following details (as appropriate) with the next progress report:

• Evidence of the completion of the measure and the benefits delivered.
• Timescales of any measures identified to address deliverables in measures listed in section (b).
  Date: Six monthly on 30 June and 30 November until revocation of this notice.

2. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
   Date: Complete (31 July 2022)
3. Submit a revised audit strategy, following review to ensure it covers newly added measures (b) 8, 9 and 10 above.
   Date: Complete
4. Submit any revisions of the audit strategy produced under measure (c)3.
   Date: Within 1 month of a revision
5. 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
6. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
   Date: 30 June 2025

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
17 July 2024
Reference: UUT-2021-00006 v4