The Drinking Water Quality Regulator for Scotland (DWQR) is open for business, although as with all of us – under very different conditions than we were used to.
DWQR is the title of the Regulator herself: Sue Petch, who is independent of Scottish Ministers and is responsible for the scrutiny of the water company in Scotland, Scottish Water, with respect to drinking water quality; and the supervision of local authorities in their regulation of private water supplies.
There are ten of us in the Drinking Water Quality team authorised to work for Sue; covering operations, policy and support functions (we also use the term ‘DWQR’ to apply to the whole of Sue’s team). The Operations Team are primarily involved with the regulation of Scottish Water, and assisting with the supervision of local authorities who regulate private water supplies. The Regulatory Team are responsible for developing and implementing legislation, guidance and other policies with respect to drinking water quality in Scotland, as well as managing all of our data. Lately we have been setting up and leading a steering group to advance and overhaul private water supplies legislation; and are also trying to make sense of the recast Drinking Water Directive. To achieve all of this we are usually busy attending meetings with a variety of stakeholders; visiting water treatment works for investment sign-off, audits and incident investigation; contributing to training and conferences; and researching innovation. We are rarely all in the office at the same time and each week is different and brings its own challenges.
However at time of writing we are under lockdown in Scotland, and we anticipate that even when restrictions are eased things will not return to ‘normal’ for some time to come – either for us in DWQR or Scottish Water.
Over the last few months we have developed and adapted our working practices to accommodate the necessary changes required by our current circumstances so we can continue to provide the necessary direction to Scottish Water and local authorities in a fast-changing situation.
The backbone to regulation is the sampling and analysis of drinking water from consumers’ taps at a frequency set by legislation. Back in February we could see the potential for COVID-19 to make a significant change to the practices of regulatory sampling if it became an issue in Scotland, so after discussion with Scottish Water we developed and issued alternative sampling guidance so that samplers did not have to cold call consumers and to take account of potential staff absence. We were also aware that the households sampled were often elderly as these people were more likely to be at home during the day (pre-lockdown), and both Scottish Water and DWQR did not wish to risk their health or unnecessarily cause concern. Around the same time Scottish Water samplers started to experience some pushback on doorsteps from consumers who were wary at allowing access to their homes. We formalised the guidance in Information Letter 1/2020 and initiated regular virtual meetings with Scottish Water’s scientific services and public health team to keep communication open and monitor the situation. The Information Letter allowed Scottish Water to cease sampling from consumers’ taps and instead take zonal samples from storage point outlets and final water sample points, with the exception of plumbing metals which are to be caught up when restrictions are lifted. The overall aim is to ensure that public health is safeguarded at all times.
Meanwhile in DWQR HQ we postponed conferences in Edinburgh and Inverness organised with Scotland’s local authorities on private water supplies and cancelled non-essential visits to Scottish Water sites.
The week before lockdown was officially announced we held our annual business planning meeting under the cloud of realisation that this was probably the last time we would be in each other’s company for the foreseeable future. This was especially poignant for our colleague Hollie, who is now on maternity leave and very busy with preparations of her own!
Like the rest of the world, the end of March felt like it took about a year and April flew by, as we all got used to life at home and online. We confirmed the changes to Scottish Water’s operations for sampling and analysis and kept in regular contact about these as everyone adapted to the ’new normal’. Specific challenges for Scottish Water have included the transport of samples from the Scottish islands with restricted flights and ferries, which has resulted in subcontracting microbiology samples to a local UKAS accredited lab in Shetland. When bottle necks in analysis formed, the analysis of some indicator parameters (including colony counts) were temporarily suspended. Cryptosporidium sampling and analysis was scaled back to the regulatory minimum. These measures were done with full consultation and agreement of DWQR, and analysis restarted as soon as resource was available. The rigour demonstrated by the company has meant that DWQR has a high level of trust in their intentions and actions to only reduce their service when absolutely essential.
Fortunately the Scottish Government has always advocated working from home, and we were able to transfer all our internal meetings to videoconferencing without too much difficulty. The software and internet has (mostly) held up under the strain – and we have all becoming more tech savvy. Our meetings with external stakeholders are all online now too: with Scottish Water and also DEFRA and DWI, local authorities and other regulators. We even hold regular team ‘cake’ meetings online (as we have to provide our own cake, it’s an excuse to show off our new baking skills).
So at the moment we are in a new ‘business as usual’ phase. We continue to regulate from a distance: scrutinising data and events; examining paperwork and asking for photo/video evidence and auditing by videoconference. Our regular meetings with Scottish Water continue. DWQR may still visit Scottish Water sites when required for urgent regulatory purposes, taking account of any reasonable precautions requested by the company. The whole team is involved in writing our Annual Report at the moment, which is something that lends itself to working from home. We’re also doing plenty of training online, and without travel to occupy our weeks, we are eventually getting to the bottom of our ‘to do’ lists.
Looking forward, we are working towards exit strategies – including protocols for physically distant site visits and audits, and preparing with Scottish Water for an eventual return to ‘normal’ regulatory sampling – with the constraints of physically distancing and the awareness that consumers may be very reluctant to welcome doorstep calls for some time. At the moment the discussion is around sampling from Scottish Water employee’s homes and from trade and public buildings where this is appropriate to get the correct spread of zonal samples. The DWQR team have also offered their kitchen taps as sample points.
Over the last few months DWQR has developed new ways of working that we are confident will ensure our scrutiny of Scottish Water and drinking water quality continues despite the constraints we are all enduring, and we look forward to the day we can do something as simple as attend a meeting where someone else brings the biscuits.
Special thanks to Moira Malcolm, Drinking Water Specialist at DWQR for submitting this content, an interesting read on how fellow regulators are adapting their work under current Coronavirus restrictions.