Directive A PHI will conduct a site-specific risk assessment and issue a “directive” for each SDWS outlining the operational requirements that must be carried out by the owner/operator. The directive is a legal document that is specific to each drinking water system, and can include requirements for sampling, testing, treatment, training, and posting signage. Both the owner/operator have a legal responsibility to ensure compliance with the directive and failure to do so may result in legal action. It is important to note the directive is in effect as long as the SDWS is operational, and is still applicable when a new owner or operator is designated. Amendments to the directive can be made, or a new directive can be issued when necessary (e.g. additional treatment). Appealing a Directive Section 38 of Ontario Regulation 319/08 allows owners of SDWSs to request a review by the local Medical Officer of Health (MOH) within seven days of a directive or an amendment to a directive being issued. Requests must be in writing and include: The sections of the directive or amendment to a directive to be reviewed Any submission that should be considered by the MOH A current mailing address for the purpose of receiving the MOH’s decision If you are considering seeking a review, please refer to Ontario Regulation 319/08 for complete details of the review process. Compliance Monitoring and Progressive Enforcement Owners/Operators are responsible for ensuring sampling, testing and maintenance of SDWSs is conducted in accordance with directives, applicable regulations and guidelines. Public Health Inspectors monitor compliance by: Reviewing water sampling test results and compliance in the Laboratory Results Management Application (LRMA) Following up during other public health routine inspections/assessments Responding to adverse water quality incidents, complaints and inquiries Non-compliance means the owner/operator is not following the requirements prescribed by the regulation or directive. Some examples of common non-compliance issues are failure to sample
If contaminants are naturally occurring and are not expected to increase, or the test result is limits specified in the Ontario Drinking Water Quality Standards, repeat testing may not be required. The Ontario Drinking Water Quality Standards sets the maximum acceptable concentrations, aesthetic objectives and operational guidelines for various parameters of drinking water such as taste, odour and turbidity, as well as several different minerals, metals and chemicals that can be present through industrial, commercial, and agricultural processes. If contaminants have the potential to fluctuate in a manner that may pose a risk to the health of regular sampling and testing may be required. As always, remember to follow licensed laboratory instructions to ensure proper collection and submission of samples. Operational Checks All owners/operators are required to conduct operational checks of their SDWS at a frequency indicated in their directives, equipment manufacturer guidelines, or as required to maintain the system. Operational checks include but are not limited to: Testing free available chlorine or combined chlorine residual levels Measuring turbidity – a measure of the amount of suspended material in water which can impact disinfection processes Monitoring the status of equipment i.e. UV system status, filter condition, chlorine solution level Conducting well inspections including inspection of the well cover or sanitary seal for cracks and holes; examination of the condition of well vents Ensuring all filters and treatment devices are maintained as per the manufacturer’s directions Where filtration and primary or secondary disinfection is required: Chlorine residual should be tested once every 24 hours or as directed by a PHI Turbidity should be tested at a frequency in accordance with risk level and system configuration Ensure water treatment equipment is: Operated whenever is being supplied