Guidance For Providing Safe Drinking Water in Areas of Federal Jurisdiction - Version 1

Introduction

In Canada, the responsibility for providing clean, safe and reliable drinking water to the public generally lies with the provincial and territorial governments.

That said, the federal government has or shares responsibility for ensuring the safety of drinking water supplies on federal lands, in federal facilities, and in First Nations communities. While most supplies and facilities are located on Canadian soil, others such as military vessels and Canadian diplomatic missions may lie outside of Canada's physical borders.

In some cases, departments may have responsibilities for drinking water right from the source through to the tap. In others, departments may only be responsible for the quality of drinking water after it enters a federal building or facility and until it reaches the consumer.

The goal of the federal drinking water program is to protect the health of consumers by providing them with a clean, safe and reliable supply of drinking water. As a matter of policy, the onus for making sure these supplies are safe rests with each department.

Departments demonstrate the safety and reliability of their supplies through their monitoring programs, developed through and complemented by periodic sanitary surveys, vulnerabilities assessments and chemical baseline analyses.

Departments, and other responsible authorities, accountable for treating their own water, will have to develop more comprehensive quality management programs than those that receive treated water from a well-regulated outside agency (e.g., municipality).

In locations where the quality of tap water is unreliable or consistently unsafe for consumption, a department or responsible authority may choose to provide additional localised treatment through the use of point-of-entry or point-of-use devices, or by providing an alternative source to consumers, such as bottled water.

This document recognizes that federal government drinking water purveyors face a number of challenges in carrying out their duties, including:

• The size and location of drinking water systems: Most federal drinking water systems are very small, serving fewer than 500 people. In addition, many of these systems are located in remote areas, in countries where water supplies may be unreliable², or on-board airplanes and ships, including Coast Guard and military vessels.
• Jurisdiction(s) responsible for the source water: In some cases, the federal government has jurisdiction over the land which contains the source used for drinking water at a given facility and is also the operator of the facility. In many situations, though, the water source falls under the jurisdiction of a provincial government and the drinking water treatment plant is operated by a public or municipal utility. In remote locations, drinking water may need to be hauled into a community by truck. In other cases, the only practical water supply may be bottled water.
• Cost of infrastructure: Because the number of people served by the federal government in each location is often very small, the per capita cost of installing, operating and maintaining the necessary infrastructure is extremely high. This cost increases further with remote locations.
• Cost of water quality monitoring: The costs associated with water quality monitoring are based on the number of samples and the type and frequency of tests conducted, not directly on the number of people served by a water system. Because of the number of federal systems and the relatively small number of people served by each one, the relative costs for water quality monitoring are high.
• Jurisdictional issues: Because of challenges related to the source water responsibilities or to cost issues, the federal government may enter into agreements with other governments or third parties to provide drinking water to its facilities. In some cases, the lines of responsibility may not be clear.
• Funding: In order to ensure that federal drinking water systems are properly designed, constructed, operated and maintained, departments need to have adequate funds and program management controls in place. On-going funding is also required to cover employee training and infrastructure maintenance and upgrades. Some departments may not have adequate funding structures or agreements in place to cover these costs.

Purpose

The purpose of this document is to give clear, consistent guidance on how to implement the Guidelines for Canadian Drinking Water Quality and the Canada Occupational Health and Safety Regulations of the Canada Labour Code. Guidance is directed to federal civil servants and other responsible authorities whose jobs relate, either directly or indirectly, to ensuring the safety of drinking water on federal lands, in federal facilities and/or in First Nations communities. These employees could be at a management or policy-setting level, or could be directly responsible for drinking water supplies, such as treatment plant operators or drinking water monitors.

Technical standards, benchmarks and targets for water quality are provided to assist federal departments and responsible authorities to meet the Guidelines for Canadian Drinking Water Quality and drinking water-related regulations. Meeting these requirements will ensure a more consistent approach to managing drinking water systems across areas of federal jurisdiction.

All affected departments and authorities are encouraged to at least meet the minimum guidance set out in this document in order to protect the health of the people they serve. In some cases, it may be preferable for a department to meet more stringent objectives than those detailed in this document. This decision is left to the discretion of each department or responsible authority.

It is recognized that departments operating unique facilities, such as those in remote locations or in locations beyond Canadian borders, may face challenges that prevent them from meeting all the guidance contained in this document in a timely manner. In such cases, these departments are encouraged to strive to meet the guidance to the best of their ability.

Scope of this document

This document relates to the management of drinking water supplies on federal lands and in federal government facilities. These supplies include those serving:

• federal government employees working in Canada, as well as Canadian Coast Guard, Canadian Forces personnel, and federal government Canadian diplomatic mission staff working abroad
• inmates, staff, and visitors to federal correctional facilities
• Visitors to federal lands and facilities
• Residents of First Nations communities

The guidance in this document applies to facilities owned by and/or leased to and/or funded by the federal government.

The document describes the requirements for conducting assessments; for designing, operating, and maintaining drinking water treatment and distribution systems; and for setting up, running, and evaluating monitoring programs. Departments may have, or wish to develop, more detailed protocols for their staff which address their department's unique circumstances or requirements. This guidance document is meant to complement such efforts.

Given that the majority of federal water systems supply drinking water to fewer than 500 people, the guidance contained in this document relates primarily to very small drinking water systems.

While this document recognizes the importance of managing drinking water from source to tap, source water issues are touched on only briefly. Waste water issues are considered to be beyond the scope of this document.

How to use this document

The document is divided into two main parts: Part 1: The Federal Framework (Sections 1 and 2) and Part 2: Application of the Federal Framework (Sections 3 to 8).

Part 1: The Federal Framework

Section 1: Setting the Stage provides details about the multi-barrier approach to safe drinking water and key jurisdictional issues related to drinking water in Canada. The multi-barrier approach is the overarching concept which ties together each of the individual commitments and tasks outlined in the subsequent sections.

Section 2: Federal Legislation and Policies outlines the federal government's legislated and policy-based responsibilities as a purveyor of drinking water on federal lands and in First Nations communities, as well as in facilities owned or leased by the federal government.

Part 2: Application of the Federal Framework

Section 3: Surveys, Assessments and Monitoring outlines the steps involved in developing a monitoring program, including the choice of the source water, and conducting vulnerabilities assessments, the sanitary survey and the baseline chemical analysis.

Section 4: Technical Standards, Benchmarks and Targets is a summary of the standards, benchmarks and targets that federal drinking water purveyors must strive to meet.

Section 5: Treatment System Design and Maintenance looks at various design and maintenance issues related to the treatment system.

Section 6: Distribution System Design and Maintenance looks at various design and maintenance issues related to the distribution system, including the distribution of drinking water within buildings and other federal facilities (i.e., plumbing systems).

Section 7: Operational Requirements provides guidance on a range of issues, including operational planning, operator certification, monitoring requirements, record-keeping, incident and emergency response planning, and audits.

Section 8: Information and Resources provides readers with further resources.

² A concern for Canadian diplomatic missions and Canadian Forces personnel