Executive Summary (M Sc Wrm 2008)

The Potential for Adapting the UK Water Quality Regulatory
Model for ASEAN Cities
- Further development of a unique Singapore model and a study of
technical example of metaldehyde-containing pesticides in UK as an
illustration of regulatory issues in the UK

MSc Dissertation 2008 by Christopher Chua

Executive Summary

Safe Drinking Water is one of the important factors for the protection of
public health and for supporting national developments for ASEAN cities. There are
wide ranges of technologies available to provide safe drinking water, and funding
available from international organisations like the Asian Development Banks (ADB)
and World Bank (WB) for the implementation of water infrastructure projects for
these developing countries to meet the growing needs of sustainable clean water
supply in lieu of the United Nations Millennium Development Goals (MDG). There
are also a growing number of water professionals and technologists in the region.
However, the developments in regulatory framework and institutional
arrangements needed are not growing in the same pace as the focus on technology
and treatment capabilities. Technology and regulatory frameworks focuses on the
micro- and macro- issues respectively for sustainable water supplies for a
population’s basic needs and national developments.

This dissertation focuses on water quality regulatory models and considers
the possibility of adapting the UK water quality regulatory model for use in assisting
ASEAN countries to develop high levels of drinking water quality in their cities and
surrounding rural communities. The UK model could also potentially be modified
by Singapore in an innovative manner to further develop a unique water quality
regulatory model.

The United Nations recognises that safe drinking water and adequate
sanitation are crucial for reducing poverty, sustainable developments and for
achieving all the Millennium Development Goals (UN news centre, 24 Oct 2007).
The UN targets to halve the proportion of people without sustainable access to safe
drinking water and basic sanitation by 2015. Prüss-Üstün A. et al (2008) concluded
that the frequency of diarrhoeal diseases could be reduced by 25% with
improvement in water supply and by 31% if there is improvement in water quality.

The WHO Guidelines for drinking water quality defines safe drinking water
as water of a certain microbiological, chemical, physical and radiological quality that
does not represent any significant health risk over a lifetime of consumption. The
WHO has, since 1994, provided guidelines, and not international standards, on
drinking water quality and adopted a risk-based approach for setting national or
regional standards and regulations. The WHO guidelines specifies concentration
limits for 2 microbiological quality parameters, 95 chemical quality parameters, 2
radiological screening parameters and 5 acceptability quality parameters.

Drinking water regulations is required to ensure that the roles of each
stakeholder are clearly defined in the provision of safe potable water with effective
control for consumers. Regulations is meant to help water utilities (both public and
Christopher Chua -1- MSc in Water Regulation & Management
Dissertation 2008 Executive Summary

private) in ensuring they are providing the best possible water services to the public
in the local context. An understanding of the current international WHO guidelines,
EU and UK drinking water regulations will allow the development of a suitable
regulatory model that could be adapted by Singapore and ASEAN cities.

The internationally recognised WHO Guidelines for drinking water quality is
commonly used as a reference source for drinking water standards for most
countries in the world, although the WHO recommends that the countries adopt a
preventive approach and cautions that water quality standards should be based on
the local context. The framework for safe drinking water comprises of the health
based targets, water safety plans and surveillance is carried out using a risk based
approach to determine the health related targets to achieve, a multi-barrier critical
assessment and remediation of the entire water supply system from catchment to
tap and active surveillance to ensure that the systems are in place. Surveillance is
either carried out by direct assessment by the regulators or by 3rd party verification
of water supplier’s compliance of regulatory requirements in assessment, testing
and remedial actions.

Institutional arrangements are important factors in successfully adapting the
framework recommended in WHO Guidelines for drinking water quality for the
provision of safe drinking water, especially with regards to amending the legislation
in requiring water utilities to implement Drinking Water Safety Plans (WSPs). There
is a need to balance the preventive approach in the WHO guidelines with regular
and sufficiently frequent monitoring programmes. There is no assurance of water
quality unless there is evidence through proper sampling and analysis of water
samples;

The European Union (EU), comprising of 27 member states, has distinct,
separate legislative, executive and judicial organs of government, the power of
which is transferred from the member states to the community by virtue of treaties
and that the community law overrides the national laws.

The EU council adopted the Drinking Water Directive 98/83/EC (DWD) on 3
November 1998 for all member states to transpose into national law to ensure that
potable water for consumption is clean and wholesome for the protection of public
health in the EU. The DWD requires that water intended for human consumption is
wholesome and clean if it contains no micro-organism, parasites and concentration
of substances that endanger human health; and meet the minimum parametric
values and requirements set out in the DWD. There are 2 microbiological
parameters (5 for water for sale in bottles or containers); 26 chemical parameters
and 20 indicator parameters.

In the UK, England & Wales has a very unique situation, as it has a self-
regulated fully privatized water industry comprising of many of its water companies
being subsidiaries of international enterprises; and many stakeholders, including 3
regulators (OfWat, EA, DWI) looking at economic, environmental and water quality
aspects respectively. Drinking water quality standards specified in the Water Supply
(Water Quality) Regulations 2000 are based on the 1998 EC Drinking Water
Directives. The regulations also specify other water quality related information like
sampling frequency, compliance location, analysis specification and investigations


and actions required in the event of failed parameters. A diagram illustrating the
current UK regulatory model is shown in Figure 1.

WHO
(International Advisory)

Regional
European Union
(Regional)

UK Govt Ministries (DEFRA)

UK Government Agencies (Regulatory)

(England & Wales)
National
Local Water UK & Other
Authorities Associations

Private Water Public Water Suppliers Consumer
Council for water

Consumer
Figure 1. UK Water Quality Regulatory model

The Chief Inspector of Drinking Water is specifically designated by legislation
to act as an independent regulator to ensure that drinking water supplied to
customers in England and Wales is safe and in compliance with the water quality
regulations. The Drinking Water Inspectorate for England & Wales (DWI) carry out
an independent check on all water quality data provided by water companies, carries
out technical assessments on whether the investigation and actions by water
companies are appropriate when there is a breach in standard and carries out audits
for prioritised high risk water supply systems.

May A. (2006) conclude that “privatisation has achieved significant benefits
in drinking water quality, but only with strong regulation and a regulator specifically
dedicated to drinking water quality.” This would also apply to any water supplier,
whether private or public. The reason is that the regulations should be based on
evidence and facts to show where the companies are meeting the regulatory
requirements, and where the improvements have to be made in the water systems.

The advantage of the UK water quality model is that it allows the government
to focus on being regulators, rather than service providers. With a strong
independent water quality regulator, it has proven effective in ensuring that safe
drinking water is provided through regulatory compliance. It is also cost-effective,
as it allows water utilities to be self-regulated and for the provision of water quality
information to the DWI for analysis.


A study of a technical example for metaldehyde-containing pesticides was
carried out to illustrate the role of the UK regulatory model. Metaldehyde, a
common active component for molluscicide, is one of the emerging contaminants
that UK water utilities are required to deal with in their treatment systems. Water
utilities are finding that their current treatment processes (commonly comprising of
GAC and ozone) do not seem to be effective in removing metaldehyde from drinking
water and thus there might be a risk that this might contravene the pesticide
standards. There is also no accredited approach for analysing metaldehyde in water.
Analytical results from the case studies raised many questions as the data does not
seem to make sense, especially since some of the final treated water samples have
higher metaldehyde concentration than that found in the raw water sample.
Sampling and analytical approaches need to be developed to ensure the timely and
accurate detection of metaldehyde in water. These studies indicate that the UK
water quality regulatory structure, the presence of the DWI and the sharing of
information between water companies and DWI have ensured that water companies
are working to monitor and resolve the metaldehyde issue and other contraventions
in a consistent manner.

The Association of Southeast Asian Nations (ASEAN) comprises of 10
Southeast Asian nations and operates primarily on the principles of recognition of
equality and sovereignty of each member country; non-interference in the internal
affairs of other member countries; peaceful resolution of differences and intra-
national issues; and effective co-operation among member countries.

In Southeast Asia, the UN (2008) reported that the percentage of population
with access to clean water in urban areas have decreased from about 94% in 1990 to
89% in 2005, while the percentage in rural areas has increased from about 68% in
1990 to about 76% in 2004. The decrease in percentage for the urban areas appears
to be due to the fact that the service delivery systems are unable to keep pace with
the rapidly growing population.

The Asian Development Bank (ADB) (2005) recommended the need for
establishing a regulatory framework for water services (both public and private
supplies) in Asian countries to ensure that that all stakeholders’ interests are catered
for and that water services are efficient and cost-effective. Based on ADB’s
experience in Asia, there is a need for competent, credible and independent
regulators within a transparent regulatory framework throughout Asia and that
subsidies are the purview of the government and not the water services providers.

There is a critical need to ensure that there are sufficient and adequate safe
drinking water supplies for the rapidly growing ASEAN cities. It is important for
ASEAN to develop ASEAN water quality standards and ensure that its member
countries review and enact the relevant water policies and legislation.

Singapore’s successful experience in water resources management highlights
the need for any country to put in place a long term sustainable water resources
management strategy. It also clearly shows that the Singapore government sees
water as an important strategic resource for survival, public health and economic
development. However, Singapore has just started on developing a regulatory
framework for drinking water quality in view of its future need. A diagram to
illustrate the current Singapore model is shown in Figure 2.

Ministry of Environment & Water Resources
Water Services division
Responsible for overall strategic policy on all water issues (water master plan,
policies and planning considerations, pricing, legislations)
Formulates policies for water industry
Regulates PUB on efficiency & performance
Determines the tariff structure for public drinking water supplies

Other
authorities

National Environment Agency (NEA)
PUB
Environment and Water quality regulator
Manages the entire water cycle
Responsible for approval of Water safety
Responsible for integrated urban water
plans and sampling programme
resources management
Regulations sets the WHO guidelines
Sole public drinking water supplier (except
(1 microbiological, 3 physical, 3
for small private supplies for internal
radiological, 94 chemical
consumption)
parameters) for quality
Regulates operational requirements for parameters and sampling
water supply system (including plumbers) frequency

Operational training for utilities Responsible for regulating private water
supplies

PUB-owned drainage Private owned NEWater
Private water supplies for internal
systems, reservoirs, factories and desalination
consumption (campsites on offshore
water treatment plant owned & operated
islands) – NEA is responsible for water
works, NEWater under the PPP
quality
factories, arrangement

Water Supply system to household, public buildings,
private buildings and industries

Figure 2. Singapore Water Quality Regulatory model

The Ministry of Environment & Water Resources (MEWR) appointed the
Director-General of Public Health to discharge the duties as specified in the
Environment Public Health Act 1987 under section 3 of the said Act (Singapore
Government, 1987). The act allows the National Environment Agency (NEA) to
introduce the new Environmental Public Health (Quality of piped drinking water)
Regulations 2008 as well as the Code of Practice for piped drinking water sampling
and safety plans recently in 2008. However, the specified water quality parameters
include 1 microbiological parameter, 95 chemical parameters, 3 radiological
parameters and 3 physical-chemical parameters, which are essentially extracted

entirely from the WHO Guidelines for Safe Drinking Water (Singapore Government,
2008) (NEA, 2008).

With the introduction of the new Environmental Public Health (Quality of
piped drinking water) regulations 2008, NEA has formed a new Drinking Water
Unit (DWU) to be responsible for regulating water quality for both public and
private water suppliers, while PUB, Singapore’s national water agency, is likely to be
still responsible for the technical and operational requirements of water supply
(PUB, 2008).
Singapore has successfully implemented sustainable water resources
management and has been focusing on technology development. The government
has just started on developing a regulatory framework for drinking water quality.
The introduction of the new regulations in Singapore and the DWU are positive
steps in aligning with the WHO Guidelines on drinking water quality and in
ensuring the sustainable development of safe drinking water in the country

As the DWU is a relatively new regulatory unit, it would be useful to
collaborate with the DWI to develop its competencies in a unique Singaporean
model. To discharge its duties, some of the possible areas in which the DWU can
develop to strengthen its competencies and knowledge are to:
o Set up water quality database for water quality analysis;
o Develop frameworks for technical audits and incident investigations;
o Refine the Singapore water quality standards and tighten the water quality
legislation;
o Focus research on emerging water quality issues; and
o Provide continual training for staff in water treatment, water quality and
public health issues required in carrying out their regulatory functions.

Arising from the research, a flexible basic water quality regulatory model for
ASEAN cities, shown in Figure 3, is proposed to be adapted for each ASEAN city to
ensure adequacy and sufficiency of an uninterrupted supply of safe drinking water
in ASEAN cities. The model is split into International, Regional/sub-regional, and
National arrangements to identify the roles of different stakeholders. The model is
developed by adopting the principles found in the effective UK regulatory model and
in Singapore’s success in integrated water resources management.

The dissertation focuses only on water quality regulatory models and has
only covered the tip of the iceberg of the challenges faced in the provision of a
sustainable, uninterrupted and safe drinking water supply to the ASEAN cities.
Some potential areas of further studies are the:
o Further development and implementation of the ASEAN water quality
regulatory model, taking into consideration the local conditions within the
ASEAN member countries;
o Development of a training framework for competent regulators;
o Review and tighten the Singapore water quality legislations;


o Identification of the institutional arrangements required for the
implementation of the WHO framework for safe drinking water; and
o Development of strategies for the effective treatment and control of
metaldehyde in drinking water.


International Regional &
United Nations WHO
(International Co-ordinator & Support) (International Health Authority & Advisor)

ASEAN

Sub-regional
(Regional co-ordinator and advisor)

ASEAN Network of
Water Regulators

National Environment Ministry

Accredited Regulatory Agencies Ψ
Laboratories Water Quality Regulator

Public Water Agency

Public Statutory Private Water
Water Supply Supplier
Public owned companies
drainage and

National
reservoir system

Public Owned Private Water Public Statutory
works works Supplier works

Public Water Agency Public Statutory Supplier
Distribution Network ж distribution network ж
ж

Consumer
Ж – Consumer Representative group
Ψ – Regulatory agencies include the environment agencies, land use/town
planning authorities, accreditation authority, and local authorities/councils
Figure 3. Proposed ASEAN Water Quality Regulatory model


Executive Summary (M Sc Wrm 2008)

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