Toronto Water appreciates…

Toronto Water appreciates the opportunity to review and provide comments on the above-noted proposal. Toronto Water has committed to achieving full compliance with all applicable legislation and regulations and has an excellent and established compliance history. We have and continue to develop proactive quality management systems to ensure ongoing compliance with regulations as well as continuous improvement.
Toronto Water has reviewed the proposal document (Changes to the Protocol of Accepted Drinking Water Testing Methods and Practices for the Collection and Handling of Drinking Water Samples Documents).
We have the following questions on the Updated Protocol of Accepted Drinking Water Testing Methods V3, and request for clarification from the MECP:

1. In section 1.2.1 “Criteria for Licensing - Accepted Reference Method” under “Data Reporting” subsection, the second bullet states that the laboratory’s test results report must “include one additional digit more than the ODWQS concentration where possible”.

Does this supersede the data reporting requirement in the “Laboratory Update Bulletin: Drinking Water Testing, Issue 2”, where the data reported is required to “be expressed by two to three significant figures for the expression of chemical data.”?

2. In section 1.2.2 “Additional Criteria – Alternate Reference/In-house Methods” under section (a) “Confirmation of Identity”, what does the MECP consider as “authentic” reference standard?

3. In Appendix C “MECP Sample Collection and Handling Requirements”, the maximum holding time for Benzo(a)pyrene was listed as “20 days before extraction, 40 days after extraction at ≤ 10°C” with reference to E3480.

However, Revision 7 of the E3480 (July 2023) states the maximum holding time of Benzo(a)pyrene as “extract within 14 days and 40 days after extraction”

There is a discrepancy with Reference Method E3480. Does the reference method trump the document (Updated Protocol of Accepted Drinking Water Testing Methods)?

Toronto Water is appreciative of the opportunity to submit these questions and considerations and looks forward to the Ministry's responses.