These comments are made from…

These comments are made from the point of view of both an auditor (internal and external) and a QMS representative.

• Element 9 was updated to include the comment role and/or job title for Management Review and Top Management. The Roles, Responsibilities and Authorities section and the definition section does not have this update. These sections both still refer to the person, persons or group of people. Consider adding the same to these sections.

• Element 3 – Under the Plan section it has a requirement that the both the Owner and Top Management provide a written endorsement of the contents of the Operational Plan. There is no DO requirement for the Owner. Consider including a DO element for the Owner.

• Element 3 and Element 4 – in both of these elements there lists a requirement for ensuring that the either the Operating Authority or the personnel are aware of all applicable legislative and regulatory requirements. This is a redundant requirement. It is a difficult task for one person to be responsible for this. It should be all staff that are responsible for ensuring that they are aware of legislation. It could be listed under Element 9 or 10 instead. There should also be consideration to creating a requirement for listing regulatory requirements. This would create a similar requirement to what is in place already, but it wouldn’t list specifically one person being responsible for it.

• Element 4 – items c) sets up the QMS Representative for failure. This is not something that can truly be done by one person. An auditor should technically give a non-conformance for this if there are any Document Control issues identified during the audit. Consider updating this to say something about being responsible for updating documents and passing on information.

• Element 6 – Item a) ii) and iii). My understanding is that ii) is for systems that are treatment systems and iii) are systems that are distribution only systems. The way iii) is written it sounds like there are systems that don’t have primary or secondary disinfection. All systems would require secondary disinfection (even if equipment isn’t present). Consider writing these as Treatment and Distribution Only instead.

• Element 7 – consider changing the requirements for the review on this element. It should emphasize that the Risk Assessment is updated with major changes and reviewed annually. The 36-month requirement is not valuable. Some people believe that they need to redo the entire thing from scratch every 36 months which is not the intent. As an example, changing a rating from a 3 to a 4 does not typically create new procedures or even change the critical control points. There is no value in this. The value comes from identifying new or increasing risks and this shouldn’t wait until a 36-month review. If this change isn’t considered, then the 36-month review should at least be changed to every 3 calendar years.

• Element 6 and 9 – In both of these Elements it says that the Owner has to be identified. This is redundant. Considering removing the requirement in these Elements and putting it in Element 1.

• Element 18 – Consider listing a requirement for how often the emergency response testing should be completed. Most auditors expect that this is completed on an annual basis and this would be considered best management practice. Emergency preparedness is a critical component of providing safe drinking water.

• Element 21 – Most operating authorities are considering Best Management Practices on a regular basis and not waiting for every 36-months. Consider removing the 36-month requirement or at least changing it to every 3 calendar years. It may be beneficial to include this in the Management Review instead of the Continual Improvement.