RE: York Region Response –…

RE: York Region Response – ERO 019-8413 – Updates to the Drinking Water
Quality Management Standard (DWQMS)

Mr. Manning,

York Region thanks the Ministry of the Environment, Conservation and Parks (MECP)
for the opportunity to provide feedback on the proposed updates to the Drinking Water
Quality Management Standard (DWQMS). It is requested that the Province consider
these comments when finalizing DWQMS 3.0.

Align DWQMS updates with ISO 9001: 2015 to promote standard harmonization
and best practices

York Region staff recommend revising Element 4 – Quality Management System
Representative and Element 21 – Continual Improvement to align with International
Organization for Standardization (ISO) standards to promote shared responsibility and
risk-based thinking.

Staff are concerned that Element 4c is impractical as the requirement to appoint a
single management system representative places undue burden on a single individual
to ensure all current document versions are always in use across the entire system.
Instead of having one Quality Management System (QMS) Representative, sharing
responsibility among top management ensures leaders are engaged in the quality
management system and system performance. This drives support and accountability
across the organization. It’s been York Region experience that ISO 9001 QMS
emphasis on shared leadership and commitment of top management in the
administration of management systems has a net positive effect on driving management
system buy-in. Applying the ISO principle of shared responsibility to DWQMS can help
ensure drinking water systems are maintained effectively and supports continual
improvement under DWQMS.

York Region staff also recommend renaming “Preventive Actions” in Element 21:
Continual Improvement to “Opportunities for Improvement” to align with the ISO 9001
approach. To ensure continual improvement, ISO 9001 promotes risk-based thinking
and a system-wide improvement approach. This focuses on identifying issues early,
taking proactive steps to mitigate risks, reducing undesired effects and capitalizing on
opportunities. Adopting similar wording under the DWQMS would clarify that a similar
proactive approach is intended and would drive implementation of improvements across
the quality management system.

Updated BMPs are needed to support effective commenting on this proposal and
continued compliance with DWQMS

It is recommended that MECP release a consolidated list of best management practices
(BMPs) for municipalities noted under the posting as soon as possible. Without formal
BMPs, it is challenging for municipalities to effectively comment on this requirement
and ensure they can maintain conformance with DWQMS elements. Proposed changes
to Element 16 – Sampling, Testing, and Monitoring requires the Region to have a
procedure to prepare exception reports conforming with unspecified BMPs. Operational
adjustments or considerations may be required as a result of the BMPs, which will take
time to implement. Releasing these BMPs will be critical for municipalities to maintain
their compliance obligations.

Standardize timeframe references to promote consistency

York Region staff recommend standardizing timeframe references to “Calendar Year(s)”
throughout the DWQMS to ensure consistency and prevent confusion. For example,
Elements 7h and 21a reference “every thirty-six months”, while "every Calendar Year”
appears throughout.

York Region thanks MECP for considering this input and requests ongoing collaboration
with the Ministry in updating the DWQMS. If you would like to discuss these
recommendations, please contact Meredith Pratley, at Meredith.Pratley@york.ca.

Sincerely,

David Szeptycki
Director of Sustainability, Communication, and Innovation
Public Works
The Regional Municipality of York