Commenting on Element 10:…

Commenting on Element 10:

Element 10: competencies - requires up-to-date documentation of the knowledge, skills and abilities that personnel whose jobs affect drinking water quality must have, and the activities necessary to ensure that competency requirements are met and maintained

updated plan a) to specifically include mandatory licensing, certification or training requirements

To ensure competent leadership, a standardized, prescriptive set of requirements (e.g.Director has a Class IV license for systems at that class, a Professional Engineering designation, experience, and/or education requirements, etc.) should be established and enforced through the MECP. Leaving these definitions to individual owners or operating authorities creates a vulnerability where senior leadership could compromise integrity by pressuring staff to dilute qualification criteria, thereby enabling the placement of unqualified personnel in oversight/management roles. This is currently happening at a municipality in Southern Ontario.