Other public consultation…

Other public consultation opportunities
The ministry is seeking comments on any or all of the proposed regulatory amendments from any interested stakeholders. The following questions highlight areas of interest to the ministry with respect to some of the proposed changes, but interested stakeholders need not limit comments/concerns exclusively to these questions:
1. Are there any other types of issues or challenges faced by owners, operating authorities or operators of drinking water systems related to emergencies, or the aftermath of emergencies, that you would also want to be addressed through the proposed amendments? If so, please explain the issues and ideas for addressing them, if the proposed amendments would not do so. Nothing at this time
2. Are there any other types of exceptional situations that should trigger the use of the proposed emergency related provisions by the ministry director, or by the owner or operating authority of a subsystem? Yes. Prolonged, large scale black outs, brown outs such as the Northeast blackout in 2003 and or major loss of internet communications.
3. Questions on Proposed Emergency Related Amendment 4, i.e. Allowing substitute personnel to temporarily operate a subsystem:
a. Are you supportive of the proposal to allow knowledgeable, non-certified personnel to temporarily operate drinking water subsystems if needed to maintain the safe continuity of operations in an emergency? For example, if a disease outbreak were to cause a critical shortage of certified operators at a water treatment plant due to illness and quarantine requirements. Yes. We can assign them to non- critical jobs under the direction of Certified Ops. Cleaning, turning valves. Job specific work. Critical work we would not allow – Non-Critical Ops
b. Do you agree with the proposed list of types of substitute personnel that could be employed to temporarily operate a drinking water subsystem in an emergency? Professional Engineers - Not necessarily – Professional Engineer with related water experience. Retired Operators – Yes, that have retired within the last 5 years. CET with direct water experience that has had it within the last 5 years- Yes. Managers with at least 5 years of related water experience- Yes. Related maintenance staff - Yes, but carefully vetted, such as electrical contractors that have worked within our systems.
c. Are there any types of substitute personnel not listed that should be included? Yes Public Works staff that don’t normally work in water. Water/Wastewater related Lab technicians. Others, that are under the direct supervision of certified operator. Alternatively, are there types of substitute personnel listed that should be removed? No
d. Do you agree that the condition requiring a Certified Engineering Technician or a Certified Engineering Technologist have at least 3 years experience working in a subsystem is appropriate given the qualifications for these designations? Yes, with specific, first hand knowledge of our systems.
e. Do you agree that the condition requiring a manager, or maintenance or technical support personnel, to have at least 5 years’ experience working in a subsystem is appropriate? Yes. Specific knowledge of the system would be an asset
f. If operators of a drinking water subsystem work in a unionized setting, is there a possibility that the proposed amendments to permit the use of temporary personnel in an emergency would conflict with any aspect of a collective agreement? Yes If so, would these conflicts prevent owners and operating authorities from readily being able to employ non-certified substitute personnel temporarily to operate a drinking water subsystem in an emergency if needed? No. However, it would be Collective bargaining agreement specific. Union is defending certified union members. Can we agree to hire uncertified operators with temporary certification would be a topic of discussion with the Union? If we could move our own staff around from system to system, we may not need to use outside employees to make it work, but if we had to bring in outside staff, they would be able to assist under the direct supervision of a certified operator.
g. What possible alternatives, if any, do you see to the proposed approach of allowing owners and operating authorities to temporarily employ knowledgeable, experienced but non-certified substitute personnel to operate a drinking water subsystem in an emergency if needed (e.g. critical shortage of certified operators)? Professional Engineer with related, recent water experience. Retired Operators – Yes, that have retired within the last 5 years. CET with direct water experience that has had it within the last 5 years- Yes. Managers with at least 5 years of related recent water experience- Yes. Related maintenance staff - Yes, but carefully vetted, such as electrical contractors that have worked within our systems. Please explain.
4. Questions on temporary substitute personnel in relation to drinking water testing. Please refer to Proposed Emergency Related Amendment 4 above and Schedules 7 and 8 of O. Reg. 170/03 for context:
a. To ensure that drinking water testing is conducted properly during emergency situations, would it be reasonable to stipulate that the only types of substitute personnel who could act in the place of a certified operator for the purposes of conducting or supervising drinking water testing would be licensed engineering practitioners (e.g. Professional Engineers) or people who previously held an operator’s certificate within the last 5 years (e.g. retired operators)? Or do you think that, in emergencies, substitute personnel other than Professional Engineers and retired operators should be able to act temporarily in the place of certified operators when it comes to drinking water testing? Please explain. Yes, but they need to have specific training in a related field such as a certified lab technician, certified nursing practitioners, etc
b. Should substitute personnel including managers, certified engineering technicians/technologists, and maintenance and technical support personnel (excluding water quality analysts) who conduct drinking water testing do so under the following conditions?
• be trained by a certified operator to conduct tests Yes. Absolutely
• work under the supervision of a certified operator Yes. but not always under the direct supervision. Task specific. Sampling and Operational changes would have to be directly overseen by certified Operators.
• immediately advise a supervising certified operator of the test results Yes
5. Do you agree that the 14-day deadline for the initial submission of the strike-plan is reasonable? If not, should the proposed number of days be increased or decreased? Is reasonable but could be longer depending on the specific circumstances.
If the strike plan is submitted it must go to someone for immediate turnaround on response back to the operating authority or owner.
Additionally, on the matter of having a strike plan, why aren’t all water systems operating authorities and water operators deemed essential, such as Ontario Clean Water Agency? This makes no sense. Fire Fighters are essential but wouldn’t have water to put out fires without water operators supplying the water. It makes no sense that OCWA operators are deemed essential, but the rest of Ontario’s operators are not.