1. Proposed change to…

1. Proposed change to Element 9: "...requires an up-to-date description of the organizational structure of the operating authority including respective roles, responsibilities and authorities" - the comment/explanationstates "Updated plan c) and d) to identify the role and/or job title of person(s) responsible to undertaking the management review and people having top management responsibilities."

It has been suggested at DWQMS Workshops, not to include "names" of people in the Operational Plan. Therefore I would suggest for the above, to remove "people" from the explanation and use "those responsible" and "roles having top management responsibilities." The word people suggests that names should be used.

2. Proposed change to Element 11: Comment states "Updated to identify specific scenarios that must be considered in the procedure for personnel coverage, including periods of routine operations, labour disruptions and emergency situations."

My suggestion is to remove "labour disruptions". This is similar to language used in union contracts and may invite confusion. Should the QMS be responsible for defining/reiterating process used during such events? Or would this be a Municipal-wide policy/requirement based on requirements of the employer?

3. Proposed change to Element 17: Comment states "Updated to include verification, in addition to calibration and maintenance."

More detail on this requirement would be helpful. Verification that equipment was calibrated? (i.e. records, certificates, stickers), or verification that the equipment is working properly following calibration? (i.e. testing equipment following calibration? Could be difficult for larger municipalities with numerous systems / many pieces of calibrated equipment.)

4. Proposed change to Element 21: "Updated plan b) ii. to be more consistent with standard processes for identification and management system corrective actions."

More details regarding the meaning of "standard processes" would be helpful.

It would be very beneficial for the MECP to publish Best Management Practices. The auditor asks about ours at every audit and having a "template" or even suggestions to work with would help.