Thank you for the…

Thank you for the opportunity to comment on the updates to the DWQMS, it's sincerely appreciated.

Please find below my summary points:

- Appreciate the new cover page (with large white space, black & white - which is nicer to print than previous versions that had a lot of colour).

- Page 2 - Consider adding www.ontario.ca/drinkingwater as another place to access the DWQMS

- Page 4 - Last line in the introduction section - "Operating authorities "ARE" accredited..." (instead of "will be")

- Page 5 - Last line of first paragraph under Roles, Responsibilities and Authorities: "If the same person, persons or group of people are assigned both Owner and Operating Authority roles, responsibilities and authorities, then the requirement to communicate the QMS between Top Management and the Owner is met by the person, persons or group of people in possession of the information to be communicated."
--->>> This may possibly be construed as removing the duty for municipal water departments to report to Council (as representatives of the Owner). Perhaps reconsider?

- Page 5 - Second line of second paragraph under Roles, Responsibilities and Authorities: "If the Owner is not the same entity as the Operating Authority, s.14 of the SDWA specifies that the Owner and the Operating Authority shall enter into an agreement that identifies, among other things, their respective responsibilities."
--->>> Should s.14 of the SDWA apply to two-tier or multiple municipalities that influence safe water for the same community? (as these organizations are their own legal entities) - where one may be the water supplier (e.g. a regional municipality - under its own Owner and Operating Authority) and another municipality (another Owner and Operating Authority) for the water distribution system. The delineation through a SDWA s.14 agreement of roles / responsibilities / authorities would be important in this case. Or, another example - a water supplier (under its own Owner and Operating Authority) that supplies water to & through other inter-connected municipalities (different Owners and Operating Authorities)... Might be worth considering?

- Page 6 - Title Director's Direction (with "s" at end?) and in the paragraph: "Environmental Bill of Rights Registry" should be "Environmental Registry of Ontario" (new name)

- Page 8 - Consider adding a definition for "Ministry" and in the text of the standard simply refer to "Ministry".

- Page 8 - Operational Plan definition - Director's Directions (with "s" at end?)

- Page 9 - QMS definition - a) establish policy and objectives, and "PROCESSES" to achieve those objectives... (consider adding the word "processes")

Regarding El. 6 PLAN a) iii. - Because O. Reg. 170/03 defines "secondary disinfection" as a process or series of processes intended to provide and maintain a disinfectant residual in a drinking water system's distribution system... the start of El. 6 PLAN a) iii. can be confusing to those that are distribution-only systems as they have a series of processes to ensure the maintenance of the acceptable disinfectant concentration ("secondary disinfection") that applies to their system. Critical control points identified in distribution systems consistently relate to monitoring programs and activities to maintain secondary disinfection, and at a minimum, the acceptable disinfectant concentration in all areas of their systems at all times.

The changes that are summarized for the draft DWQMS 3.0 for all elements are generally great changes.

Regarding El. 7 PLAN a) - the "Potential Hazardous Events..." document is not yet available at ontario.ca/drinkingwater (is currently only available with the original ERO notice). Can the latest "Potential Hazardous Events..." document be made available online with the updated DWQMS, once released?

Regarding El. 16 PLAN d), will the applicable best management practices be published? I know some utilities had questions about "exception reports" to be produced.

Regarding El. 18 PLAN c) "training" and d) "testing" - an annual event for each should be a best management practice.

Thanks again for the opportunity to comment!