Proposed updates to the Director’s Directions - Minimum Requirements for Operational Plans

ERO number
019-2787
Notice type
Policy
Act
Safe Drinking Water Act, 2002
Posted by
Ministry of the Environment, Conservation and Parks
Notice stage
Decision
Decision posted
Comment period
December 11, 2020 - January 25, 2021 (45 days) Closed
Last updated

This consultation was open from:
December 11, 2020
to January 25, 2021

Decision summary

We have updated the Director’s Directions: Minimum Requirements for Operational Plans.

Decision details

We have updated the Director’s Directions: Minimum Requirements for Operational Plans in order to reflect current practice in municipal residential drinking water systems and improvements in technology that have occurred since the directions were published in 2007.

The ministry has updated its plan based on feedback received through the proposal notice. See “Effects of consultation” for specific details.

Background

The Director’s Directions govern the minimum requirements for preparation and content of operational plans that are developed for municipal residential drinking water systems.

An operational plan is the documentation of a quality management system developed to conform to the requirements of Ontario’s Drinking Water Quality Management Standard (DWQMS).

All municipal residential drinking water systems in Ontario are managed by an operating authority accredited against the requirements of the DWQMS. Accreditation is issued by a third-party organization designated as an accreditation body in accordance with section 22 of the Safe Drinking Water Act, 2002.

The administrative updates to the Director’s Directions are intended to reflect:

  • current practice in municipal residential drinking water systems
  • improvements in technology that have occurred since directions were published in 2007

The updates include:

  • clarification of content requirements that apply when a single Operating Authority operates multiple, distinct, drinking water systems for the same owner
  • removal of reference to transitional accreditation options that were used during initial roll-out of the Municipal Drinking Water Licensing Program
  • updates to reflect more prevalent use of operational plans that can be made available to the public on the internet and can be electronically version controlled

Comments received

Through the registry

5

By email

2

By mail

0
View comments submitted through the registry

Effects of consultation

In consideration of the comments received, additional administrative updates have been made to the Director’s Directions.

The following information provides a summary of questions asked and concerns expressed in the comments received. It also identifies updates that were made as a result of this feedback:

General

Timeline for implementing changes

  • A concern was raised about the timing of the proposed updates and the potential need to update operational plans as a result. The proposed updates are administrative in nature and provide flexibility for requirements that are already in place. In most cases, significant updates to an operational plan should not be necessary as a result of the changes.
  • A transition date of April 1 2022 has been added to the Director’s Directions ensuring that any updates to the operational plans, if required, can be made along with other routine updates to the plans.

Retention

  • A question was asked about retention timelines for operational plans. No change to retention times are included in the updates to the Director’s Directions. Operational plans that were the subject of an audit by an auditor for the accreditation body are required to be retained for a minimum of ten years. If one audit is conducted each year, ten versions of the operational plans would be retained as part of the system owner’s records.

Operational plan content requirements (section 3.0)

Transitional accreditation

  • A question was asked about the need for transitional accreditation types. No changes to the transitional accreditation are included in the updates to the Director’s Directions. Transitional accreditation is still required in circumstances where there is a change in operating authority.

Incorporating documents by reference

  • Concerns were raised about the potential for differing interpretations when information is incorporated by reference rather than being duplicated within the body of an operational plan.
  • The Director’s Directions have been updated to clarify that documents can be incorporated into the operational plans by reference in place of information being maintained and updated to two different locations.

Version control

  • Concerns were raised about the potential for differing interpretations of the requirements when using electronic document control software or when individual sections of the operational plan are revised.
  • The Director’s Directions have been updated to ensure that requirements are flexible enough for document control software to be used and to clarify that individual documents forming the operational plans may be updated on at different frequencies (have different dates).

Title of operational plan

  • Concerns were raised about the challenge of listing every drinking water system within the title of operational plan when it applies to multiple systems.
  • The Director’s Directions have been updated to provide additional flexibility for plans that apply to multiple systems.

Submission to the director

  • Concerns were raised about the challenge of providing a copy of the operational plan as a single file in “PDF” format.
  • The Director’s Directions have been updated to clarify that documents can be submitted to the ministry in another format, where acceptable to the director.

Public disclosure of operational plans (section 5.0)

Risk assessment

  • Concerns were raised about the potential for differing interpretations when information relating to identification and evaluation of risks to the drinking water system are excluded from public disclosure.
  • The Director’s Directions have been updated to clarify that activities used to control or manage risk to the drinking water system may be excluded if public disclosure could threaten the safety / quality of drinking water.

Maintaining hard copies of the operational plan for public viewing

  • A question was asked about making hard copies of the operational plans available to the public. The updated Director’s Directions allows for operational plans to be made available for public viewing at a principle place of the owner and/or a website accessible to the public. Where the plans are made available for public viewing as a hard copy, the hard copy should be the most current version of the plans for the system.

Maintaining online versions of the operational plan for public viewing

  • Questions were asked about which portions of the operational plan should be made available for viewing by the public and whether a summary of the plans is sufficient for this purpose.
  • Concerns were also raised about the onerous nature of maintaining an always up-to-date version of the operational plan on the website when documents and procedures in the plan are constantly changing.
  • The Director’s Directions have been updated to clarify that versions of the operational plan made available to the public on a website can be updated on the website at regular intervals or at major revisions to the plan. The content of the plans should be made available for viewing by the public, with the exception of information that qualifies for exclusion based on the Director’s Directions.

Consent of owner

  • A question was asked about obtaining consent of the system owner before disclosing the operational plan. No changes to the requirement for consent are included in the updates to the Director’s Directions. All operational plans for a drinking water system remain the property of the owner of the system, irrespective of who prepares or revises the plan (as per s. 17 of the Safe Drinking Water Act, 2002). Consent from the owner should be obtained before the operational plans are disclosed or shared by any person subject to the Director’s Directions.

Schedule “A” (Definitions)

  • A suggestion was made to include a definition of “principle office” and to update the definition of “subject system” to ensure consistency in interpretation.
  • A definition of “principle office” has been added to the Director’s Directions and the definition for “subject system” has been revised to point to the existing definition within the Drinking Water Quality Management Standard.

Schedule “C” (Form)

  • A question was asked about how the Subject System Description Form in Schedule “C” should be included in an operational plan. There are no specific rules on how a Subject System Description Form is incorporated into the plans. Examples include but are not limited to: inserting it as an index page directly after to cover page in a hard copy of the document, referencing it as a separately maintained file in an electronic version of the plan and referencing it within information prepared to conform with Element 6 of the Drinking Water Quality Management Standard (description of the drinking water system).

Supporting materials

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Please reach out to the Contact listed in this notice to see if alternate arrangements can be made.

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Original proposal

ERO number
019-2787
Notice type
Policy
Act
Safe Drinking Water Act, 2002
Posted by
Ministry of the Environment, Conservation and Parks
Proposal posted

Comment period

December 11, 2020 - January 25, 2021 (45 days)

Proposal details

The Ontario Ministry of the Environment, Conservation and Parks is proposing administrative updates to the Director’s Directions: Minimum Requirements for Operational Plans (“the Director’s Directions”). The Director’s Directions govern the minimum requirements for preparation and content of operational plans that are developed for municipal residential drinking water systems.

An operational plan is the documentation of a quality management system developed to conform to the requirements of Ontario’s Drinking Water Quality Management Standard (DWQMS).

All municipal residential drinking water systems in Ontario are managed by an operating authority accredited against the requirements of the DWQMS. Accreditation is issued by a third-party organization designated as an accreditation body in accordance with section 22 of the Safe Drinking Water Act, 2002.

Proposed updates to the Director’s Directions

The proposed administrative updates to the Director’s Directions are intended to reflect:

  • current practice in municipal residential drinking water systems
  • improvements in technology that have occurred since directions were published in 2007

The proposed updates include:

  • clarification of content requirements that apply when a single Operating Authority operates multiple, distinct, drinking water systems for the same owner
  • removal of reference to transitional accreditation options that were used during initial roll-out of the Municipal Drinking Water Licensing Program
  • updates to reflect more prevalent use of operational plans that can be made available to the public on the Internet and can be electronically version controlled

Supporting materials

View materials in person

Important notice: Due to the ongoing COVID-19 pandemic, viewing supporting materials in person is not available at this time.

Please reach out to the Contact listed in this notice to see if alternate arrangements can be made.

Comment

Commenting is now closed.

This consultation was open from December 11, 2020
to January 25, 2021

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