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

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).