Drinking Water Standards for New Zealand 2005 – Impact on RMCA Member Clubs
October 2007 Update
The third and final reading of the Health (Drinking Water) Amendment Bill was done on 9 October 2007, and it became an Act on 17 October 2007. This will enact the 2005 Drinking Water Standards and has an expected commencement date of 1 July 2008.
There is a proposed staggered compliance timetable, with water suppliers such as Clubs possibly having 3-4 years from 2008 to comply. This will also be dependant on any timetables imposed by the Drinking Water Assessors (DWA) appointed by the District Health Boards (DHB’s).
In regard to the suggested actions from the 2005 and 2006 reports submitted to the RMCA, the following is an update;
1) RMCA undertakes an audit of all member Club buildings to determine their water source and if they are supplying other buildings.
As a result of a combination of audit returns from Clubs, and myself visiting each Club when gaining the GPS coordinates, I can confirm that each Club at Iwikau, Turoa, and Tukino have individual water supplies and storage facilities. Club buildings at Whakapapa Village are on a community reticulated supply.
2) RMCA works with Stan Abbott to test the water and to suggest cost effective methods to improve the water quality.
Initial suggestions are to; replace lead or copper flashings and spouting, repaint with non-lead based paint, install ash bypasses (which a lot of Clubs have already done as a result of the 1995-96 eruptions), ensure that storage tanks are sealed against dust and vermin entry, once a year empty storage tanks and remove any silt on the bottom, install filters in the internal supply lines and service them regularly.
3) RMCA writes to the Ministry of Health for formal conformation that Clubs meeting the criteria are exempt
The supporting documentation to the Bill notes that the Department of Conservation (DoC) could seek an exemption based on the remote locations and low visitor use of their facilities. However, it has been deemed that an exemption for DoC would be inappropriate as the facilities are governed by the Building Act 2004. Clubs are also bound by the Building Act 2004, are generally more accessible, and possibly have higher usage. Therefore, an exemption is very unlikely to be granted to Clubs.
As per section 69G (Interpretation) of the Bill, whether Clubs have minor, small, or very small drinking water supplies and the associated compliance requirements is also open to interpretation. This will have to be confirmed with the Ministry of Health.
An unofficial indication has been given that Clubs may only be required to have their water tested once a year, perhaps just before the beginning of the ski season. This will also be dependant on the DWA’s.
Club buildings at Whakapapa Village are on a reticulated supply and the operator of that supply will have to conform to the Act.
The final version of the Bill has struck out the definition of a “small drinking-water supply” and replaced this with a new definition of “neighborhood (sic) drinking-water supply” (a drinking-water supply to “between 25 and 100 people (inclusive for at least 60 days per year”). This is most likely to be the definition best fitting Club situations collecting water from the roof, having their own tank, and reticulating a single building. Now that the Act has been passed, confirmation that Club’s are within this definition will be made with the Ministry of Health.
4) RMCA prepare a Public Health Risk Management Plan (PHRMP) on behalf of the Clubs and distribute the final version to the Clubs. This will allow Clubs to identify improvements to be taken into account for future capital or maintenance work.
I have some draft PHRMP’s from the Ministry of Health, and while some items could be applied now (mentioned in #2 above), I suggest that a final PHRMP be prepared and distributed once the Bill is enacted and the requirements are more detailed. To be included in the PHRMP, I shall be approaching RAL for a copy of the report they had commissioned a few years ago regarding the safety of the snow produced by the snow making machines.
In the meantime, attached is a copy of a PHRMP guide (not a plan as such) for roof water sources which contains examples of potential risks, preventive measures, and corrective action. This can also be accessed at http://www.moh.govt.nz/moh.nsf/238fd5fb4fd051844c256669006aed57/5af58e090cf4098bcc25699600754798?OpenDocument
The operator of the Whakapapa Village reticulated supply will have to prepare their own PHRMP.
The new definition of a neighbourhood drinking-water supply falls into the section that a “Medical officer of health may require preparation and implementation of public health risk management plan”. I still believe that it will be very worthwhile exercise for the benefit of Club’s, and in anticipation of a Medical officer requesting it be done.
5) RMCA contact the DWA’s for; Whakapapa/ Iwikau – Health Waikato, Turoa – Mid Central Health Wanganui, Tukino – Pacific Health? and work them in the preparation of the PHRMP and any on-going water issues.
To date, no contact has been made with the DWA’s. Contact will be made once the Bill is passed.
Now that the Act has been passed, contact will be made with the DWA’s regarding the preparation of the PHRMP and other water issues.