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Private Water Supply Regulations 2009 amendment

Comment 21st July 2010

With a view to allowing water of a suitable quality that may not meet every parameter of potability as defined in the Regulations, there should be an amendment or several to permit the effective derogations that were allowed under the previous Private Water Supply Reguations. Any amendment would not allow any increase in risk to consumer health, but would reduce the onerous cost of compliance from the food and drink sector.

As a suggestion for achieving the desired end, the following is proposed, but some alternative drafting to achieve the same effect would equally be welcome, if there are unintended consequences of my proposal.

Under section 3 Exemptions, add "(d) water used in food processing that does not affect the fitness for human consumption of any food or drink derived from the process"

The effect will be to apply risk assessment, as is the intent of all food safety legislation according to the Food Standards Agency, rather than to impose inappropriate costs of water treatment onto food manufacturers.

Why does this matter?

Until these regulations came into force, local authorities (LAs) were able to grant derogations from the analytical standards of potability. LAs therefore have a long history of considering the risks associated with any one or more analytical parameters being outside regulatory limits. In the past they have applied their judgement cautiously, but have concluded that certain processes pose no risk to consumer health if the water used meets wider specifications. The new regulations appear to have left common sense behind, and EHOs are driving companies to spend capital and revenue money to meet standards which – in their own words -offer no benefit to protection of consumer health. One quote from a local authority is “the levels were not considered to be a health risk and the relaxation was readily granted at a level considerably in excess of the analytical results. “

There is no allowance in the Regulations for deviation from each and every definition of potability. Potability itself is somewhat subjective, but the use of potable water in processing is even more so, as the water used may be outside potability parameters without affecting either the quality of the food and drink products or their wholesomeness – and this has been recognised for decades by EHOs.

Any costs incurred unnecessarily should be avoided – in this case the costs are onerous, and remove incentive to use private water supplies, pushing companies towards using supplies from water companies. Either unnecessary local treatment or purchasing of commercial water carries costs both financial and in greenhouse gas emissions. The former makes UK businesses less competitive, and many food and drinks compete in a global market. The latter runs against joined-up thinking and legislation across government, along with an environemntal disbenefit.

In any cost-benefit assessment, if there is nil or negative benefit, it is not possible to justify a cost. This is the foundation of the argument for this change.

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