Last year, the Dungeons and Dragons rules were revised for the first time in ten years. Favourite rules of mine, some of which were purely for setting game tone and others which were mechanical and balance-adjusting, were tweaked and adjusted. Because of this I have had to learn a valuable lesson – good practice doesn’t just come from the people who make the rules. Every game rules problem in D&D can be fixed at the table by discussing the issues between players and game master and house-ruling whatever makes the game better. It’s one of those features that makes tabletop roleplaying games still relevant, and distinct from comparable video games.
Taumata Arowai were also hard at work last year, updating their own version of a rulebook. The Drinking Water Quality Assurance Rules (DWQAR) for New Zealand were updated, and as of January this year the changes are now live. The DWQAR are the regulations that outline the minimum requirements for a drinking water supplier in New Zealand. The new revision of the DWQAR affects smaller suppliers who follow the S1/T1/D1, S2/T2/D2 and VSC rule sets, as well as those who follow the variable population rules (VP). Large suppliers (supplying more than 500 people) follow the S3/T3/D3 rules, and those suppliers can breathe easy for now – the tier 3 rules are unchanged in this new revision.
While they are undoubtably easier to read than before, the new revision pruned many rules that served as guide rails to encourage good sampling practice. As an example, a T2 network is required to test E. Coli in water leaving the treatment plant every month. There used to be a 12-day minimum gap between samples, which prevented taking samples at the end of one month and the beginning of another, but this mandatory gap has been removed. You can now take a sample on the last day of January, another sample the following day in February, and not take another E. Coli sample until the end of March, and still technically be compliant with the DWQAR. This leaves a gap of almost two months’ time in which you are not taking any samples. That’s money in the bank if you combine those two sampling events into one lab suite and save! But it is also almost half the effective sampling data of a supplier following the rules more conventionally. Many of the other ‘guide rails’ that have been removed or deprecated were also originally mandated to ensure a minimum of good practice – such as sampling for iron (previously mandatory, now being removed from S1 rules) or how much and for how long to increase sampling frequency after an exceedance of the MAV or 50% MAV (both decreased in S1/S2 rules). Note that not all requirements have loosened – if you currently monitor groundwater arsenic every three years under rule S2.1 for example, that requirement has tightened to requiring you to monitor it every year – so I recommend you look over the new rules to see if your sampling schedule is still regulation-compliant.
Remember - the primary goal of sampling is to understand your water source, your treatment process and your delivery network – not to fulfil the requirements of regulations. Anyone familiar with workplace health and safety should already be aware that ‘technically compliant’ is not enough when it comes to people’s health. The legislation requires you to supply safe drinking water. The regulations are (mandatory) guides to help you do that, but even following the letter of the regulations may not be enough if the spirit of the rules are not also followed.
Other guides include the six principles of water treatment we covered in a previous series of blog posts. When paired with appropriate planned responses in your water safety plan (WSP), a good sampling schedule will enable you to align your water safety strategy with the principles 2. Protection of Source Water is of Paramount Importance; 4. Change Precedes Contamination; and 6. Apply a Preventative Risk Management Approach. I would also consider it a good sign of a supplier being proactive in support of principles 1 and 5, showing a standard of care and ownership of the safety of their water supply, and even potentially constitute a barrier in some cases, as per principle 3.
Top 5 Changes to the Drinking Water Quality Assurance Rules (DWQAR)
No |
Change |
Details |
| 1 |
Removal of TWDS rules and VSC.3 Unplanned Population Increase |
The TDWS rules, which covered any temporary water supply and very small community supplies that temporarily exceeded 50 people, have been removed from the DWQAR. VSC rules still apply to any supply that services 25 people or less but now, if the population temporarily exceeds 50 people, the rules for that temporary event are incorporated into VSC and require only a single treatment barrier; either UV, chlorine or filtration; compared to TDWS rules that required filtration and chlorine. The sampling requirements are also greatly reduced and the TDWS.2 rule that required monitoring for cyanobacteria is removed. |
| 2 |
Groundwater Arsenic Monitoring Frequency |
The requirement for monitoring groundwater arsenic for level 2 suppliers has increased from every three years to every year under rule ID S2.1 |
| 3 |
Cyanobacteria ‘No Risk’ Category |
Suppliers following the S2 rules for populations between 100 and 500 people have always been required to classify their source as low, medium or high risk. The revised S2.5 rule adds the option of ‘no risk’ as a classification for source water, intended for groundwater sources where cyanobacteria will be unable to photosynthesize. We recommend caution and careful assessment of the source before making this classification. |
| 4 |
Cyanobacteria/Cyanotoxin response plan no longer required for level 2 supplies |
The old rule S2.5 required sources identified as high or medium risk for cyanobacteria contamination to produce and maintain a response plan for managing outbreaks of cyanobacteria. This requirement has been removed, although, for sources that are at such risk, we still strongly recommend planning for this eventuality. |
| 5 |
Widespread removal of requirements to have a minimum number of days between samples. |
VSC.1, T2 rules and D2 rules had conditions requiring suppliers to space out their samples by a minimum length of time to prevent taking those samples too close to one another. This requirement has generally been removed from these samples, although in some cases new rules have been introduced to achieve a similar purpose (e.g. D2.4). |
I would encourage any supplier to embrace strategies like event-based sampling to learn and monitor the characteristics of the source. In event-based sampling, you anticipate weather events like heavy rainfall and do extra samples during that event to understand what impact that kind of event can have on the source water. The more events you can capture, the more complete of a picture you can paint using the resulting data.
While I understand that simplifying the rules will probably make compliance easier, I also believe that loosening the rules will lower the floor of performance. And as a consulting engineer, when almost every problem I can help a supplier solve will start with the words ‘can I see your sampling data’, I really want to see us raise the bar on this nationwide. With government regulation pulling back it now falls more directly than ever on small New Zealand drinking water suppliers to understand the vulnerabilities of their source. I hope we don’t see the new rules being interpreted as a green light to loosen supplier vigilance, the way a speed limit increasing is a tacit encouragement to drive at that speed from now on. We are at a crossroads now – will the future resemble a video game where the health of the system is dependent on rules changes from some ultimate authority? Or a tabletop game where the players work together to fill the gaps inherent in a written ruleset?
Principal 1 : A High Standard of Care Must be Embraced
Principal 2 : Protection of Source Water is of Paramount Importance
Principal 3 : Maintain Multiple Barriers Against Contamination
Principal 4 : Change Precedes Contamination
Principal 5 : Suppliers Must Own the Safety of Drinking Water
Principal 6 : Apply a Preventive Risk Management Approach
Link to Taumata Arowai Information:
What do the revised DWQAR mean for me?
