Recycled Water in QLD - What is 'fit for the use'?
All recycled water schemes in Queensland are required to ensure that the recycled water is ‘fit for the use’ under the Public Health Act 2005 (PH Act) Section 57F.
What does ‘fit for use’ mean?
In Qld, the following types of schemes require an approved RWMP and validation program:
a critical recycled water scheme
to augment a supply of drinking water via a source supply (e.g. a dam)
to premises by way of a dual reticulation system
irrigate minimally processed food crops
a use prescribed under a regulation made under the Water Supply (Safety and Reliability) Act 2008.
For these schemes, the regulatory requirements are straight forward, and there are guidelines that detail how to meet the regulatory requirements. But the majority of recycled water schemes will not fit into the categories above and often involve the irrigation of open spaces, sporting areas and pastures. There are no regulatory guidelines or guidance notes that define how a recycled water provider should confirm that the recycled water is ‘fit for the use’.
Recycled water providers need to be sure that the recycled water that they supply is the appropriate quality, that the scheme can consistently supply that quality of water and there are processes in place to take action where the water may not be safe. Additionally, the recycled water provider needs to confirm that the customers are implementing the required onsite exposure controls.
Establishment of a risk management framework is the best way to ensure recycled water is fit for the use. The Australian Guidelines for Water Recycling (AGWR) are considered the industry standard for managing recycled water and application of these 12 elements are the best option for proving that recycled water is fit for the use. This doesn’t have to be onerous, especially for a simple schemes, that may supply to just one or only a small number of customers.
Tips for establishing a recycled water risk framework:
Have a strategic direction for recycled water – determine how the organisation will manage recycled water. This will inform all current and future recycled water activities and set the standard for the organization
Use the risk assessment – make sure the risk assessment is the basis for all subsequent actions – preventive measures, procedures, monitoring and improvements
Integrate recycled water into existing processes within the organisation – expand drinking water, environmental and/or emergency management processes to include recycled water.
Focus on operational control – establish critical control points, operation monitoring and corrective actions. Use verification monitoring as the final check to confirm this is working.
Include regular (at least annual) inspections/visits to customer sites to confirm that the contract is being complied with, that control measures are being implemented and to confirm communication protocols.
Communication and reporting – establish communication protocols within the organisation to increase awareness across the business
Continuous improvement – review performance regularly, including monitoring data, the relevance of the risk assessment and the progress in implementing the improvement plan. Audit your system, make changes if it is not working.
Check out our previous blog posts on monitoring, critical control points and setting critical limits for more detail.
We are always happy to discuss ways to establish a recycled water framework that will work for your organisation.