This blog presents an overview of the findings from audits conducted by Viridis in 2024. The audits identified significant aspects in both drinking water and recycled water management plans, which may be informative for any utility implementing a water quality risk management plan.
Auditees
The audits covered both drinking water and recycled water management plans, assessing compliance with regulatory requirements and industry best practices. The audits included organisations responsible for drinking water and recycled water management in NSW and Qld, covering both urban and regional areas:
Large Water Utilities – Serving major metropolitan areas with millions of customers.
Regional Water Boards – Managing water supply for regional and rural communities.
Local Councils – Overseeing smaller municipal water services for local communities.
Industrial Water Providers – Supplying specialised water services.
Auditors
Viridis uses a team of auditors, the auditors involved in this study are detailed below:
1. Tasleem Hasan (Viridis)
Tasleem holds a Master of Science in Chemistry and a Bachelor's in Chemistry/Mathematics, is a Certified Lead Water Quality Management Systems Auditor for drinking and recycled water and has conducted over 50 audits for water utilities to ensure compliance with standards.
2. Tracy Hay (Viridis)
Tracy is a specialist in water quality audits, focusing on Drinking Water Quality Management Plans (DWQMPs) and brings practical field experience and technical expertise to the audit process.
3. James Howey (Viridis)
James Howey is a seasoned auditor in the water and sewerage sector with 20 years of experience, he is experienced in a range of audits: water quality: environmental and asset management.
4. Jim Sly (Cobbitty Consulting)
An operational audit specialist with expertise in risk assessment and process evaluation for water and sewerage businesses, who has conducted comprehensive audits to ensure operational compliance and performance.
5. Karen Pither (Pither Consulting)
Karen Pither is a well-regarded water quality auditor with deep knowledge of regulatory compliance and water management systems, often involved in reviewing and approving audit reports to ensure they meet stringent quality standards.
Audit Methodology
Below are some common methodology points that were applied across all the audits:
Regulatory Framework:
Conducted in accordance with relevant legislation (e.g., Water Supply (Safety and Reliability) Act 2008) and audit guidelines.
Structured Audit Process:
Planning and scoping of the audit, including defining objectives and audit criteria.
Use of a standardized audit methodology (e.g., ISO 19011:2018 for management system audits).
Evidence Collection:
On-site inspections of infrastructure and facilities.
Review of documentation and records such as calibration logs, maintenance records, water quality data and risk assessments.
Interviews with key personnel, including management, operational staff, and technical teams.
Observation of operational controls (e.g., SCADA systems, Power BI dashboards) to verify compliance.
Verification:
Cross-referencing collected evidence with approved plans and regulatory requirements.
Verification of past corrective actions and ongoing compliance measures.
Reporting and Follow-Up:
Identification of non-compliances, opportunities for improvement, and recommendations.
Structured reporting that includes audit findings, conclusions, and action plans for non-compliances.
Challenges Affecting Audits
Audits like any other process are not immune to challenges. These can almost always be overcome, but can impact the timelines, the level of certainty regarding findings and compliance. Some of the challenges faced are listed as follows:
1. Availability and Accessibility of Records
Some organisations struggled to provide complete records in a timely manner, particularly for:
Calibration logs for monitoring equipment.
Evidence of revalidation assessments.
Incident reports and corrective action tracking.
In some cases, records were stored in multiple systems or required manual retrieval, leading to delays in evidence collection.
Audits rely on verifiable evidence, if it cannot be provided to the auditor then this can impact compliance grades.
2. Scheduling and Coordination Issues
Logistical challenges in scheduling site visits and interviews with key personnel:
Staff availability was impacted by operational priorities, requiring rescheduling of audit interviews.
Some audits were conducted earlier than originally planned, which limited the time available for organisations to prepare.
External factors, such as weather events or operational incidents, occasionally delayed site inspections.
Audits use a sampling process and if the appropriate staff cannot be interviewed or sites inspected then it can mean that insufficient evidence is obtained to make an assessment.
3. Changes in Personnel and Institutional Knowledge
In some audits, key personnel had recently changed roles, leading to:
Limited knowledge of historical audit findings or previous corrective actions.
Difficulty in answering detailed process-related questions during interviews.
Some organisations lacked a centralised knowledge management system, making it harder to track past improvements or justify decisions.
Knowledge management is an ongoing issue. Staff changes are inevitable, but organisations need to have systems in place so that key information is retained.
4. Constraints in On-Site Inspections
While most site visits went smoothly, a few challenges arose:
Access restrictions at certain facilities due to security protocols or ongoing maintenance.
Time constraints preventing in-depth inspections of all relevant infrastructure.
Auditors require appropriate access to sites to collect the required evidence. Note that if verifiable evidence cannot be seen for one of the audit criteria then this may lead to a non-compliance.
5. Coordination Between Multiple Stakeholders
For organisations that worked with third-party contractors (e.g., maintenance providers), audit evidence was not always readily available.
Just because part of the operation is contracted out the service provider is still ultimately liable. If samples aren’t taken or maintenance isn’t done, although contractors maybe at fault under the agreements, the service provider still carries the risk under the regulation. Liability cannot be contracted out, therefore, contractors fulfilling duties are also within the scope of audits.
Where multiple teams (e.g., compliance, operations, engineering) were involved, internal communication gaps sometimes slowed the audit process. There can also be issues with internal stakeholders, as well as external.
Non-compliances
Across all audits, compliance levels were generally high. Most organisations demonstrated strong adherence to regulatory requirements and internal management plans, with robust operational controls and effective risk management processes in place. Minor non-compliances were noted in areas such as record-keeping, calibration practices, and procedural documentation, while major non-compliances were rare. Overall, the audits reflected a sound performance with only isolated opportunities for improvement, reinforcing confidence in the current water quality management systems.
Firstly, we’ll have a look at the number of non-compliance by organisation type. When analysing the data we must consider that there are low numbers in most categories, so firm conclusions cannot be drawn.
There were 21 non-compliances in total across 9 organisations, split as follows:
Large Water Utilities: 7, all minor
Regional Water Boards: 4 all minor
Local Councils: 8, 6 minor and 2 major
Industrial Water Providers: 2, all minor.
Whilst definitive conclusions cannot be made, across all audits only 2 major non-compliances were identified, and these were both at local councils. This is a theme from previous audit reviews that smaller utilities with stretched resources and complex water treatment and distribution systems to manage tend to have a higher level of non-compliance.
The key reasons for these non-compliances can be grouped into the following themes:
1. Record-Keeping and Documentation Issues (6 cases)
Missing or incomplete calibration records for water quality monitoring equipment.
Lack of verifiable evidence for required routine checks (e.g., turbidity analyser calibration, CCP verification).
Inconsistent record-keeping practices leading to gaps in compliance tracking.
2. Procedural Non-Compliance (5 cases)
Failure to follow internal procedures for recycled water validation triggers.
Delays in reviewing and updating risk management plans.
Deviations from approved plan, drinking water or recycled water.
3. Training and Awareness Gaps (4 cases)
Staff not fully aware of reporting requirements for non-compliances or process changes.
Lack of documented training on key procedures, such as incident response and CCP monitoring.
Inadequate training of new staff on regulatory requirements and risk management processes.
4. Monitoring and Compliance Failures (3 cases)
Failure to consistently monitor and report certain parameters, such as chlorine residuals or turbidity.
Missed sampling events due to resource limitations.
Gaps in SCADA monitoring, alarm settings, or compliance reporting.
5. Infrastructure and Maintenance Issues (3 cases)
Delays in addressing identified maintenance issues, such as faulty sensors or deteriorated equipment.
Lack of preventive maintenance tracking for critical infrastructure.
Failure to verify the condition of key assets in line with risk management frameworks.
Breakdown of Non-Compliances by type:
Minor Non-Compliances (19 cases): Mostly related to record-keeping, procedural compliance, training gaps, and monitoring failures.
Major Non-Compliances (2 cases): Related to SCADA system issues and lack of staffing capacity, which resulted non-compliance with the plans and increased risk due to inadequate monitoring of water quality.
Opportunities for Improvement
Across the audits, the following common opportunities for improvement (OFIs) were identified:
Documentation & Record-Keeping:
Update process flow diagrams to reflect current operations accurately.
Enhance maintenance and calibration records, ensuring that all routine checks are fully documented.
Refine risk registers to incorporate recent changes and ensure all control measures are current.
Operational Procedures:
Improve verification monitoring processes and clarify sampling protocols.
Consider incorporating additional critical control points (e.g., disinfection with free chlorine monitoring) to strengthen risk management.
Update trade waste management procedures and related documentation where needed.
Training & Induction:
Incorporate comprehensive training on new and existing procedures (including HACCP plans and calibration protocols) into operator induction packages.
Address identified gaps in staff awareness to ensure consistent procedural compliance across all shifts.
System & Infrastructure Enhancements:
Enhance the integration and functionality of monitoring systems (e.g., SCADA and data dashboards) for improved oversight and timely alerts.
Improve labelling and management of recycled water systems, including ensuring appropriate color-coding or signage for clarity.
These OFIs aim to further bolster compliance, improve operational efficiency, and strengthen risk management across the water quality management systems audited.
Take Away Message For Auditees
Based on the aggregated findings across these audits, here are some conclusions and key recommendations for a utility preparing for an upcoming audit:
Ensuring a Smooth Audit Process: Assist in preparation of a detailed audit plan so auditor/s and auditees are on the same page. Designate an audit coordinator to facilitate communication between the audit team and operational staff, addressing any queries promptly to minimize disruptions and ensure a smooth and efficient audit process. Ensure auditors have access to the required resources and staff to fulfil the audit scope.
Maintain Comprehensive Records: Ensure that all calibration logs, maintenance records, and verification reports are up-to-date and easily accessible. Gaps in documentation were a common issue that led to non-compliances.
Review and Update Procedures: Regularly review and, if necessary, update your operational procedures and process flow diagrams to reflect current practices. This includes clear guidelines on revalidation triggers and emergency protocols.
Strengthen Staff Training: Focus on thorough training and regular refresher sessions for all relevant personnel, especially regarding critical control points (CCPs) and incident reporting procedures. Ensuring everyone understands their roles can mitigate minor non-compliances.
Enhance Monitoring Systems: Verify that your online monitoring systems (e.g., SCADA, Power BI dashboards) are fully integrated and functioning as intended. Automated alerts and robust data management systems can help address monitoring gaps.
Improve Internal Coordination: Foster clear communication between teams (e.g., operations, compliance, maintenance) to ensure that corrective actions and process updates are consistently implemented.
Proactive Risk Management: Regularly conduct internal reviews and risk assessments to identify potential areas for improvement before the audit. This proactive approach can help address issues like procedural lapses or equipment maintenance delays.
Implementing these recommendations should assist any utility not only to prepare for an upcoming audit but also enhance overall compliance and operational efficiency.
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