All Victorian water agencies were required to undertake drinking water quality audits between 1 Jan to 30 April 2023 - here's our take.
This year we launched Viridis Auditors, our new brand within the company focused on providing further value, resources and specialised expertise to our audit clients. Viridis Auditors successfully completed 11 of the Victorian Safe Drinking Water Act (SDWA) audits, approximately half. Alongside fluoride plant technical appraisals and audits in Queensland and New South Wales. The Victorian SDWA audits are initiated by the Department of Health Victoria and covered the audit period 1 Jan 2021 to 31 Dec 2022.
Auditing half the water agencies at a single point in time gives us the opportunity to observe insights across the industry. We’ve reviewed the opportunities for improvement (OFI) that we provided to agencies and looked for trends.
There are eight common areas:
The following graph illustrates the number of times each theme was brought up as an OFI across the 11 audits.
Other utilities may benefit from these insights and use them as an insight for areas that generally need improvement.
1. Document/Procedure Review
Document and procedure reviews emerged as the leading theme across most audits. Maintaining a robust system for the review and update of documents and procedures is imperative to organisation efficiency and the key to successful management and operation. Updated documentation facilitates seamless knowledge transfer among personnel, facilitating a culture of continuous learning while improving company practices. Failing to do so often results in inconsistency and inaccuracy of scheme descriptions and procedures which do not reflect current operations. Implementing scheduled review cycles of documentation will ensure greater currency and reliability to warrant regulatory compliance and further substantiate company processes. Furthermore, establishing performance metrics relating to document accuracy and effectiveness can encourage diligence in maintaining up-to-date materials.
2. Monitoring Program
This theme was the second-most pervasive issue where many agencies lacked robust oversight mechanisms to ensure successful implementation of monitoring programs. This issue was observed to be caused by factors including instances where monitoring is not representative of the water quality, omitted parameters and inadequate procedures, lack of sample point location diversity, and incorrect implementation of the program. Monitoring programs serve as the linchpin of proactive water management, characterising changes in water quality and highlighting areas where further treatment is needed. It is advantageous therefore, to develop procedures for overseeing monitoring schedules alongside rigorous reviews regarding the implementation of the program. Through this, the company can fortify its commitment to accurate water assessment and ensure the delivery of quality drinking water.
3. Preventive measures
This theme is pivotal within the context of risk management. This issue can often be prompted by preventive measures failing or not being undertaken, as well as operational control and critical control points being inadequate or missing. Preventive measures are developed during the risk assessment process to manage significant risks. It is essential that these are implemented and to ensure the ongoing safety of the drinking water supply. Thus, focusing on implementing programs which oversee effective control limits, testing, chemical application and increased examination of infrastructure would mitigate system failure. It is also important to maintain auditable records to show that these actions are undertaken. Rember the age-old question ‘If a tree falls in the forest and there is no one around to hear it, does it make a sound?’
Absent and inadequate training programs and records were frequently observed across agency audits. Considering the current widespread industry training deficit, internal company training has become especially important. It effectively provides a robust foundation for successful treatment and distribution services through equipping staff to tackle evolving challenges, adopt best practice, and implement innovative water management strategies. By fostering expertise, training upholds operational excellence and responsible resource stewardship. There should be a greater focus on periodically reviewing and updating training so that knowledge is current. Maintaining records and scheduling training will ensure that all staff remain confident in their responsibilities while providing auditable company evidence.
5. Risk Assessments
Insufficient risk management stands as an area of reasonable concern. Many agencies often miss the mark on providing inclusive plans both for system operations as well as uniform organisation risk assessments. Through modifying and adapting risk plans compliant with the requirements under the SDWA, agencies can more effectively mitigate risks to prevent the recurrence of past issues and better predict future hazards. Risk assessment frameworks should be adaptable and scalable to optimise usability. This can be achieved through continually updating and improving risk plan documentation through annual reviews as well as carrying out internal audits to identify specific areas for risk management improvement.
6. Record Keeping
Although less frequently recommended as an OFI, record keeping is essential for informed decisions, compliance, and accountability. Records were observed to be either completely absent from the system or missing critical details such as attendance, review dates and meeting minutes. Comprehensive records support sufficient monitoring, emergency response, and long-term planning while building trust and enabling collaborative resource management. It would be beneficial to implement checklists for routine tasks to validate data and information. Additionally, shifting to a centralised document management system would streamline record organisation and allow ease of access for relevant staff.
7. Health Based Targets (HBTs)
HBTs have been a consistently identified audit theme. These generally refer to inadequacy and inaccuracy of assessments, procedures and treatments surrounding sanitation-based hazards. Defining and identifying HBTs are imperative in guiding effective treatment, monitoring, and risk prevention to instil public confidence in the agency’s water supply. Addressing these challenges requires a comprehensive approach. HBT methodologies must be accurately and systematically followed across an agency’s water supply schemes. Findings from an assessment must also be an input into the risk assessment process and acted upon within a reasonable timeframe.
8. Asset Management
Although infrequently mentioned within audits, asset management is still worth noting. It was found that preventive maintenance and inspections were not consistently undertaken. This can result in misguided prioritisation of system improvements. Well-managed assets optimize resources, improve performance and ensure long-term reliability, benefiting both economically and water quality. Establishing maintenance programs should not be the end, review should be undertaken to ensure its effectiveness and completion of the program monitored and action taken as appropriate.
Our extensive experience undertaking audits has highlighted the need for continual improvement. Embracing a culture of continued progress encourages employees to consistently seek personal development. This enables the industry to proactively address evolving challenges such as intense weather events, workforce competency, changing regulation and technological advancement.
Viridis Auditors attained significant knowledge through the breadth and depth of audits that we have undertaken, and we are fully committed to outlining pragmatic solutions so that effective strategies may be applied for optimal performance and organisation success. Our work and dedication has been reflected in the positive feedback received from regulators and audit clients.
"[They] provided a sound audit of the Resorts new DW system. The feedback provided by James during the audit on where improvements could be made across each aspect of the system was excellent." (Mt Baw Baw - Alpine Resorts, SDWA Audit)
"When [Tasleem] came onsite he had already read all of the evidence, and questions were good. He knew our systems and the risk-based framework. All in all, very good and very thorough. Good understanding of the regulations." (GWM Water, SDWA Audit)
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