Providing Safe Drinking Water to Cisterns at Non-Residential Drinking Water Systems Serving Designated Facilities

What are my responsibilities to ensure safe drinking water under the Safe Drinking Water Act, 2002 and O. Reg. 170/03 for designated facilities that receive transported water and maintain cisterns?

Designated Facilities are buildings and places which are used by people who may be more susceptible to illness from drinking water of poor quality. Designated Facilities include:

• children’s camps
• child and youth care facilities, including child care centres
• health care facilities including hospitals, nursing homes and seniors’ residences
• social care facilities receiving funding from the Ontario government
• hostels and other delivery agent care facilities
• schools and private schools
• universities, colleges of applied arts and technology, or institutions with the authority to grant degrees.

Introduction

Under the Safe Drinking Water Act, 2002 and the Drinking-Water Systems Regulation (O. Reg. 170/03), owners and operators of drinking water systems that supply water to the public have responsibilities to ensure the water is safe to drink. This guide outlines the responsibilities of owners and operators of non-residential drinking water systems that serve Designated Facilities which receive transported water and maintain cisterns.

While owners can hire someone to operate their systems for them, they are still responsible for understanding their requirements under the drinking water regulations.

Designated Facilities provide water to people who may be more susceptible to adverse effects from consuming poor quality drinking water, especially children, the elderly, and patients with certain medical conditions.

Important: Even though your drinking water system receives treated water that is already tested, your system is still subject to some O. Reg. 170/03 requirements for monitoring and reporting, regardless if you only supply water for a limited time during the year or the whole year.

If your system supplies drinking water to a school, a private school or a child care centre (exclusively or in addition to another facility), the facility is also subject to O. Reg. 243/07 (Schools, Private Schools and Child Care Centres), for lead sampling and testing.

Following this guide and complying with the regulation and undertaking best management practices will help ensure that the health of these Ontarians is protected and drinking water standards are maintained.

Summary of requirements

Summary of Section 7, O. Reg. 170/03

Because water that is transported for cisterns must already have been treated by the supplier, you are exempt from certain requirements if two conditions in section 7, O. Reg. 170/03 are met:

1. You must ensure that the water you receive has had both primary and secondary disinfection as specified by O. Reg. 170/03.
2. The on-site container used to store the water must be constructed in a manner to prevent contamination and must be maintained to continue to prevent contamination. If your system meets these requirements, you are not required to:
   • treat the water
   • do microbiological sampling and testing
   • do chemical sampling and testing, except for annual lead sampling
   • do maintenance and operational checks of treatment equipment (except for chlorine residual testing)
   • arrange for an Engineering Evaluation Report(s) (EER).

Although treatment is not required, some owners choose to install Point of Entry (POE) treatment units. POE equipment, most commonly ultraviolet (UV) treatment, is designed to provide primary disinfection. It is installed at or near where the water enters a building or structure and is connected to the plumbing associated with that building or structure. If these units are installed according to the requirements in section 7 you are also exempt from chlorine residual testing. For information on the detailed exemption requirements in section 7 related to POE units, please refer to subsections 7(4) and (5) of O. Reg. 170/03.

There are further details about your requirements in the chart below and in the guide. Note: “Not required” only applies to where the requirements under section 7 of the regulation are met.

Does this guide apply to my drinking water system?

If you have a cistern or water storage system which holds transported water and you provide this water to the public, you are regulated under O. Reg. 170/03 and may be regulated under O. Reg. 243/07. Transported water means water which is supplied to your system via a water hauling truck, rather than from a direct connection to a water main, well or surface water.

If your system fits any of the categories below, your drinking water system is covered by one or both of the two regulations:

O. Reg. 170/03

• small or large non-municipal, non-residential system
• small or large municipal, non-residential system

And your system serves a designated facility such as a:

• public or private school, and/or a child care centre
• children’s camp
• child and youth care facility
• health care facility including hospital, nursing home, seniors’ residence
• social care facility receiving funding from the Ontario government
• hostel or other delivery agent care facility
• university, college of applied arts and technology, or institutions with authority to grant degrees

O. Reg. 243/07

• your system serves a public or private school, and/or a child care centre.

Register your drinking water system

• All drinking water systems serving Designated Facilities must register with the Ministry of the Environment, Conservation and Parks. This information is stored in the ministry’s Drinking Water Information System. Registration information helps meet our shared commitment to safe clean water for the people of Ontario.
• To register, complete the Drinking Water System Profile Information form. Once completed, email it to: waterforms@ontario.ca.
• Once you have registered, you will be sent a letter with your system’s Drinking Water System (DWS) number and category. Use this DWS number for reference purposes when contacting the registration team and when completing ministry and laboratory forms.
• You must register within 30 days of beginning operations.
• Any changes to your drinking water system (e.g., contact information or changes in water treatment equipment) must be submitted by sending the Drinking Water System Profile Information form via email to waterforms@ontario.ca within 10 days of the change.
• Note: If your system serves a school, a private school and/or a child care centre, you must also submit a separate registration form for lead sampling as required by O. Reg. 243/07.
• If you have any questions about registration, call the Registration Help Desk at 1-866-793-2588.

Select a licensed laboratory

• Drinking water samples must be sent to a laboratory licensed by the ministry for testing of any relevant parameters, except for chlorine residual which must be done on-site.
• To hire a licensed laboratory for testing, view the list of licensed laboratories or contact the Registration Help Desk at 1-866-793-2588, or contact a laboratory directly. You must use a laboratory licensed by the ministry.
• It is important that you contact the licensed laboratory directly to arrange for testing prior to submitting samples to them.
• Before sending your samples to a licensed laboratory for the first time, you must submit the Laboratory Services Notification form to the ministry which identifies the licensed laboratory(ies) that you have hired and the specific testing they will be performing.
• It is extremely important that your registration information is fully completed and up-to-date at all times. Test results will not be considered by the ministry unless all of this information is included in laboratory submissions.
• Your licensed laboratory must send a written report of all results to you within 10 days of their approval of the results. Your results are also submitted electronically to the ministry by the licensed laboratory.
• If the licensed laboratory finds an adverse test result, they must notify you, the ministry, and the local medical officer of health immediately by telephone. The laboratory must then give written notice of the adverse test results to the ministry and the local medical officer of health within 24 hours of giving verbal notice.

Storage of transported water

All systems that receive transported water must ensure that the storage container, e.g., cistern, water tanks or reservoir, is constructed using materials, including the surface coating, that do not contain any impurities that could dissolve into the drinking water. It must be maintained in a manner that prevents surface water and other foreign materials from coming into contact with the treated water.

Ensure that the cistern is not connected to the rainwater drain system, as contaminants from the roof will contaminate the cistern water. Cisterns should also have a screened vent to allow proper pressure within the tank and prevent insects or vermin from entering the vent. Since most cisterns are below ground, common weaknesses in cistern construction include improperly installed vents or below ground level cracks or damage due to improperly protected cistern covers. Vents and covers are above ground and are vulnerable to damage by cars and snow removing equipment.

As part of your regular maintenance, check the cistern opening and the area around the cistern to ensure there are no cracks or damage which could allow surface contamination to enter the cistern. Also ensure the ground around the cistern slopes away from the hatch and any vents, and that the hatch seal is in good condition and prevents surface water or vermin from entering the cistern.

Cisterns should be emptied and cleaned about every two to five years as sediment may collect and biofilms may form over time, causing bacteria to grow in the cistern. The cleaning frequency depends on the source water quality and whether the cistern is only used seasonally, in which case it is recommended you disinfect annually with chlorine. We recommend you consult the local health unit regarding how to best clean your cistern.

Supplier of transported drinking water

To ensure the quality of drinking water delivered by the water hauler, you must only use water from a regulated drinking water system providing primary and secondary disinfection, most commonly municipally treated and tested water.

Municipal drinking water systems are regulated under O. Reg. 170/03 for monitoring, sampling, treatment, and adverse test results. Municipal residential systems also undergo rigorous ministry annual inspections to ensure compliance with regulations. If the water comes from a non-municipal owned drinking water system, you must ensure it is registered with the ministry and regulated under O. Reg. 170/03.

It is recommended that you ask the water hauler for the Drinking Water System number of the system(s) they obtain water from to fill your cistern. This will help you confirm that you are receiving water that is treated properly. Also ask the water hauler to find out if the system the drinking water is obtained from provides chlorination or chloramination as this affects measurement of chlorine residual.

When you register your system with the ministry, you will be required to provide the supplier’s DWS number(s).

Water haulers are not regulated by the Ministry of the Environment, Conservation and Parks. We recommend that the water hauling truck you retain is only used for transporting treated drinking water. For information regarding water haulers in your area, you can contact your local public health unit. Some public health units have recommendations for using water haulers. Your local municipality may also have a list of water haulers that regularly transport treated municipal water to regulated drinking water systems.

Microbiological sampling/testing of the raw, treated and distribution water

Normally drinking water systems regulated under O. Reg. 170/03 are required to sample raw, untreated water as well as treated and distribution system water and test for microbiological parameters such as total coliforms and E.coli. The transported water will already have been treated and tested under O. Reg. 170/03 prior to delivery to this cistern. As a result, no additional sampling/testing is required by you.

Although not required by the regulation, the ministry recommends you sample your received water for microbiological parameters on a regular basis. If you have installed optional POE treatment units, you can sample before the treatment unit to test the water in the cistern itself and after the treatment unit to test the water after it is treated.

Regular sampling helps to ensure that the integrity of either the water hauler’s tank or the cistern has been maintained. Detection of microbiological organisms in cistern water would indicate that the water hauler’s tank, the cistern or the supply line from the cistern has been compromised, either through the intrusion of surface water into the cistern/supply line, or through improper handling in the water hauler’s tank. By testing for microbiological parameters, you will be able to react in a timely manner to any contamination.

Only a licensed laboratory is permitted to test drinking water samples for microbiological parameters. Such samples must be sent to a licensed laboratory.

Chemical sampling/testing

Similar to microbiological parameters, because the transported water was already sampled and tested, it does not have to be resampled and tested by cistern owners except for lead. Chemical sampling can be done voluntarily for parameters such as metals or inorganic and organic contaminants such as pesticides and volatile compounds (e.g., petroleum products).

Annual lead sampling under Schedule 15.2, O. Reg. 170/03 is required. Lead must be sampled from a location that is most likely to have higher lead levels, e.g., the oldest pipes. The frequency is reduced to once every 36 months if in the most recent 24-month period no lead test results exceeded the Ontario Drinking Water Standard for lead. Only a licensed laboratory is permitted to test drinking water samples for health related chemical parameters such as lead.

Water treatment

Since transported water must be treated before it is delivered to the cistern owner, the water does not require further treatment once received.

If you choose to install treatment equipment, you must ensure that the equipment is operated in accordance with the Safe Drinking Water Act and its regulations. See the next section, Operational Checks, for more information about optional POE treatment units or chlorine injection units.

Engineering evaluation reports

An Engineering Evaluation Report (EER) would also not be required if the system had treatment equipment installed prior to the installation of the cistern or if the cistern had additional treatment equipment to ensure the continuous quality of the drinking water.

Systems which receive transported water should ensure that the supplying system is regulated under O. Reg. 170/03. These systems are required to have an Engineers Evaluation Report. The report can be viewed at the supplying systems’ offices upon request.

Operational checks

If you receive chlorinated water, you must take daily chlorine residual readings in your distribution system to ensure disinfection is maintained. Measure free chlorine residual if the supplier provides chlorination but not chloramination. Measure combined chlorine residual if the supplier provides chloramination.

A trained person is required to perform these tests. The trained operator understands how to perform the testing and what to do if the chlorine levels need to be increased. They also understand that a free chlorine residual result below 0.05 mg/L or a combined chlorine residual result below 0.25 mg/L must be reported as an adverse test result.

A trained person is a person who is a certified operator or who in the preceding 36 months has successfully completed a course approved by the ministry that relates to the operation and routine maintenance of drinking water systems. A correspondence course entitled Operation of Small Drinking Water Systems has been approved for this purpose. For more information on the correspondence course and other training opportunities, please see the Walkerton Clean Water Centre website or call 1-866-515-0550. Other approved courses are listed on the Ontario Water Wastewater Certification website, or call 1-877-231-2122 for more information.

Chlorine residual readings are not required on a day on which all Designated Facilities and all public facilities served by the system are closed.

In lieu of daily chlorine residual monitoring, you may choose to install a POE treatment unit to further treat drinking water leaving the cistern. This unit must be equipped with either an automatic shut-off or causes an alarm to sound at locations specified in section 7 of the regulation in case the unit malfunctions or loses power. A POE unit must be connected to the plumbing of every building or structure served by the cistern that is part of a designated facility or public facility.

If a POE unit is used that meets the section 7 requirements, then there is no requirement to take chlorine residual readings or employ a trained person, certified operator or water quality analyst. However, the ministry recommends that at least one person involved with the drinking water system take the trained person course.

Alternatively, although not a requirement, you may use a chlorination injection system to maintain a continuous level of treatment of the treated drinking water. You must still do daily chlorine residual testing; and a trained person, certified operator or water quality analyst is required to monitor the chlorine injection and collect and analyse samples.

Although not required, routine maintenance and operational checks are recommended to ensure a safe source of drinking water. If you use UV POE equipment, maintenance recommendations would include: changing UV bulbs annually or as recommended by the manufacturer, regular checks documenting that the UV light is on and that (where equipped) the automatic shut-off valve is in automatic mode, not manual mode.

Operational checks for chlorination injection systems could include checking injection tubing for wear and tear, checking the injection pump for leaks, and replacing gaskets/seals.

Refer to the equipment manufacturer’s recommendations for other types of treatment equipment you may choose to install.

It is a good idea to use a logbook to document these routine checks. The information will help to anticipate the necessity of adding chlorine to the chlorine tank, equipment servicing or replacement and minimize the potential for breakdowns. It is recommended to have back-up equipment on-site and a trained person or certified operator on-call in case of equipment failure.

There is a Keeping Track schedule that outlines your testing requirements. A log book template is also available. Ask your local water inspector.

Adverse test results and other problems

An adverse test result is one that is listed in section 16-3 of Schedule 16 of O. Reg. 170/03. This includes a result that exceeds any of the standards prescribed by Schedule 1, 2 or 3 to the Ontario Drinking Water Quality Standards if the result is from a sample of drinking water. Chlorine residual readouts lower than the limits set in section 16-3 are also considered adverse test results.

Note: Facilities subject to O. Reg. 243/07 must also report exceedances of the standard for lead.

You may be informed about an adverse test result by your licensed laboratory or from a test result of a sample taken on-site.

Adverse test results and system problems related to improper disinfection must be reported to the listed authorities.

What to do if you have an adverse test result

You should ensure ahead of time that contact information for the ministry’s Spills Action Centre and your local medical officer of health at your local public health unit is easily accessible to anyone who may need it.

As soon as you become aware of an adverse test result, you are required to immediately contact your local medical officer of health and the ministry’s Spills Action Centre (SAC) at 1-800-268-6060. If there is a designated facility served by the cistern, you are also required to contact the operator of the facility immediately.

First: Make an immediate report

Immediately report the adverse test result or other problem to all of the following:

• your local medical officer of health at the local public health unit, by speaking with someone in person or on the telephone. Contact information for your local public health unit can be found at the Ministry of Health and Long-Term Care website
• the ministry’s Spills Action Centre (telephone 1-800-268-6060); the Spills Action Centre is open 24 hours/day and 365 days/year
• the operator of each designated facility served by your system, by speaking with someone in person or on the telephone if that operator is someone other than yourself.

Second: Deliver written notice

Within 24 hours of giving the verbal notice, you must complete and submit Section 2(A) Notice of Adverse Test Results and Issue Resolution (Schedule 16) to all of the following:

• the local medical officer of health by fax or in person
• the ministry’s Spills Action Centre by fax at 1-800-268-6061 or 416-325-3011 or by email at AWQI.Reporting@ontario.ca
• the operator of a designated facility by fax or in person if that operator is someone other than yourself
• the interested authority for the designated facility by fax. The interested authority is usually the Ontario government ministry to which the designate facility is responsible, e.g., the Ministry of Education if it is a school.

For adverse chlorine residual results, you (or your operator) must also fill and submit Section 3 of the form.

Third: Deliver follow-up notice of corrective action taken

Once you have resolved the problem, you have seven days to submit Section 2(B) Notice of Adverse Test Results and Issue Resolution (Schedule 16) form.

The follow-up written notice must summarize the corrective action taken and the results achieved. Send the notice to:

• the local medical officer of health and the ministry’s Spills Action Centre within seven days of resolving the issue and
• the interested authority for the designated facility within 30 days.

Take corrective action if required

If you are required to report an adverse test result or other problem, not only must you notify the appropriate authorities as stated above, you must also follow corrective actions to resolve the problem and protect the people who are using your water. You must follow the proper set of corrective actions for the specified adverse result or problem.

You can also contact your local Ministry of the Environment, Conservation and Parks office for further advice on any adverse test results.

Post warning notices of potential problems whenever required

You must post approved ministry-issued warning notices if:

• following adverse test results or other problems, you are required to notify users to use an alternate source of drinking water or, if no alternate source is available, to bring water to a rapid boil for at least one minute before use or
• you are not currently meeting your sampling requirements or
• you have not yet carried out required corrective actions.

Where to obtain official warning notices

Warning notices must be in a form provided by or approved by the ministry. There are two types of warning notices available from the ministry. Ensure with ministry staff that the proper notice is used.

You can obtain ministry approved warning notices by calling the Registration Help Desk at 1-866-793-2588.

If you have not yet obtained warning notices, you can (as an interim measure) post any sign that states: “Public Notice: Do not drink this water” until you have received the ministry approved warning notices.

Where to post warning notices

• Warning notices must be posted in prominent locations where they are likely to be seen by those using water from the system.
• Warning notices must also be posted at every entrance to every building or structure that is part of a designated facility.
• If you do not own or operate the designated facility, you do not have to post notices in the designated facility as above, but you must ensure that the operator of the facility is provided with:
  • sufficient copies of the warning notices and
  • instructions to post the warning notices as above.
• If a warning notice that is required is not posted at your drinking water system, a provincial officer, public health inspector or agent of the interested authority may do so instead.

Warning notices do not provide an exemption from testing or corrective action

The warning notices required to be posted are a temporary requirement meant to protect users of the system in the short term. The owner must still comply with testing and corrective action requirements as soon as possible, despite posting the warning notices.

Prepare an annual report

All drinking water systems subject to the Drinking Water Systems Regulation must prepare an annual report each year, a copy of which must be kept on-site. A copy must also be given to each designated facility served by the system, and if applicable, to each interested authority.

For most systems to which this guide applies, the annual report must cover the period from April 1 of the previous year to March 31 of the current year and must be prepared by May 31 of every year.

Different deadlines may apply to some systems – consult section 11 of O. Reg.170/03 for more information.

The annual report must include a:

• description of the drinking water system
• summary of any adverse test notices
• summary of all tests and their results
• summary of any corrective actions undertaken
• description of any major expenses for the system.

Retain records

You must include daily chlorine monitoring data (unless using POE treatment) and annual lead sampling data in your records.

Schools, private schools and child care centres must also keep flushing and lead sampling records. In your records you need to keep information on the date and time samples were taken, an estimate of the standing time before the first sample was taken, the sampling results and who performed the sampling. For flushing information, include the date, time and the location of the flushing and who performed the flushing.

If you voluntarily take microbiological sampling, keep the laboratory reports at the site.

Keep copies of all the test results from your required samples, every order that applies to the system, and your annual report on-site. Where continuous monitoring equipment is used, only the daily minimum, maximum and mean results need to be available. You must make all the records available free of charge to the public, upon request, at the facility between 9:00 a.m. and 5:00 p.m. or during normal business hours. You must also have a copy of O. Reg. 170/03 available to the public.

Records and reports must be kept for certain time periods for review by ministry inspectors and any licensed engineering practitioner/hydrogeologists preparing an opinion, report or assessment regarding your system for the purposes identified in O. Reg. 170/03.

Keep the following for at least two years:

• operational test results
• records of maintenance checks and activities.

Keep the following for at least six years:

• lead results
• annual reports.

Records kept on site should also include:

• the date the cistern was installed
• the size of the cistern
• receipts from the water hauler, including where they retrieve the municipally treated water as well as any maintenance work such as repairs on the cistern system or treatment system (if there is any).

Who to contact for more information

If you would like other guides and fact sheets related to drinking water, please visit the ministry’s drinking water web page or contact:

Registration Help Desk
waterforms@ontario.ca
Tel: 1-866-793-2588