The Public Health Act 2010 and the Public Health Regulation 2022 require drinking water suppliers to have and comply with a ‘quality assurance program’ (or drinking water management system). This requirement applies to water suppliers defined in the Act, including water utilities, private water suppliers and water carters. Major water utilities, such as Hunter Water Corporation, Sydney Catchment Authority and Sydney Water Corporation, already have risk-based drinking water management systems as a requirement of their operating licences.
A drinking water management system (DWMS) consists of documents, procedures and other supporting information for the safe supply of drinking water. The DWMS must address the elements of the Framework for Management of Drinking Water Quality (Australian Drinking Water Guidelines) relevant to the operations of the supplier. At the heart of the Framework are Critical Control Points (CCPs). A CCP is an activity, procedure or process that is critical to control a water quality hazard (for example chlorination and filtration/particle removal).
The DWMS must be kept current and regularly reviewed to ensure that it has been properly implemented and risks are effectively addressed. The DWMS must be internally reviewed by the water utility at least annually and a report provided to the local Public Health Unit (PHU). A complete review should be conducted in consultation with relevant stakeholders including the PHU and Department of Planning, Industry and Environment (DPIE) Water every four years in line with Strategic Business Planning. NSW Health recommends the use of an external facilitator for the risk assessment workshop. There is also guidance on external review/audit below.
The utility should assess risks, and if necessary, test for indicator organisms, pathogens, cyanobacteria, pesticides, disinfection byproducts, other organic compounds and radiological contamination. The local PHU can help with technical support for risks assessments through specialist contractors and, where applicable, project monitoring. The NSW Health Drinking Water Monitoring Program booklet also provides information on further testing.
The PFAS National Environmental Management Plan provides information on a range of activities that may be associated with per- and poly-fluoroalkyl substances (PFAS) (refer to Appendix B). NSW Environment Protection Authority (EPA) has established a PFAS investigation program for prioritising sites around NSW where PFAS were used in significant quantities. Utilities should ensure that they have assessed the risk to drinking water from PFAS, and include this in their drinking water management system. The water utility should engage the local PHU, the polluter and other relevant stakeholders. NSW Health recommends that all local water utilities undertake initial screening for PFAS. For local water utilities that have not tested for PFAS, NSW Health can arrange for testing of one sample of treated drinking water from each supply system.
Microbial health-based targets provide an assessment of the microbial safety of drinking water, including Cryptosporidium. The Australian Drinking Water Guidelines now include guidance on these targets.
NSW Health and the Department of Planning and Environment (DPE) Water have developed guidance to incorporate health-based targets into drinking water management systems and when applying for Section 60 approval. See Incorporating health-based targets into drinking water management systems and Section 60 approvals for more information on the adoption of health-based targets in regional NSW. Also see Health-based targets for Cryptosporidium in regional NSW drinking water supplies for more information on Cryptosporidium risk assessments and the adoption of health-based targets in regional NSW.
The NSW Guideline for Review and Audit of Drinking Water Management Systems has been recently updated (September 2024) to reflect changes to reviewer and conflict of interest recommendations. The use of a NSW Health approved reviewer is not required and NSW Health will not maintain a process to approve reviewers. Local water utilities may directly engage an external reviewer to audit their drinking water management system. NSW Health recommends that local water utilities ensure that the external audit is conducted by a person with appropriate experience and qualifications. For example:
NSW Health recommends that local water utilities ensure that the reviewer does not have any related conflicts of interest. If a conflict is identified, NSW Health recommends the local water utility ensure the interest is declared and documents how it will be managed.
The DWMS must be reviewed by the water utility at least annually to ensure that it is being properly implemented and risks are effectively addressed. The DWMS must be kept current.
The internal review should consider critical control point (CCP) performance, response to exceptions, and progress on actions and improvements. Utilities should immediately notify the Public Health Unit of any incident affecting drinking water safety, refer to the NSW Health response protocols for further information.
A brief annual review report should be provided to the local PHU. The DWMS should also be provided if any changes were made. CCP data monitoring and annual report templates are available to help utilities report and review DWMS implementation. Water utilities may use the templates below or develop their own format. Water utilities can contact their local PHU for assistance in using the templates.
NSW Health will, as part of its submission on annual Performance Monitoring, provide to NSW DPE Water the list of utilities that have submitted an annual review report.
