INTRODUCTION
1. ABOUT THE APPROVALS PROCESS IN THE UNITED KINGDOM
The following Regulations apply to the approval of substances and products used in the provision of public water supplies in the United Kingdom:
- England - Regulation 31 of The Water Supply (Water Quality) Regulations 2000 (Statutory Instruments 2000 No 3184) - http://www.dwi.gov.uk/regs/si3184/3184.htm
- Wales - Regulation 31 of The Water Supply (Water quality) Regulations 2001 (Welsh Statutory Instrument 2001 No 3911 (W.323) - http://www.opsi.gov.uk/legislation/wales/wsi2001/20013911.htm
- Scotland - Regulation 27 of The Water Supply (Water Quality) (Scotland) Regulations 2001 - http://www.opsi.gov.uk/legislation/scotland/ssi2001/20010207.htm
- Northern Ireland - Regulation 30 of The Water Supply (Water Quality Regulations) (Northern Ireland) 2002 - http://www.opsi.gov.uk/sr/sr2002/20020331.htm
The products on this list have been subject to separate authorisation by the Department of Environment, Food and Rural Affairs together with The National Assembly for Wales, the Scottish Ministers and the Department of Environment (Northern Ireland) (collectively referred to as the Authorities) under their respective approval and/or regulatory regimes.
Approvals are also recognised in many other parts of the world.
The Committee on Products and Processes
The Committee on Products and Processes for Use in Public Water Supply ( CPP) provides expert advice to the Chief Inspector of Drinking Water in England and Wales on approval issues. As set out in the Memorandum of Understanding between the United Kingdom Drinking Water Regulators (March 2005 - http://www.dwi.gov.uk/mou/mouukregulators.pdf), the CPP provides a similar function for the authorities in Scotland and Northern Ireland, although the regulatory provisions are different.
The Committee is an advisory Non-Departmental Public Body. It currently consists of seven members with expertise in engineering, materials science, toxicology, chemical analysis, organic chemistry, water treatment and consumer relations. Details of the membership are given in section 3. The Committee meets approximately four times a year.
The dates of Committee meetings are posted on the CPP website: http://www.dwi.gov.uk/cpp/ccmeet.shtm.
The Drinking Water Inspectorate provides technical and administrative support to the Committee. The Committee' Technical Secretariat can be contacted at cpp@defra.gsi.gov.uk
Basis of approval.
When considering an application for approval, the Committee advises only on whether the use of a substance or product will adversely affect the quality of water, or cause a risk to the health of consumers. The Committee does not assess fitness for purpose. Therefore approval by the Authorities cannot be taken as a favourable assessment of the performance, or technical merits of a product. Approved products have not been assessed for suitability for use with regeneration chemicals used in association with some water treatment processes; for regeneration chemicals used in association with some water treatment processes; for such use, specific testing after exposure to the appropriate aggressive chemicals should be undertaken.
The Committee cannot advise on approval of products that will not be placed on the United Kingdom market.
Applications are considered for all construction products used in contact with water in water treatment processes, water supply pipelines (including raw water pipelines) and drinking and raw water storage installations. In addition the Committee considers water treatment chemicals and filtration media which are not covered by a published BSEN standard; products (individual chemicals or filter media) that conform with a BSEN standard may be used without the approval of the Authorities.
A series of Advice Sheets gives an overview of the regulatory requirements and information that must be provided in support of applications. These advice sheets are available on the CPP website: http://www.dwi.gov.uk/cpp/guidance.shtm. Currently, the sheets available are:
- Overview of the application process
- Instructions for Use ( IFU) document
- Treatment chemicals, filter media & ion exchange resins
- Changes to Approved Products
- Approval of products made from recognised materials
- Approval of membrane filtration systems & associated equipment
- Construction products for water retaining structures in water collection, treatment and distribution systems
The Committee also publishes a series of test protocols for use in assessing the suitability of products for use with drinking water - see the CPP website: http://www.dwi.gov.uk/cpp/guidance.shtm. Currently, the protocols available are:
0. Designated Test Laboratory requirements
1. Reporting Requirements
2. Non-metallic products: General Method
3. Cement admixtures and concrete
4. Metallic products: general Method
5 Water Treatment Membranes
6. Filter Media and ion exchange resins
The Annual List of Approved Products
Each year a list of all substances and products for which approval has been granted, refused, revoked or modified, or for which their use has been prohibited, is published. This list, together with unconsolidated "Update" listings giving details of changes and additions to the List of Approved Products, is posted on the DWI website: http://www.dwi.gov.uk/cpp/pagea.shtm, the Scottish Executive website - http://www.scotland.gov.uk/Publications/, and in Northern Ireland - www.ehsni.gov.uk/water/drinkwater/regulations.htm.
2. Report for 2006
Committee Business
During 2006 the Committee met on four occasions and 105* applications for approval were considered, including 41 new applications. 71 approval letters were issued on behalf of the Authorities, 5 products were re-instated and one product was refused approval. The Authorities gave approval to the modification of conditions to 5 currently listed products.
Note: 105* - this number includes the applications discussed during CPP meetings, the applications handled by the Secretariat, together with any modification or changes to approved products or re-instatements of approval.
Communications with water industry and approval holders DWI now communicates with the water industry and approval holders on approval issues only through Information Letters.
Two relevant DWI Information Letters were issued in 2006:
- 04/2006 introduced the 2005 list of approved products.
- 09/2006 provided details of changes to the in situ lining of water mains and provided clarification on the role that DWI will take from 1 January 2007. The letter had been separated into three parts:
- Notification of DWI's withdrawal as nominator of certifying bodies and management of the Operational Requirements and Code of Practice.
- Update to the Operational Requirements and Code of Practice for the In-Situ Resin Lining of Water mains.
- Determination of Minimum Spin-Up Time and Adequate Mixing
The CPP also issues Information Bulletins, from time-to-time, to Regulation 31 practitioners working for water suppliers. One was issued in 2006, for Materials for use in well and borehole construction and installation.
Copies of Regulation and relevant Information Letters, together with Information Bulletins are available on the website: http://www.dwi.gov.uk/cpp/25_31reg.shtm.
Audit of approved products
A requirement for audit of approved products was introduced in July 2002 and the programme of auditing, which started in Autumn 2002, has continued throughout 2006. A total of 147 approval holders' products were selected for audit. As of December 2006:
- 96 audits had been completed
- 40 products had been delisted because they were no longer made and/or sold to the water industry, the approval holder declined the audit or the approval holder no longer existed.
- 11 audits were outstanding
Full details of products removed or revoked from the 2005 List are given in Appendix 1of this report. Future audit arrangements are now set out on the CPP website: http://www.dwi.gov.uk/cpp/auditsummary.shtm
European developments in treatment chemicals and construction products
The majority of chemicals and filter materials for drinking water treatment are now the subject of European standards. A full listing of the relevant standards published by the British Standards Institution in its BSEN series is contained in Appendices 2.1 and 2.2. Appendix 2.3 lists the European standards for testing the effects of organic materials on water intended for human consumption.
DWI provides expert representation on the European Commission's ( DG Enterprise) Expert Group - Construction Products Drinking Water, that is advising the Commission on the development of a revised European Acceptance Scheme ( EAS) for drinking water construction products under Essential Requirement 3 (Hygiene, health and the environment) of ANNEX 1 (Essential Requirements) of the Construction Products Directive 89/106/EEC - CPD). It is unclear, at present, as to when this revised EAS could be implemented since the preparation of some of the required harmonised product standards and supporting test methods is yet to be completed, which could delay implementation by several years.
Although DWI has taken steps to prepare for the possible future implementation of the revised EAS, including where appropriate and possible, early implementation of European standards for test methods for construction products, there are currently uncertainties concerning -
- the extent to which the revised EAS, based upon the CPD, will meet the product approval requirements and arrangements under Regulation 31 of the Water Supply (Water Quality) Regulations 2000 and 2001 (based upon Article 10 of the Drinking Water Directive (98/83/EC - DWD))
- whether all the products currently approved under Regulation 31 will be covered by the revised EAS based upon the CPD.
3. Membership of the Committee
The Committee was established as an advisory Non-Departmental Public Body in May 1998. All appointments to the Committee are made in accordance with the guidelines issued by the Office of the Commissioner of Public Appointments. The current membership as of December 2005 is:
Chairman:
Mr Owen Hydes OBE was nominated by the Royal Society of Chemistry. He is an independent consultant.
Members:
Mrs Joy Fraser is an independent member appointed to represent consumers' interests.
Dr John Greig was nominated by the British Toxicology Society as an expert in toxicology. He is an independent consultant.
Dr Roger Stokes was nominated by the Institute of Materials, Minerals and Mining as an expert on construction products and materials used in the water industry. He is an independent consultant.
Mr Geoff Tute MBE was nominated by Water UK as an expert in civil engineering, water treatment and water operations. He is an employee of Southern Water.
Mr Robin Walls was nominated by the Royal Society of Chemistry as an expert in analytical chemistry and quality assurance. He is an independent consultant.
Mr Steve Scott was appointed after open competition for a specialist organic chemist. He is an independent consultant.
Advisers:
Mr John Ashworth is a civil servant in the Drinking Water Inspectorate and is nominated by Defra as an adviser on the Regulations, and implementing the CPP' s recommendations.
Mr Stephen Robjohns is a toxicologist in the Chemical Hazards and Poisons Division of the Health Protection Agency (a non-departmental public body).
Technical Secretariat:
Ms Yamide Dagnet : Technical Secretary
The Technical Secretary is a civil servant employed by the Drinking Water Inspectorate.
LIST OF APPROVED PRODUCTS
All approved products must be used in accordance with the specific conditions of approval, listed against the product names in Part I-IV. In addition, the following general conditions of approval apply to all approved products:
- That use is in accordance with an Instructions for Use document. Approval holders must provide water companies with copies of the Instructions for Use Document that was considered by the Committee when approval was recommended.
- That the approval of the Government Authorities is obtained on condition that there shall be:
- no change in the formulation of the approved product, including change in source or identity of raw materials;
- no change in the manufacturing process, including location of manufacture;
- no change in designation of the approved product;
- no change in name or ownership of the organisation holding the approval.
- That the producer shall ensure that the product is tested for conformity with its formulation, and the source or identity of its raw materials, at such intervals and by such persons, as may be determined by the Secretary of State. The results of such testing shall be sent to the Authorities.
- No Claim of "Approval by DWI" is permitted. For further information on acceptable claims , please see the following website: http://www.dwi.gov.uk/cpp/pdf/FAQ2.pdf