_____________________________________________________________________

Office of Water (4601M)

Office of Ground Water and Drinking Water
Total Coliform Rule Issue Paper

Hazard Analysis Critical Control Point (HACCP)

Strategies for Distribution System Monitoring,
Hazard Assessment and Control

DECEMBER 2006
 PREPARED FOR:

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water
Standards and Risk Management Division
1200 Pennsylvania Ave., NW
Washington DC 20004

PREPARED BY:

HDR, Inc.
The Cadmus Group, Inc.
U.S. EPA Office of Groundwater and Drinking Water

Background and Disclaimer

The USEPA is revising the Total Coliform Rule (TCR) and is considering new possible
distribution system requirements as part of these revisions. As part of this process, the
USEPA is publishing a series of issue papers to present available information on topics
relevant to possible TCR revisions. This paper was developed as part of that effort.

The objectives of the issue papers are to review the available data, information and
research regarding the potential public health risks associated with the distribution
system issues, and where relevant identify areas in which additional research may be
warranted. The issue papers will serve as background material for EPA, expert and
stakeholder discussions. The papers only present available information and do not
represent Agency policy. Some of the papers were prepared by parties outside of EPA;
EPA does not endorse those papers, but is providing them for information and review.

Additional Information

The paper is available at the TCR web site at:

http://www.epa.gov/safewater/disinfection/tcr/index.html

Questions or comments regarding this paper may be directed to TCR@epa.gov.

Hazard Analysis Critical Control Point (HACCP) Strategies
for Distribution System Monitoring,
Hazard Assessment and Control

January 19, 2007

PREPARED FOR

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water
Standards and Risk Management Division
1200 Pennsylvania Ave., NW
Washington DC 20004

FIRST DRAFT PREPARED BY:

HDR, Inc.
10900 NE 4th St. Suite 1110
Bellevue, WA 98004

REVISED BY:

The Cadmus Group, Inc.

1600 Wilson Blvd, Suite 500
Arlington, VA 22209

USEPA Contract No. 68-C-02-042

Work Assignment No. 2-06
 January 19, 2007

Table of Contents

1 Overview .................................................................................................................1

2 Introduction............................................................................................................1

3 Background ............................................................................................................4
3.1 The HACCP System.........................................................................................5

4 Use of HACCP in Regulatory Frameworks.......................................................11

4.1 World Health Organization Drinking Water Guidelines .................................12
4.2 USEPA Aircraft Drinking Water Rule ............................................................13
4.3 Australian Drinking Water Guidelines ............................................................15
4.4 New Zealand Public Health Risk Management Plans .....................................16
4.5 Switzerland Hygiene Regulations....................................................................18
4.6 Iceland Food Legislation .................................................................................18
4.7 France Regulation on Water Safety .................................................................18
4.8 Ontario Water Quality Management Standard ................................................18

5 Benefits of HACCP ..............................................................................................20

5.1 Improvements in Public Health Protection ....................................................21
5.2 Improved Regulatory Compliance .................................................................21
5.3 Demonstration of Due Diligence ...................................................................21
5.4 Improvements in Water System Processes.....................................................22
5.5 Improved Understanding of Risks and Risk Management.............................23
5.6 Improvements in Employee Skills .................................................................24
5.7 Improvements in Work Processes ..................................................................24

6 Challenges of Implementing HACCP ................................................................25

6.1 Resource Needs ..............................................................................................26
6.2 Management Support and Commitment.........................................................27
6.3 Employee Support and Commitment .............................................................27
6.4 Small System Issues .......................................................................................27
6.5 Large System Issues .......................................................................................28

7 HACCP Approach in Hazard Assessments.......................................................29

7.1 Hazard Identification......................................................................................29
7.2 Hazard Assessment.........................................................................................30

8 HACCP Approach in Control of Contamination .............................................34

9 HACCP Approach in Distribution System Monitoring ...................................35

10 HACCP Approach for Verification....................................................................36

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10.1 Internal Verification Procedures...................................................................37

10.2 External Verification Programs ....................................................................37

11 HACCP Approach for Documentation and Record-Keeping .........................39

12 Supporting Programs ..........................................................................................40

13 Summary...............................................................................................................41

References.........................................................................................................................44

Appendix A – Application of HACCP Principles City of Austin, Texas

List of Figures

Figure 1 Steps and Principles of the HACCP System......................................................7

Figure 2 Average Weekly Turbidity of Final Product ...................................................23
Figure 3 Example Risk Factor Matrix............................................................................32

List of Tables

Table 1 HACCP Programs for Controlling Public Health Risks in

Drinking Water ................................................................................................11
Table 2 Comparison of HACCP and Water Safety Plan Risk Management Approaches
..........................................................................................................................15
Table 3 New Zealand Approach for Preparing Public Health Risk
Management Plans ...........................................................................................17
Table 4 Example Hazard Analysis and Control............................................................33

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Evaluating HACCP Strategies for Distribution System Monitoring,

Hazard Assessment and Control

1. Overview
The USEPA is revising the Total Coliform Rule (TCR) and is considering new possible
distribution system requirements as part of these revisions. As part of this process, the
USEPA is publishing a series of issue papers to present available information on topics
relevant to possible TCR revisions. This paper on the Hazard Analysis Critical Control
Point (HACCP) system was developed as part of this effort. The HACCP system
provides an alternative approach to identifying and controlling microbiological
contamination in the distribution system. It offers a more proactive and comprehensive
framework that reduces the reliance on end-point monitoring and organizes all utility
programs and practices related to maintaining distribution system integrity. Through
implementing a HACCP program, a water utility identifies and prioritizes hazards that
can allow contamination to enter their distribution system, and establishes and
implements control measures to control these hazards.

The purpose of this paper is to review and summarize existing literature, research data
and case studies on the HACCP system to illustrate how HACCP can be applied to
distribution system protection. It includes examples of HACCP applications in
regulatory frameworks and draws on utility experiences summarized in a recent AwwaRF
study (Martel et al., 2006). The scope of this paper does not include a discussion of how
the HACCP system could be integrated into the existing U.S. drinking water regulatory
framework.

2. Introduction
Current distribution system management practices may leave some systems vulnerable to
contamination, as evidenced by failures linked to waterborne disease outbreaks. U.S.
waterborne disease records from 1920 to the present show that up to 40 percent of
waterborne disease outbreaks have been caused by distribution system problems (Lippy
and Waltrip, 1984; Kramer et al., 1996; Levy et al., 1998). For example, a Salmonella
typhimurium outbreak in Gideon, Missouri, was likely caused by bird droppings in two
finished water storage facilities when poor distribution system flushing practices caused
the complete draining of the two tanks into the system (Clark et al., 1997; Geldreich,
1996). An outbreak of hemorrhagic Escherichia coli (E. coli) serotype O157:H7
occurred in Cabool, Missouri during December 1989 and January 1990 and resulted in
243 cases of diarrhea and 4 deaths (Swerdlow et al., 1992). Shortly before the peak of
the outbreak, 45 water meters were replaced and two water mains ruptured. Swerdlow et
al. (1992) concluded that system wide chlorination as well as hyperchlorination during
repairs might have prevented this outbreak.

Inadequacies in design, operation, and maintenance of water distribution systems have

also been documented through recent research funded by the American Water Works
Association Research Foundation (AwwaRF). Kirmeyer et al. (2001) identified the
various potential pathways for contaminants to enter the distribution system, including

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 January 19, 2007

poorly designed, constructed, or maintained storage facilities, unprotected cross-

connections, and water main break and repair sites. Kirmeyer et al. (2001) also
documented evidence of fecal pollution and enteric viruses in the vicinity of water main
break sites, confirming the potential for pathogen intrusion given an available pathway
and favorable pressure conditions. Further research on pathogen intrusion during
pressure transients by Friedman et al. (2004) confirmed that transient negative pressures
do occur in distribution systems, and that significant volumes of water have been shown
to enter a pilot-scale distribution system through small leaks during transient pressure
events. Based on surveys of tank inspection firms, State primacy agencies and utilities,
Kirmeyer et al. (1999) concluded that many storage facilities in the United States are
never inspected, and many facilities are inspected less frequently than the 3-year
frequency recommended by the American Water Works Association (AWWA) (AWWA
Manual M42, 1998). A comprehensive survey on cross-connection control programs
(Lee et al., 2003) showed that 91 percent of survey respondents have developed cross-
connection control programs, but only 49 percent have a requirement for reporting
backflow incidents [to state primacy agencies]. There is no Federal reporting
requirement for cross connections. Most survey respondents were community water
systems (99 percent of those surveyed).

In addition to inadequacies in water system processes and procedures, the human element
affects a water system’s susceptibility to contamination. Kuslikis and White (2004) give
several examples of how water system employees can impact risks and risk management:

• Competent and loyal employees sometimes take shortcuts to save time or money, and
unknowingly take major risks
• Employees may not see the big picture and may have a much higher tolerance of risk
than water system management

Smith (2004) also acknowledges that some utility personnel may occasionally be
careless, understaffed or poorly trained.

Recently, the water industry has begun to move towards a more proactive approach to
managing the safety of water supplies by incorporating quality assurance principles. The
U.S. drinking water industry employs several quality assurance principles, especially for
the control of pathogens. For example, the Surface Water Treatment Rule (SWTR), as
amended, sets goals for pathogen occurrence in the finished drinking water, and has
regulatory provisions for meeting those goals. Provisions include watershed control,
source water quality, treatment performance requirements, and periodic on-site sanitary
surveys. Pathogen monitoring is not required under this rule. The goal of monitoring for
the SWTR and other microbial regulations is to assess the effectiveness of pathogen
control measures, using monitoring tools such as total coliforms, fecal coliforms, E. coli,
water turbidity, and disinfectant levels.

The USEPA Office of Groundwater and Drinking Water (OGWDW) encourages water
utilities to develop voluntary treatment optimization programs such as Comprehensive
Performance Evaluation (CPE) programs and Area-Wide Optimization Programs. Both

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of these programs focus on treatment facilities for surface water supplies. The CPE is a
thorough review and analysis of treatment plant performance and associated
administrative, operation and maintenance practices. The Area-Wide Optimization
Program (AWOP) may be used by state primacy agencies to identify systems with the
highest public health risk and to help these systems implement proactive measures to
improve performance. The focus of the AWOP is to optimize treatment performance of
existing particle removal, disinfection and distribution system facilities.

The USEPA has established numerous partnerships with industry and regulatory agencies
that encourage cooperation and sharing of resources for drinking water and other
environmental projects. For example, the Adopt Your Watershed program encourages
stewardship of the nation’s water resources. The Water Use Efficiency Program focuses
on creating market enhancement for water efficient products. The National Nonpoint
Source Management Program seeks to maintain and restore water quality in areas
affected by nonpoint source pollution. EPA’s Volunteer Monitoring Program encourages
volunteers who conduct water quality monitoring on local resources to share their data
and become involved in watershed stewardship and education.

The AWWA has several voluntary programs that incorporate quality assurance principles
for controlling pathogens in drinking water: QualServe, the Partnership for Safe Water,
and a new distribution system standard. QualServe is a continuous quality improvement
program that helps utilities improve overall service using a self-assessment tool, a peer
review process, and a benchmarking clearinghouse. The Partnership for Safe Water, a
joint initiative among AWWA, USEPA and other drinking water organizations, also uses
a self-assessment tool and a peer review process to optimize treatment plant performance
for systems using surface water supplies. AWWA Standard G200, Distribution Systems
Operation and Maintenance, effective May 1, 2004, describes critical elements for the
operation and management of water distribution systems.

In Australia, the McClellan Inquiry into the 1998 Sydney Water Cryptosporidium
contamination incident recommended introducing quality assurance procedures as a
framework for guiding water quality protection (Davison et al., 1999). A major revision
to Australian food legislation (Exposure Draft Food Bill) in 1999 included tap water in
the definition of food, and required a quality assurance system incorporating HACCP
principles for all food suppliers to assure food safety (Davison et al., 1999). More
recently, the Walkerton Inquiry in Canada also concluded, “Perhaps the most significant
recommendations in this report address the need for quality management through
mandatory accreditation and operational planning.” (O’Connor, 2002) The
recommended quality management system should include real time process control and
preventive strategies to identify and manage risks to public health (O’Connor, 2002).
This proactive, risk-based management approach is further emphasized by the new WHO
guidelines (3rd edition) and the complementary Bonn Charter for Safe Drinking Water
that are discussed later in this report (see section entitled Use of HACCP in Regulatory
Frameworks).

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3. Background
Quality assurance (QA) principles and procedures, such as the HACCP system, are
important in controlling risk. EPA defines QA as

… an integrated system of activities involving planning, quality control

(QC), quality assessment, reporting and quality improvement to ensure
that a product or service meets defined standards of quality with a stated
level of confidence. (EPA, 1991)

EPA defines QC as

… the overall system of technical activities whose purpose is to measure

and control the quality of a product or service so that it meets the needs of
users. The aim is to provide quality that is satisfactory, adequate,
dependable, and economical.” (EPA, 1991)

Application of QA principles may have some value for water supply since it is very hard
to manage the QC of drinking water between release from storage and the point of
consumption. In the water distribution system, QC is accomplished using water quality
monitoring, typically a combination of on-line monitoring and manual grab samples.
Because the monitoring samples represent a very small percentage of the actual volume
of finished water produced, it is difficult to measure and control the quality of the
finished drinking water strictly by QC measures. However, it is possible to improve
quality control over the transfer of water from treatment and storage to the customer
using QA principles so as to be confident that the water is likely to be safe. For example,
control measures may be instituted to improve safety of the finished water downstream
from water main construction sites. These control measures may include inspector
training, policies that restrict use of system valves and disinfection procedures for water
mains being returned to service, among others.

QA systems are incorporated into production and service delivery processes across the
developed world. There are a number of standards and guidelines available, with
International Organization for Standardization (ISO) being the internationally recognized
standards that are commonly applied in Europe, Australia, and Asia. Two ISO Standards
commonly employed by water utilities include ISO Standards 9001 and 14001. ISO
Standard 9001 defines a Quality Management System that demonstrates the ability to
consistently provide products and services that meet customer needs, regulatory
requirements and internal goals (Nyman, 2004). ISO Standard 14001 defines an
Environmental Management System (EMS) that addresses potential impacts on the
environment (Nyman 2004). These ISO standards evaluate current utility processes,
policies and procedures for specific business systems (i.e. accounting, customer service).
The ISO standards do not include an evaluation of risks/hazards and safety of the product
so cannot be considered as an alternative to HACCP certification/registration.

Most utilities that have implemented HACCP have first implemented quality

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management systems such as ISO 9001 and ISO 14001. “These management systems
helped the utility to gain management control of people and processes which made
implementing HACCP relatively straightforward.” (Martel et al., 2006) Integrated
management systems are becoming a new trend in the water industry where one quality
assurance system covers all business management aspects, including general quality
management (ISO 9000), protection of the environment (ISO 14001), drinking water
safety to the user (HACCP), and worker health and safety. The benefit of implementing
one integrated system is that only one audit would be required and utility staff will
implement only one set of policies and procedures (Deere, 2005).

3.1 The HACCP System

Originating in the 1960’s, HACCP was designed to ensure safety of food and beverages
from microbiological hazards for the first NASA manned space missions thus preventing
astronauts from falling victim to gastroenteritis while in space (NASA, 1991). HACCP
has been applied to food production processes since the 1980s and to drinking water
systems since the mid-1990s. The World Health Organization (WHO) guidelines for
HACCP, Codex Alimentarius, have been adopted internationally as the primary
recognized food safety methodology for risk management. The current HACCP
guideline was developed in 1997 by the Codex Alimentarius Commission
(http://www.who.int/foodsafety/codex/en ).

For drinking water, the HACCP system promotes a “source to tap” philosophy for
utilities to identify the critical points throughout the entire system, i.e., those points
within the system or its operation whose disruption or failure would result in a greater
public health risk compared to other points, and then to focus resources on these critical
locations and processes. This systematic approach would help the utility to identify
potential hazards closer to their source, thus minimizing the occurrence and effects of
incidents that degrade water quality and cause a public health threat. This type of
philosophy is already employed to some degree by many water utilities. For example,
utilities that use surface water supplies comply with the Federal SWTR using the
multiple barrier concept to control microorganisms in the finished drinking water. The
multiple barriers include source protection, coagulation/filtration, primary disinfection
and distribution system control measures. Under the multiple barrier approach, all
process steps are optimized to reduce risk (Smith, 2004). To integrate HACCP with
existing practices based on the multiple barrier approach, the utility could select critical
control points within several of the barriers or process, depending on the hazards of
concern.

A second example of utility experiences with the HACCP-type approach is the State-
mandated sanitary survey. The sanitary survey is a system audit conducted by an
independent, qualified third party to review a water system’s effectiveness in producing
and distributing safe drinking water. Through the sanitary survey, the inspector may
identify current or potential breaches in one or more of the multiple barriers including
physical facilities and/or utility procedures. The results of the sanitary survey may
inform the utility of facilities and procedures that need improvement in order to protect
the finished drinking water. However, the sanitary survey is not uniformly applied in all

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States and is dependent on state allocated resources and interpretation of federal

guidelines. The sanitary survey could be improved to be a more proactive inspection
with more emphasis on follow-up activities to assure that existing deficiencies are
corrected and action is taken to prevent potential deficiencies from occurring.

The Codex Alimentarius Commission defines 12 sequential steps (or 5 initial steps and 7
major principles) for planning and implementing a HACCP system (WHO, 1997). The
information prepared in completing these 12 steps constitutes the utility’s HACCP Plan.
These steps are summarized in Figure 1 and described in more detail as applied by the
City of Austin, Texas as part of a continuing research project funded by the Awwa
Research Foundation and the USEPA (City of Austin, 2003).

The City of Austin developed a HACCP Plan for one pressure zone of their water
distribution system. Austin’s HACCP Plan, included in Appendix A to this paper,
illustrates how the 12 steps of HACCP apply to their distribution system. The first seven
steps were developed in a training workshop held at the utility location in May 2003.
Workshop attendees included staff with a broad array of skill sets from various divisions
within the utility including individuals from the Water Lab, Systems Planning, Cross-
Connection Control, Process Engineering, Distribution System Operation, Water Quality,
Regulatory Compliance, and the State’s Regulatory Agency. At the workshop, a HACCP
team was formed to finalize the remaining steps of the HACCP plan as well as to guide
its implementation. Austin’s HACCP Plan was finalized in September 2003, and
implemented over a 12-month pilot study period from October 2003 through September
2004.

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Assemble a team

Describe the product

Document intended use of product

Initial steps in
the HACCP process

Construct a process flow diagram

Validate process flow diagram

Conduct hazard analysis

Identify Critical Control Points

Establish critical limits

The seven principles

of HACCP
Identify monitoring procedures

Establish corrective action procedures

Validate/verify HACCP plan

Establish documentation and record keeping

Source: WHO (1997)

Figure 1. Steps and Principles of the HACCP System

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Step 1 – Assemble a HACCP Team. Pull together a multidisciplinary team to plan,

develop, verify, and implement the plan.

The City of Austin’s HACCP team is composed of a state regulatory manager plus seven
utility employees: the water quality manager, a water laboratory supervisor, a
construction superintendent, an engineer, a cross-connection control program
superintendent, an infrastructure supervisor, and the assistant director of treatment. It is
important to include utility staff across all departments that have responsibilities and
expertise in drinking water quality and management. To foster employee empowerment
and acceptance of HACCP, it is equally important to involve as many employees as
possible including staff with all levels of seniority.

Step 2 – Describe the Product. Describe the product, in this case drinking water,
including its source, treatment, storage, distribution and any existing standards for
product safety.

Austin’s source of supply is the Colorado River. Raw water for the pilot study area is
currently diverted at Lake Austin and treated at the Ullrich Water Treatment Plant using
lime softening, recarbonation/pH adjustment, chloramination, filtration, and addition of
ferric sulfate, fluoride, and sodium hexametaphosphate. Treated water is stored at the
Ullrich Plant in two 10 MG clearwells, and in the distribution system in tanks. The
Utility owns a contiguous distribution system that serves a population of approximately
770,000 through roughly 183,000 service connections. The distribution system contains
2,995 miles of water mains of a wide variety of materials including cast iron, ductile iron,
PVC, asbestos cement, and reinforced concrete cylinder. The distribution system also
contains 30 tanks ranging in size from 300,000 to 34,000,000 gallons. Because of the
varied topography in the utility’s service area, the distribution system is divided into
eight major pressure zones. Austin’s product description also describes Federal and state
regulations that pertain to the distribution system as well as Austin’s internal water
quality goals for the distribution system.

Step 3 – Identify Intended Use. Describe how the product is used and the major users.

The City of Austin has residential, commercial and industrial customers. The City’s
finished drinking water is used for the following purposes:

• Drinking
• Manufacturing, including semi-conductor manufacturing processes that are sensitive
to total organic carbon and trihalomethane levels
• Irrigation
• Culinary uses
• Fire fighting
• Construction uses
• Sanitary uses (toilet flushing and showers)
• Medical uses (hospitals, dialysis centers, dental offices)
• Product water (Coca Cola and Abbott Labs)

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Step 4 – Construct a Flow Diagram. For a comprehensive HACCP, this would be a

schematic showing sources of water, details of treatment, storage, pumping, and
distribution to end users. For a HACCP directed toward a distribution system, the
schematic would be restricted to showing the water flow path from the treatment plant to
end users.

Austin’s process flow diagram is included in Appendix A.

Step 5 – Validate Process Flow Diagram. As a critical element around which the
HACCP is based, the flow diagram needs confirmation of accuracy by the HACCP team.

The City of Austin’s HACCP team validated the process flow diagram in a meeting held
following the training workshop. The process flow diagram is signed and dated by a
HACCP team representative to document that the validation step has been completed.

Step 6 – Conduct Hazard Analysis. Using the process flow diagram, identify hazards,
their likelihood of occurrence, potential consequences, and control measures.

Austin’s HACCP team identified many potential hazards for the pilot study area, but the
team decided to base the pilot study on two particular hazard events that scored high
marks in the hazard analysis – unprotected cross-connections and hazards at new
construction sites that can potentially degrade the finished water quality. Additional
details on Austin’s hazard analysis and the scoring for each hazard are provided in
Appendix A.

Step 7 – Identify Critical Control Points. For each significant hazard, identify points in
the process where the consequences of failure are irreversible.

In Austin’s case, for the hazard of unprotected cross-connections, each service

connection is considered to be a critical control point. For the hazards at new
construction sites, each construction site is a critical control point.

Step 8 – Establish Critical Limits. Determine critical limits for the critical control
points that will trigger a corrective action. A critical limit is a criterion that separates
acceptability from unacceptability.

For Austin’s hazard of unprotected cross connections, one control measure is to maintain
system pressure at all times. The critical limits for this control measure are to maintain
pressure above 35 psi under normal conditions and above 20 psi during emergency
conditions. A second control measure is to inspect plumbing of new customers. For this
control measure, the critical limit is compliance with the local plumbing code.

Step 9 – Identify Monitoring Procedures. Establish monitoring points, frequency, and

responsibility.

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For the examples used in Step 8, monitoring procedures are described. System pressure
is monitored continuously using pressure transducers and data loggers located at pump
station discharge points. Pressure data are collected and tracked with the SCADA
system. The plumbing of new customers is inspected visually by City plumbing
inspectors.

Step 10 – Establish Corrective Action Procedures. Develop plans for follow up

activities when critical limits are exceeded. These activities may include operations
and/or maintenance activities, water quality monitoring and/or communications with
customers.

For the examples used in Steps 8 and 9, corrective action procedures are described. If
system pressure falls below the critical limits, additional pumps are turned on to raise the
pressure. At the same time, the utility would search for main breaks. If necessary, the
utility would issue a boil water advisory. If a new customer’s plumbing does not meet
the local plumbing code, enforcement action is taken per the Plumbing Code and Cross-
connection Ordinance.

Step 11 – Validate/Verify HACCP Plan. Have the HACCP team and other affected
parties check the HACCP plan for accuracy, ability to implement, and potential
effectiveness.

Austin’s HACCP plan was validated at meetings on August 15 and 28, 2003 by members
of the HACCP Team. Additional validation was done with inspection staff and staff of
the On-Site Sewage Facilities Division.

Step 12 – Establish Documentation and Recordkeeping. Develop a record keeping

system to track system performance at critical control points.

In Austin’s HACCP Plan (Appendix A), documentation and recordkeeping activities are
listed for each critical control point. These “tracking” methods include the utility’s
SCADA system, various databases, log books and a work order system. Water quality
samples collected for new mains prior to their release to service are tracked using water
laboratory approval letters. The completion of inspector training is documented using
attendee sign-in sheets.

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4. Use of HACCP in Regulatory Frameworks

The HACCP concepts have been incorporated into regulatory frameworks in several
countries as summarized in Table 1. These applications of HACCP are described in more
detail in the following sections.
Table 1
HACCP Programs for Controlling Public Health Risks in Drinking Water

Regulation or
Country/ Regulatory Website for current
Organization Guideline information Reference
World Health Guidelines for Drinking www.who.int/water_sanitation_ Davison and Bartram (2004)
Organization Water Quality (3rd health/dwq/guidelines2/en/
Edition)
U.S./EPA Aircraft Drinking Water http://www.epa.gov/safewater/a USEPA (2006)
Rule (under irlinewater/regs.html
development)
Australia Australian Drinking www.nhmrc.gov.au/publication NHMRC and NRMMC (2004)
Water Guidelines s/synopses/eh19syn.htm
(Guideline)
New Zealand Health (Drinking Water) www.moh.govt.nz/water
Amendment Bill
(Proposed regulation)
Switzerland W1002 Regulatory Swiss Gas and Water Industry
guideline: Association (2003)
Recommendations for a
Simple Quality
Assurance System for
Water Supplies
(Guideline)
Hygiene Ordinance (SR Bosshart (2003)
817.051, HyV), Article
11 (Regulation)
Iceland Food legislation: Act no. http://english.ust.is/media/log Gunnarsdottir and Gissurarson (2006)
93/1995 /L1995-93_ensk.htm
France French National Metge (2003); DeBier and Joret (2004)
Transcription: Decree
2001-1220 (Dec. 20,
2001) Water Safety for
Human Health, Risk
Assessment and
Management; Article 18-
2 (Regulation)
Ontario, Canada Water quality http://www.ene.gov.on.ca/envis Ministry of the Environment (2006)
management standard ion/env_reg/er/documents/2006
based on HACCP, ISO /Drinking%20Water%20Qualit
9001, and ISO14001 y%20Management%20Standar
(Guideline) d%20-
%20October%202006.pdf

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4.1 World Health Organization Drinking Water Guidelines

The third edition of the World Health Organization (WHO) drinking water guidelines
outline a framework for drinking water safety based on the multiple barrier approach and
several risk management and quality management approaches including the HACCP
principles (Davison and Bartram, 2004). The WHO framework has three main
components: health-based water quality targets based on public health protection and
disease prevention; a Water Safety Plan (WSP) as described below; and independent
surveillance activities including audits of the WSP and final checks on the finished
drinking water. Countries that use WHO guidelines as the minimum criteria for water
system regulation will need to recommend or require that water utilities develop WSPs.
WHO recommends that water suppliers develop a WSP that documents the following
major elements:
1. A source-to-tap system assessment that determines whether a water system can
deliver water meeting certain water quality targets.
2. Control measures for identified hazards and operational monitoring of control
measures.
3. A management plan that documents the system assessment, control measures, the
monitoring plan, corrective action procedures to address water quality incidents,
communication plan and supporting programs such as standard operating procedures
(SOPs), employee training and risk communication.

The WSP concept continues to evolve as the water industry gains experience by
developing and implementing Water Safety Plans. Table 2 provides a comparison of
HACCP and the two slightly different approaches for Water Safety Plans as presented in
the WHO drinking water guidelines (WHO, 2004) and a more recent WHO guidance
manual (Davison et al., 2005). The only significant difference between the two WHO
approaches is that the 2004 guidelines do not utilize the term “critical control points” in
determining where control measures should be implemented, and instead rely on the
multiple barrier principle. The 2005 guidelines acknowledge that control measures
sometimes represent a process step (e.g., filtration) that can be referred to as a “critical
control point.” The intent is to enable the effect of the multiple barriers to be assessed
together (Davison et al., 2005). Other differences between these two approaches listed in
Table 2 appear to be either semantics (different words used to describe similar tasks) or a
different sequence of tasks.

The Bonn Charter for Safe Drinking Water complements the new WHO guidelines in
providing international guidance on drinking water quality management (Breach, 2004).
This Charter is the end product of two expert workshops held in Bonn, Germany in
October 2001 and February 2004, and is applicable to all water systems worldwide. The
Charter’s key principles include the following (Breach, 2004):

1. Good safe drinking water can only be provided reliably and consistently through an
integrated, source-to-tap approach.

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Table 2
Comparison of HACCP and Water Safety Plan Risk Management Approaches

Step HACCP Approach Water Safety Plan Approach Water Safety Plan Approach
(WHO, 1997) (WHO, 2004) (Davison et al., 2005)
1 Assemble Team Assemble Team Assemble Team
Describe Water Supply
2 Describe the Product Document & Describe System (construct & confirm flow
diagram)
Document Intended Undertake Hazard Assessment
3 Conduct Hazard Analysis
Use of Product & Risk Characterization
Construct a Flow Assess the Existing System Identify Control Measures and
4
Diagram with Flow Diagram Critical Control Points

5 Confirm Flow Diagram Identify Control Measures Define Operation Limits

Conduct Hazard
Analysis (e.g., Identify
Define Operational Limits and
6 Hazards, Assess Risks Establish Monitoring
Monitoring Procedures
and Identify Control
Measures)
Identify Critical Establish Procedures to Verify Establish Corrective Action &
7
Control Points WSP is Working Incident Response
Establish Critical
8 Develop Supporting Programs Establish Record Keeping
Limits
Prepare Management
Identify Monitoring
Procedures Including
9 Procedures for Critical Validation & Verification
Corrective Actions for Normal
Limits
and Incident Conditions
Establish Corrective Establish Documentation &
10
Action Procedures Communication Procedures
Validate/Verify
11
HACCP
Establish
12 Documentation &
Record Keeping
Source: USEPA (2006)

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 January 19, 2007

2. The integrated approach requires close cooperation and partnerships among

governments, water suppliers, health agencies, environmental agencies, land users,
contractors, plumbers, consumers, and manufacturers of materials, products and
devices used in the water supply system (Breach, 2004).
3. Traditional verification of drinking water quality based on measurement of various
parameters against predetermined standards or guidelines will continue to play a
critical role in ensuring drinking water quality. In the future, there should be much
greater emphasis on use of preventive, risk-based management control systems.
4. The quality assurance process and derivation of specific standards need to be
transparent to assure consumer confidence.
5. The standards used to measure water quality and safety can legitimately vary between
different countries and regions depending on local circumstances (Breach, 2004).
However, these standards should ensure the provision of water that has the trust of
consumers, is affordable, and meets the following minimum criteria (Breach, 2004):
a. Does not pose a health threat to consumers
b. Is acceptable to consumers in terms of taste, odor, and appearance
c. Is reliable in terms of both quality and quantity
6. Effective approaches to managing drinking water quality rely on an interlinked set of
processes that must involve the following three elements (Breach, 2004):
a. Establishment of clear responsibilities and institutional arrangements for the
different stakeholders
b. Implementation of effective control systems directed to identifying and managing
risks, thereby mitigating their impacts (Drinking Water Quality Management
Plans)
c. Assessment of compliance against the necessary minimum standards for drinking
water quality (verification)
7. A Drinking Water Quality Management Plan that includes the following three
elements (Breach, 2004):
a. A system wide risk-based assessment of safety from source-to-tap
b. Identification of the most-effective control points to reduce the risk
c. Effective systems and operational plans to deal with both routine and abnormal
operating conditions

4.2 USEPA Aircraft Drinking Water Rule

EPA has initiated a rulemaking effort that will tailor the requirements of the National
Primary Drinking Water Regulations to the unique characteristics of aircraft. The
existing NPDWRs were designed to regulate water quality in stationary public water
systems, not mobile water systems with the capability of flying throughout the world.
The rulemaking effort utilizes a systematic risk management approach that draws on the
principles of the HACCP approach and a multiple barrier approach. EPA established a

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multi-disciplinary, interagency Aircraft Drinking Water Rule team that includes

representatives of several EPA offices, Regions 1-7 and 9, representatives of the Food
and Drug Administration, and the Federal Aviation Administration. EPA is working
collaboratively with stakeholders representing airline and airport owners and operators,
pilots, flight attendants, passengers, fixed base operators, and environmental/public
health interests.

4.3 Australian Drinking Water Guidelines

In Australia, drinking water is regulated by State health agencies. The Australian Drink-
ing Water Guidelines (ADWG) ensure the accountability of drinking water suppliers (as
managers) and of state/territory health authorities (as auditors of the safety of water
supplies) (NHMRC and NRMMC 2004) but they are not mandatory, legally enforceable
standards. The current revision of the ADWG includes the “Framework for Management
of Drinking Water Quality” that provides guidance on establishing preventive, source-to-
tap risk management systems for drinking water quality. The State of Victoria promul-
gated the Safe Drinking Water Act 2003, which came into effect on July 1, 2004 and
requires all water utilities to implement a risk management plan based on the ADWG.
The Australian Framework for Management of Drinking Water Quality was derived by
supplementing the information on preventive system management already provided in the
ADWG with principles described in existing quality management systems such as ISO
9001 (Quality Systems), ISO 14001 (Environmental Management Systems), Australian
and New Zealand Standard 4360 (Risk Management) and the HACCP system. The
Framework includes 12 main elements (NHMRC and NRMMC, 2004):

1. Commitment to Drinking Water Quality Management

2. Assessment of the Drinking Water Supply System
3. Planning-Preventive Strategies for Drinking Water Quality Management
4. Implementation-Operational Procedures and Process Control
5. Verification of Drinking Water Quality
6. Incident and Emergency Response
7. Employee Awareness and Training
8. Community Involvement and Awareness
9. Research and Development
10. Documentation and Reporting
11. Evaluation and Audit
12. Review and Continual Improvement

The Framework promotes monitoring as a verification tool for assuring that preventive
measures are working effectively and reduces the reliance of compliance monitoring as
the primary means for managing water quality.

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 January 19, 2007

4.4 New Zealand Public Health Risk Management Plans

In New Zealand, proposed new legislation would amend the Health Act of 1956 by intro-
ducing a legislative framework that is based on risk management principles. The Health
(Drinking Water) Amendment Bill, introduced to Parliament on June 21, 2006, would
require compliance with drinking water standards that are now voluntary. The Bill would
also require water suppliers serving more than 500 people to develop a “Public Health
Risk Management Plan” (PHRMP). The proposed legislation is driven by a concern that
the current reliance on voluntary drinking water standards is inadequate to safeguard the
treatment and distribution of drinking water. New Zealand has relatively high rates of
enteric or gastro-intestinal disease. For example, the campylobacteriosis rate in New
Zealand is twice that of England and three times that of Australia and Canada
(http://www.moh.govt.nz/moh.nsf/indexmh/drinking-water-proposed-legislation).

To assist water suppliers in developing and implementing this PHRMP, the Ministry of
Health prepared a series of guides that are based on the risk management framework
contained in AS/NZS 4360:1999 (Standards Australia/Standards New Zealand, 1999) and
HACCP methodology (Codex Alimentarius, 1993). These guides contain the following
information:

• Potential problems during different processes and operations that might allow
contaminant intrusion
• Corrective actions when contamination occurs
• Preventive measures to reduce the likelihood of the problems recurring

A separate booklet discusses the overall approach to developing and implementing a Plan
as outlined in Table 3 (Ministry of Health, 2005).

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Table 3
New Zealand Approach for Preparing Public Health Risk Management Plans

Contribution to the Public Health

Step Description
Risk Management Plan
Identify the elements in the supply and
1 the PHRMP Guidelines needed.
Flow diagram of the supply
Identify which barriers to contamination Check-list of barriers present in the
2
are present. supply
Identify events that may introduce
3
hazards into the water.
Use the Guides to identify: Risk information table for the supply
• Causes overall
4 • Preventive Measures
• Corrective Actions
Decide where improvements should be
5 Improvement Schedule
made
• Improvements needed
Decide on the order in which
6 • Levels of importance
improvements need to be made
• Timetable
Draw up a timetable for making the
7 • Responsibilities
improvements
Note links to other quality assurance
8 Note of other quality assurance systems
systems
Contingency plans for each supply
9 Prepare contingency plans
element
Prepare instructions for Performance Set of instructions for review of the
10
Assessment of the Plan performance of the PHRMP
Decide on communication policy and
11 Set of instructions for reporting
needs

Source: Ministry of Health (2005)

PHRMP – Public Health Risk Management Plan

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4.5 Switzerland Hygiene Regulations

In Switzerland, Article 11 of the hygiene regulation (SR 817.051, HyV), requires
application of the HACCP principles. A regulatory guideline (W1002) entitled
“Recommendations for a Simple Quality Assurance System for Water Supplies” has been
prepared to assist water utilities in complying with this requirement. The regulatory
guideline recommends the following nine-step approach (Swiss Gas and Water Industry
Association, 2003):

1. Organization, Responsibilities and Expertise

2. Survey of the Water Supply (develop process flow diagram)
3. Assessment of the Water Supply (evaluate hazards, list critical points)
4. Elimination of Hazards (Critical Points)
5. Reduction of Hazards by Maintenance
6. Control of Hazards (Critical Points)
7. Practical Implementation of the Instructions
8. Annual Evaluation of the Water Supply
9. Confirmation of Self-Assessment by Third Party

4.6 Iceland Food Legislation

Since 1995, drinking water in Iceland has been classified as food and waterworks have
been classified as food processing companies per amendments to The Foodstuffs Act
(http://english.ust.is/media/ljosmyndir/matvaeli/Log_um_matvali_a_ensku.pdf)
(Gunnarsdottir and Gissurarson, 2006). Water systems of certain sizes are required by
food legislation to implement a HACCP Plan or similar risk management system. Small
water systems are required to implement a simpler water safety plan. By 2006, 21
waterworks serving 67 percent of the Icelandic population had implemented HACCP
plans or a simpler water safety plan. Guidelines for a simple water safety plan, called
“The Five Steps” were developed for small systems by Samorka Federation of Icelandic
Energy and Water Works.

4.7 France Regulation on Water Safety

In France, Article 18-2, Optimization of Monitoring, of the French National
Transcription: Decree 2001-1220 (Dec. 20, 2001) entitled Water Safety for Human
Health, Risk Assessment and Management requires risk assessment, identification of
critical control points and control measures.

4.8 Ontario Water Quality Management Standard

In Canada, the legislative responsibility for providing safe drinking water to the public
generally falls under provincial or territorial jurisdiction. Each province and territory has
adopted legislation to establish requirements to provide clean, safe, and reliable drinking
water. In British Columbia, Manitoba, New Brunswick and the territories, the authority
for drinking water rests with ministries of health; in all other provinces, this authority is

18
 January 19, 2007

provided by ministries of environment (http://www.hc-sc.gc.ca/ewh-semt/pubs/water-

eau/doc_sup-appui/phi-isp/i_e.html#3)

The Ontario Ministry of the Environment promulgated revisions to the Drinking Water
Systems Regulation (O. Reg. 170/03) effective June 5, 2006 in response to waterborne
disease outbreaks in Walkerton, Ontario, and North Battleford, Saskatchewan. Owners
and operators of municipal residential drinking water systems are required to have an
accredited operating authority by establishing and maintaining a quality management
system. Minimum requirements for the quality management system are outlined in the
Drinking Water Quality Management Standard (Ministry of the Environment 2006).
Although this standard does not make specific reference to HACCP or a Water Safety
Plan, it includes many comparable elements. The Quality Management Standard
includes the following 21 elements:

1. Develop an Operating Plan that establishes and maintains a Quality Management

System (QMS)
2. Document a Policy on QMS that illustrates commitment to customers and to
maintenance and continual improvement of QMS
3. Include a written endorsement by top management and owner in Operating Plan
4. Identify a Quality Management System representative in the Operating Plan
5. Document a procedure for document and records control in the Operating Plan
6. Describe the water system in the Operating Plan including sources of supply,
treatment facilities, distribution system components, and a process flow diagram
7. Conduct and document a risk assessment that identifies and ranks hazards, and that
identifies control measures and critical control points
8. Document risk assessment outcomes in the Operating Plan including procedures to
monitor and respond to deviations in critical control limits
9. Describe the organizational structure, roles and responsibilities of the Operating
Authority
10. Document competencies and training needs for water system staff to maintain water
quality
11. Document a procedure for providing sufficient numbers of competent employees to
operate the water system and maintain water quality
12. Document procedure to communicate elements of QMS between top management
and system owner, Operating Authority personnel, suppliers and the public
13. Identify essential supplies and services for providing safe drinking water, and develop
a procedure to ensure the quality of supplies and services
14. Document a procedure to conduct an annual review of system infrastructure
15. Document the Operating Authority’s infrastructure maintenance, rehabilitation and
renewal programs
16. Document monitoring programs for process control and finished drinking water
quality
17. Document procedures for calibration and maintenance of measurement and recording
equipment
18. Document emergency preparedness procedures
19. Document internal audit procedures to evaluate conformity with QMS

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 January 19, 2007

20. Document management review procedures for evaluating the effectiveness of the
QMS
21. Strive to continuously improve the effectiveness of the QMS

5. Benefits of HACCP
The HACCP system may provide both tangible and intangible benefits to water utilities,
including (Fok and Emde, 2004; Davison and Deere, 2004; Smith, 2004; and Kuslikis
and White, 2004; Gunnarsdottir and Gissurarson, 2006):

• Improvements in public health protection

• Improved regulatory compliance
• Demonstration of due diligence
• Improvements in design and operation of water system processes
• Improved understanding of risks and risk management
• Improvements in employee skills related to system operation
• Improvements in work processes such as SOPs, monitoring strategies, documentation
procedures, and communication methods

The WHO framework for drinking water safety that is based on HACCP and other risk
management programs offers many benefits to water utilities. Schmoll (2003) indicates
that implementation of a Water Safety Plan provides the following benefits:

• Support in setting priorities

• A structure to organize risk-based management
• Support of multi-agency and multi-stakeholder involvement and communication, as it
requires an approach from source to tap
• Demonstration of due diligence and justification of decisions on all levels up to
senior management
• Improved system understanding reduces uncertainty in decision-making
• Water Safety Plans change the mindset, impacting the organizational culture
• Having a Water Safety Plan is positive for the reputation
• For small supplies, a Water Safety Plan may be a resource, i.e. instrumental in using
resources more efficiently

This section summarizes documented benefits of HACCP. Because the application of

HACCP to water systems is relatively new and not well documented in the published
literature, several examples are included from the food industry and from personal
communications such as e-mails and written correspondence. Some examples given
below are not strict applications of HACCP principles but programs or procedures that
are similar to HACCP.

Although some benefits have been documented, it is difficult to tie water quality and
public health improvements directly to HACCP since the utility may implement multiple
system improvements while implementing HACCP. Five Australian utilities that have

20
 January 19, 2007

implemented HACCP and attained certification reported that they have continued to be
audited and re-registered each year since they believed that, overall, the benefits of the
HACCP system, including the certification discipline, outweighed the costs (Martel et al.,
2006)

5.1 Improvements in Public Health Protection

By helping to improve food production processes to prevent contamination, the HACCP
system can reduce or prevent the occurrence of food borne illnesses. In October 2003,
the USDA/FSIS reported four consecutive annual drops in human Listeria infection and a
70 percent decline in positive food samples compared with years prior to HACCP
implementation (Fok and Emde, 2004).

5.2 Improved Regulatory Compliance

A preliminary evaluation of HACCP applications in Iceland found that water systems
improved compliance with drinking water regulations after implementing HACCP
(Gunnarsdottir and Gissurarson, 2006). In the City of Reykjavik, the percentage of
samples that complied with regulations increased from a mean value of 94 percent to 99
percent after HACCP implementation in 1997. In Akureyri, a similar analysis showed
that after HACCP implementation in 1999, the percentage of samples meeting regulatory
requirements increased from 88 percent to 99 percent. Major corrective actions
implemented at Akureyri included improvements to 22 water intakes for spring supplies;
distribution pipe renewal in areas with high bacterial counts; and cleaning an over-sized
main serving the airport.

5.3 Demonstration of Due Diligence

Davison and Deere (2004) illustrate how HACCP can help a utility to demonstrate “due
diligence” or the “prevention of foreseeable harm.” This demonstration of due diligence
is accomplished using five elements of the HACCP system (Davison and Deere, 2004):
(1) assessing risks from the sources of supply through to the customer’s tap; (2)
implementing a risk management system; (3) employing a “culture of compliance;” (4)
seeking out and incorporating new knowledge into system processes and procedures; (5)
planning for emergencies.

Three of five Australian utilities that participated in the AwwaRF HACCP project
(Martel et al., 2006) - South East Water, Yarra Valley Water, and Gold Coast Water -
found that HACCP implementation has helped to improve system credibility and
demonstration of due diligence or the “prevention of foreseeable harm.”

South East Water attributed these improvements to improved record-

keeping practices. At Yarra Valley Water, employees have an improved
awareness of water quality risks and management processes. Gold Coast
Water noted that the structure of the HACCP system has helped with
system credibility and demonstration of due diligence. (Martel et al.,
2006)

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 January 19, 2007

5.4 Improvements in Water System Processes

Since the Gold Coast Water, Australia HACCP system was put into place in 2001, the
water treatment and distribution system performance parameters have seen steady
improvement (Smith, 2004). The average weekly turbidity of the finished water has
improved from 0.28 NTU in July 1999 to 0.18 NTU in June 2003 as shown in Figure 2.
Gold Coast Water implemented a “modified” HACCP system that draws from several
risk management techniques (e.g. multiple barrier approach, Partnership for Safe Water,
WHO Water Safety Plans, ISO 9000, and the Australian Framework for Water Quality
Management) and ties them together within the HACCP system framework (Smith,
2004).
HACCP has several features that make it appealing as the framework to
bind the other philosophies together. Its structure is well known, it is
certifiable, it is proven to be robust and it has the flexibility to incorporate
different circumstances. (Smith, 2004)

Five Australian utilities have found that water quality improvements did become evident
following the implementation of HACCP, but in most cases, those changes did not appear
conclusive for three or more years (Martel et al., 2006). Observed water quality
improvements included reduced numbers of customer complaints and water quality
incidents, and fewer microbial indicators.

Average Weekly Turbidity of Final Product from Molendinar WPP

Gold Coast, Aust.
0.70

0.60

0.50
T u rb id ity (n tu )

0.40

0.30

0.20

0.10

0.00
J ul-9 9

N ov -9 9

J an -0 0

M ar-0 0

M ay -0 0

J ul-0 0

N ov -0 0

J an -0 1

M ar-0 1

M ay -0 1

J ul-0 1

N ov -0 1

J an -0 2

M ar-0 2

M ay -0 2

J ul-0 2

N ov -0 2

J an -0 3

M ar-0 3

M ay -0 3
S ep-99

S ep-00

S ep-01

S ep-02

Date
Source: Smith (2004)

Figure 2. Average Weekly Turbidity of Final Product

Before HACCP, 0.8 water quality complaints were registered per 1000 properties per year.
Within 6 months of implementing HACCP, water quality complaints were reduced to 0.4 per

22
 January 19, 2007

1000 properties per year.

5.5 Improved Understanding of Risks and Risk Management

Smith (2004) documents a case study at Gold Coast Water in Australia that illustrates
how a HACCP excursion report helped the utility to identify a previously unidentified
risk in an existing manganese control procedure and its reporting instructions. “The
loophole in the HACCP manganese control procedure meant that staff did not technically
have to report this particular failure to anyone and this became an attractive option.”
(Smith, 2004) The HACCP excursion reporting system was developed as part of the
HACCP Plan, specifically addressing HACCP Principle 7, Documentation and
Recordkeeping. The HACCP excursion report showed that the daily limit of six dirty
water calls (Smith, 2003b) had been exceeded on 1 day. Although Gold Coast Water’s
HACCP Plan includes critical limits on customer calls, they are not really considered to
be critical control points (Smith, 2003b). (All of the storage facilities in the distribution
system are regarded as CCPs. However, because each reservoir zone is only sampled
once per month and each storage facility is inspected on a quarterly basis (Smith, 2003b),
the customer calls often provide timely information. A follow-up investigation revealed

a problem where plant staff failed to adequately respond to changes in raw water quality.
The existing procedure was subsequently tightened.

5.6 Improvements in Employee Skills

While implementing an integrated risk management system based on HACCP and ISO
9001 and ISO 14001 for 14 water supply systems in the regional municipality of Durham,
Canada, Kuslikis and White (2004) found that employee awareness of legislation and
regulations improved. Also, training programs across this regional municipality became
more consistent and hence more effective and efficient.

The City of Austin, Texas conducted a pilot study on HACCP as part of an AwwaRF-
funded research effort. The HACCP pilot study helped the utility to raise employee
awareness on several issues (Pedersen, 2004):

• The need to respond quickly to main breaks in small pressure zones

• The location of pressure zone boundaries
• The possible occurrence of boundary zone violations
• The possibility of pressure transients causing low or negative pressure in the
distribution system
• The need to maintain positive pressure at all times
• Existing data sources

The HACCP study also helped Austin to improve internal communications (Pedersen,
2004). Survey responses collected at the conclusion of the HACCP training workshop
showed that all workshop attendees gained new information on the utility’s distribution
system management practices or potential hazards. One survey respondent commented
that the workshop’s dialogue between different departments helped them to better

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 January 19, 2007

understand how other utility employees do their jobs.

5.7 Improvements in Work Processes

Australian utilities that have implemented HACCP have integrated the HACCP system
with systems for quality management, occupational safety, water quality and safety, and
environmental considerations (Martel et al., 2006). The utilities found that the principal
benefit of this integrated management system was the avoidance of duplication, leading
to reduced staff time and costs, and improved process integration.

The Capitol Health region in Edmonton, Alberta, Canada used HACCP principles to
develop a new boil water advisory protocol in 1998 (Fok and Emde, 2004).

The use of the HACCP process resulted in a better understanding of

monitoring parameters and fostered communication and understanding
between …[the health department and the water utility]. (Fok and Emde,
2004)

While implementing an integrated risk management system based on HACCP, ISO 9001,
and ISO 14001, Kuslikis and White (2004) found that the consistency of region-wide
procedures improved. The risk management system, implemented from source to tap,
also helped to resolve some maintenance issues at water plants, and spurred the
undertaking of a comprehensive chemical inventory and cleanup. As part of
implementing the risk management system, an electronic library was established to make
water system permits, procedures and forms more accessible. It should be noted that no
two risk management or HACCP plans will be identical. In identifying and prioritizing
hazards, each system has its own needs and priorities, and will therefore focus their plan
on the highest ranked hazards.

Gold Coast Water has observed a progressive change in the organizational culture since
implementing HACCP (Smith, 2004). For example, at the Mudgeeraba water treatment
facility, there was cultural resistance to compliance in year 2002 (Smith, 2003b). The
lack of cultural acceptance was dealt with by close internal auditing during the early
stages of HACCP implementation and eventually the staff realized that there were
benefits to adhering to the system (Smith, 2003b). “Managerial and operational staff has
indicated they would be reluctant to go back to the rather ‘loose’ arrangements that
existed 4 years ago.” (Smith, 2004)

At Gold Coast Water, procedures have been developed for each process step or
significant risk. Each procedure is a formal instruction from the manager to the
operational staff (Smith, 2004). These procedures, typically 1 to 3 pages in length,
outline the process steps, the risks, the monitoring strategies, control measures, corrective
actions, and assignment of responsibilities.

Another case study from Gold Coast Water illustrates how certain operational practices
were improved based on data collected for a HACCP excursion report (Smith, 2004).
The HACCP excursion report indicated that the water’s chlorine residual at a suburban

24
 January 19, 2007

booster station had fallen below a critical limit. An investigation by senior management
revealed that the chlorine gas cylinders were empty because no one had been given the
responsibility to keep them full. Also, the chlorine residual and other instruments at the
booster station had not been calibrated since their installation simply because the
instruments had never been placed on a calibration schedule. Although the low chlorine
residual may have been detected prior to HACCP, it is unlikely that the incident would
have been investigated since no one had been given that responsibility. As a follow-up to
this incident, operational and asset management staff improved their practices not only at
this booster station, but across the system (Smith, 2004).

6. Challenges of Implementing HACCP

Although the HACCP system may provide many benefits to a water utility, it also may
present challenges that are difficult to overcome, such as:

• Resource needs
• Management support and commitment
• Employee support and commitment
• Small system issues
• Large system issues

Case studies from the published literature and personal communications are used to
document the challenges of implementing HACCP.

6.1 Resource Needs

The resource needs for developing and implementing a HACCP system are outlined in
the AwwaRF report, Application of HACCP for Distribution System Protection (Martel et
al., 2006) based on experiences of five Australian utilities:

• One-time costs for HACCP training, coaching, technical advice and documentation.
Costs can vary depending on the extent to external service providers are utilized.
• Increased water quality monitoring and instrumentation to further evaluate risks or as
part of control measures to manage risks. Costs can vary as deemed appropriate by
the HACCP team.
• Special investigations, professional services, and/or laboratory testing, to further
evaluate risks or to implement control measures.
• Annual HACCP awareness training for new staff and existing staff as needed.
• Personnel costs such as the HACCP coordinator and other staff requirements. The
time requirement for a full-time HACCP coordinator varied by utility from 1 month
to 12 months depending on how tasks were delegated amongst the HACCP
coordinator and other staff, and the amount of work required to implement the
HACCP plan.

Since these Australian utilities had all implemented other quality management systems
prior to implementing HACCP, their actual costs cannot be compared to a utility
implementing only HACCP.

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 January 19, 2007

The City of Austin, Texas completed a pilot study for the AwwaRF project but was
unable to estimate costs of developing and implementing the HACCP Plan (Martel et al.,
2006). Austin found that implementing the HACCP plan was a lengthy time commitment
that included HACCP team meetings, coordination meetings with other staff, and time
spent on database management. The HACCP team only tracked the time required for
team meetings and not other staff time spent implementing HACCP procedures. Because
Austin’s HACCP Plan was only implemented for one small portion of their distribution
system, the resource requirements for implementing HACCP system-wide were not
developed. Austin found that existing databases would need to be modified to facilitate
the implementation of HACCP system-wide. Databases that track plumbing inspections,
cross-connection inspections, waterline disinfection, etc., were not set up with HACCP in
mind. Therefore, data retrieval for the pilot study was undertaken manually and was
cumbersome.

Gold Coast Water did not add any other staff to implement HACCP but purchased
additional instrumentation and increased water quality testing (Smith, 2004). Smith
(2004) estimates a 4 to 6 week timeline for developing and implementing a HACCP
system for a catchment, treatment or distribution system with no serious process flaws.
However, the cultural change could take as long as 6 months (Smith, 2004).

The regional municipality of Durham in Ontario, Canada has learned that the following
resource commitments are needed to successfully implement a risk management system
(Kuslukis and White, 2004): management support at all levels; top management
commitment and participation; a full-time coordinator familiar with the water industry;
and involvement of all staff throughout the process. Kuslukis and White (2004) also
express caution against underestimating the time commitment, which is huge.

Based on their experiences implementing HACCP in 45 water systems in France, DeBeir

and Joret (2004) estimate an average of 30 to 60 person-days to implement HACCP in
one system (from the catchment to the customers’ taps).

A preliminary evaluation of HACCP implementation in Iceland has shown overall

success but limited resources have prevented full implementation of auditing steps
(Gunnarsdottir and Gissurarson, 2006).

6.2 Management Support and Commitment

Sydney Water Corporation in Sydney, Australia is also participating in the on-going
AwwaRF-funded project, Application of HACCP for Distribution System Protection.
Sydney Water has initiated development of a HACCP Plan; however, Sydney Water
management has not made a decision to utilize the HACCP system (Stevens and Martel,
2004). As a result, the HACCP plan has not been implemented at the operational level.
Sydney’s experience shows that even a large utility requires commitment at a relatively
high management level if HACCP plans are to be implemented operationally. Sydney
Water has implemented some of the HACCP steps as part of implementing ISO 9000
and, therefore, do not feel that they need an additional audit (Deere, 2005).

26
 January 19, 2007

The City of Austin, Texas found that HACCP is more complex than initially envisioned
(Pedersen, 2004). Originally, the Utility thought that HACCP would involve identifying
critical flow paths within the distribution system and monitoring them more intensively
to assure water quality to downstream sites. Instead, the HACCP plan focused on
operations and maintenance activities that occur in the distribution system, adding layers
of complexity to the existing monitoring program.

6.3 Employee Support and Commitment

Smith (2004) cites the need for a HACCP “champion” who is solely dedicated to
administering the HACCP system. “The HACCP champion should have a background in
chemistry and microbiology, plus experience in water industry processes.” (Smith, 2004)

6.4 Small System Issues

Small systems may face several challenges in implementing HACCP, as summarized by
Martel et al. (2006):

• Small systems often lack expertise in one or more topic areas covered by the HACCP
Plan. This challenge may be overcome by using consultants or other experts as

necessary to help facilitate the HACCP training workshop and to support the utility
HACCP team.
• The small utility may lack adequate historical water quality and system data to
identify and rank risks/hazards in the HACCP hazard analysis (Step 6). This
dilemma, experienced by the South Berwick Water District as part of their Project-
pilot study, was addressed by initially focusing the HACCP Plan to collect additional
information to evaluate, document, and improve control over these hazards.
• In practice, the small utility may lack adequate manpower or other necessary
resources to develop and implement a HACCP Plan independently. In some cases, a
small system has received assistance from larger systems with more resources and
technical knowledge. For example, the Katherine system that serves 10,000 people in
the Northern Territories of Australia received help from its corporate organization,
Power and Water Corporation, that is responsible for providing energy, water,
sewerage, and communications services throughout the Northern Territory (Martel et
al., 2006). In Iceland, guidelines for a simple water safety plan, called “The Five
Steps”, were developed for small systems by the Samorka Federation of Icelandic
Energy and Water Works.

The South Berwick Water District in South Berwick, Maine, a small system serving
4,000 people, participated in the AwwaRF project but was unable to implement their
HACCP plan due to limited staff (Martel et al., 2006). Nadeau (2004) explained that, in
addition to operating and maintaining the water system, the Water District’s three staff
members were simultaneously involved in building a new treatment facility, developing a
new rate structure, dealing with local and state political issues, and struggling with
unanticipated personnel and medical issues.

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6.5 Large System Issues

Large water utilities face different types of challenges as compared to small systems in
implementing HACCP, as summarized by Martel et al. (2006):

• Communication across departments and between management and operational staff

• Organization-wide coordination on water quality management issues

These challenges can be addressed through the HACCP training workshop and through
careful selection of HACCP team members and, most importantly, through strong,
proactive support from the highest levels in the organization.

7. HACCP Approach in Hazard Assessments

The first HACCP principle (Conduct Hazard Analysis), as presented in Figure 1, includes
three elements: hazard identification, hazard assessment, and identification of control
measures. The first two elements are discussed in this section. Control measures are
discussed in the next section.

Most U.S. water utilities are familiar with hazard assessments from their experiences
with completing federally mandated vulnerability assessments and developing cross
connection control programs. For example, in developing a cross connection control
program, a utility may identify and rate possible cross-connections as low, medium, or
high hazards, and then install (or require the customer to install) backflow prevention
devices for high hazard locations. The applicability of utility experiences with
vulnerability assessments to the HACCP approach is discussed later in this section.

7.1 Hazard Identification

Once a HACCP team is formed and the preliminary steps completed (e.g., constructing
and validating the process flow diagram as presented in Figure 1), “…the HACCP team
should list all of the hazards that may be reasonably expected to occur at each step from
primary production…and distribution until the point of consumption.” (Codex
Alimentarius, 1993). To perform this step, the HACCP Team relies on their experience,
system knowledge, historical data, and current technical knowledge. In identifying
potential distribution system water quality hazards, the HACCP Team should consider:

• Potential physical, chemical, microbiological, and radiological hazards

• Whether the elimination or reduction of the hazard to an acceptable level is essential
for water to be considered potable.

Examples of potential hazards to a water distribution system are summarized as follows:

• Contamination due to treatment failure

• Fecal contamination of storage tanks and standpipes
• Backflow event causing contamination
• Contamination caused by negative or low pressure transient resulting in intrusion of

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untreated water through submerged air valve, faulty seal or point of leakage
• Contamination caused by fecal material or by foreign inanimate objects (e.g., dirt,
mud, timber, plastic) during repair, alterations, or connection to existing mains
• Contamination by hazardous substances as a result of use of products, materials or
coatings that are not approved for contact with potable water
• Contaminants introduced by permeation, pipe degradation or corrosion

The system supplying water to Zurich, Switzerland considers four categories of potential
risks: personnel that are not properly trained or experienced; materials in contact with
drinking water; machines in contact with drinking water; and faulty methods or
procedures related to distribution system management (Bosshart, 2003).

The Swiss regulatory guideline (W1002) entitled “Recommendations for a Simple

Quality Assurance System for Water Supplies” includes checklists of possible hazards
(Swiss Gas and Water Industry Association, 2003). Checklist items that pertain to
distribution system reservoirs include the following hazards:

• Natural risks (e.g., trees, landslides, animals, vermin)

• Unsecured access (e.g., doors, windows, ventilation)
• Poorly separated water chambers
• Poor building condition (e.g., concrete, coating, piping)
• Poor water circulation (e.g., fire water reserve)
• Poor ventilation (e.g., water chamber, dehumidification plant)
• Pollution (e.g., wastewater, soiled clothing)
• Unsuitable process control (e.g., no displacement of inlet)
• Materials (e.g., chemicals, cleaning agents)

Checklist items that pertain to piping networks include the following hazards (Swiss Gas
and Water Industry Association, 2003):

• Natural risks (e.g., line breaks)

• Unsecured access (e.g., hydrants, gate valves)
• Unfavorable pressure conditions (e.g., suction of external water)
• Impaired functionality (e.g., motors, controllers)
• Blocked access (e.g., shut-off valves)
• Missing or incorrect flushing (e.g., mains, hydrants, fountains)
• Improper repair work and connections
• Unsecured customer installations (e.g., immersions, pressure pumps)
• Consumer behavior (e.g., seasonal operation)

7.2 Hazard Assessment

The first HACCP principle (Conduct Hazard Analysis) also includes an assessment of
each identified hazard (WHO, 1997). For each hazard, the HACCP Team determines its
likelihood of occurring, and its potential seriousness. Mullenger, Stevens and Deere
(2003) outline several considerations to be included in this evaluation:

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• The path(s) that could allow contamination to occur;

• Frequency of occurrence of the hazard;
• Perseverance of contaminants; and
• Severity of consequences if the hazard was to occur (including potential adverse
health effects and survival or growth of microorganisms of concern)

This assessment is typically completed in a workshop setting through group discussions

and consensus.

The HACCP Team should determine the most appropriate manner for incorporating
assessment criteria into their risk assessment. This could be either qualitative or
quantitative (Mullenger, Stevens and Deere, 2003). For example, the Team could use a
risk score or risk rating factor to compare hazards. At its most simple, a semi-
quantitative analysis could be used as follows (Standards Australia/Standards New
Zealand, 1999):

Risk Factor = Likelihood x Severity of Consequences.

Figure 3 presents an example matrix for assigning a numerical value to the “Likelihood”
and “Consequences” factors.

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Severity of Consequences
Insignificant Minor Moderate Major Catastrophic
Risk Factor Matrix: (No impact / not (Customer (Impact on (Impact on (Public Health
detectable) Complaint) Customer Operating Risk)
Charter) License)

Almost Certain 5 10 15 20 25
(Once a day)
Likely 4 8 12 16 20
(Once a week)
Moderate 3 6 9 12 15
(Once a month)
Likelihood

Unlikely 2 4 6 8 10
(Once a year)

Rare 1 2 3 4 5
(Once every 5 years)
Source: Standards Australia/Standards New Zealand (1999)

Figure 3. Example Risk Factor Matrix

Depending on available resources, the HACCP team decides how many hazards can be
addressed by the HACCP Plan (e.g., all hazards with a risk score >10 will be addressed)
and how they will be prioritized.

An example hazard analysis is summarized in Table 4. This example is a subset of the

hazard analysis completed for the South Berwick Water District in South Berwick, Maine
on June 25, 2003 as part of the ongoing AwwaRF 2856 project entitled Application of
Hazard Analysis Critical Control Point for Distribution System Protection (Nadeau,
2003). Utility staff identified the potential hazards of concern. The risk scores for each
hazard were assigned as a result of discussions and consensus by workshop attendees. In
addition to utility staff, the HACCP workshop attendees included several “outside
experts” including engineers familiar with the South Berwick system, state and EPA
regulators, and a microbiologist.

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Table 4 Example Hazard Analysis and Control

Severity of Likelihood of
Consequences Occurrence
(score using 1 (score using 1 to Risk Factor Additional
to 5 scale with 5 scale with 5 = Existing Control Measures
5 being most being most Likelihood Control Recommended by
Hazard Event severe) likely) x Severity Measures HACCP Team
• Utility installs double • Utility needs to
check valves on enforce testing of
residential services commercial
• Commercial backflow prevention
Backflow customers install devices.
through an backflow • Public education
unprotected prevention device • The feasibility of
cross- 4 5 20 as required testing backflow
connection • Utility maintains prevention devices
good records of at multi-family units
backflow should be further
prevention devices evaluated (Nadeau
• System static et al. 2003).
pressure >40 psi
system-wide
• Storage tank site • On-site security
fenced and well- camera
maintained • SCADA enabled
• Gravel road to site is intrusion alarm
Contamination
gated
via Storage 5 2 10
Facility Vents • Site inspection 3x
weekly
• Insect screening on
vents kept in good
repair
• Disinfection and • Review inspection
flushing of all main procedures
breaks before • Review water
Main Break 5 2 10
placing back into quality testing
service procedures

Source: Adapted from Nadeau (2003)

Note: The information presented in this table has been made possible through funding from the Awwa Research Foundation. The
information is based upon intellectual property which is jointly owned by Cooperative Research Centre for Water Quality and Treatment
and the Foundation. The Foundation retains its right to publish or produce the jointly owned intellectual property in part or its entirety.

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8. HACCP Approach in Control of Contamination

Once hazards have been identified and ranked according to their likelihood of occurrence
and severity of consequences, the HACCP Team focuses on how to eliminate or reduce
the seriousness of the highest ranked hazards. This is accomplished with HACCP
Principles 1 through 5 (aka steps 6 through 10) as illustrated in Figure 1.

In HACCP Principle 1 or step 6, the HACCP team identifies existing control measures
that are being used within the distribution system, and any additional control measures
that systems may consider for future operations. Typical control measures for
distribution system hazards include maintenance of positive pressure at all times; use of
sanitary procedures during construction; and adequate construction of all storage and
distribution facilities. Table 3 lists control measures for several hazards identified by
South Berwick Water District (Nadeau, 2003).

In HACCP Principle 2 (aka step 7), the HACCP team identifies critical control points,
defined as steps at which control can be applied and is essential to prevent or eliminate a
safety hazard or reduce it to an acceptable level (WHO, 1997). If a subsequent step in
the process will further control the hazard, then the point being considered may not be a
critical control point. The process flow diagram, developed in Step 4, is a helpful
reference when evaluating critical control points. Examples of critical control points in
the distribution system include chemical addition points, storage facilities, water main
repair sites, and points of possible cross connections.

In HACCP Principle 3 (aka step 8), the HACCP team establishes critical limits to assess
whether a particular control measure is effective. If this critical limit is exceeded or not
met, it triggers the need for a corrective action. The critical limit can be either a
numerical limit (e.g., chlorine residual concentration, system pressure) or a yes/no type
response on whether a particular control measure was completed (e.g., a site inspection,
training course, communication with contractor). For example, the City of Austin, Texas
identified each construction site as a critical control point (City of Austin, 2003). Several
control measures were developed to manage potential hazards at new construction sites.
One control measure is to maintain intact pressure zone boundaries. The critical limit for
this control measure is that no valves are to be opened by contractors between pressure
zones. If this critical limit is breached, corrective actions include closing valves to
isolate the area, and issuing a written warning to the contractor or a verbal warning to the
site inspector. Utilities are familiar with the critical limit concept through compliance
with Maximum Contaminant Levels established by the SDWA regulations for various
water quality parameters.

In HACCP Principle 4 (aka step 9), the HACCP Team develops a monitoring plan to
measure the status of the distribution system water quality and efficacy of the control
measures in place. Monitoring is discussed in the next section.

In HACCP Principle 5 (aka step 10), the HACCP team develops the corrective action
procedures needed for each significant potential hazard identified through the hazard

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analysis. Examples of corrective actions used in the distribution system include flushing,
disinfection, and cleaning storage facilities.

9. HACCP Approach in Distribution System Monitoring

Monitoring is a critical component of the HACCP approach to control contamination as

discussed in the previous section. Each monitoring activity is documented in the HACCP
Plan, including the following information:

• Monitoring parameters
• Monitoring locations
• Monitoring procedures
• Frequency of monitoring
• Responsible Person

The results of the hazard analysis can help the utility redefine monitoring and inspection
points within the distribution system.

At Gold Coast Water in Australia, improved monitoring and reporting procedures

implemented as part of the HACCP Plan have provided more information to management
and have motivated operational staff to work harder to avoid failures (Smith, 2004).
Operational staff was consulted during development of the HACCP plan to identify
realistic critical limits and monitoring procedures. When a critical limit is exceeded at
Gold Coast Water, the operators submit an excursion report to management (Smith,
2004). For example, a plant operator may file an excursion report because they have
failed to maintain treated water pH for 4 hours due to aging lime dosing equipment.
Management can quickly review these excursion notices and decide if they represent
minor incidents or if further inquiry is warranted. Operators do not like reporting
excursions so they try harder to avoid having failures in the first place. It is hard to cover
up failures because the utility has numerous on-line devices (e.g., turbidity, pH, chlorine)
and close internal auditing methods that reveal cover ups (Smith, 2004). Auditing
methods are discussed below in Section 10.

At Gold Coast Water’s Mudgeeraba plant, Smith (2003b) reports that there was initially
under reporting of a turbidity problem due to inferior monitoring (one combined meter
compared to six meters at another plant). There was also more cultural resistance to
compliance at this plant and it took a change to instrumentation and some close internal
auditing to reveal serious problems at that plant in 2002. Two problems were revealed.
One was that operators had poor skills in dosage optimization in changing conditions.
Secondly, the backwash system components were in poor condition, which compromised
filter performance under certain conditions. The lack of cultural acceptance was dealt
with by closer internal auditing in the early stages and eventually staff realized that there
were benefits all round if everyone adhered to the system (Smith, 2003b).

Monitoring strategies associated with a HACCP Plan do not rely solely on water quality

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testing but may also include inspections and checks on various databases or other utility
records. For example, as summarized in Appendix A, the City of Austin, Texas focused
on two hazards for their HACCP Plan – cross-connections and new construction sites
(City of Austin, 2003). Monitoring strategies for evaluating control measures for the
cross connection hazard include the following:

• Plumbing inspections and water protection surveys to identify any unprotected cross
connections and to check for working backflow prevention devices
• Plumbing inspections and water protection surveys to check on repairs of failed
backflow prevention devices
• Pressure monitoring throughout the distribution system to evaluate whether system
pressure is being maintained
• Reviews of the utility’s database to check if annual inspections of backflow
prevention devices were conducted
• Visual inspection of on-site septic systems to check for system failures

Monitoring strategies for the new construction site hazard include the following:

• Phone and radio contact with site personnel to check on unauthorized use of system
valves
• Visual inspection of contractor disinfection practices on new water lines
• Water quality samples to check coliform bacteria counts and free chlorine levels of
water in new mains prior to being placed into service
• Monitoring tank water level and pressure point alarm levels that would indicate if any
valves were opened between two pressure zones
• Site inspections to check if contractors utilized the One-Call system (a
communication system that provides a toll-free number for contractors/designers to
call facility owners prior to excavating to prevent damage to underground facilities
and utility lines) to mark water utility lines
• Reviews of sign-in sheets for training workshops to check whether site inspectors
attended required training sessions

10. HACCP Approach for Verification

Verification is the use of methods, procedures, or tests to determine if the water utility is
in compliance with the HACCP Plan and/or whether the HACCP Plan needs
modification and revalidation. HACCP principle 6 (Step 11), illustrated in Figure 1,
requires the water supplier to conduct internal verification activities to assure that the
HACCP plan and its associated procedures are being followed. HACCP principle 6 also
encourages external verification of the utility’s HACCP plan and procedures by an
independent third party. To pass a HACCP audit, the system would be scrutinized for
conclusive evidence that the HACCP Plan is effective when followed properly. For
example, the Plan’s monitoring procedures should be effective at identifying failures;
failures should be detected early enough to allow corrective actions to be implemented;
corrective actions should be effective in protecting the drinking water (Deere and
Davison, 1998).

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Australian utilities that have implemented HACCP reported that verification activities
(auditing), though sometimes uncomfortable for operating staff, is a necessary and useful
element of HACCP (Martel et al., 2006). Auditing ensures that periodic reviews will be
conducted, and also keeps utility staff and management up-to-date on important issues.

This section describes internal verification procedures at one Australian utility, and
external verification programs in the U.S., Switzerland and New Zealand.

10.1 Internal Verification Procedures

At South East Water Ltd. in Australia, internal verification procedures include the
following (Mullenger, 2002):

• Random water quality sampling to substantiate that the water is safe

• Daily check records such as indicator organisms and customer complaints
• Weekly audits to ensure that only equipment designated for water use is being used
for repairs
• Checks on appropriate corrective actions (booster chlorine dosing or flushing)

The HACCP Plan is reviewed annually at a minimum both internally and by an

independent auditor. The Plan is also reviewed in the following circumstances
(Mullenger, 2002):

• Changes to water quality zone boundaries or the disinfection process

• Equipment or facility modifications such as covering an open reservoir
• Regulatory amendments
• Changes in piping materials or repair techniques
• Occurrence of a significant hazardous event such as a security breach

10.2 External Verification Programs

In the United States, NSF International provides a HACCP registration program that
verifies that a water utility’s HACCP Plan is controlling known hazards based on the
internationally accepted standard, Codex Alimentarius (www.nsf.org). NSF
International’s registration process involves the following elements:

• A desktop audit of HACCP documentation to identify strengths, weaknesses and

opportunities for improvement
• An on-site readiness review to evaluate whether the utility is ready for registration
• An on-site registration audit to comprehensively assess the HACCP system
• On-going surveillance audits to ensure the HACCP system is being maintained

Currently, no systems in the United States have become registered for HACCP, but there
are United States utilities that are registered for NSF ISO 9000 and ISO 14001. More
than 300 systems in Europe and elsewhere have NSF registration for HACCP. The ISO
registration process does not include an evaluation of risk.

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Health authorities in Switzerland developed an inspection method for evaluating food

production and distribution enterprises including drinking water suppliers (Walker 2003).
Four aspects of a water supplier are judged: their self-assessment program; water quality;
processes (e.g., monitoring, disinfection) and activities (e.g., staff training) used to
control hazards; and buildings/equipment/devices. Each of the four aspects is given a
score related to the perceived safety level (bad, poor, fair or good). The overall safety
score is the arithmetical average of the four scores. In 2002, inspections conducted at
1,500 water systems rated 95 percent of water suppliers at the “good” or “fair” safety
levels. The inspection criteria, methods and reports are practical and use simple language
so that results can be clearly understood by the water distributor, the regulators and the
consumers. The inspection can be completed in 2 to 8 hours, depending on the size of the
company or water utility. Problems identified during inspections are specified in the
inspection report along with recommended corrective measures. More frequent
inspections are conducted at water suppliers with poor scores.

Proposed legislation in New Zealand will require water supplies to be audited to ensure
that the Public Health Risk Management Plans have been prepared and are being
implemented (Nokes, 2001). Health Protection Officers will carry out this assessment by
performing the following tasks:

• Verification of the adequacy of the risk assessment, the risk management plans and
the contingency plans prepared by water suppliers
• Verification that the risk management plans are being implemented
• Verification of operator competence in sampling and “field” and “process control”
analyses, and checking the validity of calibration of field analysis methods
• Verification that continuous analyzers have been properly calibrated
• Verification of data quality in the Water Information System New Zealand (WINZ),
an electronic database system for water quality data for public drinking water systems
• Management of the link between district and national WINZ
• Verification that the drinking-water supply complies with the Drinking-Water
Standards for New Zealand: 2000
• Sampling for surveillance and some field testing
• Training small laboratory operators in sampling and approved analytical tests
(optional function)
• Assessment of the effectiveness of water suppliers’ complaint management
procedures
• Drawing inconsistencies in the Ministry of Health drinking-water management
procedures to the attention of the Ministry

To be able to carry out these tasks, assessors will be trained, and their competence
accredited by an internationally recognized accreditation agency (Nokes 2001).
Assessors will need the following competencies (Nokes, 2001):

• A public health qualification

• Good knowledge of legislation relating to drinking-water
• Good knowledge of the Ministry of Health drinking-water policy and documentation

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• Good working knowledge of drinking-water treatment and distribution practice

• Good competence with the WINZ electronic drinking-water information base
• Knowledge of the concepts of risk, risk management and risk communication
• Knowledge of assessment and auditing of risk management systems
• Ability to assess the competence of drinking-water suppliers
• Ability to carry out “field” and “process” sampling and analyses, and to assess the
competence of drinking-water supply staff in performing these functions
• Knowledge of the principles of calibration of continuous monitors, and checking that
the instruments are recording correctly
• Ability to assess the “fitness for purpose” of equipment and procedures
• Knowledge of enforcement practice, chain of evidence, etc.
• Competence in training
• Communication skills

11. HACCP Approach for Documentation and Record-Keeping

“Efficient and accurate recordkeeping is essential to the application of a HACCP system.

HACCP procedures should be documented.” (Codex Alimentarius, 1993) Examples of
HACCP documentation include all information used during the development of the
HACCP Plan, site sampling plans, monitoring data, corrective actions implemented,
internal and external audit reports, employee training records and regulatory reports. All
HACCP documents and records should be dated and signed (Mullenger, 2002). As with
other sensitive information related to water system security and vulnerabilities, the
HACCP Plan and supporting documents should be controlled in a secure manner.

Smith (2004) cites a case study that illustrates the benefits of improved documentation
procedures and record keeping practices. Before the HACCP system was put into place,
Gold Coast Water had no record of system failures—no one reported the frequency or
magnitude of failures (Smith, 2003b). A HACCP excursion reporting system was
implemented as part of the HACCP Plan. In December 2002, the Health Department
advised Gold Coast Water of a small outbreak of cryptosporidiosis in one part of the city.
The Health Department needed to know if this outbreak was caused by the public water
supply. Within 20 minutes of receiving the call, the utility was able to collate
comprehensive data records that indicated the outbreak was not likely caused by the
water supply. These records included weekly counts for E. coli at the source of supply;
24 hour trend data for various water quality parameters (e.g. raw water turbidity, dosed
water pH, filtered water turbidity, plant chlorine residuals); supply reservoir inspection
reports; weekly water quality data for a sampling location adjacent to the area of concern;
and consumer call records. The utility had a high degree of confidence in the information
provided to the Health Department because the sampling and laboratory work was carried
out by a certified lab and the trended data was provided by instruments with up-to-date
calibration records and verified several times daily against a reference instrument (Smith,
2004). No Cryptosporidium monitoring records were available.
Another case study from Gold Coast Water (Smith, 2004) illustrates how HACCP
documentation and recordkeeping can provide improved information to regulators. For
example, regulators “…have access to almost real time results representative of the

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utilities supply system.” (Smith, 2004) The HACCP excursion reporting system also
provides explanations for each event where a critical limit was breached.

12. Supporting Programs

The HACCP system alone is not enough to ensure the quality and safety of the water
reaching customers’ taps. Like all risk management systems, HACCP depends on key
supporting programs to be effective:

• Commitment from all levels of the organization to HACCP

• Good operational practices as described in standard operating procedures (SOPs)
• A compliance culture with strong auditing to ensure procedures are followed
• Document control and data management systems
• Raw material and product traceability
• Ongoing education and training of personnel (Mullenger, Stevens and Deere, 2003)

Prior to initiating a HACCP Plan, it is important to identify these other programs that
may contribute valuable information related to the condition of the distribution system
and distribution system water quality. The distribution system HACCP plan may be
integrated with these programs to avoid duplicative work. The programs may already
exist in some form but may need improvement or augmentation.

The AWWA Standard G200-Distribution Systems Operation and Maintenance provides

specifications for distribution system programs and standard operating practices that can
be important tools for maintaining water quality. Examples of supporting programs may
include a water main cleaning and flushing program, a tank maintenance and inspection
program, and a valve maintenance program. Examples of specific SOPs for the water
distribution system may include hydrant and valve opening procedures, tank inspection
procedures, and sanitary procedures associated with water main repair. The G200
standard emphasizes the need for specific water quality goals, action plans to respond to
problems and written procedures. Specific water quality goals for the distribution system
may include maximum retention time/water age for finished water storage facilities,
minimum disinfection residual levels, and numbers of customer complaints. As with
other supporting programs, compliance with the AWWA G200 standard is advisable
prior to implementing HACCP.

Gold Coast Water in Australia has developed a number of SOPs to support their HACCP
Plan (Smith, 2003a). SOPs for the distribution system include the following:

• Distribution Water Quality Analysis and Interpretation

• Investigating Dirty Water Complaints
• Reservoir Inspections
• Rechlorination

Each SOP references the HACCP Plan and related critical limits and critical control
points. Each one also details its objective, procedures, corrective actions, and reporting

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activities.

Fok and Emde (2004) emphasize that the effectiveness of a HACCP program is
dependent on the education level and interest by staff to implement the program.

13. Summary
The purpose of this paper is to review existing literature, research data and case studies
on the HACCP system for controlling potential hazards as it applies to water distribution
systems.

For some drinking water systems, current distribution system management practices may
leave these systems vulnerable to contamination, as evidenced by failures linked to
waterborne disease outbreaks. Recently, the water industry has begun to move towards a
more proactive approach to managing the safety of water supplies by incorporating
quality assurance principles. Inquiries into two recent waterborne disease incidents in
Sydney, Australia and Walkerton, Canada both recommended that water utilities
incorporate quality assurance principles for guiding water quality protection.

Originating in the 1960’s, HACCP was designed to ensure safety of food and beverages
from microbiological hazards for the first NASA manned space missions thus preventing
astronauts from falling victim to gastroenteritis while in space (NASA, 1991). HACCP
has been applied to food production processes since the 1980s and to drinking water
systems since the mid-1990s. The World Health Organization (WHO) guidelines for
HACCP, Codex Alimentarius, have been adopted internationally as the primary
recognized food safety methodology for risk management. The current HACCP
guideline was developed in 1997 by the Codex Alimentarius Commission
(http://www.who.int/foodsafety/codex/en ).

The Codex Alimentarius Commission defines 12 sequential steps (or 5 initial steps and 7
major principles) for planning and implementing a HACCP system (WHO, 1997):

Step 1 – Assemble a HACCP Team

Step 2 – Describe the Product
Step 3 – Identify Intended Use
Step 4 – Construct a Flow
Step 5 – Validate Process Flow Diagram
Step 6 – Conduct Hazard Analysis
Step 7 – Identify Critical Control Points
Step 8- Establish Critical Limits
Step 9 – Identify Monitoring Procedures
Step 10 – Establish Corrective Action Procedures
Step 11 – Validate/Verify HACCP Plan
Step 12 – Establish Documentation and Recordkeeping

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The information prepared in completing these 12 steps constitutes the utility’s HACCP
Plan.

In several countries, HACCP steps and principles are being incorporated into national
guidelines or regulations. WHO’s current drinking water guidelines include a framework
for drinking water safety based on HACCP and other risk management systems.
Countries that use WHO guidelines as the minimum criteria for water system regulation
are in the process of developing Water Safety Plans.

The HACCP system may benefit the water utilities in the following ways:

• Improvements in public health protection

• Improved regulatory compliance
• Demonstration of due diligence
• Improvements in design and operation of water system processes
• Improved understanding of risks and risk management
• Improvements in employee skills related to system operation
• Improvements in work processes such as SOPs, monitoring strategies, documentation
procedures, and communication methods.

The HACCP system may present challenges that are difficult to overcome, including the
following:

• Resource needs
• Management support and commitment
• Employee support and commitment
• Small system issues
• Large system issues

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References

AWWA. 1998. Manual M42. Steel Water Storage Tanks. Denver, Colo.: AWWA.
Bartram, J. 2003. The Third Edition of WHO’s Guidelines for Drinking-water Quality
(2003). In Water Safety-Risk Management Strategies for Drinking Water -
Conference Materials. Berlin, Germany: Federal Environmental Agency
(Umweltbundesamt).
Bosshart, U. 2003. HACCP – Hazard Analysis and Critical Control Points at the Zurich
Water Supply. In HACCP in Drinking Water Supplies in Switzerland. Zurich,
Switzerland: Swiss Gas and Water Industry Association.
Breach, B. 2004. The Bonn Workshops – A Charter for Safe Drinking Water. In Proc. of the
NSF Conference on Risk Management Strategies for Drinking Water Utilities.
www.nsf.org/cphe/cphe_rms_presentations.html
Bryan, J.J. 1993. Hazard Analysis and Critical Control Points and Their Application to
the Drinking Water Treatment Process. In Proc. of the 1993 AWWA Water
Quality Technology Conference. Denver, Colo.: AWWA.
City of Austin. 2003. Austin Water and Wastewater Utility Hazard Analysis Critical Control
Point Plan. Denver, Colo.: Awwa Research Foundation Internal Report.
Clark, Robert M., D.A. Reasoner, K.R. Fox, and C.J. Hurst. 1997. Drinking Water
Treatment and Distribution: Its Role in Preventing Waterborne Outbreaks. Presented
at Workshop on Design of Waterborne Disease Occurrence Studies. March 12-13,
1997, Atlanta, GA.
Codex Alimentarius 1993, Guidelines for the Application of the Hazard Analysis Critical
Control Point (HACCP) System, CAC/GL 18-1993.
Committee on Public Water Supply Distribution Systems. 2006. Drinking Water
Distribution Systems: Assessing and Reducing Risks. Washington, D.C.: The
National Academies Press. www.nap.edu .
Cunliffe, D.A., 2004. Australian Framework for Management of Drinking Water Quality. In
Proc. of the NSF Conference on Risk Management Strategies for Drinking Water
Utilities. www.nsf.org/cphe/cphe_rms_presentations.html
Cunliffe, D.A., 2003. Application of the Australian Risk Management Framework: A Public
Health Authorities Perspective. In Water Safety-Risk Management Strategies for
Drinking Water - Conference Materials. Berlin, Germany: Federal Environmental
Agency (Umweltbundesamt).
Cunliffe, D.A. 2001. Australia’s Framework for Management of Drinking Water Quality. In
Proc. of the AWWA Annual Conference. Denver, Colo.: AWWA.
Davison, A., G. Howard, M. Stevens, P. Callan, L. Fewtrell, D. Deere and J. Bartram.
2005. Water Safety Plans – Managing drinking-water quality from catchment to
consumer. Geneva, Switzerland: World Health Organization.
Davison, A., and J. Bartram. 2004. HACCP and WHO Water Safety Plans. In Proc. of the
NSF Conference on Risk Management Strategies for Drinking Water Utilities.
www.nsf.org/cphe/cphe_rms_presentations.html
Davison, A., S. Davis, and D. Deere. 1999. Quality Assurance and Due Diligence for Water:
Can HACCP Deliver? In Proc. of the Australian Water and Wastewater Association
Conference.

42
 January 19, 2007

Davison, A. and D. A. Deere. 2004. Liabilities, Due Diligence and Utilities: HACCP As A
Legal Defense. In Proc. of the NSF Conference on Risk Management Strategies for
Drinking Water Utilities. www.nsf.org/cphe/cphe_rms_presentations.html
DeBeir, L. and J-C. Joret. 2004. HACCP as a Tool for Assuring Safe Drinking Water:
The Veolia Water Experience. In Proc. of the NSF Conference on Risk
Management Strategies for Drinking Water Utilities.
www.nsf.org/cphe/cphe_rms_presentations.html
Deere, D. 2005. Question on Sydney Water. Email to K. Martel. 1.3.05.
Deere, D. and A. Davison. 1998. Safe Drinking Water: Are Food Guidelines the Answer?
WATER:Nov/Dec.
Deere, D. and A. Davison. 1999. Assuring Water Quality. WATER21, 1(1): 8-9.
EPA. 1991. Quality Assurance Glossary and Acronyms. ORD-QA Management Staff.
Washington, D.C.
EPA’s Office of Ground Water and Drinking Water, 2002. Potential Contamination Due to
Cross-Connections and Backflow and the Associated Health Risks – White Paper
http://www.epa.gov/safewater/tcr/pdf/ccrwhite.pdf
Fawell, J. 2003. Can HACCP Principles Be Applied to Chemicals in Drinking Water. In
Water Safety-Risk Management Strategies for Drinking Water - Conference
Materials. Berlin, Germany: Federal Environmental Agency (Umweltbundesamt).
Fok, N. and K.Emde. 2004. HACCP in Water Treatment – What It Is and What It Isn’t. In
Proc. of the NSF Conference on Risk Management Strategies for Drinking Water
Utilities. www.nsf.org/cphe/cphe_rms_presentations.html
Friedman, M.J., L. Radder, S. Harrison, D. Howie, M. Britton, G. Boyd, H. Wang, R.
Gullick, M. LeChevallier, J. Funk and D. Wood. 2004. Verification and Control of
Low Pressure Transients in Distribution Systems. Denver, Colo.: AwwaRF and
AWWA.
Geldreich, E.E. 1996. Microbial Quality of Water Supply in Distribution Systems. Boca
Raton, FL: Lewis Publishers.
Gunnarsdottir, M.J. and L.R. Gissurarson. 2006. HACCP in Icelandic Water Supply –
evaluating eight years of experience. In Proc. Of the NVK 2006 Conference.
http://www.samorka.is/Apps/WebObjects/Samorka.woa/1/swdocument/1000721/Pro
ceedings+from+NVK+2006.pdf .
Havelaar, A.H. 1994. Application of HACCP to Drinking Water Supply. Food Control,
5(3):145-152.
Joret, J.C., L. deBeir, H. deMascureau, and M-C. Muller. 2003. Vivendi Water: Application
of HACCP Principles in Drinking Water. In Water Safety-Risk Management
Strategies for Drinking Water - Conference Materials. Berlin, Germany: Federal
Environmental Agency (Umweltbundesamt).
Kirmeyer, G.J., M. Friedman, J. Clement, A. Sandvig, P.F. Noran, K. Martel, D. Smith, M.
LeChevallier, C. Volk, E. Antoun, D. Hiltebrand, J. Dykesen, and R. Cushing. 2000.
Guidance Manual to Maintain Distribution System Water Quality. Denver, Colo.:
AwwaRF and AWWA.
Kirmeyer, G.J., M. Friedman, K. Martel, D. Howie, M. LeChevallier, M. Abbaszadegan, M.
Karim, J. Funk and J. Harbour. 2001. Pathogen Intrusion Into the Distribution
System. Denver, Colo.: AwwaRF and AWWA.

43
 January 19, 2007

Kirmeyer, G.J., L. Kirby, B.M. Murphy, P.F. Noran, K. Martel, T.W. Lund, J.L. Anderson,
and R. Medhurst. 1999. Maintaining and Operating Finished Water Storage
Facilities to Prevent Water Quality Deterioration. Denver, Colo.: AwwaRF and
AWWA.
Kramer, M.H., B.L. Herwaldt, G.F. Craun, R.L. Calderon, and D.D. Juranek. 1996.
Waterborne Disease: 1993 and 1994. JAwwa, 88(3):66-80.
Kuslikis, B. and B. White. 2004. Implementing a Sustainable, Integrated Risk Management
System for Water Safety and Quality. In Proc. of the NSF Conference on Risk
Management Strategies for Drinking Water Utilities.
www.nsf.org/cphe/cphe_rms_presentations.html
LeChevallier, M.W. 2003. Assuring the Microbial Safety of Drinking Water. In Water
Safety-Risk Management Strategies for Drinking Water - Conference Materials.
Berlin, Germany: Federal Environmental Agency (Umweltbundesamt).
Lee, J.J., P. Schwartz, P. Sylvester, L. Crane, J. Haw, H. Chang and H.J. Kwon. 2003.
Impacts of Cross Connections in North American Water Supplies. Denver, Colo.:
AwwaRF and AWWA.
Levy, D.A., M.S. Bens, G.F. Craun, R.L. Calderon, B.L. Herwaldt. 1998. Surveillance for
Waterborne Disease Outbreaks--United States, 1995-1996.
www.cdc.gov/epo/mmwr/preview.
Lippy, E.C. and, S.C. Waltrip. 1984. Waterborne Disease Outbreaks - 1946-1980: A Thirty-
Five Year Perspective. JAwwa, 76:60-67.
Martel, K., G. Kirmeyer, A. Hanson, M. Stevens, J. Mullenger, and D. Deere. 2006.
Application of HACCP for Distribution System Protection. Denver, Colo.: AwwaRF,
AWWA and IWA Publishing.
Metge, S. 2003. The French Experience with the Application of HACCP Principles in
Drinking Water. In Water Safety-Risk Management Strategies for Drinking Water -
Conference Materials. Berlin, Germany: Federal Environmental Agency
(Umweltbundesamt).
Ministry of Health. 2005. A Framework on How to Prepare and Develop Public Health Risk
Management Plans for Drinking-Water Supplies. Wellington, New Zealand: Ministry
of Health.
Ministry of the Environment. 2006. Drinking Water Quality Management Standard. Ontario,
Canada: Ministry of the Environment. Available at:
http://www.ene.gov.on.ca/envision/env_reg/er/documents/2006/Drinking%20Water
%20Quality%20Management%20Standard%20-%20October%202006.pdf .
Accessed 11.28.06.
Mullenger, J., M. Stevens and D. Deere. 2003. Hazard Analysis and Critical Control Point
(HACCP) for Drinking Water Distribution Systems. Draft Work Product for
AwwaRF 2856 – Application of HACCP for Distribution System Protection.
Mullenger, J. 2002. HACCP Principles 6 and 7. In The How, Where and Why of Applying
HACCP to Water – AWWA WQTC Workshop Manual. Melbourne, Australia:
Melbourne Water Corporation.
Murphy, B. 2003. AwwaRF 2931 Vulnerable Points in the Distribution System – Proposal to
AwwaRF. Bellevue, WA: EES.
Nadeau, M. 2004. Letter to K. Martel (July). South Berwick, Maine: South Berwick Water
District.

44
 January 19, 2007

Nadeau, M. 2003. Hazard Analysis and Critical Control Point Plan. October 2003 Draft
Plan. Denver, Colo.: AwwaRF Internal Report.
NASA. 1991. A Dividend in Food Safety. Spinoff 1991, NASA Technical Report ID
20020086314.
National Health and Medical Research Council and Natural Resource Management
Ministerial Council. 2004. National Water Quality Management Strategy: Australian
Drinking Water Guidelines. http://www.nhmrc.gov.au and http://affa.gov.au .
Nokes, C. 2001. Public Health Risk Management Plans: An Introduction to New Zealand's
Use of a Risk Management-Based Approach to Improving the Safety of Drinking-
Water Supplies. NZIEH Conference.
Nyman, L. 2004. Benefits of ISO Programs at Elizabethtown Water Company. In Proc. of
the NSF Conference on Risk Management Strategies for Drinking Water Utilities.
www.nsf.org/cphe/cphe_rms_presentations.html
O’Connor, D.R. 2002. Report of the Walkerton Inquiry. Part 2. A Strategy for Safe Drinking
Water. Toronto, Canada: The Walkerton Inquiry.
Ogg, J.E., R.A. Ryder and H.L. Smith. 1989. Isolation of Vibrio Cholerae From Aquatic
Birds in Colorado and Utah. Applied and Environmental Microbiology, 55(1): 95-99.
Pedersen, D. 2004. AwwaRF Project #2856 Final Report - Application of HACCP for
Distribution System Protection. December 8, 2004. Austin, Texas: City of Austin.
Pierson, G., K. Martel, A. Hill, G. Burlingame, and A. Godfree. 2001. Practices to Prevent
Microbiological Contamination of Water Mains. Denver, Colo.: AwwaRF and
AWWA.
Reasoner, D. 1991. Pathogens in Drinking Water – Are There Any New Ones? In Proc. of
the AWWA Water Quality Technology Conference. Denver, Colo.: AWWA.
Schmoll, O., Ed. 2003. Workshop Conclusions. In Water Safety-Risk Management
Strategies for Drinking Water - Conference Materials. Berlin, Germany: Federal
Environmental Agency (Umweltbundesamt).
Smith, D. 2004. HACCP in Water: The War on Error. In Proc. of the NSF Conference on
Risk Management Strategies for Drinking Water Utilities.
www.nsf.org/cphe/cphe_rms_presentations.html
Smith, D. 2003a. HACCP Procedures. Email to K. Martel. 2.17.03.
Smith, D. 2003b. HACCP Case Study. Email to K. Martel.10.28.03.
Sobsey, M.D., A.P. Dufour, C.P. Gerba, M.W. LeChevallier, and P. Payment. 1993. Using a
Conceptual Framework for Assessing Risks to Health From Microbes in Drinking
Water. JAwwa, 85(3), 44-48.
Standards Australia/Standards New Zealand. 1999. AS/NZS 4360:1999 Risk Management,
Joint Australian/New Zealand Standard, Standards Association of Australia,
Strathfield, NSW, Australia.
Stevens, M. and K. Martel. 2004. AwwaRF 2856 Status Report #4 – Application of HACCP
for Distribution System Protection (August). Denver, Colo.: Awwa Research
Foundation Internal Report.
Swerdlow, D.L., B.A. Woodruff, R.C. Brady, P.M. Griffin, S. Tippen, H.D. Donnell, Jr., E.
Geldreich, B.J. Payne, A. Meyer, Jr., and J.G. Wells. 1992. A waterborne outbreak in
Missouri of Escherichia coli O157:H7 associated with bloody diarrhea and death.
Ann Intern Med, 117(10):812-9.

45
 January 19, 2007

Swiss Gas and Water Industry Association. 2003. W1002 Regulation-Recommendations for
a Simple Water Quality Assurance System for Water Supplies. Zurich, Switzerland:
Swiss Gas and Water Industry Association.
USEPA. 2006. Framework for the Water Safety Plan Regulatory Development Approach for
the Proposed Aircraft Drinking Water Rule. Incorporation of Workgroup Comments,
Draft October 5, 2006.
Walker, H.S. 2003. Safety of Drinking Water Supplies in Switzerland. In HACCP in
Drinking Water Supplies in Switzerland. Zurich, Switzerland: Swiss Gas and Water
Industry Association. World Health Organization. 1997. Hazard Analysis and
Critical Control Point (HACCP) System and Guidelines for its Application.
World Health Organization. 1997. HACCP – Introducing the Hazard Analysis and Critical
Control Point System. Geneva, Switzerland: WHO.

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 January 19, 2007

Appendix A

Application of HACCP Principles

City of Austin, Texas

Note: The information presented in this Appendix has been made possible through funding from the Awwa
Research Foundation. The information is based upon intellectual property which is jointly owned by
Cooperative Research Centre for Water Quality and Treatment and the Foundation. The Foundation retains
its right to publish or produce the jointly owned intellectual property in part or its entirety.

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 January 19, 2007

AUSTIN WATER AND WASTEWATER UTILITY

HAZARD ANALYSIS AND CRITICAL

CONTROL POINT PLAN

(September 10, 2003)

Prepared By:

City of Austin
Water and Wastewater Utility
Environmental and Regulatory Services Division
Staff Contact: Dan W Pedersen
XXX-XXX-XXXX

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HAZARD ANALYSIS AND CRITICAL CONTROL

POINT PLAN

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................................. 1

INTRODUCTION ........................................................................................................................................ 2

BACKGROUND ........................................................................................................................................... 3

MODEL HACCP PLAN DEVELOPMENT .............................................................................................. 4

A. STEP 1 – ASSEMBLE A TEAM .................................................................................................... 4
B. STEP 2 – DESCRIBE THE PRODUCT.......................................................................................... 4
C. STEP 3 – IDENTIFY INTENDED USE ......................................................................................... 4
D. STEP 4 – CONSTRUCT A FLOW DIAGRAM.............................................................................. 4
E. STEP 5 – VALIDATE PROCESS FLOW DIAGRAM ................................................................... 4
F. STEP 6 – CONDUCT HAZARD ANALYSIS................................................................................ 4
G. STEP 7 – IDENTIFY CRITICAL CONTROL POINTS ................................................................. 4
H. STEP 8 – ESTABLISH CRITICAL LIMITS .................................................................................. 5
I. STEP 9 – IDENTIFY MONITORING PROCEDURES...................................................................... 5
J. STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES.................................................. 5
K. STEP 11 – VALIDATE/VERIFY HACCP PLAN .......................................................................... 5
L. STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING ................................ 10
AUSTIN’S HACCP PLAN........................................................................................................................... 4
A. STEP 1 – HACCP TEAM ............................................................................................................... 6
B. STEP 2 – PRODUCT DESCRIPTION............................................................................................ 7
C. STEP 3 – IDENTIFY INTENDED USE ......................................................................................... 8
D. STEP 4 – CONSTRUCT A FLOW DIAGRAM.............................................................................. 9
E. STEP 5 – VALIDATE PROCESS FLOW DIAGRAM ................................................................... 9
F. STEP 6 – CONDUCT HAZARD ANALYSIS................................................................................ 9
G. STEP 7 – IDENTIFY CRITICAL CONTROL POINTS ............................................................... 13
H. STEP 8 – ESTABLISH CRITICAL LIMITS ................................................................................ 14
I. STEP 9 – IDENTIFY MONITORING PROCEDURES.................................................................... 14
J. STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES................................................ 14
K. STEP 11 – VALIDATE/VERIFY HACCP PLAN ........................................................................ 24
L. STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING ................................ 24
ATTACHMENT A – PROCESS FLOW DIAGRAM ............................................................................. 25

ATTACHMENT B – LIST OF STREETS IN THE SOUTHWEST C PRESSURE ZONE................. 26

ATTACHMENT C – SOUTHWEST C PRESSURE ZONE MAP ........................................................ 28

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INTRODUCTION

Hazard Analysis Critical Control Point (HACCP) is a food quality control program originally
developed for the National Aeronautics and Space Administration (NASA) in the early 1960’s.
It focuses on the process of preparing food for consumption by astronauts in space that is safe to
eat. HACCP looks at each step in the process of preparing, packaging, storing, and delivering
food. Critical points where the food might become contaminated are identified and monitored so
that food safety is assured. In subsequent years, HACCP has been widely adopted in the food
industry.

In recent years there has been discussion of applying HACCP to the drinking water industry.
The Partnership for Safe Water, in which the Utility participated, is in many respects a HACCP
program. It focuses on turbidity as a critical control point in the treatment of drinking water.
Australian Utilities have been in the forefront of applying HACCP to control source water
quality prior to treatment. Even though the application of HACCP to distribution systems is not
yet fully developed, the EPA has been studying it as they revise the Total Coliform Rule and in
the development of a Distribution System Rule.

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BACKGROUND
In March 2002, the American Water Works Association Research Foundation released a request for
proposal entitled Application of Hazard Analysis and Critical Control Points (HACCP) for
Distribution System Protection. The objective of the research is to evaluate the HACCP model for
application in protecting and maintaining distribution system water quality. The first major tasks in
the research project is to review previous HACCP plans to see how they were tailored to meet the
unique needs of the users and tailoring a HACCP for use in the distribution system. The next step is
to develop a model HACCP system and have it reviewed by Utilities with an emphasis on the ability
to implement the HACCP. The review was performed predominantly by Australian Utilities who
have applied HACCP principals to source water protection. The final tasks are to develop and
implement a HACCP Plan based on the model and adjust the model as necessary based on
implementation results.

The Utility was approached by the lead researcher, Economic and Engineering Services, Inc., and
asked to participate as a research team member. The Utility agreed to participate because a better
understanding of the critical control points in the distribution system will assist in optimizing the
operation of the distribution system. Our commitment to the project was estimated to be at least 200
man-hours, with an in-kind value of at least $15,000. Actual tasks include participating in a HACCP
workshop in our office, development of a HACCP plan based on the model, implementation of the
HACCP plan in at least a portion of our distribution system, assembling system records, and
performing monitoring and analysis activities. The Southwest C Pressure Zone was selected as a
manageable area in which to apply the HACCP plan.

The complete research team consists of Economic and Engineering Services, Inc., the
Cooperative Research Centre for Water Quality and Treatment, Melbourne Water, Sydney
Catchment Authority, Sydney Water Corporation, Austin Water and Wastewater Utility, South
Berwick Water District, Northern Territories Power and Water Authority, South East Water,
Yarra Valley Water, Gold Coast Water, Monash University, Egis, and the Victoria Department
of Human Services.

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MODEL HACCP PLAN DEVELOPMENT

In the initial tasks of the research, the research team developed and refined a twelve-step model
for preparing and implementing a HACCP plan for a typical distribution system. The following
are the twelve steps and a brief description of them:

A. STEP 1 – ASSEMBLE A TEAM

Pull together a multidisciplinary team to plan, develop, verify, and implement the plan.

STEP 2 – DESCRIBE THE PRODUCT

Describe the product, in this case drinking water, including its source, treatment, storage,
distribution and any existing standards for product safety.

STEP 3 – IDENTIFY INTENDED USE

Describe how the product is used and the major users.

STEP 4 – CONSTRUCT A FLOW DIAGRAM

For a comprehensive HACCP, this would be a schematic showing sources of water, details of
treatment, storage, pumping, and distribution to end users. For a HACCP directed toward a
distribution system, the schematic would be restricted to showing the water flow path from the
treatment plant to end users.

STEP 5 – VALIDATE PROCESS FLOW DIAGRAM

As a critical element around which the HACCP is based, the flow diagram needs confirmation of
accuracy by the HACCP team.

STEP 6 – CONDUCT HAZARD ANALYSIS

Using the process flow diagram, identify hazards, their likelihood of occurrence, potential
consequences, and control measures.

STEP 7 – IDENTIFY CRITICAL CONTROL POINTS

Based on the hazard analysis select the most significant hazards for control. These are typically
points in the process where the consequences of failure are irreversible.

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 January 19, 2007

STEP 8 – ESTABLISH CRITICAL LIMITS

Determine critical limits for the critical control points that will trigger a corrective action. A critical
limit is a criterion which separates acceptability from unacceptability.

STEP 9 – IDENTIFY MONITORING PROCEDURES

Establish monitoring points, frequency, and responsibility.

STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES

Develop plans for follow up activity when performance measures for critical control points are
exceeded.

STEP 11 – VALIDATE/VERIFY HACCP PLAN

Have the HACCP team and other affected parties check the HACCP plan for accuracy, ability to
implement, and potential effectiveness.

STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING

Develop a record keeping system to track system performance at critical control points.

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 January 19, 2007

AUSTIN’S HACCP PLAN

On May 21, 2003, the Utility held a one-day HACCP workshop. Attendees included staff with a
broad array of skill sets from various divisions within the Utility with varying perspectives on
Utility and distribution system operation. In particular, attendees included individuals from the
Water Lab, Systems Planning, Cross-Connection Control, Process Engineering, Distribution
System Operation, Water Quality, Regulatory Compliance, and the State’s Regulatory Agency.
Workshop attendees were able to completed Steps 1 through 7 and identified a core group of
people to serve as the HACCP Team. The Team met several times during the summer of 2003 to
finalize the remaining steps of the plan prior to implementation. The following are the results of
the workshop and work of the Team and serves as the HACCP plan that will be implemented:

B. STEP 1 – HACCP TEAM

The following are members of the Utility’s HACCP team:

Name Position Telephone Fax Email

Water
Barrios,
Laboratory xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Rosie
Supervisor
TCEQ
Bennett,
Regulatory xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Tony
Manager
Bohr, Onnie Infrastructure
xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Superintendent

Burazer, Asst. Director of

xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Jane Treatment
Cross
Kuhn, Connection
xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Robert Control
Supervisor
Lutes, Engineer/Planne
xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Teresa r

Ojeda, Construction
xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Edward Inspector

Pedersen, Water Quality

xxx-xxx-xxxx xxx-xxx-xxxx xxxxxx@xxxxx
Dan Manager

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 January 19, 2007

STEP 2 – PRODUCT DESCRIPTION

The following description of the Utility’s drinking water (product) was prepared at the May 21,
2003 HACCP Workshop:

Step Description
Source Water Austin’s source of supply is the Colorado River. Raw water for the
Southwest C pressure zone is currently diverted at Lake Austin.
Treatment Processes Raw water for the Southwest C pressure zone is treated at the Ullrich
Water Treatment Plant using treatment processes consisting of:
lime softening,
recarbonation/pH adjustment,
chloramination,
filtration,
ferric sulfate,
fluoride, and
addition of sodium hexametaphosphate

Storage After Treatment Treated water is stored at the Ullrich Plant in two 10 mg clearwells, and in
the distribution system in tanks.

Conveyance The Utility owns a contiguous distribution system that serves a population
of approximately 770,000 through roughly 183,000 service connections.
The distribution system contains 2,995 miles of water mains of a wide
variety of materials including cast iron, ductile iron, PVC, asbestos
cement, and reinforced concrete cylinder. The distribution system also
contains 30 tanks ranging in size from 300,000 to 34,000,000 gallons.

Because of the varied topography in the Utility’s service area, the

distribution system is divided into eight major pressure zones. The flow
path to the Southwest C pressure zone, which is the subject of the HACCP
plan is shown in the attached flow diagram.

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 January 19, 2007

Step Description
Special Controls Federal or State Drinking Water Regulations
• Water pressure must be maintained at 35 psi under normal
conditions and 20 psi during emergencies throughout the
distribution system.
• Maintain a minimum total chlorine residual of 0.5 mg/L throughout
the distribution system.
• Monthly flushing of dead-end water mains that have a history of
customer complaints.
• Inspection of new service connections.
• An active cross-connection control program.
• Water main separation from sanitary sewers.
• Finished water storage design and construction requirements.
• Annual cleaning and inspection of finished water storage tanks.
• Routine distribution system total coliform monitoring.

City of Austin requirements

• Maintain total chlorine residual of 1.0 mg/L throughout the
distribution system.
• Routine maintenance program for public and private fire hydrants
• Monthly chlorine residual and total coliform monitoring at finished
water storage tanks.

STEP 3 – IDENTIFY INTENDED USE

Based on the results of the May 21, 2003 workshop the following table lists the typical uses and
customer classes for the Utility’s drinking water:

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 January 19, 2007

Intended Uses Intended Consumer

• Drinking • Residential
• Manufacturing, including semi-conductor • Commercial
manufacturing processes which are • Industrial
sensitive to total organic carbon and
trihalomethane levels
• Irrigation
• Culinary uses
• Fire fighting
• Construction uses
• Sanitary uses (toilet flushing and showers)
• Medical uses (hospitals, dialysis centers,
dental offices)
• Product water (Coca Cola and Abbott
Labs)

STEP 4 – CONSTRUCT A FLOW DIAGRAM

The process flow diagram is included as Attachment A.

STEP 5 – VALIDATE PROCESS FLOW DIAGRAM

The process flow diagram was developed on May 21, 2003, reviewed for accuracy by July 28,
2003, and finalized on August 15, 2003.

STEP 6 – CONDUCT HAZARD ANALYSIS

At the May 21, 2003 HACCP Workshop, Utility staff conducted a hazard analysis for the
distribution system in the Southwest C Pressure Zone. The complete results of this hazard
analysis are shown in the following table. While there were a large number of potential hazards
identified for the Southwest C Pressure Zone, Utility staff decided to base its HACCP pilot study
on two particular hazard events that scored high marks in the hazard analysis – cross-connections
and new construction.

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 January 19, 2007

Hazard Analysis Table

Hazard Severity of Likelihood Risk Factor Existing Control Additional Required

Event Consequen of = Measures Control Measures
ces Occurrenc Likelihood
(Score e x Severity
Using 1 to (Score
5 Scale) Using 1 to
5 Scale)
Cross- 5 5 25 • Identify cross- • Provide public
Connection connections and install education such as
Example: backflow prevention safety presentations
Irrigation(exist devices
ing) or hydrant • Repair failed backflow
vandalism devices
• Require annual
inspections of
backflow prevention
devices
• Perform field surveys
especially at
commercial
installations with
significant potential
for cross-connections
• Inspect plumbing of
new customers
• Check for cross-
connections when
responding to
customer complaints
• Maintain distribution
system pressure
• Monitor OSSF and
report failures

New 5 4 20 Note: No new • Inspection

Construction construction inspectors • Design standards which
(including were present at the May include plan review,
inappropriate 21, 2003 workshop and a monitoring of pressure
valve turning) comprehensive discussion and bacteria upon
of “Existing” and installation, and good
“Additional” control materials storage
measures was not possible. practices

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 January 19, 2007

Hazard Severity of Likelihood Risk Factor Existing Control Additional Required

Event Consequen of = Measures Control Measures
ces Occurrenc Likelihood
(Score e x Severity
Using 1 to (Score
5 Scale) Using 1 to
5 Scale)
• Inspector training
which includes training
on water quality –
related issues
• Coordination between
Water Quality and
Supply and Public
Works groups
• Ensure that storm water
does not reach trenches
• Make contractor
responsible for water
quality-related
condition of new mains
• Flushing to clean new
mains
• Review of finished
project
• Limit valve operations
to approved personnel
only
• Disinfect new mains
• Improve education of
operators with respect
to valve operation
• Ensure the correct
amount of pressure is
available in areas of
pressure zones and
with potential for
transients
Septic Tanks 3 3 9 • Inspect and certify • Inspect septic systems
(County) septic annually
systems to • Hook customers up to
demonstrate that they city sewer system
meet county criteria
• Inspect (County)
septic fields upon sale
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 January 19, 2007

Hazard Severity of Likelihood Risk Factor Existing Control Additional Required

Event Consequen of = Measures Control Measures
ces Occurrenc Likelihood
(Score e x Severity
Using 1 to (Score
5 Scale) Using 1 to
5 Scale)
of home

Water Main 3 4 12 • Follow SOPs for

Repair, repair, shut-down,
Breaks, and/or water quality and
ground pressure testing
shifting • Meet state
requirements for
depressurization
• Supervise repair work
• Maintain positive
pressure during work
where possible
• Use standard products
for disinfection, etc.
• Use different tools on
drinking water main
repairs and wastewater
repairs
Sewer Mains 2 5 10

Vandalism 3 3 9

Main break 4 2 8
external to
zone
Break external 4 2 8
to zone

Hydraulic 2 2 4
transients

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 January 19, 2007

Hazard Severity of Likelihood Risk Factor Existing Control Additional Required

Event Consequen of = Measures Control Measures
ces Occurrenc Likelihood
(Score e x Severity
Using 1 to (Score
5 Scale) Using 1 to
5 Scale)
Nitrification or 2 2 4
Residual
below 1.0
mg/L
(Austin’s goal)
Nitrification or 4 1 4
no residual

Tanks 1 4 4
Example:
unmaintained
screens,
ponding on
top, or
cleaning

STEP 7 – IDENTIFY CRITICAL CONTROL POINTS

As mentioned in the Introduction, the Utility’s role in the research project is to develop and
implement a pilot of the model HACCP. To facilitate this role, the Utility selected a portion of
its distribution for purpose of the pilot. Workshop participants were asked for suggestions on
which portion of the distribution system was most suitable for the pilot with the Southwest C
Pressure Zone given as a possibility because of a number of boil water advisories issued there in
recent years. Additionally, the Southwest C Pressure Zone has other features that make it
appropriate for a HACCP plan. It contains four sites (Blue 2, Blue 11, Blue 19, and Maroon 1)
that are routinely monitored under the Total Coliform Rule and provides a history of water
quality in the area. Additionally, one of those sites (Blue 19) is a monitoring point for
compliance with the Disinfection By-Products Rule, which further enhances understanding of
water quality in the area. The Southwest C Pressure Zone is located on the extreme
southwestern edge of the distribution system, containing maximum water age for that portion of
the distribution system. Water traveling to this area passes through two tanks and three pump
stations, which have the potential to affect water quality by increasing water age. It is a growing
area with new construction occurring. It is a semi-rural area with older homes on septic systems
that, should they fail, might pose a hazard to leaking water mains subject to low or negative
13
 January 19, 2007

pressure transients.

At the May 21, 2003 workshop, participants identified twelve hazard events and for purposes of
the HACCP selected the two highest-ranking hazards as areas to focus on. The HACCP Team
met subsequently and identified specific critical control points within these two hazards. The
critical control points are as follows:

Cross-connection Hazard
Each connection to a potential hazard within the customer’s plumbing system
Throughout Southwest C Distribution System

New Construction Hazard

At each site of new construction

STEP 8 – ESTABLISH CRITICAL LIMITS

Critical limits for the cross-connection hazard and the new construction hazard are listed in the two
tables below.

STEP 9 – IDENTIFY MONITORING PROCEDURES

Monitoring of the critical limits for the cross-connection hazard and new construction hazard are
listed in the two tables below.

STEP 10 – ESTABLISH CORRECTIVE ACTION PROCEDURES

Corrective actions, in the event that a critical limit is exceeded, for the cross-connection hazard
and new construction hazard are listed in the two tables below.

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 January 19, 2007

Table for the Cross Connection Hazard

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
Each Identify Critical Texas Method: Existing Corrective
connection cross- Limit #1: Commission on Plumbing inspections Actions:
to a connections Presence Environmental and water protection Enforce requirements
potential and install of Quality’s surveys using penalties, etc.
hazard backflow working regulations for Monitoring Additional Corrective
within the prevention backflow public drinking Frequency: Actions Required:
Enforcement actions on non
customer’s assemblies & preventio water and City Annual testing of -compliant customers.
plumbing devices n device ordinances backflow prevention
system on high hazard
situations.
List Responsible Immediate Action
Person: Plan: Permit and
Plumbing Inspections Inspect new and
– Robert Brown, chief remodeled plumbing
plumbing Inspector installations.
Water Protection
Surveys – Robert
Kuhn, water Protection
Supervisor
Monitoring List Responsible
Location(s): Person:
At residential, Robert Kuhn
commercial, industrial,
and institutional
customers.
Tracking:
WPTS Database
Repair failed Critical Texas Method: Existing Corrective
backflow Limit #1: Commission on Plumbing inspections Actions:
assemblies Presence Environmental and water protection Enforce requirements
surveys using penalties, etc.

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 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
of Quality’s Monitoring Additional Corrective
working regulations for Frequency: Actions Required:
Enforcement actions on non
backflow public drinking Annual testing of -compliant customers.
preventio water and City backflow prevention
n device ordinances on high hazard
situations.
List Responsible • Immediate
Person: Action Plan:
Robert Kuhn, water Permit and
Protection Supervisor Send Customer
Notice
• Send reminder
notice
• Run delinquent
report
Monitoring List Responsible
Location(s): Person:
At residential, Robert Kuhn
commercial, industrial,
and institutional
customers.
Tracking:
WPTS Database
Require Critical Texas Method: Existing Corrective Actions:
annual Limit #1: Commission on On line & manual data Enforce requirements using
penalties, etc.
inspections Backflow Environmental entry
of backflow assemblie Quality’s Monitoring Additional Corrective
assemblies s pass regulations for Frequency: Actions Required:
operationa public drinking Monthly enforcement actions
l test water and City on non -compliant
ordinances customers

16
 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
Responsibility: Immediate Action
Robert Kuhn Plan:
• Send Customer
Notice
• Send reminder
notice
• Run delinquent
report
• Terminate
service or file
criminal
charges as
necessary.
Monitoring List Responsible
Location(s): Person:
At residential, Robert Kuhn
commercial, industrial,
and institutional
customers.
Tracking:
WPTS Database
Throughout Inspect Critical City ordinances Method: Existing Corrective
Southwest plumbing of Limit #1: Visual inspection by Actions: Enforcement
C new Complian City plumbing per the Plumbing Code
Distributio customers ce with inspectors and Cross-connection
n System Plumbing Ordinance
Code Monitoring Additional Corrective
Frequency: Actions Enforcement
Each occurrence of actions on non -
new plumbing compliant customers.
construction

17
 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
List Responsible Immediate Action
Person: Plan:
Plumbing Inspections Schedule at least two
– Robert Brown, chief water protection
plumbing Inspector surveys in the sample
Water Protection area
Surveys – Robert
Kuhn, water Protection
Supervisor
Monitoring List Responsible
Location(s): At Person: Robert Kuhn
residential,
commercial, industrial,
and institutional
customers.
Tracking:
WPTS Database
Check for Critical Texas Method: Existing Corrective Actions:
cross- Limit #1: Commission on Visual inspection Enforce requirements using
timeframe for correction and
connections No Environmental penalties, etc.
when potable Quality’s Monitoring Additional Corrective
responding water regulations for Frequency: Actions Required:
to customer services public drinking Each customer enforcement actions
complaints with a water and City complaint upon on non -compliant
cross- ordinances customer demand customers

18
 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
connectio Responsibility: Immediate Action
n Robert Kuhn and his Plan:
staff • Send Customer
Notice
• Send reminder
notice
• Run delinquent
report
• Terminate
service or file
criminal
charges as
necessary.
Monitoring List Responsible
Location(s): Person:
Customer properties. Robert Kuhn and his
staff
Tracking:
WPTS Database
Maintain Critical Texas Method: Existing Corrective Actions:
distribution Limit #1: Commission on Pressure transducer
Turn on additional pumps to
system Pressure Environmental and data logger. raise pressure.
pressure should be Quality’s Pump station Search for main breaks
above 35 regulations for discharge points on the Issue boil water advisory, if
psi under public drinking SCADA System w/ necessary.
normal water tracking through
conditions SCADA.
. Monitoring Additional Corrective
Pressure Frequency: Actions Required:
may be as Continuous with data
low as 20 recorder.
psi during Responsibility: Immediate Action
emergenc Dan Pedersen Plan:
y
conditions

19
 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
Monitoring List Responsible
Location(s): Person:
SCADA monitoring Turning on pumps –
locations. pumping division
Search for main breaks
-- field crews
Boil water advisory –
Dan Pedersen.
Tracking:
Utility’s SCADA
system.
Monitor on- Critical City ordinances Method: Existing Corrective
site septic Limit #1: Visual, olfactory Actions:
facilities for No above inspection. On-site inspection and
failure ground enforcement plan
discharges Monitoring Additional Corrective
from Frequency: Actions Required:
failing As part of customer Municipal court fines
septic complaints, plumbing for not correcting
systems inspections, and failing septic system
surveys.
Responsibility: Immediate Action
Robert Kuhn Plan:
Seyed Miri Follow Utility process
for correcting failing
septic systems.
Monitoring List Responsible
Location(s): Person:
Throughout the Seyed Miri and OSSF
Southwest C staff
Distribution System as
other inspections are
made.
Tracking:
SRs and monthly
report to the TCEQ.

20
 January 19, 2007

Table for the New Construction Hazard

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
At each Valve Critical Standard Method: Existing Corrective Actions:
site of operation Limit #1: specifications, Via telephone or radio Close valves to isolate
affected area.
new No Section 510. call. Speed memo/warning to
constructi unauthori contractor or verbal warning
on zed valve to inspector.
opening Special billing/fines.
or closing Monitoring Additional Corrective
Frequency: Actions Required:
Each occurrence.
Responsibility: Immediate Action
W&WW Dispatch. Plan:
Infrastructure Support. Close valve(s).
Monitoring List Responsible
Location(s): Person:
At the Dispatch Office Inspector or valve
crew.
Tracking: Through
SRs, work orders, or
log books.
Disinfection Critical AWWA Method: Existing Corrective Actions:
of water lines Limit #1: Standards and Visual or olfactory. Isolate main, disinfect, and
flush.
All water City standard Additional Corrective
Monitoring
mains to specifications Actions Required:
Frequency:
be
Each occurrence.
disinfecte
d prior to Responsibility: Immediate Action
On site inspector. Plan:
being
placed in • Isolate main
service • Flush
• Sample
• Issue Boil
Water Advisory

21
 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
Monitoring List Responsible
Location(s): Person:
Job site. Valve Crews,
Dan Pedersen
Tracking:
Water lab approval
letters.
Critical State Method: Existing Corrective Actions:
Limit #2: regulations, Grab samples Flush main and
All water AWWA resample. If necessary
mains to standards, and redisinfect.
have City SOPs Monitoring Additional Corrective
Frequency: Actions Required:
typical
COA Each new main.
water Responsibility: Immediate Action
(bacti and On site inspector. Plan:
free
chlorine Monitoring List Responsible
negative) Location(s): Person:
prior to Job site.
being Tracking:
placed Water lab approval
into letters.
service
Intact Critical Standard Method: Existing Corrective Actions:
Pressure Zone Limit #1: Operating SCADA tank or
Close valves to isolate
Boundaries No valves Procedures pressure point alarm affected area.
opened levels. Speed memo/warning to
between contractor or verbal warning
pressure to inspector.
zone Special billing/fines.
boundarie Monitoring Additional Corrective
Frequency: Actions Required:
s
Each occurrence.
Responsibility: Water Immediate Action
and Pumping Division Plan:
Close valve(s).

22
 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
Monitoring List Responsible
Location(s): Person:
South First Street Inspector or valve
Office. crew.
Tracking: Through the
SCADA system.
No Critical One-Call Law Method: Existing Corrective Actions:
contractors to Limit #1: requirements in Visual – markings on
Job site shut down.
accidentally Contracto place except for the ground. Speed memo/warning to
hit water rs to emergencies. contractor.
mains while contact Contractor’s Special billing/fines.
performing One-Call responsibility Monitoring Additional Corrective
their work prior to to locate Frequency: Actions Required:
conductin underground Each occurrence and
g work. utilities and periodically
renew One-Call throughout the project.
ticket every 30 Responsibility: Immediate Action
days. A Project Inspector. Plan:
general
construction Monitoring List Responsible
notes Location(s): Person:
requirement Job site.
Tracking:
An access database.
Inspector Critical Standard Method: Existing Corrective
Training Limit #1: operating Attendance sign in Actions: None, course
Inspectors procedures sheets. attendance is
to have voluntary.
essential Monitoring Additional Corrective
knowledg Frequency: Actions Required:
e to Annually at each bacti
perform sampling training
their session.
work. Responsibility: Immediate Action
Water Quality Plan:
Manager – Dan
Pedersen.

23
 January 19, 2007

Critical Control Critical Validation Monitoring Corrective Action

Control Measure Limits (Step 8) (Step 9) (Step 10)
Point (Step 6) (Step 8)
(Step 7)
Monitoring List Responsible
Location(s): Person:
Bacti sampling
training session
classroom.
Tracking:
Attendance sign in
sheets.

STEP 11 – VALIDATE/VERIFY HACCP PLAN

The HACCP plan was validated at meetings on August 15 and 28, 2003 by members of the HACCP
Team. Additional validation was done with inspection staff and staff of the On-Site Sewage
Facilities Division.

STEP 12 – ESTABLISH DOCUMENTATION AND RECORD KEEPING

Tracking of monitoring of the critical limits is shown in the cross-connection hazard and new
construction hazard tables.

24
 January 19, 2007

Attachment A – Process Flow Diagram

25
 January 19, 2007

Attachment B – List of Streets in the Southwest C Pressure

Zone

Street Block Street Block

Acton Drive Medicine Creek

Drive
Anchusa Trail Midwood Parkway
Arroyo Canyon Mowinkle Cove
Black Mountain Cove Mowinkle Drive
Black Mountain Drive Murmuring Creek
Drive
Blue Hill Drive Nandas Trail
Boling Drive Oak Valley Road
Bright Star Lane Old Bee Caves Road 8700
Candelaria Drive Phoenix Pass
Chiplea Cove Pitter Pat Lane
Cima Circle Putnam Drive
Circle Drive Rawhide Trail 10100-
10700
Claxton Drive Rehobeth Circle
Clear Night Drive Rehobeth Cove
Cobble Stone Rising Smoke Loop
Conifer Cove Roaring Springs
Cove
Copper Path Roaring Springs
Drive
Covered Bridge Roaring Springs
Cove Road
Covered Bridge Rockwood Circle
Drive
Crackling Creek Rosson Drive
Drive
Crest View Road Sam Carter Drive
Dawning Court Samuel Bishop Drive
Deer Haven Road San Diego Road
Distant View Drive San Juan Pass
Dorella Lane Scenic Brook Drive 7900-8100
El Dorado Drive South Bend Avenue
El Rey Boulevard 8400-9300 Southview Road
Espanola Trail State Hwy 71 West 8700-
11000
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 January 19, 2007

Feather Hill Road Streamside Drive

Felts Lane Summer Sky Drive
Fenton Drive 8600-8800 Sunset Ridge
Foggy Mountain Superview Drive
Drive
Fort Benton Drive Thomas Springs
Road
Granada Hills Drive 8400-9000 Thomas Wood Lane
Haskel Drive Thunderbird Cove
Hudson Loop Thunderbird Road
Indian Scout Trail Towana Circle
Jay Creek Cove Towana Trail
Kathleen Drive Trenton Drive
Kingston Drive US Hwy 290 7700-8600
La Fauna Path Weir Hills Road 5800
La Fauna View West Creekview
Drive
La Tosca Drive West View Road
Lauralan Drive Williamson Creek
Drive
Lenape Cove
Lenape Trail

27
 January 19, 2007

Attachment C – Southwest C Pressure Zone Map

28