AKBLG Business Meeting: IHA Small H20 Systems

Interior Health
Small Water Systems
Strategic Plan
J. Ivor Norlin, Manager of Infrastructure Programs
AKBLG Annual Conference
Creston, April 11th, 2014
Health Protection
Less Risk ~ Better Health
Interior Health Region
• ~850km across
• ~742,000 full-time residents
IH Health Protection
•
~110 staff, 6 managers
• ~1,930 permitted water supplies
• ~1,200 rec water facilities
•
~850 personal service
establishment
• ~975 community care facilities
• ~6,175 food facilities
• Incident & emergency response
Small System – Strategic Plan
• Being accountable for what we do (Fall 2012)
• Large Water Systems Program – strategic plan (2012/13)
• Small Water Systems Program – strategic plan (2013/14)
Why? You already have a drinking water plan.
Health Protection
Less Risk ~ Better Health
Is small water really different?
Criteria
# of systems
IH population served
# on Boil Water Notice
IH-HP service model
Owners
Health Protection
•
•
•
•
•
•
•
•
•
•
•
Small Water Systems
1,800
<20%
~350
~35 EHO, 5 supervisors
Local governments
Federal/Provincial government
Improvement Districts
Private Utilities
School Districts
Shared Interest
Strata Corporations
Water Users Communities
Private businesses
Societies
“Good neighbours”
Less Risk ~ Better Health
•
•
•
•
Large Water Systems
123
>80%
~3
5 specialist EHO, 1 supervisor
Local governments
Federal/Provincial government
Improvement Districts
Private Utilities
IH Small Systems Program
Multiple Barriers of Protection (2009)
Boil Water Notice Remediation Program (2010)
IH Small Systems Program
Small Systems – Looking Forward
Strategic Options:
1. Do nothing
2. Do the same
3. Change focus by:
a) enhancing compliance & enforcement
b) enhancing outreach & education
Opportunities
Strengths
1.
Knowledge and one-on-one relationships some staff have built with operators, service
providers, industry, and government agencies in their respective areas; having a solid
grasp on what they are capable of achieving and a link to the community
2. EHO proximity to individual systems
3. EHO training and ability to handle a diverse workload
4. Engineering Direct
5. Internal communications regarding public notifications (e.g. Outlook notification, dated
notes)
6. Timely, high quality decisions in responding to bad samples and emergencies … public
health ethic and sense of duty to the public to reduce risk for communities
7. Working relationship between operations & program planning staff (e.g. backing each
other up in demand; support documents)
8. Boil Water Notice Remediation and Multiple-Barriers materials supporting consistent
message
9. Collaborative, “team approach” between EHO and PHE
10. Flexibility to address total water system, investing in education/advocacy to implement
step-wise improvements that provide greatest risk reduction
11. Evaluations (Ombudsperson & PHO Reports; Edwards et al., 2012) of small systems
12. Funds to supplement water system testing … provides tangible contributions & outcomes
1.
2.
3.
4.
5.
6.
7.
8.
9.
Phase 1: Internal Consultation
1.We can do better
Weaknesses
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
10.
11.
12.
13.
Innate credibility of public health agency/service provider
New data system coming on-line
Provincial & regional committees (e.g. EH policy; DWLC;
BCWWA)
Partnerships with industry, academia, and local governments
Recent successes (e.g. Laird Water Improvement District)
Communications (e.g. newsletter; time with SET & Board)
Knowledge built-up in local service providers and industry to date
Demonstrated education/advocacy (i.e. through COPs) … first
stage of Mandate Continuum
Clustering and focusing based on proximity, issues, &/or service
(e.g. Osoyoos area systems, Water User Communities;
enforcement)
Financial better practice resources with coordinated grant &/or
financing options for small water systems
New Regional Drinking Water Team structure
Flexibility in legislation for process and to reduce risk (e.g. waiving
Construction Permits; applying step-wise, staged improvement;
using non-certified treatment devices)
Focused education/advocacy initiatives (e.g. financial practices;
health risk & risk management)
Water safety planning approach to guide operators
Ticketing and other financial penalties
2. Focused investment to raise awareness,
skills, &
14.
Information management systems (e.g. limited use of , lack of confidence in)
Enforcement skills & resources; slow to engage in progressive compliance, lack of clear,
consistent vision as to apply progressive enforcement action to gain compliance across
Interior Health … where are we going and what are we all willing to do to get there?
Lack of clarity, continuity and accountability for program goals, objectives, and outcomes
… staff feel they are operating in isolation
Do not have clear business rules/process ; process can be obtrusive overwhelming the
technical & bureaucratic capacity of small water system owners/operators
Recording & reporting (e.g. capturing of EHO work activities; exchange of information)
Limited ability to effect watershed management
Matrix approach … historic issues with separate operations & programming when
disagreement on design/priorities and/or poor communications
Historic focus on legislative requirements (e.g. sampling) instead of risk reduction
Lack defensible, broadly accepted criteria/tool for assessing, tracking, and reporting risk
Discontinuity in service with high staff turnover, long periods between inspections & lack
of engagement in some cases, lack of historic PHE involvement in many files
Loss of WQTS involvement with large clients (e.g. BC Parks; local governments)
Limited depth of knowledge a generalist EHO can have regarding water systems
(especially regarding governance, ownership, and financial better management practices)
Inconsistent standards … asking different levels of compliance from different systems
BWN program focuses only on how to achieve compliance , not how to demonstrate due
diligence or legitimate non-compliance
Orders are not a useful enforcement tool and ticketing is difficult with establishing
appropriate evidence
One-year timelines in BWN are not realistic ,.. if not wiling/able to enforce better to set
goals without specific timelines
Program materials are not useful … provide only an overview
15.
capacity (i.e. in suppliers, public, industry)
Threats/Challenges
1.
2.
Water system infrastructure deficits systemic in region
Inconsistent practice across province … spend much time
justifying the differences rather than enforcing expectations
3. Unclear mandate (Ombudsperson vs. IHA Audit vs. Min of
Finance vs. PHO vs. MoH)
4. Constant change in provincial and local government/politics and in
some cases direct interference/opposition to improvements
5. Lack of IH ‘Public Health’ (e.g. HP in a different portfolio than
MHO)
6. Resource restrictions (e.g. on travel; increased service demands)
7. Public perceptions & cultural norms (e.g. need for change in
treatment &/or operations; chlorination; regulation)
8. Inability and/or reluctance to implement or pay appropriate fees
9. lack of financial support structure (e.g. information, training,
grants) for private and commercial systems to come up to current
standards
10. Small water system governance model in BC (e.g. MoE issues the
licences, we deal with the mess; volume of unregistered systems)
11. Limited technical capacity of private small water system operators
12. Profile of Health Protection; inability to effectively communicate
both in terms of absolute & relative (i.e. compared to the
neighbour) risk
Small Systems – Looking Forward
Strategic Options:
1. Do nothing
2. Do the same
3. Change focus by:
a) enhancing compliance & enforcement Secondary
b) enhancing outreach & education Primary
Phase 2: External Consultation
Do you agree with re-investing in education/advocacy?
Response
Yes
No
Percentage
Count
89%
11%
Total Responses
8
1
9
Where should IH focus resources?
Response
Enforcement
Education/advocacy
Percentage
10%
90%
Total Responses
Count
1
9
10
Phase 2: External Consultation
“We have an excellent relationship with [our EHO]. We appreciate our annual
meetings and the technical assistance and water quality results. We also appreciate
IHA picking up the costs of our monthly water testing and providing the results without
charge.”
“IH has done nothing to help improve small water systems.”
“Enforcement doesn’t seem to be working, so should probably only be used where
an extremely hazardous set of circumstances exists, as well as for all for-profit
systems (e.g. utilities).”
“ … [EHO] have a job to do and those of us involved in providing public
water also have a responsibility in providing safe drinking water”
“Focus on being a champion of safe drinking water, not simply a compliance
regulator.”
Small Systems – Looking Forward
Strategic Options:
1. Do nothing
2. Do the same
3. Change focus by:
a) enhancing compliance & enforcement Secondary
b) enhancing outreach & education Primary
Small Systems – Looking Forward
Strategic Goals:
1. Provide consistent, client focused health
protection services for small water supply
system owners, operators, and users.
2. Increase the knowledge and capacity of small
water system stakeholders to address
vulnerabilities and reduce risk.
Small Systems – Looking Forward
Program Objectives from Internal Scan:
1.
Move to a team approach with clear line of accountability from senior
management through to front line staff
2.
Develop IH-HP information and communication tools to facilitate monitoring and
reporting
3.
Undertake communications initiative to raise awareness, skills, and capacity of
key stakeholders
4.
Implement protocol for major incident/emergency response that includes
“lessons learned” process
Small Systems – Looking Forward
Program Objectives from External Scan:
1. Develop and implement standardized, comprehensive risk-based assessments
2. Coordinate technical assessments with local governments in support of costbenefit analyses and with available funding (e.g. provincial grant) cycles
3. Align regulatory approach and service goals/objectives with system type/size
(e.g. ownership/governance type; the UBCM small water system working group
proposed Nano, Micro, and Small sub-categories)
4. Create a safe drinking water task-force/committee composed of health officials,
industry representatives, and small water system users to advise on issues not
clearly defined by legislation
5. Employ a progressive approach to reducing risk (i.e. not just compliance)
Next Steps
-
Draft findings & recommendations to IH-HP management team
(May 8th)
-
Newsletter sharing findings & proposed recommendations
(May 31st)
-
IH-HP endorsement & recommendations to Medical Health Officers
(June 27th)
-
Final endorsement & begin implementation
(September 2nd)
4/10/2014
16
Thanks!!
250-833-4173
[email protected]