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]
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