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Tech Services - INAC
Procedure for Addressing Procedure for Addressing DWAs and Other NewsDWAs and Other News
OFNTSC MeetingRama, Ontario, October 11, 2007
Presentation by: S. Crystal & J Steeves
News from INAC HQ
PRESENTATION OUTLINE Drinking Water Protocol &
Provincial Regulations Procedure for Addressing DWAs Wastewater Protocol Circuit Rider Training Program National Assessment Summary
News from INAC HQ
Drinking Water Protocol & Provincial
Regulations
Protocol for Safe Drinking Waterin First Nations Communities
The “Protocol for Safe Drinking Water in First Nations Communities” is a set of long-awaited, clear standards for the design, construction, operation, maintenance, and monitoring of First Nations drinking water systems.
The Protocol was developed over a period of 2+ years with input from: INAC regions; OGDs; and First Nations water experts
(including the OFNTSC and Alberta’s Technical Services Advisory Group).
Protocol for Safe Drinking Waterin First Nations Communities
INAC reviewed the regulatory frameworks of all Canadian jurisdictions to identify a set of best regulatory practices.
This body of best practices was then "First Nation-ized" to be appropriate to the scale and context of drinking water systems in use in Canada's First Nations
Protocol for Safe Drinking Waterin First Nations Communities
ImplementationAs of March 21st, 2006, as per the
Minister's announcement, the Protocol was implemented immediately by INAC Regions and by now all First Nations should be complying with its requirements.
Highlights of the DW Protocol
Application:The Protocol applies to any First Nation
drinking water system that:– Is funded in whole or part by INAC; &– Serves five or more households (or a
publicly-owned facility).
Highlights of the DW Protocol
Design Requirements:Design standards for FN water systems
will be as set out in:
“Design Guidelines for
First Nations Water Works”
Highlights of the DW Protocol
Performance Requirements:Drinking water must meet the water
quality criteria set out in the latest edition of Health Canada’s “Guidelines for Canadian Drinking Water Quality” (GCDWQ)
Highlights of the DW Protocol
Monitoring Requirements:The Protocol specifies three types
of monitoring: Operational monitoring QA/QC monitoring Third party monitoring
Highlights of the DW Protocol
Monitoring Requirements:Operational monitoring is conducted
by the operator and includes daily and weekly water quality tests of: Raw water Treated water, and Distribution system water.
Highlights of the DW Protocol
Monitoring Requirements: (cont’d)Historically some First Nations have
relied solely on weekly water quality testing (at the tap only) performed by Health Canada.
Operators should undertake regular Operational monitoring.
Highlights of the DW Protocol
Training & Certification:Operators must be trained and
certified to the level specified by provincial operator certification requirements for their classification of system.
Highlights of the DW Protocol
Record Keeping:Water system operators and
managers must keep on file all records related to required water quality monitoring, operations, and system maintenance for a period of not less than 5 years.
Highlights of the DW Protocol
Annual Inspections:Inspections to verify system
performance must be completed annually by a qualified inspector as set out in:
“Guide for Annual Inspections of First Nations Drinking Water Systems” (Appendix H of the Protocol)
Highlights of the DW Protocol
Annual Inspections (cont’d):Annual inspection reports are a
collaborative process involving all stakeholders (including the Circuit Rider Trainer) and concentrate on water system performance and whether the water is safe to drink.
Highlights of the DW Protocol
Annual Inspections (cont’d):System performance will be assessed
based on: Water quality testing results (as
provided by HC and FN); Operational procedures; and Operator certification level in
relation to system classification.
Highlights of the DW Protocol
Highlights of the DW Protocol
ComplianceFirst Nations need to meet the more
stringent of either: The Protocol’s requirements; or Provincial standards
Highlights of the DW Protocol
Compliance (cont’d)This means that if an element in a
provincial standard (e.g. turbidity) is more stringent than the same element in the Protocol, then that higher objective should be adhered to in that region.
The rest of the Protocol still applies.
Highlights of the DW Protocol
Compliance (cont’d)It is not possible for a region or for a
First Nation to opt out of the Protocol.
Highlights of the DW Protocol
Compliance (cont’d)Compliance with the Protocol is
part of the terms and conditions of all funding agreements between the Government of Canada and First Nations.
To date, implementation of the Drinking Water Protocol has been disappointing.
Protocol Implementation
Implementation of the Protocol by INAC Regions began March 21st, 2006, as per the Minister’s directive.
Thus, by now (1 ½ years later) most First Nations should be complying with the Protocol’s requirements.
Protocol Implementation
Protocol Implementation
Unfortunately, many operators do not have a copy of the Protocol, or have not read it, or do not understand their responsibilities.
Protocol Implementation
More action is needed to improve uptake of the Protocol by operators.
Protocol Implementation
There are some basic questions that need to be answered: What percentage of First Nations
operators actually have a copy of the Protocol?
What percentage understand the Protocol’s requirements and comply with them?
The Protocol is a “living document” and will be refined continuously to reflect feedback from First Nations practitioners.
The latest version of the Protocol can be found at INAC’s web site:
http://www.ainc-inac.gc.ca/H2O
Protocol for Safe Drinking Waterin First Nations Communities
First Nations Drinking Water and Provincial Regulations
Why adopt provincial regulations?
Compliance with the Protocol is achieved through terms and conditions of funding agreements between the Government of Canada and First Nations (i.e.: no laws exist to enforce compliance with the Protocol).
First Nations Drinking Water and Provincial Regulations
Why adopt provincial regulations?
The government does not consider this to be an effective way to ensure compliance or to foster accountability between Band Councils and their citizens.
First Nations Drinking Water and Provincial Regulations
What might the government do?
To provide First Nations residents with the same protection that is enjoyed by most Canadians, the government is considering enacting legislation that will apply provincial water regulations to First Nations water systems.
First Nations Drinking Water and Provincial Regulations
What will this accomplish?
The intention would be to provide First Nations with a regulatory regime that is enforced by laws, rather than terms of funding agreements.
First Nations Drinking Water and Provincial Regulations
How would regulations be adopted?
First Nations water systems would become subject to provincial regulations after they are adjusted to the context of First Nations communities.
The requirements of the DW Protocol will continue on as a minimum baseline standard.
First Nations Drinking Water and Provincial Regulations
How would regulations be enforced?Provincial regulations on reserve are
expected to be enforced by provincial agencies.
First Nations Drinking Water and Provincial Regulations
Will there be penalties?Yes. There will be both monetary
penalties (fines) and punitive penalties (jail time) for non-compliance with provincial regulations.
First Nations Drinking Water and Provincial Regulations
Will all Fist Nations be regulated?Yes. In provinces where the provincial
regulatory regime is deemed inadequate, the Drinking Water Protocol will be the base level of standards upon which provincial regulations will be adjusted before adoption by INAC.
First Nations Drinking Water and Provincial Regulations
When will this happen?The process of adapting and adopting
provincial regulations for use in First Nations is expected to take 4 to 5 years.
Implementation of the new regulations is expected to take an additional 3 to 5 years.
First Nations Drinking Water and Provincial Regulations
And until then ….?The Drinking Water Protocol will
continue to apply in all First Nations across Canada until it is replaced (if ever) by provincial regulations.
News from INAC HQ
PRESENTATION OUTLINE Drinking Water Protocol and Provincial
Regulations Procedure for Addressing DWAs Wastewater Protocol Circuit Rider Training Program National Assessment Summary
News from INAC HQ
Procedure for
Addressing DWAs
Problems with DWAsThe number and the duration of Drinking
Water Advisories (DWAs) in First Nations communities has become a chronic public safety problem in some First Nations.
Background on DWAs in First Nations Communities
According to data from Health Canada, as of November 2, 2006, more than 100 DWAs were in effect in First Nations communities across Canada.
Of these 100 DWAs: 63% are more than 1 yr old 45% are more than 2 yrs old One DWA was in place for more
than 21 years.
Background on DWAs in First Nations Communities
In 2006, HC completed a survey on DWAs. The following are some conclusions of the study: Drinking Water Advisories are ineffective:
If they are not fully understood; If they are frequent, on-going, or
excessively long-term. If the causes of DWAs in First Nations
communities are not addressed effectively, serious health problems can result.
Background on DWAs in First Nations Communities
In 2005, the Drinking Water Advisory Working Group (also known as the DWAWG team) was formed to develop a procedure to help First Nations address their DWAs.
The DWAWG team had members from: Health Canada HQ and regions; INAC HQ & regions; and First Nations (including technical services
providers like OFNTSC).
Background on DWAs in First Nations Communities
The DWAWG has developed a procedure entitled:
“Procedure for Addressing Drinking Water Advisories in First Nations Communities South of 60° (Procedure)”
The Procedure is to be rolled out nation-wide this Fall at eight regional awareness sessions.
Background on DWAs in First Nations Communities
The procedure will assist First Nations to address their DWAs more quickly by: Clarifying roles & responsibilities; and Developing community-based water
team (CBWT).
Background on DWAs in First Nations Communities
The DWAWG undertook an extensive process of obtaining feedback from stakeholders to complete the final draft of the Procedure.
In July/August 2006, the draft Procedure was distributed to INAC regional managers for comment. HC also distributed the draft to its regions and selected First Nations for comments.
Background on DWAs in First Nations Communities
Most (if not all) comments received were addressed by changes incorporated into the final Procedure.
The Procedure will be a living document, regularly updated as needed.
Background on DWAs in First Nations Communities
Application
The Procedure will apply to all INAC-funded First Nations drinking water systems where effective procedures to address DWAs do not already exist.
Highlights of the Procedure
Basic Approach
The Procedure is a step-by-step guide to help First Nations address the underlying causes of DWAs in their communities.
The Procedure is intended for use by Chief and Council which will chair a new local group, called a Community-Based Water Team (CBWT), that will advise Chief and Council on how best to efficiently address a DWA.
Highlights of the Procedure
Basic Approach: (cont’d)The main task of the CBWT is to advise Chief and
Council and to help co-ordinate efforts to lift a DWA.
When a DWA is issued, it is the responsibility of Chief and Council to activate and chair the CBWT and obtain its advice on lifting the DWA.
Highlights of the Procedure
Membership of the CBWT
Representatives from: First Nations (Chief, Council, operator, …) Tribal Councils, tech. services orgs. INAC (capital and engineering) HC (ex: EHO) CRTP
Highlights of the Procedure
Formation of the CBWT
Chief and Council should recruit the membership for a CBWT well before a DWA is issued and train team members on how to use the new Procedure.
Highlights of the Procedure
Formation of the CBWT
Chief and Council should also: Maintain a list of CBWT members; and Organise a teleconference with the
CBWT periodically to address issues that could affect the safety of the drinking water supply.
Highlights of the Procedure
Steps to follow
The steps to be followed by Chief and Council and the CBWT to address a DWA issue are presented in the following flow chart …
Steps to address a DWA
Procedure to address DWAs
Drinking Water
Advisory Issued
Option 1
C&C address/lift DWA in 3-4 days and advise HC and INAC.
Option 2
Option 3
C&C or designate develop
action plan
C&C or designate
submit action plan to INAC
& HC for review *
INAC & HC review action plan
**
Action plan is
complete?
C&C or designate implement action plan
and lift DWA
YES
C&C or designate activate CBWT to aid in development
of action plan
With advice from CBWT, C&C or designate develop
action plan within 2 business days of DWA being issued.
C&C or designate implement action plan and lift DWA
NO
* - To be developed within 2 business days of DWA being issued** - To be reviewed and returned within 2 business days of receipt
Option 1
Drinking Water
Advisory Issued
Option 2
Option 3
C&C or designate develop
action plan
C&C or designate
submit action plan to INAC
& HC for review *
INAC & HC review action plan
**
Action plan is
complete?
C&C or designate implement action plan
and lift DWA
YES
C&C or designate activate CBWT to aid in development
of action plan
With advice from CBWT, C&C or designate develop
action plan within 2 business days of DWA being issued.
C&C or designate implement action plan and lift DWA
NO
Option 1
C&C address/lift DWA in 3-4 days and advise HC and INAC.
* - To be developed within 2 business days of DWA being issued** - To be reviewed and returned within 2 business days of receipt
Option 2
Drinking Water
Advisory Issued
Option 1
C&C address/lift DWA in 3-4 days and advise HC and INAC.
Option 3
C&C or designate activate CBWT to aid in development
of action plan
With advice from CBWT, C&C or designate develop
action plan within 2 business days of DWA being issued.
C&C or designate implement action plan and lift DWA
Option 2
C&C or designate develop action plan
C&C or designate
submit action plan to INAC &
HC for review *
INAC & HC review action
plan **
Action plan is
complete?
Action plan is
complete?
NO
YES
C&C or designate
implement action plan
and lift DWA
* - To be developed within 2 business days of DWA being issued** - To be reviewed and returned within 2 business days of receipt
Option 3
Drinking Water
Advisory Issued
Option 1
C&C address/lift DWA in 3-4 days and advise HC and INAC.
Option 2
C&C or designate develop
action plan
C&C or designate
submit action plan to INAC
& HC for review *
INAC & HC review action plan
**
Action plan is
complete?
C&C or designate implement action plan
and lift DWA
YES
NO
Option 3
C&C or designate activate CBWT to
aid in development of
action plan
With advice from CBWT, C&C or designate
develop action plan within 2 business days of
DWA being issued.
C&C or designate
implement action plan
and lift DWA
Intervention (if necessary)
Step 1 – INAC and HC approach Chief & Council to encourage that immediate action be taken to address the DWA situation.
This will take care of most cases according to HC.
Procedure to address DWAs
Intervention (if necessary)
Step 2 – If Step 1 is unsuccessful and public health is at risk, INAC has the authority, as set out in terms and conditions of funding agreements with FNs, to take action to remedy the situation. This can include:
Developing an action plan Activating the CBWT Implementing the action plan
Procedure to address DWAs
News from INAC HQ
PRESENTATION OUTLINE Drinking Water Protocol Procedure for Addressing DWAs
Wastewater Protocol Circuit Rider Training Program National Assessment Summary
News from INAC HQ
Wastewater Protocol
Existing Wastewater Quality StandardsAll effluents discharged on Federal lands
must meet the quality objectives set out in Environment Canada’s 1976 “Guidelines for Effluent Quality and Wastewater Treatment at Federal Establishments”
Essentially these guidelines require at least secondary-level treatment for wastewater.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
INAC’s StandardThe 1976 EC Guidelines are INAC’s
departmental standard for wastewater and apply to all INAC facilities and to First Nations wastewater systems.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
New Wastewater ProtocolINAC has now developed a draft protocol
for the treatment and disposal of wastewater in First Nations communities.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
Protocol RequirementsThe new wastewater protocol specifies
requirements for: Minimum treatment (1976 Guidelines) Design and construction Operations & maintenance Monitoring Record keeping, and reporting.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
Review & FeedbackThe first draft of a new wastewater protocol
has been sent out for stakeholder review and we are now awaiting comments: INAC regions Environment Canada First Nations technical organisations
(TSAG, OFNTSC).
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
Evolution of the ProtocolThe Protocol will be revised and refined
to reflect all comments.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
New RegulationsOver the past two years, Environment
Canada has been developing new regulations for Municipal Wastewater Effluent (MWWE) to be enabled under the Fisheries Act.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
Purpose of the New RegulationsThe main purpose of the regulations is
to ensure, Canada-wide, a harmonized minimum standard for MWWE discharges.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
Canada-Wide AdoptionThrough the Canadian Council of
Ministers of the Environment (CCME), the new Fisheries Act regulations, which will apply on and off reserves, will be duplicated in all provincial and territorial regulations that concern wastewater effluent.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
No Big ChangesThe new regulations essentially
propose a minimum standard of secondary-level treatment for wastewater.
In other words, they are essentially the same as the 1976 Guidelines.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
Consultation Environment Canada provided
information to First Nations through various venues (AFN water forum, workshops).
EC is also planning a consultation process with First Nations for the next couple of months.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
Adoption of the New RegulationsWhen Environment Canada’s finalises
and adopts the new regulations, INAC will incorporate them into the Wastewater Protocol.
Until then, the Protocol will continue to specify the 1976 Guidelines.
Protocol for Treatment & Disposal of Wastewater in First Nations Communities
News from INAC HQ
PRESENTATION OUTLINE Drinking Water Protocol Procedure for Addressing DWAs Wastewater Protocol
Circuit Rider Training Program National Assessment Summary
News from INAC HQ
Circuit Rider Training Program
Circuit Rider Training Program (CRTP)
The Circuit Rider training Program has proven to be good value for money.
In March 2007, INAC brought together Circuit Riders from across Canada to share ideas on how to improve the program.
INAC is acting on these ideas.
Circuit Rider Training Program (CRTP)
At the meeting, we also took a survey to get more information about how the Circuit Rider program is delivered in different areas. There were some interesting findings …
Circuit Rider Training Program (CRTP)
Regions with full coverage and realistic work loads for CRTs, had the fewest DWAs and other problems.
Circuit Rider Training Program (CRTP)
At the meeting, we also took a survey to get more information about how the Circuit Rider program is delivered in different areas. There were some interesting findings …
Circuit Rider Training Program (CRTP)
INAC is acting on these findings:
1. Best practices being recommended for adoption by all regions.
2. Funding being increased.
3. Coverage being expanded.
News from INAC HQ
PRESENTATION OUTLINE Drinking Water Protocol Procedure for Addressing DWAs Wastewater Protocol Circuit Rider training Program
National Assessment Summary
News from INAC HQ
National
Assessment
National Assessment
INAC is in the process of starting a national assessment of all First Nations drinking water and wastewater systems.
National Assessment
To ensure consistency and comparability between regions, detailed terms of reference for the national assessment are being drafted now.
It is expected that the assessment, which is to commence in the next 3 to 5 months, will take about 2 years to complete.
National Assessment
The assessment will identify the risk levels for all systems as well as provide cost estimates to build or upgrade, operate, and maintain water and wastewater systems to meet Departmental standards.
National Assessment
The assessment will also include a serviceability analysis (for public- and private-system residents).
News from INAC HQ
PRESENTATION OUTLINE Drinking Water Protocol Procedure for Addressing DWAs Circuit Rider training Program National Assessment
Summary
News from INAC HQ
Summary
To Summarise theDrinking Water Protocol
The Protocol for Safe Drinking Water in First Nations Communities:
1. In effect since March, 2006
2. Required under the terms and conditions of funding agreements.
3. Needs ongoing feedback from water system operators.
To summarise theProcedure for Addressing DWAs
The Procedure for Addressing DWAs: 1. INAC and HC are developing plans
to implement the new procedure in each region.
2. INAC and HC regional representatives will need to meet with Chiefs & Councils to implement the new procedure by the end of this winter.
To Summarise theWastewater Protocol
The Protocol for Treatment & Disposal of Wastewater in First Nations Communities:
1. Currently uses on EC 1976
2. Will use new regulations when they are finalised
To summarise theCircuit Rider Training Program
The CRTP:
1. Has proven to be one of INAC’s best investments
2. Funding is being increased so that the CRTP is expanded and sustained in the long-term.
To Summarise theNational Assessment
The National Assessment of First Nations water and wastewater systems:
1. Will begin in next fiscal year
2. Will require two years to complete and generate reports.
High-Risk Systems Reduction: From 207 high-risk water systems
in 2002, we are now down to only 97 high-risk systems this summer.
The minister’s objective now is to reduce the number of high-risk systems to 45 or fewer by the end of this year.
Progress to date under the FNWMS
High- & Medium Risk Systems:Five risk factors are used to calculate
the Overall Risk Score of a water system: Source risk Design risk Operations & Maintenance Risk Operator risk Record keeping & reporting risk
Progress to date under the FNWMS
High- & Medium Risk Systems:To calculate the overall score, a weight
is assigned to each risk factor: Source risk (10%) Design risk (30%) Operations & Maintenance Risk (30%) Operator risk (20%) Record keeping & reporting risk (10%)
Progress to date under the FNWMS
High- & Medium Risk Systems:
Progress to date under the FNWMS
6.2 2 2 9 9 9
Overall Risk
SourceWater
Design Risk
Operations &Maintenance
Record Keeping
OperatorCertification
High- & Medium Risk Systems:
Progress to date under the FNWMS
2.8 10 2 2 2 2
Operations &Maintenance
Record Keeping
OperatorCertification
Overall Risk
SourceWater
Design Risk
Questions?
Jim Steeves, P.Eng.Water Resources Engineer
Infrastructure & Housing Directorate
Indian & Northern Affairs Canada
10 Wellington St., Gatineau, QC, K1A 0H4
Phone: (819) 994-7226
E-mail: steevesj@inac.gc.ca
News from INAC HQ
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