Introduction
1. What is your name?
First Name
Heather
Surname
Uwins-England
2. What is your email address?
Email
heather@ihengland.com
4. Are you providing feedback as an individual or on behalf of an organisation?
Please select one item
(Required)
Radio button:
Ticked
As an individual
Radio button:
Unticked
On behalf of an organisation or group
6. Which of the options below best describes you?
Please select one item
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Unticked
Individual water drinker / consumer
Radio button:
Unticked
Registered drinking water supplier (excl marae) – registered either under the Health Act 1956 or the Water Services Act 2021
Radio button:
Unticked
Unregistered drinking water supplier (excl marae)
Radio button:
Unticked
Other commercial user of water
Radio button:
Unticked
Stakeholder representative / industry body
Radio button:
Unticked
Iwi representative organisation
Radio button:
Unticked
Marae
Radio button:
Unticked
Health professional
Radio button:
Unticked
Laboratory
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Unticked
Local Authority or Council Controlled Organisation
Radio button:
Unticked
Regional Council
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Unticked
Central government agency
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Local interest group
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Ticked
Other
Summary of proposed Drinking Water Standards
18. Do you want to submit a prepared response?
Please select one item
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I want to submit a prepared response but not answer the remaining questions
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Ticked
I want to submit a prepared response and answer the remaining questions
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I do not want to submit a prepared response but want to answer the remaining questions
Closing page
45. If you want to provide any additional feedback on any MAV please provide this here:
Additional feedback on any MAV:
Drinking Water Standards
Page 1: “The MAVs for any determinand should not be exceeded at any time”.
This statement implies that drinking water would be unsafe if an exceedance was to occur.
This is incorrect for chemical determinands. Chemical MAVs can be exceeded occasionally,
and the water remain safe to drink. As MAV’s are based on a lifetime consumption and are
conservatively set, minor occasional exceedances DO NOT impact on public health. Although
every exceedance should be reported and acted upon, it would be far better to measure
compliance to MAVs and the ability to supply safe drinking water by using a rolling annual
average rather than on single samples. Determining compliance to standards based on
individual sample results could very easy result in a supplier being deemed non-compliant
but whilst continually providing safe drinking water to its customers. This will be an
unfortunate outcome.
Table 1: MAVs for Microbial Determinands.
Consider including “human pathogenic bacteria and viruses” as a determinand with a MAV
of less than 1 in 100mL of sample or not detected. Although pathogenic bacteria and viruses
are not routinely monitored, individual pathogens may be monitored during an event or a
suspected or confirmed outbreak. This inclusion will give a clear message that any
pathogenic bacteria or viruses should not be present in drinking water and is a breach of the
standards. If human pathogenic bacteria and viruses are not included, there is potential for
a drinking water supplier to be providing unsafe water but still be deemed compliant with
standards.
Table 2: MAVs for Inorganic Determinands.
The Ministry of Health made recommendations to Taumata Arowai last year that the MAV
for Lead should be reduced to 0.005 mg/L. The World Health Organisation recognises that
there is no ‘safe’ level of lead in drinking water which supports the reduction of the MAV for
lead 0.005 mg/L. The Ministry of Health’s advice to reduce the MAV for lead to 0.005 mg/L
should be incorporated into the new standards as a matter of urgency.
Page 1: “The MAVs for any determinand should not be exceeded at any time”.
This statement implies that drinking water would be unsafe if an exceedance was to occur.
This is incorrect for chemical determinands. Chemical MAVs can be exceeded occasionally,
and the water remain safe to drink. As MAV’s are based on a lifetime consumption and are
conservatively set, minor occasional exceedances DO NOT impact on public health. Although
every exceedance should be reported and acted upon, it would be far better to measure
compliance to MAVs and the ability to supply safe drinking water by using a rolling annual
average rather than on single samples. Determining compliance to standards based on
individual sample results could very easy result in a supplier being deemed non-compliant
but whilst continually providing safe drinking water to its customers. This will be an
unfortunate outcome.
Table 1: MAVs for Microbial Determinands.
Consider including “human pathogenic bacteria and viruses” as a determinand with a MAV
of less than 1 in 100mL of sample or not detected. Although pathogenic bacteria and viruses
are not routinely monitored, individual pathogens may be monitored during an event or a
suspected or confirmed outbreak. This inclusion will give a clear message that any
pathogenic bacteria or viruses should not be present in drinking water and is a breach of the
standards. If human pathogenic bacteria and viruses are not included, there is potential for
a drinking water supplier to be providing unsafe water but still be deemed compliant with
standards.
Table 2: MAVs for Inorganic Determinands.
The Ministry of Health made recommendations to Taumata Arowai last year that the MAV
for Lead should be reduced to 0.005 mg/L. The World Health Organisation recognises that
there is no ‘safe’ level of lead in drinking water which supports the reduction of the MAV for
lead 0.005 mg/L. The Ministry of Health’s advice to reduce the MAV for lead to 0.005 mg/L
should be incorporated into the new standards as a matter of urgency.