Recommendations for monitoring drinking water fountains

Summary of the BLAG guidelines for health authorities

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After many years of ambiguity, there has finally been a guide since January 2022 with recommendations specifically for the installation of public drinking water fountains for outdoor use.

The following are excerpts from the original BLAG Kleinanlagen document, the complete version is available at Guide for health authorities to find.

‍Editor of the document: Federal-Länder-Arbeitsgruppe “Kleinanlagen”/Umweltbundesamt Berlin 2021

The guide presents professional recommendations made to the best of our knowledge and belief. It does not replace a careful assessment of the suitability, appropriateness and proportionality of monitoring and any measures to be ordered by the health department.

shortcuts

op. r. d. t.: generally accepted rules of technology

BLAG small systems: Federal-Länder Working Group on Small Drinking Water Supply Systems

DVGW: German Gas and Water Association e.V.

IfSG: Act on the Prevention and Control of Infectious Diseases in Humans (Infection Protection Act)

LYE: Country Working Group on Environment-Related Health Protection

TrinkwV: Drinking Water Ordinance

USi: the entrepreneur or other owner of a water supply system

Background and purpose of the recommendation

According to a survey in July 2019, more than 1,300 drinking water fountains were operated in Germany, which were made available to the public for drinking and refreshment purposes. The number of plants in the federal states varied between 3 and 286 plants per federal state. According to these figures, around 60% of drinking water wells are in public places and around 40% in (public) buildings. Outdoor drinking water fountains are usually only operated seasonally due to weather reasons (frost). Due to the growing number, monitoring the systems is an increasing challenge for health authorities. Directive (EU) 2020/2184 of the European Parliament and of the Council of 16 December 2020 on the quality of water for human consumption (drinking water) (TW-RL) calls for - in response to the European Citizens' Initiative “Right2Water” initiated primarily from Germany - to improve access to drinking water and to promote the use of drinking water from the tap (e.g. by installing indoor and outdoor systems to extract drinking water in public places). As a result of the implementation of the TW-Directive, which must be completed by January 2023, the number of public drinking water fountains will continue to rise in the future.

Health policy in Germany strives for a uniform level of protection for the population and therefore includes all water supply systems — including drinking water fountains that are available to the public — in official monitoring.

The purpose of this guide is

· Recommendations regarding the practicable and safe operation of

to provide drinking water fountains,

· the authorities responsible for drinking water when implementing the Drinking Water Ordinance

regarding the monitoring of freely accessible drinking water fountainss in public

to support space and

· promote uniform administrative action in this regard,

so that the required level of health protection can be ensured with reasonable effort. This guideline was prepared on behalf of the state working group on environmental health protection (LAUG) by a sub-working group of the federal-state working group on small plants. It included representatives from the Federal Environment Agency, the Federal Ministry of Health, the Federal Ministry of Defence, the Berliner Wasserbetriebe and the health and environmental authorities of the federal states. The guide therefore takes into account a wide range of expertise and experience and is based on a broad consensus.

Scope and delimitation

Drinking water fountains that provide drinking water at the collection point are subject to the Drinking Water Ordinance (TrinkwV) and therefore to monitoring by the health department.

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Definition of drinking water fountain:

· are in public spaces,

· are located outside buildings,

· are freely accessible,

· are connected to an a, b or e system in accordance with TrinkwV,

· operate year-round or seasonally,

· from which drinking water is provided and

· the removal of persons from an alternating, indiscriminable group of

drinking water is used.

Drinking water fountains are not defined as an independent water supply system in TrinkwV. The term drinking water fountain is often used colloquially. In consultation with the DVGW, BLAG Kleinanlagen has opted for the term “drinking water fountain” to emphasize that drinking water is dispensed from these fountains.

Drinking water fountains are either

· to a pipeline network of a central waterworks in accordance with Section 3 paragraph 2 letter a TrinkwV (“a-Anlage”),

· to a decentralized small waterworks in accordance with § 3 paragraph 2 letter b TrinkwV (“b-Anlage”)

or

· connected to a drinking water installation (“e-system”).

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If drinking water fountains (permanently) provide drinking water all year round, these are to be classified as systems in accordance with § 3 number 2 letter e TrinkwV (“e-Anlage”). If drinking water is only released seasonally (temporarily) from the appliance, it is a system in accordance with § 3 number 2 letter f TrinkwV (“f-Anlage”).

The USi of the drinking water fountain is responsible and duties for operating and complying with the requirements.

Drinking water dispensers or outlets within public buildings are not covered by this recommendation.

Distinction from food law

Piped water dispensers, which are attached to the drinking water pipe behind a safety device and provide carbonated water, for example, as well as free-standing, non-wired water dispensers, from which the water is dispensed from a container, are not subject to the TrinkwV regulations. Instead, water food legislation is subject to: Regulation (EC) No 178/2002; Food Supplies and Feed Code (LFGB); where applicable, the Mineral and Table Water Regulation, Regulation (EC) No 852/2004, Food Hygiene Regulation (LMHV) 1.

Technical requirements

The technical requirements for drinking water fountains can be found in the technical regulations, in particular the DVGW fact sheet W 274 — Planning, construction and operation as well as self-inspection of public drinking water fountains (working title, white printing planned for 2022) 2.

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Statutory basis

Drinking Water Ordinance (TrinkwV)

Section 3 No. 2 e)  Continuous water distribution systems: drinking water systems

Installation from which drinking water from a plant referred to in letter a

or letter b is delivered to consumers;

Section 3 No. 2 f)  Installations for temporary water distribution: systems comprising

drinking water is withdrawn or delivered to consumers, and the

temporarily to an attachment under letter a, b or letter e

are connected.

- Allocation of drinking water fountains

Drinking water fountains are to be regarded as e-systems if they are connected to an A, B or E system and drinking water can be withdrawn from them all year round. Seasonally or temporarily operated drinking water fountains are classified as f-systems.

§ 4: Drinking water must be designed in such a way that its consumption or use causes harm to human health, in particular

caused by pathogens, is not to be obtained. It must be pure and fit for human consumption. The generally accepted technical rules (loc. r. d. t.) must be complied with.

Section 13: The USi of an e-system from which drinking water is provided to the public must be reported to the health department

with regard to the following facts:

· Construction, initial start-up or recommissioning of the water supply system (at least four weeks in advance)

· complete or partial shutdown of the water supply system (within three days)

· Structural and operational changes to parts carrying drinking water, which may have significant effects on drinking water quality (at least four weeks in advance)

· Transfer of ownership or right to use the drinking water fountain (at least four weeks in advance). The USi of an f-plant is required to notify the health department regarding the construction or commissioning and the expected duration of operation of a drinking water fountain (as early as possible).

Section 14: The USi of a drinking water fountain that is operated temporarily (f-plant) has the obligation to regularly examine or have the water examined. The health department determines at what intervals which tests are to be carried out (Section 14 paragraph 2 sentence 6 TrinkwV).

Section 17: Plants for the production, treatment or distribution of drinking water must be planned, built and operated at least in accordance with the above rules; the materials and materials used must not adversely affect drinking water quality. The assessment principles of the Federal Environment Agency must be observed.

Section 18: The health department monitors the e-systems from which drinking water is provided to the public and f-systems through appropriate tests. Monitoring may include e-systems that provide drinking water as part of a commercial activity but not a public activity.

Section 19: In the case of e and f systems, the health department checks whether the USi has fulfilled his/her duties, which are incumbent on him/her under the TrinkwV. The tests also include the collection and analysis of water samples. The health department decides on the need to visit the e and f facilities.

As part of monitoring the e and f systems, the health department must examine or have examined at least those parameters which can be assumed to adversely affect the drinking water installation and shall set up a monitoring program based on appropriate random checks.

Technical regulations

DVGW W 274 — Planning, construction and operation as well as self-monitoring of public drinking water fountains (working title)

DIN EN 1717 — Protection of drinking water from contamination in drinking water installations and general requirements for safety devices to prevent

Drinking water contamination due to backflow

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Monitoring by the health department

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Duties and tasks of USi

USi's obligations under TrinkwV include in particular

· Planning, construction and operation of the plants in accordance with the i.a. d. (§ 17 TrinkwV),

· Notification and action obligations (§ 13 and § 16 TrinkwV),

· Inspection of drinking water in accordance with Section 14 paragraph 2 TrinkwV (for F systems) and on

Order from the health department in accordance with § 20 TrinkwV (for e-systems), transmission of a copy of the results of the drinking water test (two weeks after completion of the examination) to the health department in accordance with § 15 TrinkwV paragraph 3.

· It is also recommended to keep an operating book.

Scope of examination and frequency

The USi of a drinking water fountain, which is to be categorized as an f-plant, must examine or have the water examined in accordance with Sections 14 and 15TrinkwV. TrinkwV has not yet explicitly called for regular independent testing of e-systems by the USi. The health department should recommend that USi regularly examine drinking water fountains that are to be categorized as e-systems, if necessary, also arrange.

The tests for the above parameters should be carried out monthly. The frequency of examinations can be reduced with the approval of the health department. When the drinking water fountain is started for the first time and at the beginning of each season for seasonally operated drinking water fountains, in addition, Pseudomonas aeruginosa be examined.

The examination of chemical and/or physical parameters can usually be dispensed with, as drinking water fountains are normally connected to monitored systems.

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Collection and analysis of water samples

Samples are taken in the same way as the water is used by the population: without further rinsing and disinfection measures (see DIN EN ISO 19458 purpose c). In the case of drinking water fountains, in particular those that are operated continuously, it is not always possible to shut down and disinfect the outlet without problems and is also not practicable. In the case of drinking water fountains with several sampling points, sampling at one point is sufficient.

Plant and site visit

The inspection of a drinking water fountain is part of the audit in accordance with Section 19 paragraph 1 TrinkwV. In the case of e and f systems, the health authority shall decide at its own discretion whether to carry out such a visit. However, it provides important information about the hygienic status of a drinking water fountain. At a minimum, the site visit should be carried out when the plant is first put into operation. An inspection of existing plants should be rescheduled as soon as possible. Further site visits should then be carried out at least on a case-by-case basis.

The risk-related criteria for an event-based selection of investments to be entered into are in particular:

· Exceeding limit values or repeated unusual test results of drinking water tests,

· lack or insufficient self-monitoring by the USi of the systems,

· Complaints from users to the health department or USi,

· information from the operating register,

· frequency and date of recent site visits, and

· structural changes and changed environmental conditions with potential effects on water hygiene.

As part of the site visit, the surrounding area must also be inspected and indications of a possible impairment of the system or improper use must be identified. The checklist for site inspection of drinking water fountains in the appendix can be used to document the site visit.

As part of the inspection of a drinking water fountain, it is recommended to carry out or commission an investigation in accordance with Section 19 paragraph 3 TrinkwV.

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measures when limit values are exceeded, and

Failure to meet requirements

The “Guidelines for the Enforcement of Sections 9 and 10 of the Drinking Water Ordinance (TrinkwV 2001)” can be used for health assessment and possible courses of action. Depending on the hygienic condition of the drinking water fountain and on the identified excess or non-compliance, the measures must be taken or ordered by the USi. Measures on drinking water fountain to eliminate contamination or impairment may include, in particular, the following:

· Plant cleaning

· Maintenance of the existing installation of the drinking water fountain

· adequate flushing

· Disinfection of plant components

Collection and data management

It is recommended that the health department record and manage the data on drinking water fountain — preferably electronically. This data collection should contain the most important information about the respective drinking water fountain (see also appendix Checklist for Site Visiting Drinking Water Fountains). In particular, the following information should be included:

· USi of the drinking water fountain and contact person

· Location/address of the drinking water fountain and description of the surrounding area

· Operation or operating time: Is the drinking water fountain operated year-round or seasonally?

· Operational technology: Was the system a continuous operation? Or does it take place

· Water removal, e.g. mechanically, electrically or via a magnetic valve?

· Connection of the drinking water fountain: Is the drinking water fountain connected to the public

· Distribution network or connected to a building's drinking water installation?

· Notifications to the health department about initial start-up, if applicable

· Restart, e.g. when the drinking water fountain as a result of contamination or

· The accident was shut down and was put back into operation after repair and at

· technical changes.

· Results of drinking water tests

· Records of regulatory monitoring

· Special incidents: e.g. damage, contamination, complaints, closure.

Since the commissioning of drinking water fountains is subject to notification in accordance with Section 13 TrinkwV, the above-mentioned information on USi, location, operation and technical design may be collected as part of this notification.

Bibliography

Drinking Water Ordinance as amended by the announcement dated March 10, 2016 (BGBl. I p. 459), which was last amended by Article 99 of the Ordinance of June 19, 2020 (BGBl. I p. 1328) has been amended

Directive (EU) 2020/2184 of the European Parliament and of the Council of 16 December 2020 on the quality of water intended for human consumption (recast) (Official Journal of the European Union L435/1)

DVGW fact sheet W 274 — Planning, construction and operation as well as self-control of public drinking water fountains (working title, white print planned for 2022)

Infection Protection Act of July 20, 2000 (BGBl. I p. 1045), which was last amended by Article 9 of the Act of 16 July 2021 (BGBl. I p. 2947) has been amended

DIN EN 1717 — Protection of drinking water from contamination in drinking water installations and general requirements for safety devices to prevent

Drinking water contamination due to backflow. DVGW Technical Rule (2011)

“Guidelines for the implementation of Sections 9 and 10 of the Drinking Water Ordinance (TrinkwV 2001)”, BMG February 13, 2013

DIN EN ISO 19458 —Water quality - Sampling for microbiological tests (ISO 19458:2006)

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