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Australian Drinking Water Guidelines: Draft amendments to Chapters Six and Ten submission

This submission reflects the views of
Organisation Name: 
Sydney Water
Personal Details
Specific Questions
1. Is the new text relevant, accurate and easy to understand?: 

The text on rounding is clear.

The text on 'Guidance on parent compounds and environmental transformation products' is clear in what is stated but raises the issue about what action will be taken in the Austrlian Drinking Water Guidelines following the inclusion of this text. Will further guidance be provided on environmental transformation products of priority concern in the future? Or is this simply to be taken as a statement of principle about how health based guideline values are determined where data is available on transformation products? We are assuming the latter, although the former would be helpful.

The text on 'Use of screening assays' might be improved by clarifying the that the the analytical chemistry method and the bioanalytical method are both examples of the screening assays described more broadly in the first sentence. This might simply be done by adding the words 'For example' at the start of the second sentence and 'Also' at the start of the third sentence.

2. Do you have any comments on the process for rounding to one significant figure to derive chemical guideline values?: 

We understand that this is an appropriate clarification of the guidelines.

3. Do you have any comments on the explanation of how to interpret analytical results and compare these to chemical guideline values?: 

This text is clear and appropriate in our opinion.

4. Do you have any comments on the guidance on environmental breakdown products?: 

We understand the inserted text to clarify the need to examine the toxicity of known breakdown products. We are unsure if this suggests that this will be a focus of further development of the ADWG. Without further clarification we understand it to be simply the statement of a principle for risk assessment and the calculation of guideline values. It would be useful if the future ADWG addressed some priority environmental breakdown products.

5. Do you have any comments on the text on the use of screening assays?: 

We understand the text to mean simply that where screening assays are used then the result should be assumed to be due to the most toxic compound potentially detected by the assay until otherwise clarified by more specific analysis. This is an appropriate use of the precautionary principle.

6. Do you have a suggestion about other sections of the Australian Drinking Water Guidelines that could be revised as part of NHMRC’s rolling review process?: 

We feel that a revision of the advice provided on cyanobacteria and cyanobacterial toxins would be timely as there is much new knowledge about cyanobacteria that could provide helpful advice to water quality managers and regulators.

Page reviewed: 31 August, 2016