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

This submission reflects the views of
Organisation Name: 
Melbourne Water
Personal Details
Specific Questions
1. Is the new text in Chapter 6 (Section 6.5) relevant, accurate and easy to understand?: 
Yes the text is easy to understand.
2. Do you have any comments on the process for determining interim guideline values for chemicals that have been detected in drinking water but do not have a guideline value in the Australian Drinking Water Guidelines?: 
The additional text for Ch 6 identifies a hierarchy of documents to refer to if ADWG guidelines do not exist. There is no rationale explaining the hierarchy. A paragraph explaining why these reference documents are in the order presented would be useful. For example, is it because the AGWR and the WHO drinking water guidelines use the same assumptions in the acceptable concentration calculations? It is not clear why documents have been ordered as such.
3. Are the proposed amendments to Chapter 8 relevant, accurate and easy to understand?: 
The text is clear. Melbourne Water has a concern about the communication of the assessment of treatment chemicals in the absence of NHMRC in the process. For example, if a water utility in Qld approached NICNAS through their local department of health for guidance on the assessment of a treatment chemical - how will that be communicated to other States so that work is not potentially duplicated? Will this be a role that NICNAS undertakes? Also, what is the process for chemicals to be added to Table 8.2? It is not stated in the document how this might be done and some guidance would be appreciated.
5. Do you have any suggestions about other sections of the Australian Drinking Water Guidelines that need to be revised as part of NHMRC’s rolling review process?: 
No, other than the consideration of microbial Health-Based Targets which is underway.

Page reviewed: 9 February, 2016