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

This submission reflects the views of
Organisation Name: 
Personal Details
Specific Questions
1. Is the new text in Chapter 6 (Section 6.5) relevant, accurate and 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?: 
3. Are the proposed amendments to Chapter 8 relevant, accurate and easy to understand?: 
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?: 
Dear Sir/Madam, I write regarding a concern with a draft for the New proposed Guidelines. My understanding is that the NHMRC is responsible for policy setting of the Australian Water Guidelines. As per the following email, the guidelines are not mandatory and each state and territory decides itself whether or not to go by these guidelines. “While NHMRC provides advice through the Australian Drinking Water Guidelines, they are not mandatory standards in Australia. The states and territories have authority for regulating water supplies and determining the quality of water to be supplied to consumers in all parts of Australia. This means that the government of each state and territory decides whether and how to implement the latest Australian Drinking Water Guidelines.” I refer to Section 8.5. “ A drinking water chemical is considered suitable for use when used in accordance with standard operating procedures.” And “If a chemical not listed in chapter 8.5 is to be used in the treatment of drinking water, it is the responsibility of the water authority to seek advice from the appropriate state/territory health regulatory agency and take into consideration health, environmental and occupational health and safety issues. Fact sheets set out in Section 5 set out detailed information on chemicals used in the treatment of drinking water. “ The following correspondence from NHMRC should be noted. Thank you for your email in relation to your product which contains hydrogen peroxide and silver. I have previously spoken to your company, who had been referred to the National Health and Medical Research Council (NHMRC) by the WA Department of Health. As I explained NHMRC has no role in the approval of drinking water treatment chemicals. It is up to state and territory water regulators to determine what is safe and effective. Often this is done by water utilities determining what treatment chemicals best suit their purposes, demonstrating that they are effective, and consulting with the relevant state/territory government agency (usually Department of Health) to ensure the regulators are satisfied. This approach is consistent with the risk management framework in the Australian Drinking Water Guidelines. If WA has a requirement that drinking water must contain a particular chlorine residual, this is an issue for WA Department of Health – I am unable to comment on this requirement. • If NHMRC has no role in the approval of drinking water treatment chemicals, who compiled the list of recommended chemicals and which standard or criteria were they tested against? • Does this mean that each state/territory can use whichever product they like, whether it be on the recommended list of chemicals, or it conforms to the fact sheets or it is a product not mentioned at all in the Guidelines? From a company point of view, if a product is to be considered for use in all Australian States and Territories, one would have to apply 7 times ( individually to each state/territory) hardly lean or smart in this day and age of streamlined practices and good business management, let alone confusing if only some states adopt the product’s use! Total independent assessment by all states and territories – a waste of time effort and money. Where is the central body that a state or territory or health department could apply to with questions concerning water quality and where is the Australian Standard that applies to chemical testing? Disinfection of drinking water is a critical control point as set out in section 1.2 of the guidelines and according to 1.2 “no single disinfectant meets all these criteria.” Water disinfection is a complex procedure including climatic conditions, water quality type and level of contaminants not excluding risk management and health and environmental concerns. It is also important to note that when chlorine, chloramines, chlorine dioxide and ozone and are used as disinfectants, by-products are formed. • Innovation and New Product Availability One would assume that chlorine and derivatives must have been testing against specified parameters? New and innovative products and methods for water disinfection are available that do not produce undesirable bi-products, however their availability is restricted by a lack of a central body to take responsibility for assessment of a new chemical and a National Standard to test it against. • Fact Sheet for Silver Note that the Fact Sheet for Silver sets out the limit as 0.1%. This Fact Sheet was compiled in1996 has not been amended since – indicating that the information as originally set out still applies today. Nowhere in Section 8 does it state that this product cannot be used, however silver has been removed from the recommended chemical list Table 8.2 with no apparent explanation in the amended guidelines. Where is the reason for the amended guidelines? In summary: NCMRC only do the Guidelines. NHMRC said up to each State to endorse. Chlorine was endorsed in 1986. According to WA Health Dept. the Abbott Government have slashed programs. It used to be up to each state to endorse a product, however WA State doesn’t have the facilities for testing water for drinking standards. No chemical testing standard available Round Robin from NHMRC to each State/Territory Not dissimilar to the old rail gauge discrepancies with different widths between states! What Australia needs is for NHMRC to have responsibility for all products used for drinking water disinfection without state interference and to cut the red tape. Trusting the above concerns receive just consideration and public comment and I await favourable outcomes.

Page reviewed: 9 February, 2016