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Australian Drinking Water Guidelines: Chemical FactSheets and Boil Water Advisory Notice submission

ID: 
6
This submission reflects the views of
Organisation Name: 
Australian Food and Grocery Council (AFGC)
Please identify the best term to describe the Organisation: 
Non-Government Organisation
Personal Details
Questions for Guidance for issuing and rescinding boil water advisories
1. Is the information in this section clear and understandable?: 
Overall the information is clear and understandable although this does depends on the target audience and assumes a working knowledge of the ADWG. AFGC suggest consideration of the addition of earthquakes under the environmental section. Sub-headings in this section could be more distinct - it is difficult to determine which are headings and which are sub-headings which makes the document harder to follow.
3. Does this section provide sufficient and clear information on how to boil water appropriately?: 
Definition of "rolling boil" could be included in the main body of text and not as a footnote where it may be missed.
4. What, if any, other information should be included?: 
It is suggested that consideration be given to provision of guidance for the food industry or reference to where this information can be found. Food manufactures will need advice to determine whether it is safe to continue production and also for use of water for cleaning. It will also be important for food manufacturers to be aware of the Boil Water advisory to enable them to respond to consumer inquiries in relation to what actions are being taken to address the matter.
5. Does this section provide adequate and clear information to inform the decision to rescind a boil water advisory?: 
Reference to testing for E.coli in paragraph 2 may not be relevent where the advisory has been issued for another pathogen - this may cause confusion about the nature of the safety issue that has lead to the Boil Water advisory.
6. What, if any, other information should be included?: 
No comment
7. Does this section provide adequate and clear information to assist in developing the communication strategy? : 
AFGC support the development and maintenance of contact lists for the food processing industry or suggest consideration of going through the local health department, FSANZ or AFGC communication channels. AFGC support the use of electronic media as an important tool. Sub-headings in this section could be more distinct - it is difficult to determine which are headings and which are sub-headings which makes the document harder to follow.
8. What, if any, other information should be included?: 
1. Contact details for inquiries from the general public and other key stakeholders. 2.Process for notifying specific users - eg: food industry, including food service
9. Is there anything else that should be considered after the event?: 
Review should include engagement with external stakeholders such as the food industry. Suggest a written report is issued to stakeholders to share learnings. Rescinding testing for E.coli - may not be appropriate if it was not the organism of concern.
10. Is this template useful?: 
Yes, consistency of notification is supported.
11. Does it cover everything that needs to be in an advisory? If not, what else should be included?: 
1. Safety notice - it is important to include advise to be careful with boiling water to avoid scalding and/or accidental burns. 2. Advice in relation to what to do with current stored water, eg: dispose of ice and stored water and wash containers before reuse. 3. Advise how regular updates on the Boil Water advise will be provided and when.
12. Is the template understandable by the general public?: 
No comment
13. Is this template useful?: 
Yes, consistency of notification is supported.
14. Is there anything else that should be included in the template?: 
No comment
15. Is the template understandable by the general public?: 
1. AFGC query the value of providing test results to the general public. It is suggested that it may be more appropriate to advise that the water quality now meets the required standard to ensure consumer safety. 2. Document should state to identify and implement procedures to prevent a recurrence.
16. Do you have any general comments on the draft document Guidance for issuing and rescinding boil water advisories?: 
AFGC query how advise to key stakeholders will be managed. Consideration needs to be given to liaison with the food industry to ensure that companies are kept up to date with water quality status to enable them to make informed decisions in relation to their respective businesses.
General Comments
Comments: 

Comments related to the Food industry

The food industry needs to be recognised as a key stakeholder in the event of a water contamination/safety issue.  The industry needs to be alerted to an issue as soon as possible so that actions can be put in place within their respective businesses to address any health and safety issues for both staff and the products they manufacture.

Food manufacturers may have difficulty in following a boiled water advisory if they are reliant on using reticulated mains water supply and do not have a separate holding tank from which to draw water.  However, when a boiled water advisory is issued those food manufacturers that have sufficient holding capacity to be able to treat the water used in manufacturing and cleaning should be able to treat the water with using chlorine or other chemicals approved for use in drinking water, and should not be required to boil the water.  

From the point of capability to boil large quantities of water, and for worker safety, it may not be appropriate for food manufacturers to boil water and those companies that do not have onsite storage and the capability to chemically treat the water will need to consider the possibility of suspending production. 

If a food company has manufactured product with water that is likely to have been contaminated before the boiled water advisory notice was issued, the company will need to assess the potential of the food being contaminated and the need to undertake a food recall.

Additional comments:

1. It is unclear who the advisory notice is intended for - drinking water suppliers and public health or the general public.

2. It is unclear how this relates to the ADWG - does it sit within the Fact Sheet section?

Page reviewed: 17 December, 2013