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

ID: 
7
This submission reflects the views of
Organisation Name: 
Queensland Health
Please identify the best term to describe the Organisation: 
Government Department – State / Territory
Personal Details
Questions for BTEX
2. Are there any issues in relation to the safety and aesthetics of benzene in drinking water that you feel have been omitted? : 
The information in the fact sheets does not adequately address the occurrence of BTEX in groundwater, either from natural proximity to coal, petroleum, gas or shale, or as a result of extraction activities. Accordingly, the Water Quality Team suggests the addition of text to the fact sheets to include reference to naturally occurring BTEX, and the mobilisation of BTEX due to extractive activity. This could be achieved by the addition of a sentence in each fact sheet, for example: "Benzene/Toluene/Ethylbenzene/Xylenes can occur naturally in groundwater as a result of proximity to, or contact with, coal seams, petroleum and gas deposits, and shales. It/they may be mobilised by extraction activities." Appropriate references to support the statement include: H. Volk, et al. (2011). `A desktop study of the occurrence of Total Petroleum Hydrocarbon (TPH) and partially water-soluble organic compounds in Permian coals and associated coal seam groundwater'. Tech. rep., CSIRO. S. Lesage, et al. (1997). `Distinguishing Natural Hydrocarbons from Anthropogenic Contamination in Ground Water'. Ground Water 35(1):149-160. Leusch, F., Bartkow, M., (2011) A short primer on benzene, toluene, ethylbenzene and xylenes (BTEX) in the environment and in hydraulic fracturing fluids. PDF file on http://www.ehp.qld.gov.au/management/coal-seam-gas/pdf/btex-report.pdf Accessed 2/1/13
4. Are there any issues in relation to the safety and aesthetics of toluene in drinking water that you feel have been omitted? : 
See comments for Benzene above.
6. Are there any issues in relation to the safety and aesthetics of ethylbenzene in drinking water that you feel have been omitted? : 
See comments for Benzene above.
8. Are there any issues in relation to the safety and aesthetics of xylenes in drinking water that you feel have been omitted? : 
See comments for Benzene above.
Questions for Guidance for issuing and rescinding boil water advisories
1. Is the information in this section clear and understandable?: 
Yes. Would clarify the statement "...is greater than the adverse consequences" in the second paragraph. Include "the public" in the last sentence of the third paragraph. Also add the following to the end of the "Water quality incidents" section: "While E.coli may be detected in a system occasionally without an obvious cause, this should not be confused with the repeated detection of E.coli or enteric pathogens that may be the result of a contamination event or systems failure. If an investigation of a positive microbial test suggests contamination or a system failure has occurred then a boil water advisory should be considered along with immediate corrective action."
3. Does this section provide sufficient and clear information on how to boil water appropriately?: 
Yes.
4. What, if any, other information should be included?: 
Should not focus only on kettles as a method of boiling, but as the preferred of several available methods.
5. Does this section provide adequate and clear information to inform the decision to rescind a boil water advisory?: 
Yes.
6. What, if any, other information should be included?: 
Revise the first paragraph to begin: "Criteria for rescinding a boil water advisory will require a review of the risk assessment based on the identified cause of the advisory, and should be determined when the advisory is issued. Each advisory will have unique circumstances or conditions that prohibit prescriptive guidance in this document that can cover all events and circumstances. However, in general terms..."
7. Does this section provide adequate and clear information to assist in developing the communication strategy? : 
Yes.
8. What, if any, other information should be included?: 
More explanation or emphasis on establishing a communication network prior to an advisory. Also, add the following sentence to the section on "Who should issue the boil water advisory?": "However, if there is overwhelming evidence that an advisory is needed the responsible party should issue the advisory immediately and then consult with health authority as soon as possible." Should also change the title of "Rescinding a boil water advisory" to "How should the boil water advisory be rescinded?" to match the previous sections.
9. Is there anything else that should be considered after the event?: 
Should emphasize the importance of timely delivery of the message, and that this should be specifically evaluated. Could also explain that the evaluation should examine whether the message was understood and complied with by those receiving it.
10. Is this template useful?: 
YES! This will be the most used part of the guidance.
11. Does it cover everything that needs to be in an advisory? If not, what else should be included?: 
Yes. Might also discuss use of water for pets.
12. Is the template understandable by the general public?: 
Yes. Might also consider a graphic version that can be used for those with lower literacy skills.
13. Is this template useful?: 
Yes.
14. Is there anything else that should be included in the template?: 
No.
15. Is the template understandable by the general public?: 
Yes. As with the first template, might also consider graphic version.
16. Do you have any general comments on the draft document Guidance for issuing and rescinding boil water advisories?: 
Appendix C and References are also useful and important information to include in the guidance. The templates should be made available in an electronic format so they can be quickly adapted for use by water suppliers.

Page reviewed: 17 December, 2013