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

ID: 
10
This submission reflects the views of
Organisation Name: 
Australian Beverages Council
Please identify the best term to describe the Organisation: 
Other
Personal Details
Questions for BTEX
1. Is the information provided relevant and clear?: 
Yes
2. Are there any issues in relation to the safety and aesthetics of benzene in drinking water that you feel have been omitted? : 
No comment
3. Is the information provided relevant and clear?: 
Yes
4. Are there any issues in relation to the safety and aesthetics of toluene in drinking water that you feel have been omitted? : 
No comment
5. Is the information provided relevant and clear?: 
Yes
6. Are there any issues in relation to the safety and aesthetics of ethylbenzene in drinking water that you feel have been omitted? : 
No comment
7. Is the information provided relevant and clear?: 
Yes
8. Are there any issues in relation to the safety and aesthetics of xylenes in drinking water that you feel have been omitted? : 
No comment
9. How do you find the overall readability and format of the fact sheets? Could they be improved – if so, how?: 
No comment
10. Do you have any general comments on the draft fact sheets for benzene, toluene, ethylbenzene and xylenes?: 
No comment
Questions for Guidance for issuing and rescinding boil water advisories
1. Is the information in this section clear and understandable?: 
The document assumes knowledge of the ADWG. Beverages Council endorses the addition of earthquakes under the environmental section. Formatting of headings and subheadings are unclear and are not numbered. This does not assist the reader in regard to highlighting priority of information.
3. Does this section provide sufficient and clear information on how to boil water appropriately?: 
Definition of rolling boil should be in the main document rather than as a footnote.
4. What, if any, other information should be included?: 
Communication with the food and beverage industry should be addressed in this document. Manufacturers need to be informed immediately when potable water may not meet criteria in which it is arranged to be supplied. This may impact decision to carry on production, or if a decision should be made to utilise further processing of water as ingredient, or water for cleaning. Consumers often ask manufacturers for advice. It should be considered that communication with the beverages industry to advise of a safety or quality infringement be undertaken at the earliest time possible to correctly inform consumers and media outlets. Support should also be provided in relation to provision of testing of any contaminant.
5. Does this section provide adequate and clear information to inform the decision to rescind a boil water advisory?: 
A boiled water advisory may be the result of a range of contaminations in water. Reference to indicator organism, E. coli, as in the text (paragraph 2) may confuse consumer stakeholders as to the source or nature of the boil water advisory. This reference should be clarified.
6. What, if any, other information should be included?: 
Details in relation to post-incident testing of the water supply should be shared with beverage manufacturers.
7. Does this section provide adequate and clear information to assist in developing the communication strategy? : 
It is suggested that Beverages Council, or other industry group such as AFGC, regulator including ACCC and FSANZ is able to distribute advisories utilising electronic media. This would be further distributed to manufacturers’ customers to ensure correct review of hazards are undertaken at the next review - for all products and process steps, and for development of disaster recovery protocols if relevant.
8. What, if any, other information should be included?: 
There are two areas to be addressed: telephone number for consumer enquiries, and inclusion of a detailed process for notifying the broader food industry (including manufacturers, hospitals, food service)
9. Is there anything else that should be considered after the event?: 
Engagement with external stakeholders, particularly food and beverage manufacturers, and a written report (detailing outcomes) should be distributed.
10. Is this template useful?: 
Yes
11. Does it cover everything that needs to be in an advisory? If not, what else should be included?: 
General OH&S is not covered (i.e. burns, scalding and unattended saucepans), nor is management of stocks of faulty product. It would be helpful to include frequency of advisory review in documentation (i.e. hourly, every twelve hours etc).
12. Is the template understandable by the general public?: 
No comment
13. Is this template useful?: 
Yes
14. Is there anything else that should be included in the template?: 
No comment
15. Is the template understandable by the general public?: 
As the average consumer is not knowledgeable in terms such as CFU/ml. Quantifying the number of cases or contamination levels is less relevant than providing information on whether or not the water meets the requirements of the ADWG.
16. Do you have any general comments on the draft document Guidance for issuing and rescinding boil water advisories?: 
Consideration of key stakeholders, the food and beverages industry, should be updated with information on water quality status. This will enable them to make informed decisions in relation to their respective businesses to address any safety concerns at the earliest opportunity.
General Comments
Comments: 
  • Main concern of manufacturerers are with regard to safety, of both consumers and staff.
  • Manufacturers are also concerned about costly recalls that may occur consequent to water contamination if information is not shared in a timely manner.
  • It is unclear whether the advisory notice is for drinking water suppliers, general public or public health. It is also unclear how this document will fit within the current ADWG.
  • In terms of this document, the food and beverages industries need to be considered as key stakeholders in any water contamination or safety crisis. In the case of any hazard occurring manufacturers can have contingencies arranged to address any health and safety issues for staff, and within product or plant.

Page reviewed: 17 December, 2013