Drinking-Water Testing Services
(O. Reg 248/03)

During its investigations and deliberations concerning various issues with which the Council has become engaged, the importance of testing has been a recurrent theme. Testing-related issues such as availability and cost have emerged as concerns in some circumstances.

The matter of testing and laboratories received significant attention in the Part Two Report of the Walkerton Inquiry. The report discussed specific issues of quality, availability and cost. Several recommendations specific to testing and laboratories were provided, two of which the Council chose to investigate:

Recommendation 40: Where remoteness dictates that samples for bacteriological analysis cannot be delivered to a lab either within regulated times or under guaranteed conditions, the Ministry of the Environment should determine the feasibility of alternative means of providing microbiological testing that meet the requirements of “Standard Methods”.

It is the Council’s view that an opportunity for facilitating testing through the use of simplified test procedures is available.

As an example, defined substrate microbiological tests are available in pre-packaged formats that eliminate many of the potential sources of testing error and also have substantial test quality control embedded at the manufacturing stage. Such tests have been developed specifically to enable their use outside of full-scale laboratories.

The Council has previously considered the potential for use of such tests and in its "Report and Advice on Ontario Regulation 170/03 Smaller, Private Systems Review and Recommendations" (February 2005). Recommendations 14 and 15 from that report state that:

"The Council recommends that the Ministry of Environment consider allowing the use of validated alternative testing methods (that indicate the presence / absence of bacteria), where traditional sampling and testing methods are not practical."

"The Council recommends that the Ministry of Environment work with the analytical testing industry to ensure the efficacy of alternative testing methods (that indicate the presence / absence of bacteria), and that such companies be accredited and licensed by the Ministry of the Environment."

The Council envisions that the development of appropriate guidelines and controls for the use of validated alternative testing methods could eliminate the need for case-by-case assessments and promote more testing in a simplified but effective manner. The Council also suggests that the use of such products could serve to simplify and facilitate the implementation of the risk-based public health oversight of small systems, which is currently under development.

Recommendation 41: The provincial government should phase in the mandatory accreditation of laboratories for all testing parameters, and all drinking water testing should be performed only by accredited facilities.

This Recommendation has been implemented through O. Reg. 248/03, by requiring that testing of drinking water be performed by accredited and licensed laboratories.

Two lists of exceptions are provided for specific prescribed tests. One list prescribes tests that may be performed at a drinking water system by persons certified as operators or water quality analysts. The second prescribes tests that may be conducted using continuous monitoring equipment that forms part of a drinking water system.

Other than for the above prescribed tests, the requirement for laboratory accreditation and licensing applies to all testing, whether or not it is required by regulation, and whether or not the tests are for health-related, aesthetic, or operational parameters.

This approach results in the need to continuously review and amend the prescribed parameter lists in order to enable the use of advances in continuous monitoring technologies as well as meeting system operators’ needs.

The Council transmitted an advice letter on this issue on January 3, 2006, and feels that that the promotion of the use of alternate testing methods and the encouragement of more in-house testing will result in improvement in the effective and efficient delivery of quality drinking water to Ontarians.