Water Supplies In Public Buildings
UNISON Scotland's response to Scottish Executive Environment Group
Consultation on Water Supplies in Public Buildings (Paper 2002/)
UNISON welcomes the Scottish Executive consultation to strengthen
regulations governing the quality of drinking water in public buildings.
We believe in the interests of public health and safety the standards
of drinking water in public buildings such as schools, hospitals,
community centres, and in restaurants should be improved to protect
individuals consuming this water.
We support the proposals for more rigorous testing and monitoring
of water available for public consumption within public buildings.
In addition we believe that results and information on water quality
in public buildings should be readily available to the general public,
to promote confidence in water quality and to encourage public buildings
to meet the water standards.
UNISON is Scotland's largest trade union representing over 145,000
members working in the public sector. As the largest trade union
in the Scottish water industry, UNISON members are both providers
and users of water in Scotland. UNISON welcomes the opportunity
to comment on the Scottish Executive's consultative paper Water
Supplies in Public Buildings. This response needs to be seen in
the context of our previous submissions to recent Scottish Executive
consultations on the water industry.
We welcome the proposals to strengthen existing rules, and to develop
a robust regulatory framework governing the quality of drinking
water in public buildings. The provision of healthy and safe water
to all Scottish people is crucial to the wider public health and
social inclusion agenda. Our responses to the questions posed in
the consultation document emphasise the need for clear and robust
regulations, regular and appropriate monitoring, and transparency
and openness in reporting on water quality in public buildings.
This paper constitutes UNISON Scotland's response to the consultation
document issued by the Scottish Executive Environment Group - Water
Supplies in Public Buildings.
Consultation Point 1
UNISON believes that the register of public buildings should be
determined by the local authority with guidance from the Scottish
Executive. Local authorities will have local knowledge of public
buildings in their own areas, and so will be best placed to devise
their own registers of public venues. It will be easier to amend
and add new public buildings to a locally held register, than to
a national scheme. However, clear guidance on the register should
be provided by the Scottish Executive. UNISON would expect that
this additional role for local authorities be acknowledged in additional
funding for local government from central government in order that
they have the resources and personnel to carry out these additional
Consultation Point 2
Monitoring of water in public buildings should be based on a common
sense approach that takes into account the number of people using
the building, the size of the establishment, and the quality of
water registered in previous tests.
The standard monitoring frequency for public buildings should be
based on the normal occupancy of the building with a facility to
reduce the frequency if it can be shown that the water is compliant
with the regulatory standards. However, we believe that it is important
that standards are not allowed to slip and there should be a minimum
of one visit per annum for public buildings.
Consultation Point 3
UNISON believe that there should be guidelines from the Executive
on the labelling of water taps in public buildings that is not for
drinking. Such guidelines should include best practice on including
labels in the appropriate language of people who are likely to use
the building. For example, public buildings in areas where a number
of minority ethnic communities use the building should display labels
in an appropriate language, likewise if the building is to be used
by partially sighted people Braille labels should be used. In public
buildings where it is possible that members of the public may wish
to use water to boil kettles or for cooking, for example in community
centres, labels should clearly indicate if tap water is unsuitable
for this purpose.
Consultation Point 4 and 5
Again UNISON believes a common sense approach should be taken to
monitoring water, with samples taken from a number of taps at random,
in proportion to the size of the building. The taps should be identified
and selected by the sampler at the time the water samples are taken.
Consultation Point 6
UNISON agrees that the suggested list of parameters to be monitored
is about right. The monitoring of these parameters should identify
any public health concerns.
Consultation Point 7
In the interests of accountability and transparency, UNISON believes
that the results of regulatory sampling should be reported to the
owner of the building, the local authority and the Scottish Executive.
It is important that the public should be able to access this information
so as they can make informed decisions on the water they drink.
Consultation Point 8
The results of regulatory sampling should be prominently displayed
in the public building (along the lines of the clean beach flags)
and be kept on public record by the local authority and the Scottish
Consultation Point 9
The requirement to notify breaches of the Regulations to Scottish
Ministers is necessary to give transparency and accountability to
the enforcement process. However we are certain that given adequate
resources, local authorities will be able to ensure effective enforcement
of the regulations.
Consultation Point 10
The power to issue authorised departures for water quality standards
in public buildings should rest with local authorities. However
there should be a process where the Scottish Executive can monitor
the number and frequency of authorised departures issued by local
authorities. This will help to keep the local authorities accountable,
and to ensure that the highest standards of water health and safety
are adhered to.
It is vital that there are robust systems and safeguards to improve
and maintain drinking water standards in public buildings. The Executive
has ensured that Scottish Water has to meet the highest standards
in its abstraction, impoundment, and delivery of water to the public.
It is important that public buildings, whether under the auspices
of local authorities, health trusts, education authorities, or private
companies / individuals, meet their obligations to ensure water
gets to individuals safely. Although the threat to Scottish Water
of competition is diminishing for the immediate future, it is important
to remember that off-network services do still exist and are open
to competition. In some areas the off-network service is likely
to provide water to public buildings. The Executive will have to
be mindful of carefully considering monitoring and responsibility
issues in these circumstances.
For further information please contact:
Matt Smith, Scottish Secretary
14, West Campbell Street,
Glasgow G2 6RX
Tel 0141-332 0006 Fax 0141 342 2835