Select Committee on Environmental Audit Minutes of Evidence


Annex 7

Letter to Board Level Contacts of Water Service Companies and Water Companies in England and Wales from the Chief Inspector, Drinking Water Inspectorate

DWI Information Letter 11/99

FEEDBACK FROM WATER COMPANIES ON DWI PERFORMANCE IN 1998

PURPOSE

  1.  The purpose of this letter is to inform water companies of the main conclusion of Bob Price's survey of companies which was carried out to obtain feedback on DWI performance in 1998, announced in DWI Information Letter 2/99, and to advise companies on the actions the Inspectorate is putting in hand to deal with the issues identified.

BACKGROUND

  2.  DWI operates on a total quality management system of continuous improvement. It is essential therefore that inspectors know what is expected of them and that we get constructive feedback on their performance. We do this by:

    —  Our mission statement, our three-year plan, our annual targets and by setting objectives and targets for each inspector.

    —  Our Code for Enforcement which sets stringent targets for all of DWI's main activities.

    —  Obtaining views from consumers on their priorities through periodic surveys.

    —  Obtaining views from water companies on our performance.

    —  Obtaining views from other relevant organisations.

  3.  In previous years DWI has sought water companies' views on its performance by means of a questionnaire. This only covered part of the Inspectorate's activities and in later years some water companies were filling in the questionnaire mechanically. We considered that we were not getting fully accurate feedback on our performance. Consequently DWI appointed Bob Price to carry out the survey by face to face and telephone interviews.

ACKNOWLEDGEMENT

  4.  I thank water companies for the co-operation they gave to Bob Price and for the helpful and constructive feedback. I intend to use that feedback to improve DWI's procedures, performance and efficiency. I hope this will bring benefits to DWI and ultimately to water companies. A copy of the main part of Bob Price's report is attached. A short annex which makes specific confidential references to individual inspectors will not be made available to anyone outside the senior DWI management.

CONCLUSIONS FROM FEEDBACK AND ACTIONS BY DWI

  5.  The following sections set out the main conclusions that Bob Price reached, broken down into general categories of activity, and, where appropriate in italics, the action that DWI has taken or proposes to take.

General

  6.  The main conclusions were:

    —  DWI is widely respected for its high level of knowledge, expertise and professionalism, particularly in areas of laboratory work and regulation. Knowledge of treatment and distribution operations although adequate was not so well developed.

        *All Inspectors have attended training courses on modern water treatment processes and the design and operation of distribution systems. DWI will review the need for up-dating of training in these areas.

    —  Widespread respect and recognition of the role of DWI. It has made a major contribution to raising standards. Some companies would like to see DWI more involved in promoting good practice.

        *DWI is involved in promoting good practice; for example the Technical Guidance Notes associated with the Principles of Water Hygiene. DWI will continue to promote good practice when it is appropriate to do so.

    —  Some deterioration in relationships between companies and DWI, primarily as a result of perceived DWI regulatory initiatives on cryptosporidium.

        *There is on-going concern to improve the protection against cryptosporidium. Initiatives were made by Ministers as a consequence of a prosecution which failed on a legal technicality. DWI seeks a professional relationship with water companies but it will always act in the best interests of public health.

    —  DWI had been fair and objective in its dealing with companies although some considered that there had been inconsistency of treatment.

        *DWI's aim is to be fair, objective, and consistent and to treat all companies equally. Our quality system is designed to facilitate consistency. We have adopted a continuous improvement approach and we will continue to review and improve our procedures.

General Inspection and Enforcement

  7.  Water companies considered that the arrangements for the 1998 inspections were generally good and inspections carried out in a professional manner. The main conclusions were:

    —  Some inspection reports were not provided within the target times set in DWI's Code for Enforcement.

        *This performance is unacceptable. DWI is further standardising inspection reports and putting in systems for better planning of inspections so that reports can be delivered on schedule.

    —  Whilst most companies were satisfied with the conduct of their inspections, a few companies considered that there had been inconsistencies with previous inspections, excessive pedantry, inefficient handling of audit trail queries and some major differences between conclusions at round-up meetings and the subsequent written reports.

        *The Inspection and Enforcement Unit set up in January 1998 has settled in and is reviewing its procedures to improve performance in these areas. Breaches of requirements missed in previous inspections cannot be ignored unless they are trivial. New procedures have been put in place to improve the efficiency of audit trails. There are no targets for inspectors on the number of recommendations—the fewer the better. Round-up meetings give preliminary conclusions which may be modified as a result of further information from companies.

  8.  Water companies considered generally that the annual compliance assessment was accurate and any subsequent enforcement action appropriate. Most companies were supportive of the new monthly compliance assessments introduced in 1998. The main conclusions were:

    —  Many monthly assessments were not completed within the target times set and subsequently feedback to companies was delayed.

        *This performance is unacceptable. There were teething problems with the new system. The procedures have been reviewed and revised which should enable greatly improved performance in the latter half of 1999. We plan to give companies preliminary feedback within 20 working days.

Distribution Systems

  9.  Most inspections and audits were carried out by consultants under the Direction of a Principal Inspector. Arrangements were good and most companies considered the conclusions appropriate. There was a considerable improvement in meeting the targets for inspection reports compared with previous years.

        *DWI aims to improve to meet all its Code for Enforcement reporting targets.

The Periodic Review (AMP3)

  10.  There was widespread criticism of the Periodic Review process but most of this was directed at other organisations than DWI. Companies had strong professional respect for DWI's approach but believed that DWI did not have the resources to carry out fully a task that proved considerably greater than first envisaged. The main problems experienced by companies were:

    —  lack of clarity of information requirements, particularly on lead, and difficulty contacting DWI to clarify;

    —  many preliminary opinion letters were late arriving;

        *DWI considers that the process worked well and was delivered largely to time given the huge number of schemes submitted. The feedback was obtained during the AMP3 process and was unable to record the final outcome. All decisions were made in time for companies to prepare their draft business plans. However, DWI intends to carry out a full review of its procedures for AMP3 and its relationship with other organisations with a view to learning lessons for the handling of a future Periodic Review. DWI will consider proformas for data inputs.

Incidents and Complaints

  11.  Most companies considered that DWI had reached appropriate conclusions and recommendations, but a few did not and considered that there were inconsistencies. Some companies considered that DWI was primarily interested in increasing the number of prosecutions.

        *DWI's aim is to get companies to take appropriate action to prevent incidents happening so that prosecutions are not necessary.

  12.  The main conclusions were:

    —  Some improvement in meeting the target times for signing off incidents for which prosecution not being considered, but still not met in many cases.

        *DWI is continually striving to make incident investigations more efficient against a background of increasing notifications. 80 per cent of notifications in 1998 were completed with the Code for Enforcement target.

    —  Companies would like feedback on whether an incident is being considered for prosecution before the target time has passed.

        *DWI is introducing a system in which companies are advised when an investigation will not be completed within three months of receiving the company's final report. If a prosecution is under consideration the water company will receive a formal letter advising that "the Inspectorate's investigation may include consideration of an offence under Section 70 of the Water Industry Act 1991 and this could lead to the institution of prosecution proceedings".

Liaison Inspectors

  13.  There was widespread support for the concept of the liaison inspector which was introduced in January 1998. Companies were generally satisfied with their contacts with their liaison inspectors. A few companies considered that there was lack of clarity about the role of liaison inspector and insufficient contact with their liaison inspector.

        *The role of the liaison inspector was set out in a letter to companies on 26 November 1997. DWI will review its internal guidance for liaison inspectors and where necessary inspectors will clarify their role with companies. Liaison inspectors will make at least one visit to each of their companies in 1999 and, if possible, attend the final round-up meeting on inspections.

CONCLUSION

  14.  DWI considers that this has been a very positive and helpful exercise. DWI will be making the changes to its procedures outlined above. I am confident that this will result in improved performance and efficiency. I propose to carry out a repeat survey at the end of 2000 to measure the effectiveness of our continuous improvement programme.

ENQUIRIES

  15.  Enquiries on this letter should be addressed to me or to Owen Hydes (Zone 2/E4, telephone 0207 890 5960).

  16.  Copies of this letter are being sent to Pamela Taylor, Chief Executive, Water UK; Bob Dinwiddy, Head of Water Supply and Regulation Division, Department of the Environment, Transport and the Regions; Bob Macey, Environment Division, Welsh Office; and Bob Price.

  17.  Please acknowledge receipt of this letter using the enclosed slip and envelope.

28 June 1999


 
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