Water – Private Drinking Water

Policy

This policy sets out the actions that schools with a private drinking water supply must take to minimise potential health risks to students and staff.

Summary

• Schools with a private drinking water supply, including water from rainwater tanks, bores (groundwater) or carted water, are responsible for managing and maintaining their water supply to ensure it is safe to drink.
• Schools with a private drinking water supply must complete a private drinking water supply management plan (PDWSMP), and review their plan annually.
• These plans document the regular inspection and maintenance activities required to keep their water supply system safe. Schools must also ensure these activities are undertaken as planned.
• Schools must ensure system inspections, water quality testing results and maintenance activities are documented and recorded in the Asset Information Management System (AIMS), with records kept for at least 2 years. Schools who are not yet using AIMS should continue to keep local records until AIMS is available.
• Schools are encouraged to regularly review whether they can obtain water via mains reticulation, which is the safest drinking water option.

Details

Access to safe and reliable drinking water is a requirement for health and wellbeing. Some Victorian schools are unable to access drinking water from a public mains supply. For these schools, a private drinking water supply sourced from rainwater tanks, bores (groundwater) or carted water is the only supply available.

Private drinking water sources can pose health risks to students and staff, particularly if they are not maintained or managed correctly. Schools that rely on private drinking water supplies are legally responsible for managing and maintaining their water supply to ensure it is safe to drink. Refer to the relevant legalisation section for more information.

The Buildings and Grounds Maintenance and Compliance policy sets out the department’s compliance and monitoring process that applies to all key asset management activities, including management of private drinking water supplies. This policy sets out the department’s requirements for schools to manage private drinking water supplies in line with the 3 principal steps of the Buildings and Grounds Maintenance and Compliance Policy: Identify, Manage and Monitor.

Identify

Schools must identify and document all components of the water supply system on the premises by creating a private drinking water supply management plan using the department’s template (available on the Resources tab). This plan also identifies all regular maintenance and inspection activities required to ensure the system remains operational and in good condition.

Schools are required to upload their completed private drinking water supply management plan into the AIMS school documents section, or retained in the school’s file records until AIMS is available.

For guidance on how to complete a private drinking water supply management plan, refer to the Developing a private drinking water supply management plan chapter of the guidance.

Manage

To comply with the mandatory requirements for private drinking water management, schools must undertake regular inspection, maintenance, water testing and treatment activities documented in their private drinking water supply management plan and take action to rectify any faults or issues identified during regular inspection or use of the water system.

The private drinking water supply management plan must be reviewed annually by completing the corresponding work orders in AIMS.

Schools must ensure system inspections, water quality testing results and maintenance activities are documented and recorded in AIMS, with records kept for at least 2 years. Schools who are not yet using AIMS should continue to keep local records until AIMS is available.

Schools with a private drinking water supply are also required to develop a contingency plan for when the usual supply is unavailable or unfit for use.

Schools with a private drinking water supply are encouraged to check every 5 years, when updating their SMP, whether a connection with urban mains water may be feasible. Refer to the Urban mains water feasibility chapter of the guidance for more information.

Schools that have connected to mains water are required to complete the confirmation of decommissioning checklist (DOCX) to document the decommissioning of their private drinking water system. Refer to the Decommissioning private drinking water systems chapter of the guidance for more information.

Refer to the Inspection and maintenance activities chapter of the guidance for further information on inspection, maintenance, water testing and treatment activities.

Monitor

The Victorian School Building Authority (VSBA) monitors compliance with mandatory maintenance requirements (using AIMS where possible) and responds to non-compliance at a school and system level through direct support to schools or revision of policies and procedures.

The VSBA will monitor compliance with the mandatory private drinking water management requirements using the information and reports uploaded to AIMS.

Emergency management

If your school needs emergency drinking water (for example, due to a failed or contaminated private drinking water supply), back up water can be provided through the VSBA Make-Safe service provider by contacting 1300 133 468.

Refer to the Support for schools chapter of the guidance for more information about what to do in an emergency.

Reporting and exclusion for gastroenteritis

If a gastro outbreak is suspected in your school, make an IRIS alert.

Students and staff suffering from gastroenteritis should be excluded from school until 48 hours after symptoms cease.

Related policies

• Asset Information Management System (AIMS)
• Asset Management Roles and Responsibilities Framework
• Duty of Care
• Buildings and Grounds Maintenance and Compliance
• Procuring Low-Value Construction Works or Services
• Reporting and Managing School Incidents (including emergencies)
• Student Resource Package — School Infrastructure

Relevant legislation

• Children’s Services Regulations 2020 (Vic)
• Food Act 1984 (Vic)
• Public Health and Wellbeing Regulations 2019 (Vic)
• Residential Tenancies (Caravan Parks and Moveable Dwellings Registration and Standards) Regulations 2020 (Vic)
• Water Act 1989 (Vic)

Guidance for private drinking water supply management

This guidance contains the following chapters, which can be accessed using the menu bar:

• Private drinking water supply risks and hazards
• Developing a private drinking water supply management plan
• Inspection and maintenance activities
• Water quality testing
• Urban mains water feasibility
• Decommissioning private drinking water systems
• Support for schools

Private drinking water supply risks and hazards

Water quality fluctuates even with well-maintained systems.

Harmful microorganisms (pathogens) and chemicals are not visible to the naked eye and may be present in water that appears to be clear. Drinking water containing these contaminants can cause illness such as mild to severe gastroenteritis.

Children, elderly and people with suppressed immune systems are more vulnerable to contaminants and extra care should be taken to ensure the water provided is safe for drinking.

This chapter provides an overview of common contaminants and means to minimise the risk they pose to private drinking water supply systems.

Additional general information can also be found on the Department of Health Water page.

Rainwater contamination hazards

Rainwater can be contaminated by a range of sources. These can include:

• roof materials such as roofs coated in bitumen products or lead-based paints
• animal faeces
• leaves and debris
• ash and chemicals from wood heaters (for example, in instances where chimneys and flues are not installed properly or the burning of inappropriate fuel)
• wind-borne or aerial spraying of pesticides and fertilisers.

Ways to minimise risks to rainwater supply systems

Schools are encouraged to take practical measures to minimise risks to rainwater supply systems, including:

• ensuring the roof surface is suitable for collecting rainwater (i.e. not coated in bitumen products or lead-based paints)
• maintaining and regularly cleaning gutters
• installing leaf stoppers
• light-proofing the tank and plumbing to minimise algae growth
• installing a first flush device to prevent the most contaminated rainwater from entering the tank
• securely covering the tank
• mounting TV antennas off the roof
• removing overhanging branches
• disinfecting water to remove most disease-causing microorganisms, for example, chlorination
• drain for periodic tank desludging.

Bores (groundwater) contamination hazards

Bores (groundwater) can be contaminated by a range of sources. These can include:

• sewage
• animal faeces
• industrial and agricultural run-off (such as pesticides and fertilisers)
• seepage from rubbish
• polluted stormwater
• chemical spills and fuel from pump
• naturally occurring chemicals (such as arsenic)
• infiltration with contaminated surface waters and flood waters.

Ways to minimise risks to bores (groundwater supply systems)

Schools are encouraged to take practical measures to minimise risks to groundwater supply systems, including:

• surrounding the bore with a concrete slab sloping away from the bore casing for surface drainage
• ensuring the bore cover is securely in place to prevent entry of pests and contaminants
• mounting the pump on a separate concrete slab with bunding
• fencing the bore off to prevent access
• filtering the water to remove contaminants
• light-proofing the tank and plumbing to minimise algae growth
• using ultraviolet disinfection to remove most disease-causing microorganisms
• installing screens on all tank inlets, outlets and vents
• securely covering the tank
• maintaining a buffer distance between the bore and onsite wastewater system
• locating onsite wastewater system downslope of bore.

Natural events

During rain events water can be washed from other sources into rainwater tanks and move water underground, affecting bore water.

If dust is blown onto your roof and is washed into your rainwater tank, chemical residues can build up in the water.

If your school is in a bushfire affected area your private drinking water could be contaminated from debris, ash, dead animals, aerial fire retardants and water-bombing

Stagnant water

During prolonged shutdown periods (such as school holidays) water sitting in pipework can cause leaching of metals which may impact water quality.

Following a shutdown period, schools should run a tap furthest from the supply source for 2 to 3 minutes. Flushing for longer may be needed for larger water systems. This should be done before students and staff return to school.

Rural water

It is crucial that schools do not mistake rural water for urban water. Rural water is untreated water used for irrigation or toilet flushing, not for drinking. Some schools may mistakenly believe that drinking water is available through mains because rural water comes from streetside water authorities. Only urban water can be used for drinking purposes.

Developing a private drinking water supply management plan

To comply with the relevant legislation, schools with private drinking water supplies must develop a private drinking water supply management plan. Developing this plan is the first step towards managing a private drinking water supply.

The private drinking water supply management plan nominates the school person who will be responsible for the system and outlines the regular inspection and maintenance activities that are necessary to ensure the water supply for a school is safe for human consumption.

Steps to completing a private drinking water supply management plan

The following steps must be taken to complete a private drinking water supply management plan (PDWSMP):

• Step 1: Record school details and details of the nominated person responsible for the school water supply system
• Step 2: Provide a detailed description and map of the water supply system
• Step 3: Identify hazards and ways to mitigate risks to the water supply
• Step 4: Document operation monitoring and maintenance procedures for the water supply system
• Step 5: Develop a contingency plan to manage the water supply in the event of contamination or for when a supply is inaccessible.

Schools are required to create their initial private drinking water supply management plan using the VSBA template. This can be loaded into AIMS' School Documents section or retained in the school’s file records until AIMS is available.

The VSBA template is available from the Resources tab, or by contacting the Annual Contracts team.

The private drinking water supply management plan must be reviewed annually by completing the corresponding work orders in AIMS.

Refer to the AIMS and private drinking water quick reference guide (available on the Resources tab) for further information on work orders and record keeping in AIMS.

Guidance and assistance

Schools that require additional guidance on how to prepare a private drinking water supply management plan should contact the Annual Contracts team at vsba.annual.contracts@education.vic.gov.au or 03 7022 5800.

Inspection and maintenance activities

Schools manage their inspection and maintenance activities by first completing a private drinking water supply management plan which identifies the system specific inspection and maintenance activities that are necessary to ensure their private drinking water supply is safe for human consumption. Refer to the Developing a private drinking water supply management plan chapter of the guidance for further information.

Schools activate their routine maintenance tasks (Work Orders) in AIMS and close them out once the maintenance task has been completed. Refer to the AIMS and private drinking water quick reference guide (available on the Resources tab) for further information on work orders and record keeping in AIMS.

If your school is yet to be inducted to AIMS, maintenance tasks should be scheduled into the school’s maintenance calendar.

Routine inspection and maintenance activities

Schools are to undertake regular inspection and maintenance activities to keep their private drinking water supply fit for human consumption.

These activities include:

• cleaning screens and strainers regularly
• conducting regular inspections of tank covers and screens to ensure they are intact
• removing overhanging branches
• cleaning gutters and roofs regularly
• cleaning sediment build-up within the tank (desludge) regularly
• ensuring the tank is structurally sound.

Inspection and maintenance works should be carried out by a Victorian Building Authority registered and licensed plumber or suitability experienced service providers, depending on the works carried out.

Local councils require schools with private drinking water supplies to keep records of system maintenance, inspections and water quality test results for at least 2 years.

Defects

It is the school's responsibility to identify, record, and address system defects in AIMS to rectify the defects.

Schools should refer to their emergency contingency plan in their private drinking water supply management plan if water is unfit or unavailable for human consumption.

Water quality testing

Water quality testing assists in determining whether any contaminants are present and that the drinking water supply meets health-based drinking guideline values.

Routine water quality testing is required to be assured that water is safe to drink. This chapter details the different types of routine water testing required to determine whether a private drinking water supply is safe.

Microbe testing

Microbe testing means testing the microbiological quality of the water for detecting the presence of pathogens such as Escherichia coli (E. coli), which may indicate faecal contamination and the possible presence of disease-causing microorganisms.

The recommended testing frequency for microbe quality is monthly.

Microbe testing must be conducted by a National Association of Testing Authorities (NATA) approved laboratory. Accredited facilities can be found on the NATA website.

Chemical testing

Chemical testing is a comprehensive analysis that is undertaken to determine the chemical and physical quality of a water supply, and to identify any unusual contaminants.

The recommended testing frequency for chemical and physical quality is annually.

Chemical testing must be conducted by a NATA approved laboratory. Accredited facilities can be found on the NATA website.

Private drinking water must meet the health guidelines outlined in the Australian Drinking Water Guidelines by testing the following chemical and physical characteristics: antimony, arsenic, cadmium, chromium, copper, fluoride, lead, nickel, nitrate, manganese, sulphate, pH, total dissolved solids, total hardness, and turbidity.

NATA

Water samples can be collected by schools and couriered to a NATA lab for microbe testing. The lab will provide information on water sample collection requirements for microbe testing and chemical testing.

The NATA website can be used to locate your nearest lab by searching for your closest regional city. An alternative is to use a search engine to locate a NATA lab. Refer to the NATA quick reference guide (available on the Resources tab) for further information on locating your nearest lab on the NATA website.

NATA can be contacted on 1800 621 666 for assistance in finding your closest lab. If there are no nearby NATA laboratories, samples can be mailed overnight instead via express shipping. For instructions on how to collect and post samples, please contact your NATA lab of choice.

Treatment testing

Treated water, such as chlorinated water, must be tested to ensure it remains within the acceptable pH ranges.

The pH of the water must be 6.5 to 8.5. A pH of greater than 8 can decrease the efficiency of chlorine disinfection.

The recommended testing frequency is weekly.

Treatment testing can be undertaken by the nominated school person responsible for the private drinking water supply using standard pH strips. These pH test strips can be found in standard swimming pool water test kits.

Ad hoc water quality testing

Other events which require laboratory water quality testing (microbe and chemical testing) include:

• before using the water from a new treatment system
• after a treatment system has been altered
• following any infrastructure works that may affect the catchment area (roof gutter repairs)
• after a significant event such as fire, flood or chemical spill that may have affected the water quality
• after prolonged periods of shutdown, such as school holidays.

Water treatments

Treating the water supply helps to ensure the health of consumers is not placed at risk. The most common treatment methods include filtration and disinfection with ultraviolet (UV) light and/or chlorine.

To select the best method to treat the school’s water, consult a water treatment specialist.

Filtration

Filters are used to remove sediment and are commonly installed with your regular plumbing between the roof catchment area and the storage tank. They are normally used in combination with UV light and/or chlorine disinfection.

Disinfection

Disinfection is typically the last step of water treatment before being distributed for drinking use and generally includes UV and/or chlorine disinfections.

UV disinfection

UV disinfection uses UV light that disinfects water by emitting a light that will enter and damage a microorganism’s cellular function so that it will not be able to grow. UV light is not a filter so microorganisms and suspended matter will not be removed from the treated water.

UV disinfection systems need to be designed and installed by a water treatment professional. Typically UV disinfection requires less maintenance and ongoing upkeep compared to chlorination.

Chlorination disinfection

Chlorine is a chemical additive often used to treat small drinking water supplies because it is easily accessible, cheap and can treat large volumes of water. Water can be chlorinated through an automatic dosing system or manually added to the storage tank. The effectiveness of chlorine can be short-lived and will only treat water in the tank at the time of dosing; fresh run-off into the tank may not be disinfected. Schools are encouraged to undertake weekly pH testing of water treated with chlorine.

Urban mains water feasibility

Urban mains water is the safest available drinking water option. Schools are encouraged to switch to urban mains water as soon as feasibly practicable.

Schools are encouraged to investigate if they can connect to treated water supplied by the local water authority (also known as urban water, town or mains water) every 5 years in line with the refresh of their school maintenance plan. In the first instance schools are encouraged to identify and contact their urban water authority/supplier to discuss the possibility of connecting with mains water.

Schools can contact their water authority by searching their address in the Water in your region map.

Should connection be possible, schools are encouraged to arrange a feasibility assessment, including consideration of funding source and planning approvals or other processes required. If a simple and affordable solution is available, schools are encouraged to arrange for a Victorian Building Authority licensed plumber to provide a quote for the works.

If the connection to mains water is possible but will require approvals or significant investment, schools are encouraged to:

• include the option in their school maintenance plan
• consider how the works will be funded alongside other school maintenance priorities
• discuss the option with provision and planning staff in their regional office
• seek guidance from vsba.annual.contracts@education.vic.gov.au

Decommissioning private drinking water systems

When private drinking water systems are no longer used for drinking water purposes, schools must restrict access to the equipment and any outlets/taps retained for non-drinking purposes to ensure untreated water cannot be used for drinking by staff and students.

Tank or bore water may still be used for non-drinking purposes (for example, irrigation or toilet flushing) only if the plumbing for these purposes is completely isolated from the school’s drinking water supply.

To decommission private drinking water systems, schools are required to:

1. disconnect plumbing from the tank/bore to drinking outlets such as taps and bubblers
2. install signage on any still connected tanks/bores/outlets to warn against drinking with messaging such as 'Untreated water – do not drink'
3. arrange for the tank/bores to be replumbed for irrigation or other non-drinking purposes
4. deactivate any relevant AC PDW Routine Tasks and Work Orders in AIMS
5. complete the Private drinking water – confirmation of decommissioning checklist (DOCX) and email it to vsba.annual.contracts@education.vic.gov.au

Support for schools

Annual Contracts team

The department supports schools to meet their mandatory compliance obligations through the work of the School Asset Assessments Unit (SAAU) which supports schools with managing their annual contracts. The VSBA Annual Contracts team has been established to support schools directly with guidance and support and can be contacted at vsba.annual.contracts@education.vic.gov.au and 03 7022 5800.

School maintenance plans

In addition, the School Asset Leadership team provides direct guidance and support to schools on request and the School Maintenance Advice and Planning team provides support to schools to complete and operationalise their school maintenance plans. These teams can be contacted through the VSBA on 1800 896 950.

Asset Information Management System

Over 2021 and 2022, the VSBA is rolling out a new Asset Information Management System (AIMS) to all schools. AIMS will make it easier for schools to manage their assets and related compliance obligations within a single portal.

As schools gradually transition to using AIMS, they will be provided with a transition date, staff training and support. Schools not yet provided access to AIMS must continue to maintain manual records that reflect the completion of compliance obligations. Refer to the department's advice on AIMS for further information.

Routine maintenance funding

Schools should fund their private drinking water supply responsibilities from their Student Resource Package (SRP) funding.

The Annual Contracts and Essential Safety Measures ACES funding line includes an allocation to schools for inspection and servicing of sewage and water treatments as specified under SRP Guide Reference 36.

The Maintenance and Minor Works funding line is allocated to schools to meet costs associated with repairs and maintenance.

Make-Safe

Schools may request an emergency water supply through the VSBA’s Make-Safe service provider on 1300 133 468.

Emergency maintenance funding

In some situations where a school has insufficient funds for critical repairs costing $5,000 or more, they may apply for assistance through the VSBA’s Emergency Maintenance Program. For more information, refer to the Guidance tab of the Buildings and Grounds Maintenance and Compliance policy.

Department of Health

Schools may contact the Department of Health, Communicable Disease Prevention and Control on 1300 651 160 for support and advice to ensure that illness is not spread to the school community.

Resources

Private Drinking Water Supply Management Plan

• Private drinking water supply management plan template (XLSX) (staff login required)
• Private drinking water – confirmation of decommissioning checklist (DOCX)

Guides

• AIMS and private drinking water quick reference guide (DOCX) – guide for schools explaining routine maintenance tasks, work descriptions and record keeping in AIMS used to manage private drinking water supplies
• NATA quick reference guide (DOCX) (staff login required) – guide for schools explaining how to locate their nearest National Association of Testing Authorities (NATA) approved laboratory for water testing

Useful websites

• Department of Health – Water
• National Association of Testing Authorities (NATA)
• Victorian Building Authority – regulated plumbing practitioners
• Australian Drinking Water Guidelines