The State of the Industry in the EU: Update on Issues of Note
By Tony Frost
The globalization of the water treatment industry means each and every aspect is affected by events, regulations and research worldwide. Here’s a look at some of the more important issues and happenings at present in the EU.
The United Kingdom Water Treatment Association (UKWTA) is a new and dynamic trade association, formed at the beginning of last year, to represent the UK industry supplying water treatment equipment to the domestic and commercial markets. It was spawned by the urgent need to improve the representation of this industry—both in the UK and Europe.
It is the brain-child of Dr. Carl Jasper, who has extensive knowledge of corrosion and scale control in water heating systems, through his past experience with Advantica, the research organization of British Gas. His vision is a wide ranging membership representing the manufacturers, installers, retailers and users of the various products covered by the association. The remit of the association is to become the immediate point of reference for all stakeholders in the post-treatment of drinking water – the main driver being to ensure not only protection but promotion of the interests of the industry through the supply chain from manufacturer to end-user.
The membership of UKWTA has already reached over 100 and its activities are subdivided into four product sectors: softeners, drinking water filters, physical conditioners and chemical treatment. Each sector has it own agenda and management group, but the mission in each case is to establish and provide clear information to the trade and end-user, through the UKWTA website and routine public relations, on topical and relevant issues.
A classic example of the achievement of the association is the direct lobbying of the UK government, in its 2006 amendment of the Building Regulations, to specify the requirement for water treatment in water heaters in order to reduce scale where the hardness of the water supply is greater than 200 mg/l (see below). Another example is the production of an Information and Guidance Note for WRAS (Water Regulations Advisory Scheme) on installation of domestic water softeners. This leaflet details the installation requirements necessary to comply with the UK Water Supply (Water Fittings) Regulations 1999. It can be downloaded from the WRAS website http://www.wras.co.uk/PDF_Files/IGN9-07-01.pdf.
The UKWTA recognizes the paramount importance of international cooperation and is therefore actively involved in mutual cooperation with other like-minded European associations, as well as the WQA, on issues of immediate and future interest.
The following gives an outline of the position on some of these key issues in which UKTWA is either directly involved or is monitoring progress.
UK regs now require treatment of hard water
The UK Building Regulations were amended in 2006 and, as a direct consequence of lobbying by industry, guidance documents for compliance now require that, where the water supply to the premises is hard, water treatment is necessary to reduce scale deposition in boilers.
The building regulations
These Building Regulations are extensive – they specify the legal requirements for building design and cover building structure (Part A) through to electrical safety (Part P): Part L’” covers Boiler installation for dwellings and requires that “Reasonable provision shall be made for the conservation of fuel and power in buildings”. The Secretary of State issues Approved Documents giving practical guidance on procedures for compliance with the Regulations. The Approved Document for Part L references the Domestic Heating Compliance Guide.
Domestic Heating Compliance Guide
This document1 identifies minimum provisions for System Preparation and Water Treatment and states: “Where the mains water hardness exceeds 200 parts per million, provision should be made to treat the feed water to water heaters and the hot water circuit of combination boilers to reduce the rate of accumulation of limescale and the consequent reduction in energy efficiency.” (see page 54 of this issue for the guide page.)
The objectives of the Building Regulations with respect to their requirements for energy efficiency are to minimize fuel costs and maximize comfort for the occupants of the building. But they also target reducing carbon dioxide emissions from combustion of the fuel, in support of the Government policy in reducing global warming and protection of the environment.
In 2005, a group of UK companies funded tests on a boiler which had been in service in a hard water area. This demonstrated that the as little as 9 grams of scale reduced the steady-state fuel efficiency by 5.6percent. Based on the UK government’s figures, a 3percent reduction in average boiler efficiency equates to an increase of 160 kilograms of CO2 (carbon dioxide) emissions per annum. This represents in excess of 3.25 million tons of CO2 emissions per annum from the estimated 17 million gas-fired boilers in the UK in hard water areas.
This data (together with the WQA test data) was used to lobby – and successfully convince – the Government department responsible for amending the Building Regulations, to require feed water treatment in all new boiler installations in hard water areas.
WHO – drinking water hardness and health
The controversy over whether removing hardness minerals from drinking water has any significant, adverse effects on health, has received considerable, recent attention from World Health Organization (WHO). Statements and reports are progressively emerging. The suggestion that there might be a benefit stems from a number of medical studies conducted over the last 50 years, which indicate the people who live in hard water areas are less prone to heart disease than those who live in naturally soft water areas.
Evidence of health effects
The main constituents of hard water are calcium and (sometimes) magnesium which are essential minerals for the human body and many populations around the world are known to have diets that are deficient in these minerals. A systematic appraisal of all of the available medical studies was conducted by the University of East Anglia on behalf of WHO in 2005 and they attempted to identify which component(s) of hard water would contribute to this possible health benefit. This concluded that there is no evidence of a benefit from calcium but there is inconclusive evidence of a benefit from magnesium – and WHO stresses the need for more appropriate medical research.
Potential contribution from drinking water
Although, the results of their investigation are inconclusive, WHO reports suggest health authorities should consider the possible contribution of minerals from drinking water and further suggests a minimum of 10 mg/l of magnesium and 30 mg/l of calcium. For the average person, drinking 1.5 liters of water a day, these suggested minima represent approximately four percent of the recommended dietary intake for both magnesium and calcium.
Recent consultation with cardiovascular health experts has advised that such contributions are overstated and trivial in health benefit terms and this questionable benefit should steer health authorities towards dietary education and control from food sources, rather than from drinking water.
Recommendations must apply to all drinking water sources
Water, of course, is essential to life itself, but maintaining the right hydration balance can help prevent headaches, constipation, kidney stones, heart disease, cognitive impairment, falls, poor oral health and many other conditions.
Drinking water must be free from harmful substances but challenging a drinking water source based on absence of the health benefits discourages its consumption and threatens consumer hydration balance with possible adverse health consequences. Any message to the consumer which suggests that a water supply is in some way deficient must be clear and apply to all sources of water to which the deficiency applies, including municipal, bottled, softened, filtered, desalinated, etc. in order to avoid confusion, alarm and , ultimately, the real threat to the health of the consumer.
The disadvantages of hard water
Hard water supplies are frequently treated domestically, commercially and industrially to remove hardness in order to prevent limescale deposition which causes severe loss of thermal efficiency in heating systems and equipment failure. So hard water supplies contribute directly to increased energy consumption, CO2 emissions and climate change. In recognition of this, the Compliance Guidance for the 2006 amended UK Building Regulations, now requires water that is greater than 200mg/l of hardness to be treated to prevent scale deposition in heating appliances. Hardness also dramatically increases soap and detergent consumption (by up to a factor of three) increasing costs and environmental contamination.
Scale can also harbour bacteria and hard water can cause adverse effects on skin and hair condition. So the benefits of soft water are not just aesthetic – they can have health implications.
The current evidence for a potential health benefit from water hardness is very weak and confined to magnesium content, for which the contribution to dietary intake would be trivial. When balanced against the benefits of soft (or softened) water and benefits of optimum hydration, recommendations for mineral levels in drinking water, on health grounds, are inappropriate. Nutrient deficiency should be addressed by dietary control and education.
Clinical trial on the effectiveness of domestic water softeners on the treatment of atopic eczema
The U.K. government has awarded the University of Nottingham a grant of £861,728 (US$1,747,758.39) to investigate whether the installation of a domestic ion exchange water softener can improve the symptoms of childhood eczema.
A growing problem
Atopic eczema now affects around 15 percent of British children and has doubled in the last 20 years. It causes itching, soreness, secondary infection, sleep loss, distress for all the family as well as a burden to the Health Service. Current treatment uses topical steroids and emollients: steroids have skin-thinning side effects.
Historically, there has been anecdotal evidence in that many doctors and patients report an improvement in symptoms when the patients moved from hard to soft water areas and some water softener users report improvement in the symptoms after installing the softener. An epidemiological study in 1998 involving 80 primary schools in Nottingham found a relationship between the prevalence of eczema and hardness of the water supply. A similar study in Japan in 2004 concluded with similar results.
The SWET Trial
The trial, which began in May 2007, is being organised by the Centre of Evidence Based Dermatology, University of Nottingham who provide for the nursing staff, medical equipment and ultimately, collate the data and prepare the report. Industry, through the UKWTA, is providing the softeners, installation kits, salt, testing facilities, supervision, etc. Various industrial sponsors (including WQRF) have contributed to these industry provisions which amount to a total cost of £117000 (US$237,299.63). Additional funds are still needed. Acknowledgement of the sponsors’ contributions is made on the trial website (www.swet-trial.co.uk) which also gives details of the trial.
For a definitive trial, 310 families are needed; half are being provided with active softeners, half provide the comparative base (non-intervention). The clinical staff are ‘blind’ (unaware of whether the patient had a softener). Each patient is being monitored over a three-month period and then the softener is removed to see if any improvement is reversed when hard water is reinstated. As an incentive, the non-intervention patients are being provided with a softener for a period of one month at the end of their observation period. Recruitment is likely to take 18-20 months, with the analysis and report taking a further10 months.
A successful outcome will provide:
- Independent proof that water softeners are beneficial for treatment of eczema
- Indirect publicity surrounding the trial and subsequent publication of results.
- Recommendation/assistance by national health authorities for provision of softeners to eczema patients
- A positive result will enable softeners to be endorsed with a positive health benefit!
Revision of Italian Decree 443
The Italian Ministry of Health announced, last November, the proposed revision to its Decree 443 which specifies regulatory requirements for water treatment equipment. The original decree published in 1991 was then very onerous, but this revision is even more so!
The requirements of the Decree
It requires all types of water treatment equipment to be registered with the Ministry of Health but, without explanation, it requires RO, UV, Carbon filters and composite filters to be approved by testing by the Ministry of Health. The testing requirements and procedures are very vague and they include for minimum levels of hardness for softeners and RO. It also contains requirements for automatic regeneration and disinfection of softeners every four days – an issue we fought successfully five years ago in the CEN committees.
The European regulatory process
EU law requires that Member States inform all other Member States when they are changing or introducing new standards or regulations. The other Member States then have three months to respond.
In this case, a number organizations from different countries (WQA, Aqua Italia, Aqua Europa, UKWTA, Germany, Hungary) responded which resulted in the European Commission itself raising objection with the Italian government. The result was an extension of the ‘standstill’ period for a further three months to May 17th. This extended standstill was intended to allow the Italian authorities time to address the objections to its decree. The response, however, was that they saw no reason to change the decree because the measures it contained are, “to protect public health”.
During that time the UKWTA, in conjunction with other European associates, appointed a lobbyist in Brussels to make contact with the Commission and a meeting was held to discuss our objections. The Commission expressed concern at the number and complexity of the objections and, at their request, a further response was provided which condensed the concerns into three basic issues: These were microbiological growth, minimum hardness and transparency of the test protocols and process. This was supplemented by a brief estimate of the financial impact on the industry – courtesy of Aqua Italia.
The Commission then prepared a further reply to the Italian government, rejecting their position and a reaction is awaited. This is expected to be a meeting between the Commission and the Italian government and the UKWTA is currently lobbying to ensure that this meeting includes industry representation.
The industry concern is not only that this decree is an unnecessary burden within the Italian market but also that it is a barrier to the free flow of goods into Italy. But perhaps more importantly, it sets a precedent for which other Member States or even European-level regulation may be based.
Status of the EAS (European Acceptance Scheme)
Most manufacturers of water treatment equipment are aware of the frequently required certification of products for materials suitability – the products themselves must not cause contamination of drinking water. Most suppliers will also be aware that many countries have different requirements for materials suitability and this poses an enormous burden on international trade. The EAS was an attempt to overcome these barriers – within Europe at least.
The history of the EAS goes back to 1994 when CEN, the European standards body, identified the potential benefit of a harmonized European system for certifying products for contact with drinking water which would provide transparency and cost effectiveness for manufacturers, and removal of trade barriers. Following a feasibility study, the European Commission, in 1998, established a committee in to combine the relevant regulatory aspects of the Construction Products Directive and the Drinking Water Directive. The Commission issued a Mandate (M136) that defined the principle and the products involved. CEN was charged with producing the Supporting Standards (material test standards, e.g. taste, odour, microbial growth, GCMS, etc.) and Harmonised Product Standards (product standards for fittings and equipment) that would contain the requirements for compliance with the EAS.
The original target
The envisaged EAS was to provide a single European certification scheme for materials in contact with drinking water, with test methods, product standards and a definitive administration process (established at European level) that would be operated through Notified Bodies in each EU Member State. Approved products would then be CEEAS marked and be directly transferable from one Member State to another.
In 2006, DG Environment – responsible for the Drinking Water Directive – identified that it did not have the resource (staff, financial or authority) to provide the regulatory framework for the EAS and that the Drinking Water Directive could not be amended to provide the legal basis for the EAS.
The task therefore remains with DG Enterprise – responsible for the Construction Products Directive and in early 2006 the Commission issued a revised Mandate. This revised Mandate contained restrictions in the products covered by the EAS and implied that certain specifics of the Supporting Standards (test water extremes, acceptance levels, uncertainty levels) would be specified by CEN. CEN has made it clear from the outset that it does not possess the expertise or the authority to set these ‘regulatory’ requirements and, as a consequence, CEN rejected the revised Mandate pending clarification of the scope and regulatory issues.
Recognising that the scheme now lacks a sound regulatory basis both for implementation at EU level or for establishing performance criteria, the DG Enterprise has proposed that the scheme be revised to ‘harmonization’ of existing schemes. Member State national schemes would remain in place but aspects of their operation would be made common to allow comparable testing to take place in different member states.
The Supporting Standards (test methods for the materials) that have been extensively developed (scheduled completion now 2009), would, hopefully, provide consistency for testing methodology. But the Member State would decide which of these tests are to be conducted, the performance levels required and, to some extent, the technical interpretation of data.
Progress awaits the outcome of the Commission’s current review of the various Member State schemes and clarification of the responsibilities of CEN and the programme but 2012 is now being voiced as the anticipated date for implementation. But, after almost 10 years of deliberation, effort and considerable expense on behalf of industry as well as regulators and testing bodies, the Commission has decided that it does not have the resources or the authority to set up a Pan-European scheme.
- Domestic Heating Compliance Guide 2006
About the author
Tony Frost is a Director of AQUA FOCUS, LTD., a consultant in water treatment design, supplies and services in Newport, Shropshire, England. He’s a Past President of Aqua Europa and Chairman of the Bsi Committee, which ‘mirrors’ the CEN/WG13 activities in the UK. Contact him at +44 1952 691219 or email: TonyFrost@AquaFocus.co.uk