By Tony Frost
Emergence of product standards for drinking water treatment equipment in Europe promises a new dimension to the prospects of the industry. Hitherto, attitudes from some European water supply companies and regulators on the practice of enhancing water quality by in-home treatment, have been discouraging to say the least—and sometimes positively hostile. The very existence of internationally approved test standards imparts indisputable integrity for compliant products. The standards drafting process itself, however, poses enormous hurdles threatening that opportunity.
Harmonization of product standards is complex and often emotive. Dissimilar practices between European countries are highlighted in the drafting process, creating conflict that occasionally extends to attempted domination by aggression. Some member states have standards in place—in some countries, they’re a legal requirement. Awareness of the fact that the EN (European “norme” or standard) must be adopted by each member state, and replace any relevant national standard, creates apprehension because manufacturers will have built their products around their respective national standard or national custom and practice. The role of the drafting group is to produce a standard by consensus that satisfies everyone. This can be a daunting prospect given the wide diversity between national practices and the individual commercial interests of delegates.
The process started about 10 years ago when TC164/WG2 began a document entitled: “Specification for installations inside buildings conveying water for human consumption.” (These acronyms stand for subcommittees of the Comité Européen de Normalisation, or CEN, which oversees standards harmonization between its members—”TC” represents Technical Committee and “WG” stands for Working Group.) Among other things, this document identified a range of water treatment equipment that then resulted in the birth of WG13 charged with the development of product standards for that equipment. Separate drafting groups (customarily referred to as ad hoc groups) were set up to start work on the first five equipment categories approved by TC164 for drafting activity.
The standard that has reached the most advanced stage is that of Mechanical Filters, Part 1, which deals with particle filters having a rating between 80 and 150 microns. Use of this type of device is almost entirely restricted to Germany and Austria and, as they have a “DIN” standard specifically for such filters, progress has been relatively unhindered.
Not so the case with the standard for water softeners which, with their universal application (with the possible exclusion of Holland and Denmark), has been the subject of considerable controversy. Again a German standard (DIN 19636) exists; but there’s also a “Presidential Decree” in Italy and specific regulatory requirements in France. There was therefore considerable pressure within the drafting group, to emulate the DIN standard with prescriptive requirements relating to:
- Microbiological control,
- Automatic regeneration every 96 hours (regardless of water usage), and
- Blending to a minimum hardness of 150mg/L (CaCO3).
Conflict over softeners
Although only a small minority of softeners sold in Europe comply with these requirements, representation at the drafting group meetings was such that pressure to embody them in the standard was disproportionately high. The new European Drinking Water Directive is significant in this context because changes in the Directive negate the need for inclusion of microbiological control (including the 96 hour regeneration) or blending. The conventional practice in these circumstances is to create different “types” or “classes” of product within the standard. However, after a two-day meeting in Paris two years ago, agreement on the criteria for two “types” could not be obtained; so it was agreed that reference would be made to the above features qualified by the phrase: “if necessary to meet national or local regulation.”
Nonetheless, subsequent drafts contained continual reference to microbiological control. This met with sustained opposition and, following a presentation by a CEN Project Manager on standards drafting principles, the draft was rejected by WG13 on the grounds it wasn’t representative of the market as a whole and it lacked consensus.
Recognizing the significance of the controversy over microbial regrowth, Aqua Europa (see A Federation of Associations) convened a meeting of three European microbiological experts to adjudicate on the issue. The conclusion of the experts (see “The HPC Debate: Bacterial Re-Growth in Post-Treatment Devices,” WC&P, July 2000) was “…it is the opinion of this group that growth of bacteria in post-treatment devices does not represent a significant human health risk and that any European standards relating to these devices should be based upon functionality and not on microbiological parameters.”
As a consequence, the convenor of the softener standard drafting group proposed that reference to microbiological growth control should be removed except for the one phrase “if necessary to meet national or local regulation.” This proposal was embodied in the text at the drafting group meetings last April and June and the draft document is currently being revised on that basis with the intention it should be presented to the next WG13 meeting this month.
While there was general acceptance of the convenor’s proposal, it was rejected by the German delegation on the grounds that the standard won’t contain the DIN 19636 requirements, which are mandatory in Germany. Their recourse, in these circumstances, is a procedure called an “A-Deviation.” This allows a CEN member to request that certain aspects of a standard do not apply in their country because of “existing regulations.” The A-Deviation takes the form of an informative annex to the standard that identifies the aspects of the standard that’s in conflict with the particular national regulation.
Status of other standards
The Mechanical Filters Part 1 has been circulated for public enquiry and the drafting group has met to review the various national objections. A “final vote” for submission on the revised document is expected in the autumn.
The Electrolytic Dosing and Chemical Dosing Part 1 will be circulated for the public inquiry stage in September.
Mechanical Filters Part 2 (for those rated from 1 to 80 microns) is expected to be submitted, along with the softener standard, to WG13 in September for consideration for the public inquiry stage.
RO/Membrane Filters, Ultraviolet, Activated Carbon and Composite Filters are in the early stages of drafting.
The Maintenance Standard was originally proposed in order to defuse the deadlock in the softener standard drafting by extracting any reference to microbial growth to a separate document. It’s intended to accommodate installation, routine maintenance and sanitation procedures common to the whole range of water treatment products. The first meeting is scheduled to take place in July. Maintenance of water treatment products is a vital issue for successful performance, customer satisfaction and industry reputation. However, this drafting group faces the difficulty of avoiding reopening the microbiological issues tentatively resolved in the softener standard. Furthermore, maintenance cannot be effectively enforced without the necessary legal structure in place. Such a structure only exists for water supplies in only a few of the CEN member countries.
WG13 is currently considering proposals that Physical Water Conditioners be reintroduced into the programme. They were originally deleted form the list on the grounds there’s no generally accepted technical explanation for the phenomenon and no industry accepted test method. With the development of the German DVGW W512 test method for assessing the performance of a scale inhibitor, several of the European trade associations have revised their position with regard to acceptance of the technology based on compliance with an accepted test method. A proposal is being prepared for consideration at the WG13 meeting in September.
European Drinking Water Directive
A European directive differs from a standard in that its application is mandatory for members of the European Union. They must not only adopt a directive into their regulations; they’re legally bound to comply with it.
The first European Drinking Water Directive (80/778/EEC) was approved in 1980 and was ultimately adopted by each member state.
A revised directive (98/83/EC) was approved at the end of 1998. Each member state must adapt their regulations in accordance with the new directive by the end of this year. And they must comply with requirements of the new directive must be met by the end of 2003.
The new directive is simpler than the original. It’s based on the 1996 WHO Guidelines for Drinking Water Quality and divides parameters into three categories: 1) microbiological parameters (mandatory), 2) chemical parameters (mandatory), and 3) indicator parameters (monitoring purposes only).
The importance of the new directive to our industry is that it:
- Excludes the original requirement to reharden softened water,
- Relegates sodium to the indicator parameters, and
- Excludes the original maximum guide levels for total bacteria counts.
These are the three primary issues that have thus far been used to challenge the potability of softened water. Unfortunately, some member states seek to reintroduce some of these parameters using the perceived flexibility embodied in the new directive.
Aqua Europa and, in some cases, the national trade associations are actively lobbying the appropriate regulators regarding how the EU Drinking Water Directive is translated into national regulations. It also continues to work toward harmonization of equipment standards as the de facto secretariat of the CEN for water supply issues, particularly with respect to those within buildings.
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 also currently president of Aqua Europa and chairman of the BSi Committee which “mirrors” the CEN/WG13 activities in the United Kingdom. He can be contacted at +44 1952 691219 or email: [email protected]
Acronymonia—Deciphering all the letters
The Comité Européen de Normalisation, or CEN, is the body based in Brussels that’s responsible for management and development of European standards. Members of CEN are the national standards bodies of the European Union (EU), European Free Trade Association (EFTA) and the Czech Republic.
When a CEN standard is approved, all the CEN members are bound to adopt the standard and withdraw any relevant existing national standard. In general, standards aren’t mandatory in that a manufacturer or supplier isn’t bound to comply with them. This is true of CEN standards. Of course, a manufacturer may be technically or commercially disadvantaged if his products don’t comply. However, in some member countries, standards are mandatory or it’s customary that the national standard is applied where one exists.
Work on CEN standards is controlled by “Technical Committees” (TCs). “Water Supply” is managed by TC164 which in turn is divided into “Work Groups” (WGs). WG13 is responsible for “drinking water treatment inside buildings.” There are 13 product standards approved for drafting activity by WG13. They are:
- Mechanical Filters Part 1—80-to-150 microns
- Mechanical Filters Part 2—1-to-80 microns
- Electrolytic Dosing—aluminium anodic corrosion protection
- Chemical Dosing Part 1—preset dosing rates
- Chemical Dosing Part 2—adjustable dosing rates
- Ion exchange Water Softeners
- Reverse Osmosis and Membrane Filters
- Ultraviolet Disinfection
- Nitrate Reduction—ion exchange
- Activated Carbon Filters
- Composite Filters
- Rehardening Equipment
- Maintenance—a general standard to cover all of the above
In addition a request to re-introduce Physical Conditioners into the programme is being considered.
A Federation of Associations—What is it?
Aqua Europa is a “federation of trade associations.” Its members are the national trade associations of the various European countries—covering the water treatment equipment industry. Its role, much like any trade association, is to promote the interests of its members. But, in the case of a multinational association such as Aqua Europa, the objectives are to provide a forum for establishing a common position on key issues which affect the industry and provide or obtain the funding to promote and lobby for the achievement of that position.
With support from industry, Aqua Europa was very effective in clarifying some of the important aspects of the new Drinking Water Directive during its development. Its role now is to endeavour to obtain agreement among the membership to support national initiatives in sustaining the essential parameters of the directive.
In the United Kingdom, proposals exist deviating from the directive over sodium and minimum hardness on health-related grounds. In Germany, there’s a threat to reintroduce a bacterial colony count limit. And, in several other states, there are proposals for minimum hardness on the grounds of corrosivity. All of these proposals are despite the many studies contrary to their claims. The UK proposals can be accessed at: www.environment.detr.gov.uk/consult/watersup/index.htm
Just as importantly, Aqua Europa monitors the progress of CEN standards harmonization within the European Union. In fact, it serves as the secretariat, so Aqua Europa, its member organizations and the companies they represent are actually funding the process.