Volume 46 Number 1
CSA International`s Bates on Canadian DWTU Standards
In early December, WC&P had an opportunity to speak with Paul Bates, director of Built Environment Standards at CSA International, on an effort under way since this summer to establish formal drinking water treatment unit (DWTU) standards in Canada under a consensus process involving stakeholders from all segments of the industry, regulatory and public health officials, and end-users. Here's what Paul had to say:
WC&P: We were going to go over the whole process with respect to working with Health Canada and development of DWTU standards in Canada. But first, if you could, Paul, let me know what your title is?
Bates: I'm director of the Built Environment Standards.
WC&P: Define that for me, if you could.
Bates: Well "built environment" is usually the term that needs defining. It includes standards related to construction, structures and designs of building products and materials. And actually energy and utilities as well has a section under my group, which includes oil and gas pipelines, fuel-burning and fire safety—things like that.
WC&P: And water treatment as well, I assume?
Bates: Yes, and plumbing is within the construction sector, so that's where we get involved with plumbing devices that include drinking water treatment devices. Could I ask you what prompted you? I guess the contact from you is where this came from (i.e., the interview request). I'm not sure which way around it was. But what prompted you to be interested in what CSA was up to in this area?
WC&P: Well, we're familiar with CSA and what it's been doing in the water treatment segment, particularly as it relates to testing and certification, because we're an international trade magazine. We follow a lot of standards and regulation issues going on around the world. Probably, Canada and Europe are the biggest areas we keep track of outside of the United States. I had been speaking with Connie—Constance Wrigley-Thomas—over at the Canadian Water Quality Association and she mentioned this as a pretty good topic and hot issue in Canada now, recommending I get in touch with one of the technical people involved in the process at CSA, Marco Giuliacci, specifically.
Bates: In the Certification Group, yes.
WC&P: In checking with Marco, he felt like he needed to send it up the ladder a bit.
Bates: Well, I'm in the Standards Division. CSA actually has three divisions. You said you know a bit about CSA, so I'm on the standards side. But they provide input into our standards work and we communicate quite a bit.
WC&P: We were familiar with some of the other bills that have come along that were viewed by the market segment that our magazine covers primarily as somewhat of a threat. I believe C-76 was one of them several years ago and it came back as C-14. This effort is different, though.
Bates: Are you talking about the Canadian federal regulations?
WC&P: Yes. How does this differ?
Bates: Well, we're not government.
Bates: So, I can't speak too much about those proposed regulations, but Health Canada has been actively involved on our committee. Under Canada's national standard system, CSA is responsible for national standards on plumbing. Our suite tends to cover all plumbing devices that would be used when connected together as part of a plumbing system for a building, for example. It could be a small building or commercial building. So, things like fittings and fixtures generally our standards cover. And a lot of them are harmonized with the equivalent standards in the U.S. of ASME. Probably most of them are, actually, now. And the ones that aren't are in the process of being so. You know, and they're written somewhat as umbrella documents because they do serve as the basis for certification of plumbing devices by different certification organizations and are accepted by the regulators or by the plumbing officials and plumbing authorities in different jurisdictions. We saw a need to have a standard that covered drinking water treatment units because they're a new product device type that isn't covered currently in our standards portfolio. So, that's really the reason that I guess this came about. And there was interest on behalf of the regulators in having something as well that covered these devices in Canada. The approach of our standards is really somewhat of as an umbrella document. We often reference other standards and we consider this subject as part of a plumbing system.
WC&P: I understand there's a high probability that some of the standards that we work with mostly through NSF International will be referenced in these in one manner or another as well, correct?
Bates: Yes, that's right, especially regarding health effects because our focus isn't health effects, in particular. So, health effects is part of the concern of the technical committee, but electrical safety is also. For example, some of these devices contain electrical components. But generally, we're looking at plumbing, mechanical and performance compatibility with other plumbing devices that might be connected as part of this plumbing system and (ensuring) the same sort of performance requirements to be compatible with the rest of the native plumbing system…
WC&P: For example, materials, burst pressure, etc…
Bates: That kind of thing. That's right. Suitability for installation and things like that. It would certainly reference NSF standards regarding health effects. It's up to the technical committee to decide the technical content, but I'm virtually certain that's what they will do.
WC&P: When I mentioned earlier about how has this process differed, I meant in terms of the other legislative efforts that came out were straight from Health Canada, which obviously is not CSA International. You're working with Health Canada on this effort and the different perspective that was suggested to me was this is more of stakeholder-type of process where everyone including public health officials and manufacturers and distributors and utilities all have a voice in the process of how this is done.
Bates: Yes, that's right. It's a consensus-based, committee-based process. And the committee is really solely responsible for the technical content of the standard and they approve it at the end of the day before we publish it. We use the term—a balanced committee matrix, which means there's an agreed mix of categories of producers—or manufacturers—and government regulators or government and what we define as users, which in this case could include bottled water people, subcontractors and may include even some government, I suppose. The committee isn't officially constituted yet, but has actually set up a preliminary meeting and another meeting. The terms of reference and the matrix makeup of the committee has to be approved by the senior committee, which is the CSA Steering Committee on Plumbing Products and Materials. It actually closes that ballot at the end of this month, I think.
WC&P: How long has this process been under way so far?
Bates: Well, there were several task force meetings over the summer that led to our recommendation. It was sort of an ad hoc task force that was formed as a result of steering committee discussions last year. They worked over the summer. I don't remember how many times they met—three or four times maybe. And it led to the recommendation that a TC be formed to do this job and that recommendation was considered by the steering committee when it met late in the summer, in August, and approved. So, the TC has been sort of getting its act together and preparing its draft, terms of reference and membership.
WC&P: TC would be technical committee?
Bates: Yes. In the meantime, they can do some work even though they've only met unofficially. They're not officially formed yet. They've met a couple of times. And the task force met actually yesterday to look at certain aspects of preparing the standards.
WC&P: What was the impetus on this? Were there any organizations or members that sort of took a lead role in pushing this?
Bates: I guess the regulators in Canada, the people who specify in the building codes and plumbing codes in terms of defining what's acceptable for products for installation in their jurisdiction, they typically reference against a standard. And the lack of any Canadian standards that would really sort of globally cover these types of devices was an impetus. And that's why there's really quite a few regulators or government people involved on the committee.
WC&P: We were aware that Quebec had begun an effort on this last year. It started earlier but only came to our attention last year and to that of the Canadian WQA, WQA and manufacturers in the states. Did that play a part in it as well?
Bates: Well, it served to highlight the issue, because Quebec felt they had to do something. There was no Canadian standard, so they—in the interim—referenced the NSF standards and then talked to us about the issue. They're on our steering committee. That was part of the input, yes.
WC&P: I would imagine also that another factor was the fact that in the last few years there have been a few high profile waterborne contaminant outbreaks where it was felt as if some additional barriers might have helped, i.e., the E. coli outbreak near Toronto and then I believe there was also a Cryptosporidium outbreak in Saskatchewan.
Bates: Yes, there have been some outbreaks. We haven't been a part of that thinking, but I would expect that would probably tend to increase the sensitivity and the need for this type of thing in government health departments, yes.
WC&P: What's your anticipation of sort of the breadth of what's going to be done? I'm obviously more familiar with the ANSI/NSF standards. Say if one were to take a look at all the DWTU standards there, are you planning on basically coming up with a mirror set of those and then establishing your own protocols, etc., under that or adopting them or some other framework? What sort of process do you see as this rolls out?
Bates: You're really talking sort of about the structure and the makeup of the standards and it's really up to the TC. This is the kind of thing they're wrestling with to decide how to tackle it so that it's not unnecessarily duplicate of or…
WC&P: How do you work with Health Canada on this? Who's all on the committee, in other words?
Bates: There's been a couple of people involved from Health Canada and there's also people involved from the provincial departments and ministries. There are people involved from the provincial environment ministries. And the other ministries, for example, municipal and housing of Ontario that looks after the plumbing code. The city of Windsor has been involved. Health Canada is just one of the voting members on the committee, as are those other government departments.
WC&P: One of the things that Connie had mentioned was—as I'd mentioned before the earlier legislation that had come through Health Canada had been viewed somewhat threateningly—but this effort was different she pointed out because it offered an opportunity for those people within the point-of-use/point-of-entry water treatment industry to have input into that. She actually was encouraging that. How do you see the role of that group in this?
Bates: What group?
WC&P: The manufacturers and equipment producers.
Bates: Well, that's true, I think, what Constance says. That's one of the potential advantages of regulators using standards, referencing standards to complement their regulations. It has because we have a consensus process that is the basis for the standard being developed and it certainly includes the voices of the manufacturers. I can see that would be considered desirable from their point of view.
WC&P: Are they on the steering committee as well?
Bates: Yes, they're on the technical committee as well. There's more than half a dozen manufacturers on there from the U.S. and Canada.
WC&P: Would you be able to name some of them?
Bates: I guess so. I should tell you that the formal membership of the TC isn't formal yet, because the steering committee hasn't finalized the matrix yet. But those who have met and been involved include Delta Faucets, Kohler, Moen, Zenon, Envirogard—that's a few I have right here in front of me.
WC&P: How about Waterite?
Bates: Waterite was there.
WC&P: And then I assume Connie was there from Canadian WQA.
Bates: Yes, she was there.
WC&P: By the end of this month, you're going to have it formalized how you've got the committee structure set up.
Bates: Other than solidifying the matrix and I suppose they could discuss the terms of reference.
WC&P: I imagine you're looking at how others have done this similarly and whether to vary the structure of the matrix for Canadian purposes.
Bates: Yes. What you try and do is look at who the stakeholders are and they try to propose what looks like a fair balance in the makeup of the committee without it being too large so that it's not unwieldy. Then they come up with min and max numbers for each of the three or four categories and the steering committees is required to consider that and approve it.
WC&P: So what would be some of the short term goals for next year for this committee?
Bates: I haven't been at the last couple of meetings they've had. I was at some of the task force meetings. But typically, what they would want to do is make sure they all understand existing standards that are commonly used and are related to the area they're trying to develop the standard in, which would include the NSF and others standards as well as CSA's standards, which are related. So, they often would strive to all make sure they have the same information available to begin with. And that's what the task force that met yesterday was doing. Then, what they do is prepare a draft of the standards talking about the organization of each standard, as you were talking about earlier.
WC&P: You mean whether there would be one for reverse osmosis, ion exchange and carbon or other filtration?
Bates: Yes. Actually, when they've massaged the draft to the point where it looks like they're getting there, our process requires we have a couple of months period for public review.
WC&P: I believe most standards writing processes do.
Bates: Yes, and then those comments get considered, addressed and then the draft document can be finalized by the TC for formal approval. Typically, to be honest, the process for developing a standard like this in a new area, or new product, can take 18 months to three years, depending upon how much work there is and how much urgency the committee feels and how much difficulty they have reaching consensus. That's probably what would happen.
WC&P: If you were to be speaking to a group of the membership of say the Canadian WQA, what would you recommend to them in this process?
Bates: What do you mean?
WC&P: How they should view this process, etc.
Bates: Well, the WQA is involved. They've been at the table, as you know. And the other one as well, the CWWA, has been involved. They've sat at the table as well. The structure of our committee allows for voting and non-voting members. There would likely be quite a few associate, or non-voting, members as well that want to be aware of what's going on and contribute input into the process. It's meant to be an open and inclusive process based on consensus of the stakeholders involved and I think they know that.
WC&P: Who's represented CSA at the last couple of meetings?
Bates: CSA isn't represented in terms of a member. We don't have a voting membership. But typically, we'll have staff there obviously from the standards side because we administer the process. So, Abraham Murra is the project manager from Standards. Ann Jabean is the program manager, so Jabean (sp?) is his boss. And then there would probably be a couple people in Certification who would be involved in certifying products, such as Marco, for example.
WC&P: Who would be the best person for readers to contact with questions on this?
Bates: Abraham Murra. He can be reached at (416) 747-4186 or firstname.lastname@example.org
WC&P: Well, I think that about covers it.
Bates: Yes, I think so. It's nice to have the opportunity to have the interview.
Bates can be reached at CSA International at: +1 (416) 747-4270