Having previously suffered from asbestos problems, the troubled Perth Children’s Hospital project hit a further snag in May 2016 after lead levels which exceeded the Australian Drinking Water Guidelines were found in water samples.
The extent of the problem was demonstrated in June 2017 when testing revealed only 74 percent compliance with required standards despite the introduction of a phosphate treatment which was flushed through the pipes to prevent lead leaching. A report by the state’s chief health officer last August blamed brass fittings which had corroded and were leaching lead into the water system.
This incident underscored the importance of ensuring that materials used in plumbing systems around the country meet requirements stipulated under the Plumbing Code of Australia.
For this to happen, the Watermark accreditation scheme is crucial. Administered by the Australian Building Codes Board (ABCB), the accreditation certifies that the products in question satisfy the requirements of the Plumbing Code of Australia for particular uses. Certification is mandatory for product categories which are considered a substantial risk to health. Contained in a listing maintained by the ABCB, this includes categories which are involved in delivering potable water supply or sanitation, and encompasses cold water services, hot water services, non-drinking water services, sanitary plumbing systems and sanitary drainage systems.
To enhance the scheme’s effectiveness, several changes are being rolled out.
At their core, these consolidate what previously operated as a two-tier scheme into a single level scheme which is more prescriptive in nature. The extent of this should not be underestimated. In a joint interview, John Thorpe, CEO CertMark International and Talissa Ireland who runs CertMark’s Watermark division, say the scheme has grown from 24 pages in length to just over 150 pages. Along with this, there is greater detail and clarity about the testing required and the processes which certification bodies need to follow before issuing compliance certificates.
The new scheme also involves more onerous requirements for ongoing testing and recertification. Under the changes, products will need to be re-certified either every five years or where there is a change in design, specification, raw materials or manufacturing processes adopted. As part of this, the certification body will need to test samples from the open market (e.g. in warehouses or retail outlets in Australia); inspect the production, delivery of service or operation of process and inspect management systems. In addition, less extensive surveillance will be required annually for products to maintain certification. For this, certification bodies will test or inspect open market samples and conduct desktop reviews of batch test results, complaints, non-conformities and consistency with any referenced documents.
An important point is the requirement for open market sampling. Unlike traditional batch sampling undertaken at the manufacturer’s premises (often overseas), ‘open market’ sampling involves testing or inspection of samples already in the supply chain.
This is critical. A limitation of traditional sampling is the ability of manufacturers (often overseas) to provide carefully made ‘golden samples’ for testing before substituting these with cheaper stock for shipping. Where this happens, the product which is tested for certification may not be the same as that which is purchased and ultimately used. Testing materials which are already in the marketplace sees this problem averted.
The second change involves the risk assessment processes which determine whether or not particular product categories are included in the scheme and required to have certification. Under the changes, a two-stage process will apply. First, any risks which are inherent within the category will be identified and a decision about the category’s inclusion or otherwise in the scheme will be made. Where products are to be included, further assessment will determine potential causes of product failure, the likelihood of failure occurring and the technical specifications or other information needed to mitigate failure risk.
When existing product categories were re-evaluated through the revised assessment processes, those which by majority were found to be included in the scheme include cold water services, hot water services, non-drinking water services, sanitary plumbing systems and sanitary drainage systems. Those found to be mostly excluded include fire-fighting water services, roof drainage systems, surface and subsurface drainage systems, HVAC systems, on-site wastewater management systems and on-site liquid trade systems. Most ‘appliances and fixtures’, meanwhile, were excluded from the scheme as they do not satisfy the foundation criteria or risk evaluation, are not typically under the responsibility of a licenced plumber and are not covered under the PCA.
(Even where a product is excluded from Watermark, it still needs to be fit for purpose in accordance with Provision A2.2 of the plumbing code in order to be used.)
Under a third area of change, the scope and objectives of the Watermark scheme have been tightened to deliver greater alignment with the mission and objectives of the Australian Building Codes Board and the Plumbing Code of Australia.
Under its revised objectives, the scheme aims to provide a process though which to authorise and enable the used of plumbing and drainage installations in and around buildings. From this, the products used should therefore be fit for their intended purpose and should not, throughout their serviceable life, create significant risk of injury or death, environmental degradation, water contamination, adverse effects on public and private infrastructure or wastage of resources.
To support these aims, a revised scope is based around principals to have been adopted. These specify that the installation of products or materials is to be within the function of the plumbing code, within the nationally consistent roles and responsibilities of state and territory plumbing administrators, within the responsibility of a licensed plumber and within the scheme objectives including the protection of drinking water and the non-contamination of waste.
Fourth, the revised rules will be consolidated into a single document which is independent of the plumbing code and freely available to the public.
Finally, the biggest change which will benefit plumbers, builders, architects and regulators and onsite trades is a new and improved Watermark Product Database (a database of approved Watermark projects) which delivers a better user interface and enhanced functionality. WaterMark certificates and/or products can be searched for by WaterMark licence number, licensee name, product specification, product type, brand name, model name or model identification. Further refinements are possible through additional search filters whilst detailed information is available through selection of a specific product or certificate.
This, the ABCB says, will provide an easier way for builders, plumbers and others to verify that products are certified.
According to Thorpe and Ireland, the changes will have several impacts. First, the restructuring into a single level scheme with more prescriptive requirements is likely to precipitate a levelling of the playing field amongst certification bodies and thus a levelling off of the amount of fees which are charged for certification. The more extensive and prescriptive nature of the schemes requirements, meanwhile, has afforded greater certainty for all involved.
Nevertheless, they caution that certification will become costlier. This, along with requirements for recertification every five years, may be problematic for smaller product suppliers.
“That’s not a problem for those who have the money to do it,” Ireland said, speaking of the need to recertify.
“But when you look at the smaller mum and dad companies who have this great product – unfortunately, you have this testing which would be five thousand or ten thousand dollars.
“They may have to try to come up with that cost every five years but may have only sold ten products in that five years.
“They are the sorts of things which people need to think about before going down this track. It’s not cheap to get testing done.”
In addition, Thorpe and Ireland would like greater recognition of the Watermark scheme. In one case, Thorpe says a company which had been installing water fountains for fifteen years had never been asked about Watermark until recently. In another, a sophisticated water filtration system from a European supplier was installed in a hospital before the supplier was asked about Watermark – to which the supplier responded that had not heard of the certification and were not aware prior to being asked of its existence.
“A large number of plumbing product importers are ignorant of the Watermark scheme,” Ireland said.
“These people don’t seem to know that there is a mandatory scheme for any plumbing product that goes onto a potable water supply.
“There needs to be greater awareness not just in the industry but out there in the public arena that Watermark is mandatory when they are buying a plumbing product.”
Australia’s Watermark scheme is undergoing change.
If implemented successfully, the changes should deliver a stronger scheme which better helps to deliver safe water supplies.