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DAM-L ANSI Position and Comments on ISO/TS/P 194 (AFNOR Proposal to (fwd)
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From: Shiney Varghese <svarghese@iatp.org>
To: dianne@sandelman.ottawa.on.ca
Subject: ANSI Position and Comments on ISO/TS/P 194 (AFNOR Proposal to
Date: Wed, 15 Aug 2001 16:57:44 -0500
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Right to Water (right-to-water@iatp.org) Posted: 08/15/2001 By svarghese@iatp.org
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ANSI Position and Comments on ISO/TS/P 194
ANSI submits a negative vote on this proposal for a new field of ISO
technical activity with the following comments:
This proposal does not take into account relevant work already underway in
existing ISO committees (for example, ISO/TC 8, ISO/TC 67 and ISO/TC 147).
ANSI considers it is mandatory that this proposal recognize and respect such
work and not try to usurped it. The ISO/TMB should ensure that whenever
these proposals are circulated for voting they reflect an understanding of
relevant existing ISO projects and a clear delineation of the relationships
between the proposed new work and existing work. If this proposal is to go
forward, it should be advanced within an appropriate existing TC, rather
than under a newly formed TC.
This would appear to be a subject more appropriate for national and local
legislation rather than international standardization.
This proposal has much too broad a scope to be really useful. It seems to
cover activities that service personnel would perform in water and waste
plants, apparently trying to ensure that these plants would all be managed
and serviced in the same way. There may be value in that from the
vendor point of view, but not from the user or operator point of view. This
is not as useful as quality standards for water and performance standards
for various treatment operations, for example, required quality standards
and secondary aesthetic standards for drinking water, and performance
standards for various unit operations, e.g. secondary biological waste
treatment, filtration, carbon treatment, etc. The French proposal does not
seem to cover any quantitative data such as these.
This proposal falls far short of the justification Guide 72 specifies should
be provided before beginning an entire new field of management system
standardization. In this specific case, ANSI has no idea how much support
for this exists among water supplier providers and governmental regulation
organizations. We also cannot judge from the information provided whether
an entire new field of standardization is needed of just another sector
guide to ISO 9001.
It is unclear whom France is considering as the "user?" Industrial,
agricultural, and consumer "users" are discussed. However, the proposed
principle subjects appear to target only the consumer. There also seems to
be an inference that national governments are "users" in the initiatives
listed under "other comments." Certainly, water transcends political
boundaries. Even in the USA, there is a long history of competition between
agencies (cities, states, tribes) over water supply. Does this proposal
envision a standard that aligns "user" with national governance?
The initiatives presented in "other comments" do not provide sufficient
substantive information. Nor do they easily direct the reader to such
information. For example, it would be helpful to have more information
regarding the Performance Indicators for the Scandinavian cities and to know
which Trade Association is referenced and how it defined "good practices."
The proposal makes reference to the "maintenance and development of the
material and immaterial patrimony of the service." This statement perhaps
does not translate well. It is unclear what France means by "patrimony of
the service." Does this mean that France wishes to address shared
responsibilities related to maintenance of aquifers? watersheds? wetlands?
Or is the translation on a less technical and more fiscal level? It is
unclear. And, the implications are very different depending on the
interpretation.
The proposal offered by AFNOR through ISO is based on existing French
standards, which in some cases may not be appropriate starting points for
international water and wastewater facility management standards,
particularly as these operations are carried out in the United States. The
documentation provided does not reference the extensive and ongoing related
activities in the U.S. and other nations. Further, the process by which a
suggested standard becomes accepted for international use is resource
intensive for those countries or organizations most likely to be affected by
the standard. Significant effort and resources will be required to integrate
the AFNOR proposal with the work currently underway in the U.S. the AFNOR
proposal may be inconsistent with the current U.S. approach to utility
operation focused in large part on water quality protection. For these
reasons we question the value of the proposal as it relates to existing U.S.
management practices.
If any lesson can be drawn from recent experience, it is that each water
system is different, in ways that depend on the physical, hydrological,
economical, cultural, and political characteristics of the place. As such,
generic standards that cover privatization agreements are
likely to seriously conflict with local needs, regional legislation, and
national standards. Moreover, several national governments have already put
in place complex standards to guide privatization efforts. England, for
example, has eleven years of experience with a complex water privatization
effort. The various difficulties encountered with privatization there have
led to significant improvements in government regulatory oversight,
standards for performance, and benchmarking - developed and modified in an
organic way.
Primarily, the stated purpose is setting quality criteria for water service
providers. This appears to closely resemble the ISO 9000 series of
documents, for quality management. These are already in place and recently
revised, so another set of quality criteria is a duplication of efforts and
redundant. Another management system does nothing to assure clean drinking
water. And if a lower cost to the consumers is the overall objective as
stated in the proposal, then another layer of bureaucracy/paperwork will not
attain that.
Then, there is the omission of several key water providing organizations,
including the World Water Council(www.watercouncil.org), Water Environment
Federation (www.wef.org), Global Water
(www.globalwater.org), Water Health International, Inc.
(www.waterhealth.com), International Association on Water Quality
(www.iawq.org.uk), Clear Water Project (www.clearwaterproject.com) and World
Health Organization (www.who.int). These organizations work through any
means available to delivery potable water, in developed as well as in
undeveloped (a.k.a. third) world countries. They stipulate the health
constraints for certain water-borne contaminants, work to purify or clean
natural water supplies, and assist the intra-country organizations in
maintaining the water supply within those constraints. At this level, a
"management system" would either hamper or confuse the intra-country
organizations and dilute (no pun intended) the efforts of the water
providing organizations.
There is also the inclusion of stormwater collection system criteria. As
evidenced in the USA, stormwater is a very poorly identified entity - in
many cases, the outfalls or sources cannot be identified. In arid areas,
stormwater, e.g. rain or snow, is never collected or treated and is
considered beneficial rather than a nuisance. If one speaks of a sewage
treatment facility, then this again falls under the ISO 9000 umbrella.
Water resources are "owned" by the country, and in the USA by the "states,"
while within the borders. Not all water authorities are privately owned, and
governments are directly involved in setting operating and testing criteria.
To specify how a country must employ good practices is definitely not
workable standard considering the variability of water development in the
world. "Good practice rules" as called in the proposal do not universally
fit all situations.
It could also be read into the New Work Item that water quality testing,
drinking water and wastewater treatment, and possibly the acceptance
criteria are to be undertaken. This definitely infringes on the
environmental policies of countries, and the mandates as to use and reuse of
water supplies. Testing criteria are usually standardized with a discipline,
and acceptance levels set by legislation and implemented by regulation. For
ISO to set acceptance levels would only result in the "lowest common
denominator"-type standards, e.g. no PCBs or dioxane in the drinking water.
This would effect nothing, as the standard would be superceded where
regulations state more stringent standards are in place, or ignored where
attaining water is the primary problem and no regulations exist.
We question AFNOR's claim that due to the experience acquired by French
water suppliers, the French standards could be easily transposed at the
international level. France is unique in that it has only two water
management companies which, coincidentally, happen to represent the two
largest water management companies in the world - Vivendi and Suez. Each is
a publicly traded company. The United States, on the other hand, has over
60,000 municipally owned and managed community water systems and over
15,000 publicly-owned treatment works. To suggest that the standards that
work for the two French companies can be easily transposed and applied to the
thousands of U.S. municipal water and wastewater treatment plants is naive
at best.
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