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Frequently asked questions

Why do I need to register my recycled water scheme?

A register of recycled water schemes is kept to provide information to regulators and the public about where water recycling activities are occurring.

All recycled water providers must register their schemes with the regulator as follows:

  • schemes in existence before 13 May 2014 – by 1 July 2014
  • schemes that begin the supply of recycled water after 13 May 2014 and require an approved plan – before beginning to supply recycled water
  • schemes that begin the supply of recycled water after 13 May 2014 but do not require an approved plan – three months after first beginning to supply recycled water.

Download the Recycled Water Scheme Registration Application form (PDF, 153.3KB).

The decision tree (PDF, 113.6KB) may help determine whether you are a recycled water provider for the purpose of the Act. It may help you determine if your scheme needs to be registered and/or require an approved RWMP.

If you are still unclear, please contact the Queensland Water Supply Regulator (QWSR) on 07 3199 4856.

Am I a recycled water provider and do I need to register my scheme?

A recycled water provider is an entity that:

  • owns infrastructure for the production and supply of recycled water; or
  • another entity prescribed under a regulation, that owns infrastructure for the supply of recycled water. For example, the owner of a pipeline supplying recycled water from one entity to another may be prescribed under a regulation to be a recycled water provider.

Most recycled water providers are local governments. However, in some cases recycled water schemes may operate in sequence, when an entity obtains their source water from a registered service provider, such as a local government. In this case, the entity may not necessarily be required to register as a service provider themself, but if they obtain sewage or effluent from a registered service provider and undertake treatment to improve the water’s quality prior to reuse, they are captured as they are in scope of the Act and therefore must register their scheme.

Other entities may also be considered recycled water providers under the Act, if for example they produce and supply recycled water sourced from wastewater (e.g. Industrial Process Water). The term wastewater under the Act means the spent or used water generated on premises from industrial, commercial or manufacturing activities, or animal husbandry activities, other than spent or used water generated from an agricultural activity; or a resource activity as defined under the Environmental Protection Act 1994, section 107

It should be noted that recycled water sourced from wastewater is only regulated when it is supplied to another entity for reuse, where the other entity is not a related entity. Wastewater is not captured but the Act if:

  • it is not supplied to another entity, that is, if the wastewater is used by the entity generating the recycled water then it does not fall under the jurisdiction of the Act.
  • it is supplied to an entity prescribed under a regulation as a related entity to the entity that produces the recycled water. Currently there are no related entities prescribed in the Water Supply (Safety and Reliability) Regulation 2011.
  • it is generated from an agricultural activity or a resource activity as defined under the Environmental Protection Act 1994, section 107. Spent or used water generated from these activities do not meet the definition of Wastewater in the Act.

Recycled water sourced from greywater, coal seam gas, stormwater or desalinated water are not in the scope of the Act, unless these sources are blended with a source of recycled water, which is covered by the Act, such as sewage or effluent sourced from a service provider’s sewerage or wastewater.

The decision tree (PDF, 113.6KB) may help you determine whether you are a recycled water provider for the purpose of the Act.

Do I need an RWMP?

Does my recycled water scheme require an approved recycled water management plan (RWMP)?

Under the Water Supply (Safety and Reliability) Act 2008, recycled water providers are required to have an RWMP approved by the regulator before supplying recycled water to a recycled water scheme, if

  • the scheme is a critical recycled water scheme; or
  • the recycled water is supplied to augment a supply of drinking water; or
  • the recycled water is supplied to premises by way of a dual reticulation system; or
  • the recycled water is supplied for use in irrigating minimally processed food crops; or
  • the recycled water is supplied for a use prescribed under a regulation.

Who is required to register as a service provider? Do I have to be a registered service provider to be a recycled water provider?

A Service provider is an entity registered under the Act as a service provider for a water or sewerage service. The following entities must, before starting to provide a water or sewerage services, apply for registration as service provider:

  • a local government that owns infrastructure for supplying water or sewerage services;
  • a water authority that owns infrastructure for supplying water or sewerage services
  • each person who is either:
    • the relevant infrastructure owner, who is the owner of one (1) or more elements of infrastructure for supplying a water or sewerage service for which a charge is intended to be made; or
    • the "prescribed related entity" that is prescribed under a regulation as a related entity of the relevant infrastructure owner. The prescribed related must be nominated by the relevant infrastructure owner to operate the relevant infrastructure to supply the service, whether before or after the relevant infrastructure owner becomes the owner of the relevant infrastructure.

However, a service provider does not include an entity providing a service supplied by infrastructure, if one of the following applies:

  • the infrastructure is used solely for mining purposes, or
  • the service is used only by the owner of the infrastructure or the owner's guests or employees including, for example, guests at a resort, or
  • the owner of the infrastructure is a body corporate for a community titles scheme under the Body Corporate and Community Management Act 1997, and the service is used only by occupants of lots under the scheme

Owning infrastructure for the production and supply of recycled water does not in itself qualify a person or entity as a service provider, unless the person/entity also owns other infrastructure for supplying a water or sewerage service.

For further clarification regarding whether you are required to register as a service provider, contact the QWSR on 07 3199 4856

If I get effluent from a council and treat it, do I need to register my recycled water scheme?

Recycled water under the Act includes sewage or effluent sourced from a service provider's sewerage that's intended to be reused. If the council from which you obtain the effluent is a service provider and you further treat the water in order to improve the quality, it is likely that you would meet the definition of a recycled water provider, and therefore be required to register your recycled water scheme (see the decision tree (PDF, 113.6KB)).

If you simply maintain the water quality (e.g. chlorination) or further treat the water for reasons other than to protect public health (e.g. filtration to protect infrastructure), then you may not fall in the scope of the Act. If this situation applies to your scheme, it is recommended that you contact the regulator on 07 3199 4856 to obtain further advice.

When I register my scheme, what is meant by source water?

When you complete your application form for registering a RW scheme, you will see a section titled source water. Source water is the water that your scheme obtains before treatment. As an example the Source water section may be completed as “The sewerage network to the XYZ Treatment Plant including both domestic sewage and industrial trade waste.” Or “Crushing, Milling and Processing of Sugar Cane.”

My industrial process creates excess spent wastewater, which is only re-used onsite. Am I required to register or submit an RWMP application?

If the spent wastewater is

  • not sourced from sewage or effluent from a service provider, and
  • not supplied to another unrelated entity,

then you will not be required to register or have an approved RWMP.

If you are unsure whether the entity supplied to is a related entity, please contact the regulator on 07 3199 4856.

Do I need to register a recycled water scheme for the use of service water in my sewage treatment plant?

The term service water is often used to describe water that is used for maintenance of a sewage treatment plant, for example as backwash water. This may include water that is treated or partially treated water from that sewage treatment plant. The Department of Justice and Attorney-General has jurisdiction under the Work Health and Safety Act 2011 in the circumstances when effluent or partially treated effluent is used by treatment plant workers (i.e. no contact by the general public) only within the processes at the sewage treatment plant. A scheme that uses effluent or partially treated effluent only for service water does NOT need to register or submit an RWMP application. If the service water is used for any other purpose on the site i.e. garden irrigation, hardstand washdown, etc, then the service provider must apply to register the scheme.

If I am just disposing effluent from my sewage treatment plant onto land or to the environment, do I need to submit an application to register my scheme?

You will not be required to register your scheme if treated effluent/recycled water is not considered to be reused. If, as the owner of sewage treatment infrastructure, you are concerned your case does not precisely fall into the scenarios outlined below, please contact the QWSR for further advice on 07 3199 4856. The following is provided as guidance to determine whether or not your scheme will require registration. 

In any of the following situations, sewage or treated effluent sourced from a service provider’s sewerage infrastructure may be considered to be reused and would require registration as a recycled water scheme under the Act:

  1. discharge to a public area or commercial area such as sporting facilities and sports grounds, golf courses, cemeteries, show grounds, school grounds, day care centres, kindergartens, bowls clubs, botanical gardens, racecourses, commercial ornamental gardens, retail nurseries or flower farms
  2. discharge to an anthropogenic/constructed wetland(s) or water body(s) that contain public walkways, viewing platforms such as for the observation of water birds or wildlife
  3. return of recycled water to within the building envelope of a premises
  4. irrigation of gardens including shrubs or trees using commercial irrigation systems on commercial property including sewerage treatment plant sites that may have public visitors
  5. dispersal above ground in areas used recreationally, designated as picnic areas or in areas where access is encouraged to the public such as walking tracks or concrete footpaths, play equipment
  6. irrigation of heavily processed food crops, which includes but is not limited to sugar cane, cocoa, tea, coffee, cereal crops (wheat, rice and corn) grown for flour production and crops grown for oil production such as sunflower, canola and flax seed
  7. dispersal in areas where the vegetation is used for livestock feed, including pasture, stock feed, fodder crops
  8. dispersal to retail or commercial premises used for silviculture, hard wood plantations, turf farms, forestry, woodlots, cotton, and carbon sequestration.

For the following treatment facilities that are owned by a service provider:

  • an on-site sewerage facility that has chief executive approval or a dry-vault toilet that has approval under the Plumbing and Drainage Act 2002  
  • a sewage treatment plant (including environmentally relevant on-site sewerage facility and sewage treatment works), the operation of which is an Environmentally Relevant Activity under the Environmental Protection Act 1994
  • Other sewage treatment facilities that do not have approval under the Plumbing and Drainage Act 2002  that have a daily peak design capacity of less than 21EP, and treat sewage sourced only from individual toilet blocks

Where sewage or effluent is intended only to be discharged into, or disposed of in the environment, it may not be considered reuse under the Act and would therefore not require registration:

  1. dispersed over a specific land application or disposal area (commonly called a "land application area") that does not have public access or where public access is not encouraged; or that is an area that is heavily vegetated; or an area that is vegetated and steep sloping that is not easily accessible to the public; and/or
  2. discharged to a designated waterway.

If I have registered my scheme and I do not require an approved RWMP, what water quality requirements do I need to meet?

Previously a recycled water provider could apply for an exemption from preparing a recycled water management plan. The exemption approval notice would still detail water quality requirements that need to be met. There are no exemptions under the new framework, however all schemes will need to be registered.

Recycled water providers still have general obligations to ensure that recycled water is fit for use. All recycled water schemes must comply with the Public Health Act 2005, which contains provisions that complement the Water Supply Act. Recycled water can be considered a ‘public health risk’ under the Public Health Act 2005 if its supply could impact on public health. It is an offence for a recycled water provider to supply recycled water that they know, or reasonably ought to know, is not ‘fit for use’. Practices such as risk assessment and documentation processes are an important step in demonstrating that recycled water is fit for use. Queensland Health will be responsible for overseeing that recycled water supplied is fit for use, in all lower exposure risk uses under the Public Health Act 2005.

I currently have a development permit for my sewage treatment plant; do I need to register my recycled water scheme or apply for an RWMP?

Although your sewage treatment plant operates under a development permit, you may also be captured by the Act (refer to the decision tree (PDF, 113.6KB)) and be required to register a recycled water scheme and or have an approved RWMP.

The conditions of a development approval are intended to ensure sustainable development, and address matters such as management of environmental impacts associated with construction and operation of the treatment plant.

RWMP applications are required to demonstrate that potential risks to public health have been addressed and can be adequately managed.

I've got a greywater treatment system; am I required to register a recycled water scheme or to have a recycled water management plan?

Under the Act, recycled water includes sewage or effluent sourced from a service provider's sewerage; and other wastewater as defined by the Act. Greywater does not meet the definition of recycled water under the Act and therefore the scheme does not fall within the jurisdiction of the Act. Greywater schemes do NOT need to be registered as a recycled water scheme and do not require an approved RWMP.

Greywater is defined in the Plumbing and Drainage Act 2002 as wastewater from a bath, basin, kitchen, laundry or shower, whether or not the wastewater is contaminated with human waste.

Note that when the Act commenced, recycled water included greywater sourced from a large greywater treatment plant. The definition was amended to exclude greywater, commencing from 23 May 2010. Regulatory guidelines and other documents produced prior to this date may still refer to the superseded definition that includes greywater.

For information about greywater use and approvals, refer to the Department of Housing and Public Works website.

The local sewage treatment plant discharges treated effluent into a local waterway. I have approval to use water from this waterway downstream from the sewage treatment plant for irrigation of crops. Do I require an approved RWMP?

You will not be required to have an approved RWMP for the use of this water. The owner of the sewage treatment plant may be required to hold an RWMP or an exemption only if the treated effluent is supplied directly to you, or another end-user. As the sewage treatment plant is merely disposing of the effluent into the environment, they are not considered to be 'supplying' recycled water for the purpose of the Act. However, the entity responsible for the treatment plant is likely to have obligations under other legislation, such as the Sustainable Planning Act 2009. You may also require other approvals to extract water from the waterway.

Applications and approvals

When do I need to submit an application for approval of an RWMP?

Recycled water providers are required to have an RWMP approved by the regulator before supplying recycled water to a recycled water scheme, if:

  • the scheme is a critical recycled water scheme; or
  • the recycled water is supplied to augment a supply of drinking water; or
  • the recycled water is supplied to premises by way of a dual reticulation system; or
  • the recycled water is supplied for use in irrigating minimally processed food crops; or
  • the recycled water is supplied for a use prescribed under a regulation.

When designing a new scheme, you should allow sufficient time for an application process. Note, that the regulator must consider each application for approval of the RWMP and make a decision within 80 business days. If additional information is required by the regulator to assess the application, the 80 business days starts after the additional information is received by the regulator.

Recycled water schemes that intend to augment a drinking water supply, must obtain approval of the validation program before making an application for the approval of the RWMP. The regulator must consider the application to approve the validation program within 30 business days. If additional information is required by the regulator to assess the application, the timeframe starts after the additional information is received by the regulator. Futhermore, a drinking water quality management plan for the water storage or the drinking water service receiving recycled water, will need to be developed and approved before the RWMP for a recycled water scheme augmenting a drinking water supply can be approved.

Do I need to have an approved RWMP if I do not irrigate my crops/plants with recycled water when they are fruiting?

If a recycled water scheme is supplying water for the irrigation of minimally processed food crop it must have an approved RWMP and must comply with the water quality standards for recycled water as prescribed in section 18AG of the Public Health Regulation 2005 (PHR).  The standards are the classes of recycled water stated in schedule 3E of the PHR.

The definition of “minimally processed food crop” is included in the section 18AB of the PHR. This states that minimally processed food crop means a crop for a food product that may be eaten raw or will be subjected to a minimal food process only, such as washing, cutting, peeling and packaging. Food crops listed in Schedule 3E of the PHR have generally been categorised by the potential for contact between the edible portion of the crop and pathogens or contaminants in recycled water or receiving soils.

Some types of crops, i.e. perennial crops with produce grown away from the ground, e.g. grape vines, olive trees, apple trees, citrus trees, pear trees, stonefruit trees (apricots, cherries, peaches, plums, nectarines), banana trees, avocado trees, have very little potential for contact between the edible portion of the crop and pathogens or contaminants in recycled water or receiving soils, if the recycled water is not used to irrigate the crop when it is under flower and/or fruit.

If a scheme irrigates the above types of crops and wishes not to be considered as irrigating a minimally processed food crop, the crop must never be exposed to recycled water whilst under fruit, flower or at any time while producing the edible part of the fruit. The recycled water provider must contact the regulator to discuss their particular circumstances. The regulator will decide on a case-by-case basis if the crop is considered a minimally processed food crop, taking into consideration any management controls employed by the user of recycled water such as withholding periods or alternative potable supply. For example, a user that irrigates grape vines with recycled water during periods when no grape flowers or fruits are present, and then later substitutes recycled water with another appropriate water source prior to the appearance of flowers, would not be considered to be irrigating minimally processed food crops.

Do I have to engage a consultant to prepare an RWMP?

The Act does not mandate the use of consultants or specifically qualified persons to prepare RWMP applications. However, the recycled water provider should take into consideration that some recycled water schemes can be complex, and the necessary documentation may require significant expertise in a range of areas. You should consider the timeframes required to have your plan approved and remember that plan approval is required before supplying recycled water to some uses.

How much is the application fee?

Under the Act, fees for certain applications may be prescribed under a regulation. However, no fees are currently prescribed for submitting an application for approval of an RWMP.

Are there any tools available that assist in developing a risk-based approach for the management of a recycled water scheme?

We've prepared templates to help develop an RWMP (DOC, 1.7MB)in accordance with the Act.

Additionally, the Water Services Association of Australia (WSAA) has developed a continuous improvement tool (Requality) that can be useful for ongoing improvement of a scheme once approved. This tool can be used to assess progress against the twelve elements in the Australian Guidelines for Water Recycling Framework for Management of Recycled Water Quality and Use.

Can I get a pre-approval of my RWMP or an in-principal approval before I start constructing the scheme?

The regulator cannot pre-approve an RWMP for a scheme that has not commenced producing recycled water, as validation of scheme performance is an essential requirement of an RWMP or exemption application. There is no legislative mechanism to pre-approve an RWMP.

I have several recycled water schemes. Can I put them all in the one RWMP? Do they all need to be registered separately?

Multiple recycled water schemes may be included in a single RWMP only if there are connected elements of infrastructure between the schemes. This includes treatment systems, piping or storage. In addition, the connected infrastructure must form part of the scheme owned by the recycled water provider or other responsible entity for the scheme (if a multiple entity scheme).

Recycled water schemes that have an end-user in common, but are not otherwise connected by infrastructure, are not eligible to operate under a single approved RWMP. This applies even if, for example, both schemes discharge via separate pipelines to the common user's storage dam. Each scheme may have varying individual requirements under an approval and may be subject to other regulatory requirements.

The same information can also be taken to apply to scheme registration. You must apply for registration of each recycled water scheme to the regulator using the Recycled Water Scheme registration application form (PDF, 153.3KB). To enable the regulator to register a recycled water scheme, details should be provided for each scheme, including:

  • the scheme’s name (this is normally related to the name of the STP) and contact details;
  • the name of the recycled water provider for the scheme (most schemes); and for a multiple-entity recycled water scheme (if declared), the scheme manager and each recycled water provider and any other declared entities;
  • the location of the infrastructure for the production or supply of recycled water under the scheme;
  • the source water used for the production or supply of recycled water under the scheme (this is the source of water being treated e.g. sewage catchment or industrial process;
  • the uses for the recycled water.

Please also refer to the above question regarding registration.

I have a treatment plant that produces two different classes of water quality which is supplied to two separate users. Can I apply for one RWMP that covers the supply to both users?

Where most of the infrastructure for the production of the recycled water is the same, your scheme should operate under a single approved RWMP, which can address multiple uses with varing water quality criteria. It should also be registered as one scheme. However, if your scheme supplies recycled water to multiple uses, only part of the scheme that supplies to uses that require an approved RWMP (i.e. augment a drinking water supply; dual reticulation or irrigation of minimally processed food crops) will be required to be detailed and approved in the RWMP.

I receive recycled water from a council's sewage treatment plant and further treat the water. Is this a multiple-entity scheme?

No, only a critical recycled water scheme can be a multiple-entity scheme.

If the regulator has no reason to declare your scheme critical, you cannot be a multiple-entity scheme, even if your treatment infrastructure is connected to another entity's infrastructure. Each entity is responsible for having its own registration or if required approved RWMP.

It is recognised that where two schemes abut each other, there may be difficulties in determining what information should be placed in an application, especially for downstream entities treating effluent to Class A+ recycled water. In these cases, the downstream entity will need to demonstrate that they have met all the regulatory requirements, including required log reductions. Downstream entities are encouraged to speak to the provider of their source water in order to obtain sufficient information for their application.

Further guidance is provided in the Recycled Water Management Plan and Validation Guidelines (PDF, 884.6KB).

How are applications for an RWMP assessed? How long does it take to obtain approvals?

RWMP applications must be supported by enough information to enable the regulator to make a decision. The regulator will assess the application against the requirements of the Act and relevant regulatory guidelines, taking into account any applicable water quality standards, the intended uses and the potential public health risks associated with the scheme. If insufficient information is contained in the application, the regulator may issue a notice requesting additional information. This will affect the decision timeframes.

Specifically, RWMP applications are assessed against the relevant criteria detailed in Chapter 3 of the Recycled Water Management Plan and Validation Guidelines.

The regulator must make a decision on the application within 80 business days after receiving an application for an RWMP. As a thorough assessment against all criteria is required, if the regulator seeks additional information, those 80 business days recommence after the requested information has been submitted.

How long does my recycled water scheme have to be registered for?

Registration of schemes is currently a one off process and registration is kept in perpetuity. If you know the the details of your registration have changed (such as new uses for the recycled water) or if the scheme is closing, you should complete the Recycled Water Scheme Registration form and update these details.

When do I need to change details in my scheme registration?

There is no requirement in the Act for a recycled water provider to regularly review their registration details. However the regulatory will publish on a regular basis some details of the registered recycled water schemes. It is recommended that you review the details of your scheme registration yearly.

What is the duration of an approved RWMP?

An RWMP is issued in perpetuity, or until otherwise suspended or cancelled under applicable provisions of the Act. Audits and regular reviews are relied upon to ensure an RWMP remains current and relevant to the scheme's operating conditions. Furthermore if the regulator believes it is necessary to protect public health, or to ensure continuity of a critical supply where applicable, the regulator can ensure required changes are made. Further information is provided in Section 5.5 of the Recycled Water Management Plan and Validation Guidelines.

What conditions may be imposed on approval of my RWMP?

The conditions imposed on approval of your RWMP may include, but are not limited to the following:

  • specifying the water quality criteria that must be met
  • how and when to notify the regulator of a noncompliance of water quality criteria
  • frequency of monitoring
  • when a supplementary sample is required
  • maintenance and calibration of monitoring instruments and equipment
  • record keeping of test results
  • how and when to notify the regulator of an incident
  • when you must stop supply to an end user
  • when and how to notify the regulator in regard to unscheduled stoppages, permanent stoppages and any other changes in circumstances
  • the requirement to submit an annual report.

Water quality criteria and monitoring for schemes requiring an approved RWMP

How are the approved water quality criteria determined?

Water quality criteria are set to protect public health by ensuring hazards are reduced to an acceptable level. The appropriate water quality is determined by the level of human exposure associated with the intended end uses for the recycled water, with consideration of on-site control measures in place for minimising exposure. Recycled water schemes that carry a high likelihood of human exposure or ingestion of the water are required to have the highest level of treatment.

Mandatory minimum water quality standards for certain recycled water uses, where recycled water is derived from sewage or effluent sourced from a service provider's sewerage, are identified in the Water quality guidelines for recycled water schemes (PDF, 511.1KB) and the Public Health Regulation 2005.

For all recycled water schemes, the recycled water provider nominates the quality of water proposed to be supplied under the scheme in the RWMP. The regulator then sets water quality criteria as part of the conditions of approval. The criteria are based on information provided in the application that demonstrates that the water quality to be supplied is suitable for the use and that risks to public health have been analysed and can be sufficiently mitigated. The regulator may also refer to national and industry guidelines in determining appropriate water quality criteria.

There are no predefined water quality criteria for recycled water sourced from wastewater. Criteria for these schemes are set on a case-by-case basis, as wastewater can have great variability in the concentration of pathogenic microorganisms and other hazards. The Australian Guidelines for Water Recycling (Phase 1, 2006) provides guidance on determining appropriate water quality targets. It is recommended that the recycled water provider contact the regulator on 07 3199 4856 to discuss the criteria likely to be applied.

What is the point of supply?

The point of supply is a definition used to describe the point at which the monitoring of the final water quality is undertaken on a regular basis, and where the water quality criteria apply. Recycled water at this point must be representative of the water that is supplied to the user, and it should be as close as practical to the physical point where responsibility for recycled water transfers to the user.

Where the point of supply cannot be located in close proximity to the physical transfer point, evidence should be provided that there is no significant deterioration of water quality between the two points. If there is any deviation from the required water quality these must be clearly explained in your application.

If my water quality criteria for irrigation of minimally processed food crops require Class B recycled water, what do I need to monitor for?

Minimum water quality standards for classes of recycled water sourced from sewage or effluent are set in the Public Health Regulation. As a minimum, Class B recycled water must be monitored for Escherichia coli on a weekly basis. If other parameters are identified as potential hazards of significance to public health in the RWMP, these may be included as part of the water quality criteria set in the conditions of approval. Water quality criteria may also include other parameters the regulator believes need to be monitored to protect public health.

Can I use any laboratory to undertake analysis of my recycled water samples?

Analysis of all recycled water samples (irrespective of whether the samples are collected for validation or verification purposes) should be undertaken at a laboratory that is accredited by the National Association of Testing Authorities (NATA) for the relevant analysis methods.

However, we have recognised the logistical and financial difficulties this may present. If a recycled water provider chooses not to use a NATA accredited laboratory, or conducts 'in house' testing, the recycled water provider should supply documentation of the methodology for the analysis — including the quality assurance (QA) and quality control (QC) procedures used to perform this analysis.

Can I use commercial test kits as part of my sampling regime?

Commercial testing kits for detection of E.coli by presence or absence only are not suitable for recycled water monitoring as the majority of water quality standards are quantitative. However, you may choose to use them as part of your operational monitoring regime.  However, please be aware that there are limitations on the suitability of commercial testing kits for detection of E.coli in effluent/wastewater.

The quality of recycled water produced by your scheme will determine if you can undertake 'in house' testing using commercial E.coli testing kits for the purpose of final water quality monitoring. If you wish to use commercial E.coli testing kits for validation monitoring please contact us on 07 3199 4856 to discuss, noting the following:

  • If your scheme produces Class A+ water, the Regulator does not accept the use of commercial E.coli testing kits.
  • If your scheme produces Class A and/or B recycled water, you can undertake 'in house' testing using commercial E.coli testing kits as long as the QA/QC requirements discussed below are met.
  • If your scheme produces Class C or D recycled water you may not be able to use commercial E.coli testing kits due to the kits' upper detection limits. We recommend you contact us on 07 3199 4856 to discuss your specific situation.

What are the QA/QC requirements for use of commercial test kits in approved RWMPs?

If using a commercial test kit, as a minimum, the following documentation must be available to demonstrate the final water quality data is supported by a QA/QC framework. The specific QA/QC requirements will depend on your accessibility to a NATA accredited laboratory.

If you are able to access a laboratory with NATA accreditation for the analysis (i.e. it is possible to send samples to a laboratory for commercial E.coli testing):

  • duplicate water samples should be collected on a monthly (or regular) basis with one of the duplicate samples sent to the accredited laboratory so comparison of results can be obtained.

If you cannot access a NATA accredited laboratory, you must have:

  • records associated with the QA/QC procedures/practices specified by the manufacturer's specifications and method for the commercial testing kit, and
  • training records of the 'in house' users of the commercial kits demonstrating competency in the use of the kits and interpretation of the test results.

If I am not supplying recycled water to end users, do I still need to monitor the water quality? If not, do I have to notify the regulator of the 'failure to test'?

For approved RWMPs, sampling at the point of supply and reporting of non-compliance with water quality criteria is not required if you are not supplying to any end user, unless the regulator has specifically conditioned the recycled water provider must continuously monitor when supply has ceased.

During unscheduled stoppages, it is best practice to continue monitoring the recycled water if production is still occurring. Sample results may be helpful in identifying issues that may have contributed to the unscheduled stoppages or proving that water quality has not been impacted on recommencement of supply.

You will not need to notify the regulator of the 'failure to test' due to a stoppage of supply, as lack of data for this reason is not considered a noncompliance with water quality criteria. However, you will be required to explain the missing data (e.g. not supplying recycled water from 2 September 2012 to 15 September 2012) in your next annual report.

If you scheme is only registered, must comply with the Public Health Act 2005, which contains provisions that complement the Act. Recycled water can be considered a ‘public health risk’ under the Public Health Act 2005 if its supply could impact on public health. It is an offence for a recycled water provider to supply recycled water that they know, or reasonably ought to know, is not ‘fit for use’.

For my approved RWMP, how do I calculate the annual value if the scheme has not been producing recycled water for the full calendar year?

An annual value can only be calculated once 12 months of water quality data is available. For example, if you only seasonally produce recycled water for four months each year, it will take three years to accumulate 12 months of data. For such seasonal schemes, it is likely the regulator will condition in the notice of approval that the recycled water provider must provide specific information to ensure accountability of the overall performance of the scheme, until the annual values can be calculated.

The information requested may include:

  • the number of times the water quality results exceed the actual annual value
  • the number of samples tested each year
  • the number of weeks the scheme supplied recycled water throughout the year

The Water Quality Guidelines for Recycled Water Schemes (PDF, 511.1KB) gives guidance on how annual values are calculated.

I monitor the final water quality; why do I need to demonstrate the pathogen log reductions achieved by the scheme?

The recycled water provider must demonstrate the minimum required log reductions if they are:

  • supplying class A+ recycled water or
  • augmenting a supply of drinking water and
  • the recycled water is sourced from sewage or effluent sourced from a service provider's sewerage.

Final water quality samples are only a representation of a small part of the recycled water being produced. Furthermore, only indicator organisms are utilised in the monitoring of final water quality on an ongoing basis. The approach of validating the treatment processes using Log Reduction Values (LRV) aligns with the risk based approach recommended in the national guidelines to best manage public health risks. Treatment validation demonstrates the capability of the system to effectively remove more resistant and significant pathogens, such as viruses and protozoa.

Demonstrating log reduction values also reduces the chance of overestimating the efficiency of the process, especially when there is considerable variation in the influent.

Each treatment process of the scheme is investigated separately to demonstrate there is measurable removal efficiency for target organism, which is expressed in terms of log 10 reduction values. The LRV for each treatment process can be added together to provide a total LRV for the whole process.

Requirements after approval

What is an annual report?

If you are operating under an approved RWMP you will be required to prepare an Annual report in accordance with the Annual Reporting Guideline for Recycled Water Schemes (PDF, 425.2KB).

Schemes that are only registered do not need to publish an annual report.

The purpose of an annual report is to provide the regulator with information on the overall performance of your scheme for the financial year. It is also an accountability mechanism for the users of the recycled water and the public, as the provider is required to make the report available for public inspection. The content of your annual report must include:

  • details, including the circumstances, of any noncompliance with water quality criteria that occurred during the year
  • details, including the circumstances, of any prescribed incidents that occurred during the year.

A copy of the annual report must be available for inspection by the public during office hours on business days at your office. You must also publish the annual report, unless you have a reasonable excuse.

Do I need to notify the regulator if I stop supply of recycled water to undertake maintenance?

The following only applies if you have an approved RWMP. You will only be required to notify the regulator of a shut down if there is a potential impact on the risk to public health, or if there is a possibility your scheme will not meet the required water quality on recommencement. The length of time a scheme is able to be shut down and not impact on the scheme's required water quality depends on the type of treatment technology involved and therefore varies from scheme to scheme. In general, you will not need to notify the regulator if:

  • you undertake scheduled maintenance that has been detailed as part of your RWMP or as per the manufacturer's recommendation.
  • you are ceasing supply for less than 24 hours and it is unlikely that this will have a potential impact on water quality on recommencement of supply of recycled water.

However, if notification of the stoppage is required, the form WSR011 Notice of Unscheduled Stoppage (PDF, 1.0MB) should be completed.

If you are unsure, please contact us on 07 3199 4856 for advice.

Amendments to an RWMP

When will I need to amend my RWMP?

As a recycled water provider you must ensure all documents referenced in the RWMP are kept up to date. It is also expected that all operational procedures that are referenced in the RWMP are regularly reviewed, updated and incorporated into the RWMP as a part of your continual improvement process. In most circumstances, you will not have to notify the regulator of these changes.

If you make any substantive changes to a procedure or a process, you will be required to amend the RWMP and apply to the regulator for approval of the proposed amended RWMP. These changes may be considered necessary in response to:

  • an internal or regular audit or review
  • a spot audit conducted by the regulator
  • a directive issued by the regulator (in order to protect public health or, in the case of a critical scheme, ensure continuity of supply)
  • significant scheme changes
  • an incident or emergency
  • any event that may trigger revalidation.

Examples of substantive changes could include, but are not limited to:

  • changes or replacement of treatment technology
  • changes to source water and verification monitoring programs
  • changes to operational processes that will impact or be likely to impact on recycled water quality
  • changes that could impact the log reduction capability of processes for class A+ and purified recycled water schemes
  • changes to the location and parameters of monitoring critical control points.

In addition to amendments for substantive changes to your approved RWMP, you may also request minor amendments to your RWMP. The minor amendments may include:

  • the correction of a minor error in the RWMP
  • change of scheme manager details
  • change of name of organisation
  • change of contact details
  • change of infrastructure ownership.

For minor amendments to an RWMP, the required form WSR015 Request to Amend Recycled Water Management Plan (PDF, 616.0KB)should be completed. For substantive changes, the required formWSR006 Recycled Water Management Plan Amendment Application (PDF, 600.1KB) must be completed.

My scheme currently produces Class B water and I wish to upgrade the scheme to produce Class A+ water. Do I need to revalidate?

If you upgrade the existing recycled water scheme to class A+ or higher, and intend to supply to one of the following uses:

  • augmenting a supply of drinking water; or
  • dual reticulation system; or
  • irrigating minimally processed food crops; or
  • a use prescribed under a regulation,

you will need to undertake revalidation of the scheme before supplying recycled water to a new use. Revalidation is required to demonstrate the quality of the recycled water consistently meets the water quality standard for Class A+ or augmenting drinking water supply. The methodology for revalidation is described in the Recycled Water Management Plan and Validation Guidelines (PDF, 884.6KB) in validation section. You will also need to demonstrate a log reduction specified in the Water Quality Guidelines for Recycled Water Schemes (PDF, 511.1KB).

Historic water quality data and operational data could be used to support the validation process and provide evidence of the effectiveness of the existed treatment barriers to remove contaminants of concern, but cannot be solely relied on. It could be used to validate pre-existed equipment, and critical limits for some critical control points. Historical data should be critically reviewed to ensure it is still applicable to an upgraded treatment process and operating conditions for example, temperatures, volumes and pressures.

You are encouraged to contact the regulator to discuss validation of their schemes prior to preparing an RWMP to ensure the validation program is adequate and appropriate.

Other relevant legislation

Is the Water Supply (Safety and Reliability) Act 2008 the only piece of legislation relevant to the operation of my recycled water scheme?

A number of pieces of legislation must be complied with when operating a sewage treatment plant or a recycled water scheme, which may include the Public Health Act 2005, Plumbing and Drainage Act 2002, Work Health and Safety Act 2011, Sustainable Planning Act 2009 and Environmental Protection Act 1994. The requirements of the Water Supply Act do not negate the requirements of other legislation except where expressly stated or by implication. It is the responsibility of the recycled water provider, or scheme manager where applicable, to determine and ensure compliance with relevant legislative obligations.

Last updated
6 August 2014