Meeting New Requirements

May 29, 2018

About the author: Glen Kosowski, CWS-VI, is facility assessment manager for the Water Quality Association. Kosowski can be reached at 630.505.0160 or by e-mail at [email protected].

The Water Quality Association’s (WQA) Gold Seal Certification program audits companies that distribute direct additive chemicals according to an extensive criteria list. Due to recent demand for more frequent monitoring by California state regulators, the WQA has updated its policies to conduct annual monitoring of its products to NSF/ANSI Standard 60. In doing so, WQA has upgraded testing policies that now require companies producing products that dispense chemicals into water to pass testing on an annual basis, which means an increase in quality for monitoring of certified products.

Testing & Monitoring Policies

Initial testing includes all NSF/ANSI Standard 60 test requirements along with additional formulation-dependent tests specified during the toxicological assessment. WQA requires that only the strongest concentration of each chemical be tested when multiple concentrations are distributed by the manufacturer, if made with the same chemical components and manufacturing processes. It is required that all chemicals be tested unless a technical and toxicological review determines that they can be bracketed into categories to minimize testing.

For annual monitoring, testing policies divide companies that distribute and manufacture direct additive chemicals into six different categories:

1) Manufacturer of a chemical(s) using only NSF/ANSI Standard 60-certified chemical suppliers;
2) Manufacturer of a chemical using noncertified chemical suppliers;
3) Repackager, blender or distributor of chemicals received from a certified manufacturer plant;
4) Repackager, blender or distributor of chemicals received from a noncertified manufacturer plant;
5) Repackager, blender or distributor of chemicals received from certified and noncertified manufacturer plants; and
6) Relabeler of a certified product (product not opened during relabeling process).

In terms of various annual monitoring processes, WQA requires different procedures for annual certification for the different categories:

  • Category one requires one sample of one product or one group in every plant;
  • Category two requires one sample of every product or every group in one plant;
  • Category three requires one sample of one product or one group in every plant;
  • Category four requires one sample of one product or one group in every plant;
  • Category five requires one sample of one product or one group in every plant of noncertified chemical; and
  • Category six requires no sample because the product is currently tested annually.

Finally, and most pertinently, WQA’s technical department thoroughly examines and determines the testing battery used during annual retesting. At a minimum, each chemical is tested in accordance with WQA’s annual chemical minimum test battery document.

California Regulation Changes

On March 9, 2008, California lawmakers officially revamped policies regarding water certification processes. The revamped code requires that “no chemical or product shall be added to drinking water by a water supplier unless the chemical or product is certified as meeting the specifications of NSF. Certification shall be from an ANSI-accredited product certification organization whose certification system includes, as a minimum, the following criteria for ensuring the chemical or product meets NSF/ANSI Standard 60:

  • Annual product testing;
  • Annual facility inspections;
  • Annual quality assurance and quality control review;
  • Annual manufacturing practice reviews; and
  • Annual chemical stock inspections.”

Additionally, the new code requires chemical stock inspections of direct additive chemicals certified to NSF/ANSI Standard 60 (R-14-03: Adopted Waterworks Standards 3-9-08;2008; (State of California) Article 7. Additives; Section 64590 Direct Additives).

In response to California’s recently updated NSF/ANSI standards 60 and 61 regulations, WQA has updated its product certification policies nationwide so they comply with these newly updated (and more stringent) rules regarding the auditing process.

This means that WQA now tests products annually in addition to its existing annual facility inspections of companies that distribute and manufacture direct additive chemicals, regardless of a state’s certification procedure requirements.

WQA Joins Industry Committee

In addition to the standardization of annual certification requirements to comply with California state law, WQA has recently become a member of the Drinking Water Additives (DWA) Task Group on Annual Recertification. This task group serves as a monitor of the recertification sector of the waterworks industry and is currently chaired by David Heumann from the Los Angeles Department of Water & Power of California.

The DWA Task Group on Annual Recertification meets on a regular basis to keep current with the changes in requirements of the recertification processes. These meetings guarantee that there exists within the water industry a standardized approach to the recertification process. The task group reflects an increased commitment of its members to staying current with recertification efforts within the water industry.

Active membership in this task group guarantees WQA remains ahead of the curve in terms of the requirements and regulations of the recertification process. For example, if a state makes changes to policies within the waterworks industry, the task group will meet to update and educate members on the alterations, and WQA will be able to immediately modify its policies and procedures to comply with the adjusted regulations.

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About the Author

Glen Kosowski

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