The Water Directive (EU) 2020/2184 introduces a series of responsibilities and duties - on the managers of water distribution within 'priority buildings' (public and private facilities which include hotels, restaurants, gyms and spas) - in terms of assessment and risk management relating to the quality of water intended for human consumption.
The Istituto Superiore di Sanità (ISS), in its guide on how to guarantee the safety and quality of drinking water, also offers useful recommendations to condominium administrators in 'non-priority' private buildings. An in-depth look.
1) Water quality. Water Directive and Legislative Decree 18/2023
Water quality regulations intended for human consumption has been updated at European level with the Water Directive (EU) 2020/2184, implemented in Italy through Legislative Decree no. 23 February 2023. 18, in force from 21 March 2023. The main changes, compared to the previous legislation (in Italy, Legislative Decree 31/2001):
- changes to the nature and parameter values of water intended for human consumption. Some limits to existing chemical parameters are modified, new parameters to be monitored are introduced and others previously regulated are eliminated (e.g. Pseudomonas aeruginosa)
- risk assessment through 'water safety plans'
- assessment of risks related to distribution inside buildings
- effective and transparent communication to citizens
- improving access to water
- minimum hygiene requirements for materials intended to come into contact with drinking water
- introduction of mandatory training for water system managers, plumbing and other professionals.
2) Responsibility
The responsibility to maintain water quality intended for human consumption up to individual user points is attributed to the Internal Distribution Water Manager (GIDI). That is to say, depending on the case:
- 'the owner, the owner, the administrator, the director or
– any person, even if delegated or contracted
– responsible for the drinking water distribution system inside public and private premises, located between the point of delivery and the point of use of the water' (Legislative Decree 18/2023, article 2.1.q).
3) Priority buildings, risk assessment and management
The properties'large, for use other than domestic, or parts of such buildings, in particular for public use, with numerous users potentially exposed to risks related to water' – identified as 'priority buildings' (Legislative Decree 18/2023. Articles 2.1.i, 9, Annex VIII) – are subject to:
– development of a 'water safety plan', or a self-monitoring and risk management plan by the Internal Distribution Water Manager as identified above, which includes
– monitoring compliance with the chemical parameters (Annex I) of the water from the point of entry to the building to the user points (i.e. taps. Legislative Decree 18/2023, article 5, Annex I) and
- risk assessment, which varies in relation to the type of building and the risk class, according to the priorities indicated in a specific report by the Istituto Superiore di Sanità. (3)
Water managers of internal distribution must insert the documents relating to risk assessment and management, by 12 January 2029, into the AnTeA system (Dynamic Territorial Registry of Drinking Water). Providing for their review and possible updating every six years.
3.1) Priority buildings, public and private structures
Priority buildings They include:
- residential and semi-residential health, social-health and social-welfare facilities
- hotel accommodation facilities
- penitentiary institutions
- campgrounds
- gyms and sports centers, fitness and wellness
- passenger transport ships equipped with water desalination systems
- stations and airports
- public and collective catering, including public and private company and school canteens
- educational institutions equipped with sports facilities (with unacceptable derogation in favor of others, ed.)
- other structures for collective use (i.e. bathing establishments).
4) 'Non-priority' buildings, ISS recommendations
Risk assessment however, it is not required for 'non-priority' buildings such as homes, offices, shops and related condominiums. The report from the Istituto Superiore di Sanità also recommends applying general prevention and control measures in these buildings. Better yet, organize a water quality control plan which should include, in particular:
- a check for the presence of Legionella and / or Legionella pneumophila biennial in nature
- checking for any lead contamination
- the adoption of preventive and corrective measures, proportionate to any food safety risks encountered.
Maria Grazia Sangalli, Maria Ada Marzano, Dario Dongo
Footnotes
(1) Dario Dongo and Ylenia Patti Giammello. Drinking water, universal law and the EU directive. GIFT (Great Italian Food Trade).
(2) Giulia Pietrollini. Implementation of EU directive 2020/2184 on the management of drinking water. GIFT (Great Italian Food Trade).
(3) ISS. ISTISAN Report 22/32 – Guidelines for the assessment and management of water safety risk in the internal distribution systems of priority and non-priority buildings and in certain ships pursuant to Directive (EU) 2020/2184 http://tinyurl.com/ypjp7tbp
(4) See the document cited in note 3, paragraph 8 (Recommendations for non-priority buildings in class E)
Supreme Court lawyer
Maria Ada Marzano
Veterinarian specialist in inspection of food of animal origin and research doctor in animal nutrition and food safety.
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
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