6. drinking water Quality Management System Annual report for 2008
Services Rapport annuel 2008 du
système de gestion de la qualité de l’eau potable |
That Council:
1. Receive the Drinking Water Quality
Management System Annual Report for 2008 Services;
2. Approve the delegation of authority to
Operational Top Management, as defined in the report, to approve minor
revisions to the Operational Plan as described in Document 3 of this report;
and
3. Endorse the minor wording changes, as
set out in Document 3 of this report, to the Quality Management System Policy.
RecommandationS DU Comité
Que le Conseil :
1. prenne connaissance du rapport annuel
2008 sur le système de gestion de la qualité de l’eau potable;
2. approuve la délégation de pouvoirs aux
cadres supérieurs de l’exploitation, tel qu’il est défini dans le présent
rapport, en vue de l’approbation des
modifications mineures au Plan opérationnel, tel qu’il est décrit dans le
Document 3 du présent rapport;
3. appuie les changements mineurs, tels
que décrits dans le Document 3 du présent rapport, au libellé de la Politique
relative au système de gestion de la qualité.
Documentation
1.
Deputy
City Manager's report, Infrastructure Services and Community Sustainability,
dated 23 November 2009 (ACS2009-ICS-ESD-0003).
2. Extract of Draft Minutes, 8 December 2009.
Planning
and Environment Committee /
Comité de l'urbanisme et de l'environnement
November 23, 2009 / le 23 novembre 2009
Submitted by/Soumis
par: Nancy
Schepers, Deputy City Manager/
Directrice municipale adjointe,
Infrastructure
Services and Community Sustainability/
Services d’infrastructure et Viabilité des collectivités
Contact Person/Personne ressource:
Dixon Weir, General Manager/Directeur général
Environmental
Services/Services environnementaux
(613)
580-2424 x22002, Dixon.Weir@ottawa.ca
SUBJECT:
|
drinking water
Quality Management System Annual report for 2008 Services |
|
|
OBJET:
|
Rapport annuel 2008 du système de gestion de la qualité de l’eau
potable |
That the Planning and Environment Committee and
Council:
1.
Receive the Drinking Water Quality Management
System Annual Report for 2008 Services;
2.
Approve the delegation of authority to
Operational Top Management, as defined in the report, to approve minor
revisions to the Operational Plan as described in Document 3 of this report;
and
3.
Endorse the minor wording changes, as set out
in Document 3 of this report, to the Quality Management System Policy.
Que le Comité de
l’urbanisme et de l’environnement et le Conseil municipal :
1.
Que le Conseil prenne connaissance
du rapport annuel 2008 sur le système de gestion de la qualité de l’eau
potable;
2.
Que le Conseil approuve la
délégation de pouvoirs aux cadres supérieurs de
l’exploitation, tel qu’il est défini dans le présent rapport, en vue de l’approbation des modifications
mineures au Plan opérationnel, tel qu’il est décrit dans le Document 3 du
présent rapport;
3.
Que le Conseil appuie les
changements mineurs, tels que décrits dans le Document 3 du présent rapport, au
libellé de la Politique relative au système de gestion de la qualité.
On November 28, 2008, City Council endorsed the City’s Drinking Water Quality Management System (QMS) also known as the Operational Plan (ACS2008-ICS-WWS-0020), which is in conformance with Ministry of Environment standards. The City of Ottawa obtained its accreditation as an Operating Authority by the Canadian General Standards Board on April 29, 2009 (this was conveyed to Mayor and Members of Council under a memo, Municipal Drinking Water Licences, dated August 18, 2009).
A requirement of the Operational Plan is for the QMS Representative to ensure the management review results, including identified deficiencies, decisions and action items, are conveyed to Corporate Top Management and to the Owner (through Council). The main purpose of this report is to provide the Owner with an update on the implementation and the performance of the QMS.
As the Owner of the municipal drinking water systems, Council has a number of duties and responsibilities under the Safe Drinking Water Act, which are related to sections 11, 13, 16 and 17. The duties of the Owner related to the Standard of Care are under section 19.
This section of the Act (Standard of Care) is expected to come into force on January 1, 2013. On April 6, 2009, staff delivered a presentation to members of Council outlining these duties and responsibilities during a special meeting of the Planning and Environment Committee.
As the Owner, Council can be assured that the Standard of Care under the Safe Drinking Water Act is being met by having Municipal Drinking Water Licences in place for all of its drinking water systems. The elements of the Licence include:
On August 18, 2009, the Environmental Services Department circulated a memo to Mayor and Members of Council providing them with a status update on its Municipal Drinking Water Licences. In summary, the Owner has met the first three (3) elements listed above. The City has obtained licences for all of its drinking water systems. There are 2 outstanding items that are required for the licences and they include the submission of a Financial Plan and the full scope accreditation of the Operating Authority.
The Financial Plan is a long-term financial plan intended to demonstrate sustainability and it is the subject of a separate report that will be forthcoming by Q1 2010 and will confirm that the Owner is on track for complying with the submission deadline of July 1, 2010. On April 29, 2009, the City of Ottawa obtained its limited scope accreditation as an Operating Authority. In order to receive its full scope accreditation, the Operating Authority must have a successful on-site external audit of its Operational Plan conducted by the Canadian General Standards Board. The Operating Authority is also on track for submitting its application for the external audit to the Board by April 29, 2010.
As mentioned previously, the City of Ottawa has an Operational Plan that meets the MOE’s standards, and the Operating Authority has been working since the beginning of the year to implement the operational procedures. The following table describes the QMS management structure and roles and responsibilities:
Definitions of the QMS management structure |
|
Top Management |
|
Operational Top Management |
|
Operating Authority |
Please refer to Document 1 for the associated organizational charts that further define Top Management, the Quality Management Representative and the Operating Authority.
Every year, Top Management must conduct a management review of the following items:
a) Incidents of regulatory non-compliance
b) Incidents of adverse drinking water tests
c) Deviations from critical control point limits and response actions
d) Efficacy of the risk assessment process
e) Results of audits (internal and external)
f) Results of relevant emergency response testing
g) Operational performance
h) Raw water supply and drinking water quality trends
i) Follow-up action items from previous management reviews
j) Status of management action items identified between reviews
k) Changes that could affect the QMS
l) Summary of consumer feedback
m) Resources needed to maintain the QMS
n) Results of the infrastructure review
o) Operational Plan currency, content and updates
p) Summary of staff suggestions
Please refer to Document 2 for the minutes of the management review meeting of Corporate Top Management.
In summary, there were no major issues of non-compliance or incidents of adverse drinking water tests that resulted in adverse health impacts. Compliance related issues are detailed every year in the Summary Reports that are provided to Council by March 31st of each year. The latest report was delivered to Members of Council on March 31, 2009 (2008 Summary Report) and was listed as Information Previously Distributed (ACS2009-ICS-WWS-0009) at the Planning and Environment Committee on April 14, 2009.
The Owner, Top Management and Operating Authority have all endorsed the Operational Plan and are committed to continual improvement. The management review indicated that additional resources would be required to sustain the QMS. In particular additional resources are required for delivering the Drinking Water Operations Branch asset management program. Additional resources will be identified in the 2010 operating budget pressures.
The Operational Plan is a document that is available for public review. Once the Operating Authority has obtained its full scope accreditation, the external website will be updated to indicate how the public can review the Plan. It should be noted that element eight of the Operational Plan is not available for public review as it contains confidential information regarding the risk assessment of the city’s drinking water systems.
There are no rural implications associated with any of the recommendations in this report.
Public consultation is not required.
COMMENTS BY THE WARD COUNCILLOR(S)
On November 28, 2008, City Council endorsed the City’s Drinking Water Quality Management System (QMS) also known as the Operational Plan (ACS2008-ICS-WWS-0020). It is a requirement of the Quality Management System to provide an update to the Owner (Council).
There are no legal/risk management impediments to implementing any of the recommendations in this report.
CITY STRATEGIC PLAN
This report corresponds to the Governance Priority, G1 – Increase the appropriate delegation of authority to Standing Committees, ward Councillors and staff to improve Council’s ability to provide strategic direction and reduce transactional approvals.
TECHNICAL IMPLICATIONS
N/A
This report has no financial implications.
Document 2 – Minutes of the Management Review meeting of Corporate Top Management (June 18, 2009)
Document 3 – Delegation of Authority to Operational Top Management to approve minor reisions to the Operational Plan and minor changes to the QMS policy
That staff implement recommendations 2 and 3,
as approved by Committee and Council.
Document 1
Corporate Top Management
Operating Authority
Document 2
Meeting Date: June 18, 2009
Meeting Time: 9:00 a.m. – 10:45 a.m.
Attendees: Dixon Weir, Tammy Rose, Wayne Newell, Nancy
Schepers, Allison Black (minutes)
Regrets: Lawrence
King, John Moser
Date of
last management review meeting:
September 30, 2008
Supporting documents:
·
Operational Top
Management Review minutes
·
Key Performance
Indicator (KPI) Summary
·
Power Point
presentation
i)
Introductions
ii)
Background
iii)
Status of DWQMS
Accreditation
iv)
Management Review
Items a-p Report (Key Findings)
a)
Incidents of
regulatory non-compliance
b)
Incidents of
adverse drinking water tests
c)
Deviations from
critical control point limits and response actions
d)
Efficacy of the
risk assessment process
e)
Results of audits
(internal and external)
f)
Results of
relevant emergency response testing
g)
Operational
performance
h)
Raw water supply
and drinking water quality trends
i)
Follow-up action
items from previous management reviews
j)
Status of
management action items identified between reviews
k)
Changes that could
affect the QMS
l)
Summary of
consumer feedback
m)
Resources needed
to maintain the QMS
n)
Results of the
infrastructure review
o)
Operational Plan
currency, content and updates
p)
Summary of staff
suggestions
v) New
Business
q)
QMS Policy -
proposed revision
r)
Approval process
(minor revisions of the Operational Plan)
s)
DWQMS Full Scope
Accreditation timeline
t) Report to Council (format, items to provide)
Background Discussion
The
Drinking Water Quality Management System (DWQMS) management structure was
reviewed and Operational Top Management and Corporate Top Management were
defined.
Our first stage of DWQMS Accreditation was achieved on April 29, 2009 when Ottawa became an ‘Accredited Operating Authority’ (Limited Scope – Entire DWQMS).
Limited Scope Accreditation involves a desk top audit of the DWQMS
Operational Plan only.
The Operating Authority must apply for ‘Full Scope – Entire DWQMS’
accreditation within 12 months (i.e. no later than April 2010). We must be fully
implemented no later than end of 2009 to provide sufficient evidence for the
external audit that is a requirement of Full Scope Accreditation.
Our draft Municipal Drinking Water Licenses (MDWL) and Drinking Water
Works Permits (DWWP) are undergoing final review by City staff. The MDWL and DWWP will replace the existing
Ontario Certificates of Approval for each of our drinking water systems.
Staff have
reviewed the differences between the existing Certificate of Approval process
and the new license and permit applications.
As a result the Transfer of Review Program
for water will cease and replaced with pre-approved
authorized works (watermains) under the DWWP.
Pre-authorizations must meet minimum criteria and is subject to MOE
annual inspections. This impacts on developers
and the City’s Panning & Growth Management Department, and also impacts on
where the documentation is filed.
a) Incidents of regulatory
non-compliance
i)
MOE Inspection Reports
All drinking water facilities were in full compliance with MOE
requirements during the review period, with one exception at Carp well
system. In this instance, well system
logs did not record all communication failures of the
free chlorine analyzer at the Carp Arena.
We have since revised and implemented procedures to avoid a future
occurrence. MOE has
acknowledged and accepted the corrective action[1].
ii)
Operator Certification Records
The previous management
review noted a number of expired operator licenses. Since that time, new processes have been put in place to ensure
that all operator licenses are current.
This includes a new Operator Certification
Expiry report issued quarterly by the Training Coordinator, earlier submission
of renewal documentation and informing Operators that the maintenance of valid
licenses is their responsibility.
Action
Item CTM a-ii-1 – As follow up to an outstanding action item from 2008,
arrange a joint management/Union meeting to reiterate the need for Operator
responsibility for Certification, to review our new Operator licensing policy
and to discuss management responsibility under the DWQM standard to verify
competency of Operators through tests or exams following training. |
Tammy Rose |
Dec. 1, 2009 |
iii) Water Flow Rates
All
facilities were in full compliance with permitted water flow rate limits.
iv) Water Quality Testing Records
Ontario Regulation 170/03
requires water quality testing of drinking water. Ottawa has a robust program that exceeds minimum sampling
frequency requirements. In 2008, all
requirements were met with the following exceptions: Vars
Well, Dec. 21-28 (chlorine residual tests); King’s Park Well #1 (follow up
sampling - radiological result over screening value); and Britannia &
Lemieux Is. WPPs (periodic non-functional filter turbidity analyzers which may
go undetected for a period of time).
Procedures will be put in place to ensure that these exceptions do not
reoccur (see OTM action items and action items below).
Action
Item CTM a-iv-1: Add to Operational Top Management (OTM) management review
action item c-2 in the continual improvement tracking table: Evaluate whether
dual turbidity analyzers would be beneficial in reducing the likelihood of
turbidity analyzer failure. |
Tammy
Rose |
July
31, 2009 |
Action
Item CTM a-iv-2: Inform OTM of the above noted addition to the action item. |
Tammy
Rose |
July
31, 2009 |
v) Community Lead Testing Regulation
Over 360 residences,
buildings and distribution points were sampled for lead in 2008. All drinking water systems complied with the
regulation. Minor non-compliance was
related to notification time limit for customers. Internal procedures have been revised to ensure notification within
prescribed time limits.
vi) MOE Orders
Revised MOE Orders for waste management at the Britannia & Lemieux
Island Water Purification Plants (WPP) were issued on June 27, 2008 by the
province. Full compliance was achieved
before the Aug. 31, 2008 deadline and MOE has since lifted the Orders.
MOE requires that Operations Manuals and all
documentation be in place before commissioning of new facilities. This documentation was not finalized and the
associated training not completed prior to commissioning the Waste Management
Facilities, which resulted in an MOE investigation. The manuals and training have now been completed.
vii) Environment Canada Order (Lemieux
Island WPP)
An amended
Environment Canada Inspector’s Direction was issued in 2005 for a spill of
sludge effluent from filter backwash at the Lemieux Island WPP. Compliance was achieved Aug. 31, 2008 when
we complied with the provincial order.
Environment Canada has formally cancelled its investigation into the
spill.
viii) Annual Reports
Regulatory requirements for annual & summary
reports stipulate that annual reports be made available to public, that
summary reports be provided to the Owner (Council) and that these reports be
available by the end of the first quarter for the previous calendar year. All annual reports were completed, submitted
and disclosed within the prescribed time limits. The annual reports are posted on the City’s webpage
b) Incidents of
adverse drinking water tests
Sixteen Adverse Water
Quality Incidents (AWQIs) were identified in 2008, which is a decrease from 87
AWQIs identified in 2006 and 29 in 2007.
The reduction can be attributed to the implementation of improved
disinfection strategies. All MOE notification requirements for AWQIs were met and corrective
actions and resampling was conducted for each incident. None of these incidents resulted in adverse
health impacts and none were persistent (i.e. flushing & re-sampling
resolved the issue).
c) Deviations
from critical control point limits and response actions
A total of 41
Critical Control Limit (CCL) deviations for
the Critical Control Points (CCP) within the central water treatment and
distribution systems were identified in 2008.
In all cases, MOE water quality standards were consistently met and both
water purification plants were in compliance with their Certificates of
Approval. In general, plant operators
took appropriate actions to mitigate the problems and restore the treatment
process. For 2 of the 41 events
however, operational water quality targets were not met. Further analysis is being conducted to
determine root causes and preventative measures for these two events.
It should be noted
that although operational targets were not met, the quality of the drinking
water was in compliance with the water quality regulations at all times.
d) Efficacy of
the risk assessment process
The DWQMS Risk
assessment process was reviewed in 2008 and modifications were made to list of
CCPs. Staff have recommended a more
comprehensive review in 2009, which will be conducted in November 2009.
e) Results of
audits (internal and external)
The results of the 2008 Internal Audit were reported in the last review
period. Management responses and action
items were subsequently developed for each finding. Of the ten non-conformances with the DWQM
Standard, 60% have been addressed and over half of the 59 ‘opportunities for
improvement’ have also been addressed.
Outstanding actions items will be completed by the end of 2009.
No non-conformances were
noted during the external accreditation audit (this was a desk top audit of our
Operational Plan, IERP and associated SOPs), however three minor opportunities for
improvement were suggested. These will
be addressed in the next edition of the DWQMS Operational Plan. As mentioned previously, no external on-site audits have been conducted to date.
f) Results of
relevant emergency response testing
These results
were reported in September 2008 management review report.
g) Operational
performance
Sixty-six Key Performance Indicators are being
tested to track operational performance within the Operating Authority,
addressing customer services, water distribution, water production and water
quality. Data has been gathered for
2006-2008, however targets have not yet been set. The KPIs will be refined in 2009. Staff are developing responses to any evident
negative trends (e.g. slight increase in response time to customer complaints
or water quality concerns).
Action Item
CTM g-1 – Develop targets for each Operational KPI and report at the next
management review. |
Tammy Rose |
Q1 2010 |
h) Raw water
supply and drinking water quality trends
The 2008 raw water trends were typical of past years. The current treatment process is robust is
able to deal with all fluctuations. Key
results for 2008 included elevated levels of
Crypto/Giardia in raw water in the first quarter, the first ever detection of
pesticides (in 1 of 4 samples) and the occasional detection of pharmaceuticals
in raw water. It is important to note
that Tritium results were consistently well below the current health standard.
The Provincial
standard for tritium is proposed to change from 7,000 Bq/L to a running-annual
average of 20 Bq/L, based on a lifetime cancer risk. The MOE-accredited laboratory’s analytical method detection limit
is 1,000 Bq/L, which creates a challenge.
Our annual average is currently 5-8 Bq/L (analyzed by federal Radiation
Protection Bureau – detection limit 4 Bq/L).
A current discussion paper released by the Ontario Drinking Water
Advisory Council does not include corrective action requirements.
AECL Chalk River, the
primary source of tritium, is a federal facility, therefore under federal
regulations. A remaining action item
from the September 2008 management review meeting is to meet with AECL to
ensure that Ottawa receives regular reports on discharges to the Ottawa River,
including timely reports of spills (this action item is being tracked through
the DWQMS continual improvement process).
i) Follow-up action items from previous management reviews
Seventy-five
percent of the action items from the previous management review have been
completed. Those remaining are expected
to be completed by the end of 2009.
j) Status of
management action items identified between reviews
No
new management action items were identified since the last management review.
k) Changes that
could affect the QMS
There
will only be minor impacts on the DWQMS resulting from the City reorganization.
l) Summary of
consumer feedback
Programs
are in place for receiving consumer feedback and responding to complaints.
m) Resources
needed to maintain the QMS
Our experience to
date indicates the need for additional resources to fully implement the
DWQMS. These resources are required primarily for
continual improvement of the QMS. We
have redirected existing resources to support QMS implementation, which has
created gap in asset management program delivery.
A regulatory
compliance position (non-QMS) is also being recommended. Pending the final reorganization, we
anticipate requesting an additional 3.0 FTEs in the 2010 budget.
Action Item
CTM m-1 – Identify new required resources for the DWQMS to bring forward in
the 2010 budget. |
Tammy Rose |
Oct. 31, 2009 |
n) Results of the infrastructure review
Growth related and
non-growth related infrastructure needs are considered in the annual
review. The growth related review
considered the Official Plan, the Infrastructure Management Plan (IMP), the
Development Charges study, etc.
The non-growth review included an assessment of
renewal, upgrades, optimization and reliability improvements required under the
distribution
rehabilitation, distribution operational improvements and production facilities
asset management programs. For distribution
projects we are working on better defining the needs list in order to identify
priorities.
For production projects, consistent
under-spending supports the need for additional FTEs to implement
projects. More rigor in tracking asset
management for production facilities is required. This will be achieved through the development of an asset
management strategy.
o) Operational Plan currency, content and updates
The current
version of the Operational Plan will be subject to minor revisions prior to the
fall 2009 internal audit.
p) Summary of staff suggestions
Staff
suggestions are being received and tracked through the continual improvement
process.
v) New Business
q) QMS Policy (proposed revision)
The following proposed revision to the QMS policy has been approved by
Operational Top Management:
City
of Ottawa Quality Management System Policy
The City of
Ottawa is committed to consistently delivering drinking water of the highest
quality to the people of Ottawa[2]. In particular, the City makes the following
commitments:
1.
To
provide a reliable supply of safe[3]
drinking water to the consumer;
2. To
meet[4]
or exceed, applicable
legislation and regulations;
3.
To implement, maintain and continually improve the Quality
Management System, infrastructure and
technology;
4.
To deliver excellent customer
service through responsiveness, accountability and innovation.
CTM approved the proposed change to the QMS policy.
Action Item
CTM q-1: Propose these changes to the
Planning and Environment Committee (PEC)/Council. |
Tammy Rose |
Q4 2009 |
r) Approval Process (minor revisions of the Operational Plan)
Operational Top Management
recommends that we allow minor revisions to operational plan to be made with
reduced approval/endorsement requirements.
Minor changes would be delegated for approval to Operational and
Corporate Top Management, instead of bringing forward all changes to
PEC/Council.
Substantive changes to the Operational Plan would still require full
approval by Council.
CTM
approved this approach.
Action Item:
Bring forward the proposed change to the approval process to PEC/Council. |
Tammy Rose |
Q4 2009 |
s) DWQMS Full Scope Accreditation Timeline
Our
Limited Scope – Entire DWQMS accreditation is valid for 12 months. OTM approved applying for Full Scope –
Entire DWQMS accreditation in early April 2010 to allow sufficient time to
fully implement the DWQMS.
CTM
approved the proposed timeline.
t) Report to Council (format, items to provide)
The report to
Council is to include the CTM meeting minutes and all recommendations. This should be further discussed with Peter
Hume, the PEC Chair.
Action Item –
Consult with Nancy Schepers & Peter Hume to determine best way to bring forward. |
Dixon Weir |
Q4 2009 |
i.
CTM Approvals
Corporate Top Management approved:
§
The 2009 management review summary report and
recommendations;
§
Proposed revisions to the QMS Policy;
§
The proposed change to the approval process
for minor revisions of the Operational Plan;
§
The timeline for applying for Full Scope –
Entire DWQMS Accreditation;
Delegation of
Authority to Operational Top Management to
Approve Minor
Revisions to the Operational Plan
The purpose of the proposed delegation of authority for approval is to allow for minor revisions to the Operational Plan to be approved by Operational Top Management and only seeking Council endorsement for significant revisions.
Minor revisions of the Operational Plan, or individual files making up the Operational Plan would require Operational Top Management approval, whereas all major revisions of the Operational Plan require Corporate Top Management approval and Council endorsement. Minor revisions would include updates to tables, corrections of editing errors, changes to names or terms, etc. Major revisions would involve a substantive change to one or more System Procedures.
Minor Changes to the QMS Policy
The following is the proposed revision to the QMS policy:
City
of Ottawa Quality Management System Policy
The
City of Ottawa is committed to consistently delivering drinking water of the
highest quality to the people of Ottawa[5]. In particular, the City makes the following
commitments:
1. To provide a reliable
supply of safe[6] drinking
water to the consumer;
2.
To meet[7]
or exceed, applicable
legislation and regulations;
3. To implement, maintain and continually improve
the Quality Management System, infrastructure
and technology;
4. To deliver excellent
customer service through responsiveness, accountability and innovation.
drinking
water Quality Management System Annual report for 2008 Services
Rapport annuel 2008 du système de gestion de la qualité de l’eau potable
ACS2009-ICS-ESD-0003 CITY WIDE/À L'ÉCHELLE DE
LA VILLE
In response to questions from
Councillor Holmes, Dixon Weir, General Manager of Environmental Services,
indicated the report on promoting the City’s drinking water would be coming
forward in January or February of 2010, though the specific date had not yet
been determined. He confirmed that he
would advise the Councillor once that date had been set. In response to further statements from the
Chair, Mr. Weir confirmed that the funding requirements for that report’s
recommendations would be included in the 2010 rate budget.
That the
Planning and Environment Committee and Council:
1. Receive the Drinking Water Quality
Management System Annual Report for 2008 Services;
2. Approve the delegation of authority to
Operational Top Management, as defined in the report, to approve minor revisions
to the Operational Plan as described in Document 3 of this report; and
3. Endorse the minor wording changes, as
set out in Document 3 of this report, to the Quality Management System Policy.
CARRIED
[1] MOE is now closing the loop on their required action items – acknowledging when we have completed them.
[2] Former wording: “providing safe and reliable drinking water of high quality to the consumer.”
[3] Former wording: “safe and reliable”
[4] Former wording: “comply with”
[5] Former wording: “providing safe and reliable drinking water of high quality to the consumer.”
[6] Former wording: “safe and reliable”
[7] Former wording: “comply with”