New sector-specific management system standard for wastewater

What is the WWMS?

In the spring of 2025, the CSA Group is planning to publish the W217 Ontario Wastewater Management System (WWMS) standard. The WWMS standard is a quality and environmental management standard, which brings together elements of the ISO 9001 standard for quality management, the ISO 14001 for environmental management, and the Ontario Drinking Water Quality Management Standard (DWQMS). Comparatively, the DWQMS (a statutorily required standard since 2009-10) draws on the ISO 9001, as well as the Hazard Analysis and Critical Control Points (HACCP) for the food industry, and also considered elements of ISO 14001 in its revised 2017 version. 

The scope of the WWMS standard is centered on the operational processes for wastewater collection, treatment, biosolids and emissions management. These operational processes begin with wastewater inputs such as sanitary sewer, combined sewer, rainfall, inflow and infiltration and surface spills; and end with reclaimed wastewater to the environment, biosolids management, odours and other emissions as outputs. This framework is supported by a combination of support processes, some of which are in-scope, and others out-of-scope in this standard. The in-scope support process are grouped in three areas (Figure 1): 

  1. operational support (i.e., initial commissioning, compliance, emergency management, and monitoring); 
  2. infrastructure renewal (i.e., asset plan, inspection and maintenance, condition assessment, asset renewal and replacement, and asset life cycle); and 
  3. business support (i.e., risk management, personnel training, management review, continual improvement and audit).   

The out-of-scope processes include: watershed planning, environmental assessments, occupational health and safety, engineering design for new development and expansions, construction and business continuity. The W217 WWMS standard is intended to apply to the operation of wastewater system physical assets, from initial commissioning until operation of those assets ceases.

Figure 1: Scope of the wastewater management standard (adaptation from work done by E. Tovilla, 2021)

Why is the WWMS standard needed?

There is significant academic research outlining evidence in support of and wide recognition of the practical value of management system standards. These standards generate positive benefits, including incentivizing ongoing performance improvements, technological innovation, improved due diligence, risk management, and increased compliance as a way to stave off regulatory liability (i.e., to counter and defend against prosecutions under environmental protection laws and regulations).  In addition, a WWMS standard can assist organization on three important aspects:

  1. Aligning infrastructure renewal with other competing interests such as roads resurfacing and reconstruction, as well as new regulatory requirements for asset management and life cycle processes.
  2. Reducing the level of effort in adapting from ISO 9001, ISO 14001, and other standards to develop a tailor-made standard for each particular organization. 
  3. Reducing the highly labour-intensive process of generating risk assessments and the level of effort for identifying and scanning for risk factors that may affect a wastewater system. 

Moreover, laws, court decisions and government interventions analyzed in prior studies suggest that governments and courts are drawing on management system standards to address municipal environmental water issues in support of public policy objectives (Table 2). The use of management system standards is intended to improve accountability, establish the necessary duty of care, and better protect against hazards to human health and the environment.

Why an Ontario-based standard? 

Although this standard was sponsored and funded by Ontario organizations with the original objective to develop an Ontario-based standard, the W217 Technical Committee made a conscious effort to make the standard applicable to any Canadian public and private wastewater system organization willing to use it. The standard makes some contextual remarks in the preface and introduction sections to contextualize why Ontario was the best suited province to develop this standard, but the main body of the WWMS standard could apply to any public or private wastewater system.   

This new sector-specific management system standard capitalizes on more than 15 years of experience since the Province of Ontario mandated a management system standard for drinking water systems in 2003 (O. Reg. 170/03, Safe Drinking Water Act). The catalyst for this decision was the Walkerton tragedy (2000), where an estimated 2,300 people became seriously ill and seven people died from exposure to microbially contaminated drinking water in Walkerton, Ont., a town of approximately 5,000 people located northwest of Toronto (Hrudey et al., 2002).  Following this tragedy, Justice O’Connor’s Inquiry recommendations (2002) included the requirement to have a quality management system. The first version of the Drinking Water Quality Management Standard (DWQMS) was published in 2017. Finally, under the O. Reg. 188/07, owners and operating authorities of drinking water systems in Ontario, had a phased approach from 2009 to 2010, to obtain accreditation of the DWQMS including licensing of their municipal water systems.

Since 2009-10, and over a span of 15 years, there has been a growing critical mass of knowledge by municipal officials, private operators, practitioners and elected officials becoming very familiar with the minutiae of management system standards. Further, in 2017, the Province of Ontario issued the DWQMS Version 2.0, with lessons learned to increase compliance performance and implementation. This critical mass of knowledge has resulted in some municipalities knowingly or sometimes inadvertently extending some of those DWQMS elements into their wastewater systems. Further, as noted in my PhD research, by 2022, there were eleven Ontario jurisdictions already adopting forms of environmental management systems (EMS) for their wastewater systems, primarily from ISO 14001, and nine municipalities in the rest of Canada (Table 1). By population, these municipalities represent nearly 18 million Canadians already relying on some form of EMS for their wastewater systems. 

An additional factor to consider when developing management system standards is the size of the organization. Most Canadian jurisdictions adopting or in the process of developing an EMS for their wastewater systems are large municipalities (Table 1). Larger organizations have the benefit of larger resources and staff to implement new policies and procedures. This is more challenging for small to medium size organizations. In Ontario, there are 444 municipalities, and according to the Association of Municipalities of Ontario, there are 39 municipalities, which have a population of 100,000 and above, 59 municipalities between 25,000 and 99,999, and the remaining 346 municipalities are less than 24,999 (AMO, 2021).  The input from Ontario regulators and small systems both from public and private organizations within the W217 Technical Committee was critical as to ensure that the W217 WWMS would be implementable by small and medium size organizations in a similar fashion as how the DWQMS was for the same 444 municipalities in 2009-10, including lessons learned since then. 

Table 1 lists in chronological order Canadian jurisdictions who have developed or are in the process of implementing some form of EMS standard for their wastewater systems using ISO 14001. For most of these jurisdictions the adoption of forms of ISO 14001 for their wastewater systems was a voluntary and proactive measure. However, three jurisdictions were mandated as a result of court decisions or provincial government action: Calgary, Winnipeg, and the Alberta Capital Region Wastewater Commission.

ONTARIO REST OF CANADA
1 York Region (2000) Quebec City (2001)
2 Durham Region (2004) Calgary (2002)
3 Richmond Hill (2006) Edmonton (2004)
4 Collingwood (2007) Winnipeg (2004)
5 City of Ottawa (2010) Nanaimo (2005)
6 City of Hamilton (2012) Alberta Capital Region WWC (2013)
7 Region of Peel (2020) Regina (2014)
8 City of Toronto (2022) Halifax Water (2015)
9 City of Barrie (2023) Metro Vancouver (2021)
10 Halton Region (2023)
11 City of Vaughan (2023)

Table 1: Canadian municipalities with EMS for wastewater systems

Canadian courts and government influence to adopt EMS for wastewater systems 

The potential for fines and imprisonment constitutes an incentive to decrease the likelihood of prosecution, and to have measures in place that will make a defence of due diligence possible if court action does arise. In addition to the cost of financial penalties flowing from convictions for environmental offences, other costs are those associated with legal representation and environmental remediation, which in some cases are larger than the penalties (Tovilla, 2020, 2021). Table 2 illustrates examples of courts and government decisions leading municipalities to adopt ISO 14001 for their wastewater systems:

Case/Year Associated Costs Comments
R. v City of Hamilton, 2000 $450,000 in fines (landfill contamination case). City entered a guilty plea. 

In 2005, top management leadership began working on an EMS for the city. 

R. v City of Calgary, 2000; and 2014 Two cases with a combined $400,000 in remediation costs. In both cases the city entered a guilty plea. Sentence included ISO 14001 certification.
City of Winnipeg, 2002 Provincial Hearing due to sewage overflow at a wastewater treatment plant (no litigation involved). Hearing recommendations led the City to proactively implement elements of ISO 14001.
EPCOR – City of Edmonton, 2003 City was charged under the Alberta EPA (potential penalties of $4.5 million). In 2004, City adopted ISO 14001 for most public works.
McLaren v. Stratford (City), 2005 Court-certified class-action lawsuit against the city. In 2010, Stratford reached a $7.7 million settlement after already spending $1.3 million in emergency relief and wastewater system upgrades. Seeking remediation from a 2005 storm event in which municipal CSOs flooded basements of residents. 
R. v City of Ottawa, 2008 $562,000 in fines and remediation costs City entered a guilty plea.

From 2006 through 2008, spills to the Ottawa River triggered public reaction (a.k.a. in the media as “Sewergate”).

Lissack v Toronto, 2008 Est. $20,000 to $100,000.  Court found city guilty. Case brought by a private resident for a storm sewer back-up that flooded his basement, leading to a court finding that the City had breached its duty of care by failing to maintain and improve stormwater management systems
Kawartha Lakes (City) v. Ontario (Environment), 2008 The City had to cover the clean-up and remediation costs of approx. $500,000 for a 2008 oil spill (Willms, 2013). In 2013, an appeal court ruled against the city.
City of Timmins, 2012 Provincial investigation.  A Provincial Officer Order led the City to adopt elements of EMS.
Cerra v. City of Thunder Bay, 2013 $300 million class action lawsuit  Seeking remediation for flooding damages due to pollution caused by a wastewater treatment plant in a May 2012 storm event
R. v Alberta Capital Region Wastewater Comm., 2014 $200,000 in fines under the Fisheries Act, sec.36. City entered a guilty plea. 

Sentence included ISO 14001 certification.

R. v Greater Vancouver Sewerage and Drainage District, 2014 $110,000 in fines plus remediation costs. Charges under the Fisheries Act City entered a guilty plea.

In 2014, Vancouver began developing an EMS as per ISO 14001.

Table 2: Examples of Courts and government decisions leading to ISO 14001 adoption
Note: This is an adaptation of the table published in Engineers Canada (2018), and data from Willms, 2013, and from Tovilla, 2020.

Who were the sponsors and funding organizations for the W217 standard?

Since 2019, the CSA Group has partnered with representatives from public and private sector organizations to develop this standard for wastewater management systems. Conceptualization of this standard had strong support from the Ontario Ministry of the Environment, Conservation and Parks (MECP), the Water Environment Association of Ontario (WEAO – a WEF Member Association), the Ontario Good Roads Association, the Greater Toronto Sewer & Watermain Contractors Association (GTSWCA), and the Ontario Sewer & Watermain Construction Association (OSWCA). 

In 2023, the funding process for this standard was completed, which was made possible thanks to the following 17 organizations (in alphabetical order):

  • City of Barrie
  • City of Greater Sudbury
  • City of Guelph
  • City of Hamilton
  • City of London
  • City of Ottawa
  • City of Port Colborne
  • Clearford Water Systems Inc.
  • Greater Toronto Sewer & Watermain Contractors Association (GTSWCA)
  • Ontario Clean Water Agency (OCWA)
  • Ontario Good Roads Association 
  • Ontario Sewer & Watermain Construction Association (OSWCA)
  • The District Municipality of Muskoka
  • Toronto Metropolitan University 
  • Utilities Kingston
  • Water Environment Association of Ontario (WEAO)
  • York Region

Thanks to the WEAO Grants Program, launched in 2024, the CSA Group was awarded the funding to cover for free public View-Access and French translation across Canada. The free View-Access will be available for a period of five (5) years and will also include the opportunity to purchase and download the standard in English or French language. Thanks to the WEAO Board of Directors for this generous contribution to benefit all Canadian jurisdictions and potential users of the standard including French speakers!

W217 Technical Committee Members 

Significant time and effort was provided by all the 25 members of the W217 Technical Committee. All experts in their respective fields brought forward engaged discussion from January 2024, when the committee was formed until October 2024, when the public comment period ended and all comments were collectively reviewed and considered. Together they had representation from: government, private operators, industry associations, small, medium and large municipalities, First Nations, and consultants (Table 2). Below is the list of W217 Technical Committee members in alphabetical order (last name), and a group photo. 

W217 Committee Members Affiliation 
1 Lavina Ahuja City of Hamilton
2 Chris Angelo Good Roads
3 Akli Ben-Anteur City of Greater Sudbury
4 Shannon Boland Ontario Ministry of the Environment, Conservation and Parks (MECP)
5 Justyna Burkiewicz The Regional Municipality of Peel
6 Gary Burrows City of London
7 Kenneth Clogg-Wright  CSA Group 
8 Pat Coleman (Vice-Chair) Stantec
9 Sandra Gay City of Ottawa
10 Pamela Guenther City of Barrie
11 Scott Hall R. V. Anderson Associates
12 Andrew Henry Huron Elgin Water
13 Christine Hill Arcadis Professional Services (Canada) Inc.
14 Krystal Lewis Clearford Water Systems
15 Adam Long Utilities Kingston
16 Christopher Manning Ontario Ministry of the Environment, Conservation and Parks (MECP)
17 Charlene McKay City of Hamilton
18 Gus Morelli OSWCA and GTSWCA
19 Meredith Pratley York Region
20 Kristin Pressey City of Guelph
21 Brigitte Roth Acclaims Environmental Inc. 
22 Darlene Suddard Municipal Water Solutions Inc.
23 Edgar Tovilla (Chair) City of Markham, TMU
24 John Zhang OCWA
25 Ying Zheng Toronto Water

Table 3: W217 WWMS Technical Committee Members

W217 WWMS Technical Committee Group members attending the 2024 World Water Congress in Toronto (Left side, from top left to right: John Zhang, Darlene Suddard, Pat Coleman, and Edgar Tovilla; from lower left to right: Brigitte Roth, Charlene McKay, and Christine Hill. Right side, from left to right: Justyna Burkiewicz, Krystal Lewis, Christopher Manning, Gary Burrows, and Kenneth Clogg-Wright).

What other jurisdictions are doing?

Other jurisdictions outside Canada offer additional guidance on approaches to achieve better wastewater compliance and reduce legal liabilities. In 2005, the US EPA created the Guide for Evaluating Capacity, Management, Operation, and Maintenance (CMOM) Programs at Sanitary Sewer Collection Systems, a guide that covers many of the elements of the ISO 14001 (US.EPA, 2005). This is a voluntary program, although it is also referred to in abatement orders to some municipalities “as required by Federal or State compliance, audit invitation, or violation response” (WEF, 2022).  

Relevant for their parallels to Walkerton, drinking water-related tragedies also occurred in Milwaukee, Wisconsin (1993), and Flint, Michigan (2014). In Milwaukee, an estimated 400,000 people became ill and 104 died in cases attributed to water contamination (Naumova et al., 2003). While an EMS is not required in the State of Wisconsin, the ISO 14001 standard is part of the “Green Tier”, a voluntary state program established by legislation that is administered by the Wisconsin Department of Natural Resources. The program reduces liability for entities that adopt voluntary compliance (WDNR, 2014). 

In 2013, the State of Michigan switched Flint’s water supply from Lake Huron to the Flint River. This decision was made as a temporary measure while a new pipeline to bring a water supply from Lake Huron was built (CNN, 2019). In 2014, while the new pipeline was under construction, residents reported changes to their water tap colour, smell and taste. 12 people died in a Legionnaires’ disease outbreak suspected to be linked to the Flint water supply (Detroit News, 2019).  According to one class-action lawsuit, the State Department of Environmental Quality (DEQ) failed to monitor the water supply and treat it with anti-corrosive agents, and as a result the new water source eroded the iron water mains, increasing the lead concentration in the water distributed (US DCED Michigan, 2015). The State of Michigan, in its 2018 update to The Michigan Guide to Environmental, Health and Safety Regulations (Michigan State, 2018), includes a specific chapter for developing EMS with specific references to the ISO 14001.  

These initiatives, at both federal (CMOM) and state levels (Wisconsin and Michigan), provide additional evidence of how relevant the EMS, and in particular the ISO 14001, has become for municipal water and wastewater systems. In Europe, many private and public organizations have adopted the EMAS (the European equivalent of ISO 14001). By 2015, 4,600 firms and 7,900+ sites used EMAS. Examples of public water entities that have adopted EMAS for their wastewater operations include Suez (global operations), Southern Water (UK), Aguas de Barcelona (Spain).

In summary, the W217 WWMS standard will fill a void in the public and private regulatory framework and is very much needed by all public and private wastewater system operators. This sector-specific standard will reduce the level of effort to adapt and conceptualize from the generic ISO 14001 for EMS and other management standards, and will provide a streamlined approach consistent with global trends to implement a wastewater system standard. Thanks to the CSA Group, the W217 Technical Committee members and the funding partners for bringing this standard on the compliance tool kit in the wastewater sector.    

Author: Edgar Tovilla, P. Eng., PhD, City of Markham, CSA W217 Technical Committee Chair, Post-Doctoral Fellow at Toronto Metropolitan University, and WEAO Past-President

References

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CNN (2019) Flint water crisis fast facts, CNN Library, published on June 14, 2019, [Online], Available: www.cnn.com/2016/03/04/us/flint-water-crisis-fast-facts/index.html [21 Jun 2019]. 

Detroit News (2019) Editorial: Dismiss criminal charges for good, Published June 19, 2019, [Online], Available: www.detroitnews.com/story/opinion/editorials/2019/06/20/editorial-dismiss-flint-criminal-charges-good/1456358001/ [21 Jun 2024]. 

Engineers Canada (2018) Developing a stormwater quality management standard (QMS) – in light of a changing climate, Seed document to support national standard development, November 2018, Prepared by Zizzo Strategy and Credit Valley Conservation, [Online], Available: file:///C:/Users/etovilla/Downloads/scc_rpt_sw-qms_en_3.pdf  [12 Dec 2024]. 

Hrudey, S. E., and Hrudey, E.J. (2002) Safe Drinking Water: Lessons learned from Recent Outbreaks in affluent nations, IWA Publishing: London, UK. 

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Michigan State (2018) The Michigan guide to environmental, health and safety regulations, [Online], Available: www.michigan.gov/documents/deq/deq-tou-EHSguide-complete_604181_7.pdf [21 Jun 2024]. 

Naumova, E. N., Egorov, A. I., Morris, R. D., and Griffiths, J. K. (2003) The elderly and waterborne Cryptosporidium infection: Gastroenteritis hospitalizations before and during the 1993 Milwaukee outbreak, Emerging Infectious Diseases, Vol. 9, No. 4, pp. 418-425. 

O’Connor, D. R. (The Honorable Dennis R. O’Connor) (2002b) Part Two of the Report of the Walkerton Inquiry – A strategy for safe drinking water, Ministry of the Attorney General (online), available from: www.archives.gov.on.ca/en/e_records/walkerton/report2/index.html  [12 Nov 2015].

Tovilla, E. (2020) Mind the Gap: Management system standards addressing the gap for Ontario’s municipal drinking water, wastewater and stormwater ecosystem of regulations, Sustainability, Vol. 12, No. 12, pp. 1-23. https://doi.org/10.3390/su12177099. [2 Dec 2024].

Tovilla, E. (2020) Examining the evolving environmental protection policy convergence in the Ontario municipal drinking water, wastewater and stormwater sectors – Analysis of state/non-state governance and the value of an environmental management system standard for the wastewater and stormwater sectors, Toronto Metropolitan University, PhD Thesis.

Tovilla, E. (2021) Value of a made-in-Ontario management system standard for municipal wastewater and stormwater utilities, Water Quality Research Journal (WQRJ), Vol. 56, pp. 1-18. https://doi.org/10.2166/wqrj.2020.124 [2 Dec 2024].

U.S. District Court Eastern District of Michigan (US DCED Michigan) (2015) Class action lawsuit No. 15, filed on Nov 13, 2015. 

  1. EPA (2005) Guide for Evaluating Capacity, Management, Operation, and Maintenance (CMOM) Programs at Sanitary Sewer Collection Systems, [Online], Available: www3.epa.gov/npdes/pubs/cmom_guide_for_collection_systems.pdf [2 Dec 2024].

Water Environment Federation –WEF (2022) Technologies for CMOM activities in wastewater collection systems. 

Willms, J. (2013) City of Kawartha Lakes loses fight over “unfair” oil spill clean-up order, Legal Issues – Environmental Science & Engineering Magazine, Summer 2013, [Online], Available: www.willmsshier.com/docs/default-source/articles/kawartha_lakes_fights_moe_order_to_pay.pdf [12 January 2019]. 

Wisconsin Department of Natural Resources – WDNR (2014) Green Tier – Biennial Report, [Online], Available: http://dnr.wi.gov/files/PDF/pubs/co/CO574.pdf  [18 Nov 2024].

 

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