TRANSFER OF PRIVATE SEWERS – WHERE ARE WE?
The transfer of private drains and sewers is now set for 1st October 2011 and the challenges to all sides of the industry remain immense in what will be the biggest shake up the industry has seen. There is still a tremendous amount of work to be undertaken by Government in finalising regulations and procedures and the clock is ticking.
The DEFRA workshops on private sewer transfer were well attended with representatives from a wide spectre of the drainage industry but little could be gleaned from those who will finalise the regulations; the focus being on the five questions in the consultation. The Water Companies are pushing to maintain the original intention for private sewers connected to private pumping stations to be deferred until their pumping stations are transferred which could be as late as October 2015. In this case, whichever decision is made, clarification will be required to avoid confusion and conflict between variously the customer, private contractor and the water company.
There are concerns that other related issues appear to be even further from resolution. It seems obvious that the issue of new build connected to development is resolved before the transfer or anomalies will be created from the start. However, this seems as vague as ever with more questions than answers. The target date of 1st April 2011 for agreeing and putting the sewer standards, the fore runner for any new build, in place currently appears very optimistic.
“SUDS” is another subject which we feel needs to be resolved prior to transfer to allow a holistic effect. DEFRA have issued for consultation some of the “SUDS” related regulations from the Flood and Water Bill but these, as yet, do not address the specification or the definition of a “SUDS” system.
It is essential that these outstanding matters are given due consideration, recognising the concerns across the industry, and properly resolved. If this means that the transfer date has to be delayed then so be it.
Much of the work currently carried out on private sewers is done by small private contractors, many of whom are experienced, providing a satisfactory service. No-one knows just how many units are operating in the field of blockage clearance throughout England and Wales, despite the efforts of both Government and Trade Associations. Many of these may still be living in ignorance of the impending transfer and the effect it will have on their livelihoods.
The majority of the Water Companies have still to decide on what route to take for the maintenance of these transferred assets and even the procurement routes are still obscure with some such as Thames seeking declaration of interest from contractors whilst others may use existing contractors.
How does the small contractor look to securing a future workload if the Water Company is still contemplating the route to take, bearing in mind that they are also waiting for the various issues to be resolved or clarified by DEFRA? The existing work is not going to disappear and the Water Companies and their Tier One contractors will have to hit the road running once the transfer takes place. There has been talk of transitional arrangements as they go through the learning curve but these will need to be put in place in the near future.
Those responsible for procurement should ensure that standards are not diluted in chasing ever lower rates. Responsible contractors who have ensured that their staff is trained, where appropriate, in lighting, signing and coning, confined space training, pipe defect classification, high pressure water jetting etc can rightly get upset when the successful contractor is seen not to be complying with legislation or regulation and the requirements of the contract documents.
The client has a duty of care to ensure that all health and safety issues are maintained at all levels of the project through sub contractors. This can be maintained through a level of understanding of the expected levels of competence. The unit cost of a maintenance procedure in terms of an hourly rate can lead some erroneously to assume that the task is unskilled and little attention needs to be addressed to the method or result.
Blockages need to be efficiently cleaned with the debris removed from the pipe and proper disposal – not just moved down the line with the danger of a recall. Those operating cctv units need to ensure a clear picture with a steady pull through rate and a correct interpretation of defects (to BS EN13508:2). Those working on the highway need to be aware of and trained in accordance with the requirements of the New Road and Street Works Act and any likely access requirement to the sewer system requires operators to show proof of current confined space training.
The lowest price can only be cost effective if all the criteria are met as laid down in the various, long established, model contract documents. Where work has to be repeated due to the contractor taking short cuts or not having the necessary experience in a process could result in the lowest tender, on evaluation, proving more expensive than other tenderers with a proven track record. For peace of mind, all the appropriate training should have been undertaken by staff currently working for the contractor before any tender is considered.
The transfer will not only launch the Water Companies in to relatively unknown territory, it will be a test for Tier One Contractors. We would look to all supervising officers requiring an understanding of the processes involved (there are existing training courses) in order to avoid conflict between parties.
The challenge is in providing an informed call centre, knowledge of the area and sufficient operational vehicles and manpower to provide a rapid response service. Ideally this would involve the myriad of small proven local contractors utilising their local experience. To have a matrix of local contractors instead of a cascading downward series of sub-contractors would give control on standards and service. The use of computers to allocate and log work would make a payment structure viable – it has been done before.
All sides of the industry need to be proactive and urgently participate in discussion with an open mind and to come up with innovative solutions to ensure that small companies with well trained staff can have a future and not be lost to the industry. Their experience is going to be vital to a smooth and invisible transfer.
It will be in the industry’s best interest if rates are set a realistic level to maintain a cost efficient standard of work with well maintained equipment. There is still a warning in the old adage that `if you pay peanuts you get monkeys’. This industry has striven to set standards in safety and quality of work – let us not renege on the precedent set.