Code for Adoption Agreements

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www.ofwat.gov.uk

Water sector documents: Change proposal (Ref 017)

Modification proposal

Water Sector Guidance: Incorrect reference to WRAS when

referring to Approved Contractor operating as plumbers and

water supply pipe installers

Independent Water Adoption

Panel Recommendation

The Panel recommended approving a change to the water

sector documents using an alternative approach to that

proposed by FWC

Decision

Ofwat has approved this change proposal based on the Panel’s

alternative approach with a minor change to the Panel’s

recommended approach

Publication date

12 December 2023

Implementation date

01 April 2024

The structure of our decision is as follows:

• Background

• The change proposal

• Consultation and assessment

• Panel recommendation

• Our decision and reasons

• Decision notice.

Background

Fair Water Connections (FWC) submitted this change proposal to the Independent Water

Adoption Panel (the Panel) on 14 April 2023, with the Panel publishing the proposal on its

website on the same day. The function of the Panel is to consider change proposals to the

water sector guidance and model water adoption agreement (the Water Sector Documents)

which apply to companies operating wholly or mainly in England. These documents were

Code for Adoption Agreements: Change proposal 017

developed by companies as required by the Code for Adoption Agreements (the Code) and

came into effect in January 2021. A change proposal is defined in the Code as a proposed

change to the sector guidance or the model adoption agreements.

The change proposed by FWC concerns references to the Water Regulations Advisory Service

(WRAS) in the Water Sector Documents. FWC considers that the references to WRAS when

describing plumbing installers that are approved contractors are incorrect as there are

multiple approved contractor schemes that operate in England and WRAS is just one of these.

FWC also points out that WRAS had now been renamed ‘Water Regs UK Limited’. There is a

current organisation known as WRAS, but this is the Water Regulations Approval Scheme,

which certifies plumbing products and materials. FWC considers the incorrect references to

WRAS in the Water Sector Documents to be misleading and confusing.

The change proposal

In its change proposal form submitted to the Panel, FWC raised concerns with the references

to WRAS in that:

(1) There are 6 Approved Contractors Schemes across the UK approve installers under

the Water Supply (Water Fittings) Regulations 1999. WaterSafe is an umbrella brand

where members approved by all six schemes are listed on a website.

(2) The Water Regulation Advisory Service (WRAS) has been renamed Water Regs UK

Limited. This company only runs one of six Approved Contactors Schemes.

(3) WRAS (Water Regulations Approval Scheme) is new a subsidiary company that

independently certifies plumbing products and materials. To refer to WRAS is

misleading and confusing.

FWC has proposed changes to several of the Water Sector Documents to address this issue

which are marked in red font and strikethrough font:

Water Sector Guidance

• Add the following definition:

“Approved Contractor Schemes”

A scheme which approves contractors, under the Water Supply (Water Fittings)

Regulations 1999. For example, those listed by WaterSafe.org.uk such as the

APLUS, Water Industry Approved Plumbers Scheme or Watermark.

Code for Adoption Agreements: Change proposal 017

• Amend section 7 with the following changes:

An SLP’s competence can be demonstrated:

• through WIRS where the Accreditation Body awards scope-specific

accreditation against the criteria detailed in the Water Industry

Registration Scheme Requirements Document. (Details of the WIRS scheme

can be found at http://www.lr.org/en/utilities-building-

assuranceschemes/uk-schemes/water-industry-registration-scheme/ ); or

• in the case of communications pipes, or plumbing, those accreditation

schemes recognised by WRAS in the case of communications pipes, or

plumbing, accredited for a relevant scope of work by an Approved

Contractors’ Scheme (for example a WaterSafe Water Supply Pipe Installer

or Plumber;

• local accreditation arrangements which are specified by the Water

Companies in their ACS for the purposes of the “amber” activities (which

allows SLPs to carry out works beyond those by WIRS accreditation).

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Water Sector Guidance – Appendix C – Procedures

Make the following changes to stage 7 of the procedures process:

1. Replace ‘WRAC’ with Watersafe.

2. Replace ‘WRAC’ with ‘Watersafe’ replace ‘plumbing approval’ with ‘approved

contractors’.

3. Replace ‘WRAC’ with ‘Watersafe’.

4. Replace ‘WRAC’ with ‘Watersafe’.

5. Leave unchanged as this is an appropriate usage of WRAS

6. This change is not part of the original change proposal. This is an additional

change proposed by the Panel that wasn’t included in the original change

proposal which is discussed later in the document.

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Water Sector Guidance - Appendix D – Design and Construction Specification

Add the following definitions:

• “Watersafe” – “WaterSafe is a website that lists approved contractors from six

Approved Contractors’ Schemes across the UK”.

• “Approved Contractors Schemes” – “A scheme which approves contractors, under the

Water Supply (Water Fittings) Regulations 1999. For example, those listed by

WaterSafe.org.uk such as the APLUS, Water Industry Approved Plumbers Scheme or

Watermark”

Amend section 12.2 – Depth of Services:

Service Pipes shall be installed in accordance with the Water Regulations and

Streetworks UK guidance.

Service pipes shall be laid with an even grade where possible, with cover between a

depth of 750mm to 1350mm from the finished ground level in accordance with Water

Supply (Water Fittings) Regulations 1999.

If a boundary box is to be installed on the Service Pipe, the pipe shall be laid with

cover between 750mm and 850mm for a minimum of 1.0metre on each side of the

boundary box.

Service Pipes being designed outside this range shall have special protective

measures vetted and agreed by the Approving Design Engineer must be notified and

consent given under the water fittings regulations and shall have special protective

measures vetted and agreed by the Approving Design Engineer.

Amend section 13.2 – Marker Tape and Tracer Tape

Marker Tape to be compliant with CESWI and Water Fittings Regulations (for example

conforms to BS 1710).

Amend section 15.3 – Dedicated Fire Mains

Dedicated fire mains shall be designed and constructed in accordance with Water

Supply (Water Fittings) Regulations 19992016 and fitted with backflow prevention,

spiral wrapping and appropriate marker tape this would include: fitted with

appropriate backflow prevention and pipe identification (e.g. conforms to BS 1710).

Amend Appendix 1 WIS & IGN

Add the reference:

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BS 1710 Specification for identification of pipelines and services

Remove the reference:

IGN 9 04 05 Report of the expert group on the risks of contamination of the

public water supply by backflow at: http://wras.co.uk

Water Sector Guidance – Appendix E – Minimum Information

Amend Stage 7 – Make Service Connections

LoS: SLPM 7/1

All Service Pipe connections are to be notified by the SLP in accordance with the WIRS

requirements and relative to Water Regulation inspections to allow witness and / or

audit by the Water Company at its discretion or alternatively submit paperwork

according to an Approved PlumbersContractors’ Scheme.

Water Company may use a Local Practice and issue plot reference information and

costings at Stage 3.

Amend Stage 7 – Make Service Connections

3. Approved Plumbers Scheme certificate or Water Company Water Regulations

inspection pass Certificate of compliance from an approved contractor who is a

member of an Approved Contractors’ Scheme or Water Company Water Regulations

inspection pass

Consultation and assessment

In submitting its recommendation, the Panel confirmed that it met the Code requirement

assess the change in terms of:

• The need for change, for example, is it a service improvement or is it needed to

address a particular issue?

• Consistency with the principles and objectives of the Code, and any relevant statutory

requirements; and

• The impact of the change (be it positive and/or negative) on customers and on water

companies.

In considering the change proposal, the Panel has:

• Discussed the proposal at two meetings;

See paragraph 3.8.11 of the Code.

Code for Adoption Agreements: Change proposal 017

• Sought feedback from Panel members’ companies; and

• Consulted with the Drinking Water Inspectorate (DWI) on the proposal as the proposal

raised potential water quality issues. However, the Panel noted that it did not receive a

response from the DWI.

The Panel also consulted with FWC on its proposed recommendation.

Panel recommendation

On 14 August 2023, the Panel recommended to Ofwat, by unanimous decision, that we

approve a change to the Water Sector Documents. However, the Panel has proposed an

alternative change be made to the Water Sector Documents than that which was proposed by

FWC. In reaching its decision, the Panel stated that it has considered the following:

• It was noted that the references to the approval schemes within the Code could be

simplified, as there are several schemes which interact with each other, for example

some are statutory, some relate only to materials.

• There is no universal approval scheme which applies across the whole industry;

therefore it is for water companies to specify which approvals they will accept. Any

works must be certified under the appropriate regulations, which prevents non-

approved works being carried out.

• Panel members had reviewed the proposed consequential amendments with their

respective water quality teams and overall they were content with the proposed

amendments.

• However, the Panel stated that it was mindful that the inclusion of specific examples

of approval schemes could become outdated quickly, which would necessitate

frequent changes to the Water Sector Documents if the amendments were accepted.

The Panel stated that it agreed that the FWC’s proposal should be accepted. However, it

recommended using alternative wording to that proposed by FWC. This was primarily to avoid

references to specific approval schemes which could themselves become outdated if such

schemes are changed in the future. Instead, the Panel recommended referring to approval

schemes in general. In addition to the changes proposed by FWC, the Panel recommended

two amendments to the Water Sector Guidance Appendix D – Template Design and

Construction Specification, Definitions. These additional amendments address the current

references to WRAS in this document.

The Panel confirmed that it consulted with FWC on its recommended alternative approach to

making the changes to the Water Sector Documents.

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The changes to the Water Sector Documents recommended by the Panel are set out below.

The current wording of the Water Sector Documents is in black text, the changes proposed by

FWC are in red font and the alternative changes recommended by the Panel are in green font

where new text has been added. Where FWC proposed additional text but the Panel

recommended removing this proposed text, it is in red strikethrough font.

Water Sector Guidance

• Add the following definition:

“Approved Contractor Schemes”

A scheme which approves contractors, under the Water Supply (Water Fittings)

Regulations 1999. For example, those listed by WaterSafe.org.uk such as the

APLUS, Water Industry Approved Plumbers Scheme or Watermark.

• Amend section 7 with the following changes:

An SLP’s competence can be demonstrated:

• through WIRS where the Accreditation Body awards scope-specific

accreditation against the criteria detailed in the Water Industry

Registration Scheme Requirements Document. (Details of the WIRS scheme

can be found at http://www.lr.org/en/utilities-building-

assuranceschemes/uk-schemes/water-industry-registration-scheme/ ); or

• in the case of communications pipes, or plumbing, those accreditation

schemes recognised by WRAS in the case of communications pipes, or

plumbing, accredited for a relevant scope of work by an Approved

Contractors’ Scheme (for example a WaterSafe Water Supply Pipe Installer

or Plumber;

• local accreditation arrangements which are specified by the Water

Companies in their ACS for the purposes of the “amber” activities (which

allows SLPs to carry out works beyond those by WIRS accreditation).

Code for Adoption Agreements: Change proposal 017

Water Sector Guidance – Appendix C – Procedures

Make the following changes to stage 7 of the procedures process:

1. Install internal plumbing using a WRAS accredited installer and installer

suitably accredited by an Approved Contractors’ Scheme (for example a

WaterSafe plumber), and if the Water Company requires notify the Water

Company on completion (see note 7.1) Replace ‘WRAC’ with Watersafe.

2. Monitor development activity and programme Coordination & Compliance

Visits based on appropriate risk factors (see note 7.2) that takes into

account WRAS plumbing approval scheme the Approved Contractors’

Scheme accreditation, WIRS accreditation status, type approval, and recent

events Replace ‘WRAC’ with ‘Watersafe’ replace ‘plumbing approval’ with

‘approved contractors’.

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3. The minimum level internal plumbing can be fitted by any competent

person. If the installer is able to evidence competency through a suitable

WRAS or WIRS accreditation scheme accreditation with an Approved

Contractors Scheme, the Water Company may take this into account when

deciding whether to undertake subsequent due diligence checks on the

site. Replace ‘WRAC’ with ‘Watersafe’.

4. Install private service pipe using a suitably accredited installer (for example

WRAS a WaterSafe Water Supply Pipe Installer or Plumber). Replace ‘WRAC’

with ‘Watersafe’.

5. Where internal plumbing does not have signed-off type approval, or has not

been installed by an approved plumber, the Water Company may require an

internal plumbing inspection to confirm that internal plumbing meets the

Water Regs Water Fittings Regulations. Leave unchanged as this is an

appropriate usage of WRAS

6. All plumbing must comply with WQ(WF)1999 Water Fittings Regulations.

Water Sector Guidance - Appendix D – Design and Construction Specification

Amend Section 5 – Abbreviations

WRAS Water Regulation Advisory ServiceWater Regulations Approval Scheme

WRUK Water Regs UK Ltd

Add the following definitions:

• “Watersafe” – “WaterSafe is a website that lists approved contractors from six

Approved Contractors’ Schemes across the UK”.

• “Approved Contractors Schemes” – “A scheme which approves contractors, under the

Water Supply (Water Fittings) Regulations 1999. For example, those listed by

WaterSafe.org.uk such as the APLUS, Water Industry Approved Plumbers Scheme or

Watermark”

Amend section 12.2 – Depth of Services:

Service Pipes shall be installed in accordance with the Water Regulations and

Streetworks UK guidance.

Service pipes shall be laid with an even grade where possible, with cover between a

depth of 750mm to 1350mm from the finished ground level in accordance with Water

Supply (Water Fittings) Regulations 1999.

Code for Adoption Agreements: Change proposal 017

If a boundary box is to be installed on the Service Pipe, the pipe shall be laid with

cover between 750mm and 850mm for a minimum of 1.0metre on each side of the

boundary box.

Service Pipes being designed outside this range shall have special protective

measures vetted and agreed by the Approving Design Engineer must be notified and

consent given under the water fittings regulations and shall have special protective

measures vetted and agreed by the Approving Design Engineer.

Amend section 13.2 – Marker Tape and Tracer Tape

Marker Tape to be compliant with CESWI and Water Fittings Regulations (for example

conforms to BS 1710).

Amend section 15.3 – Dedicated Fire Mains

Dedicated fire mains shall be designed and constructed in accordance with Water

Supply (Water Fittings) Regulations 19992016 and fitted with backflow prevention,

spiral wrapping and appropriate marker tape this would include: fitted with

appropriate backflow prevention and pipe identification (e.g. conforms to BS 1710).

Amend Appendix 1 WIS & IGN

Add the reference:

BS 1710 Specification for identification of pipelines and services

Remove the reference:

IGN 9 04 05 Report of the expert group on the risks of contamination of the

public water supply by backflow at: http://wras.co.uk

Water Sector Guidance – Appendix E – Minimum Information

Amend Stage 7 – Make Service Connections

LoS: SLPM 7/1

All Service Pipe connections are to be notified by the SLP in accordance with the WIRS

requirements and relative to Water Regulation inspections to allow witness and / or

audit by the Water Company at its discretion or alternatively submit paperwork

according to an Approved PlumbersContractors’ Scheme.

Code for Adoption Agreements: Change proposal 017

Water Company may use a Local Practice and issue plot reference information and

costings at Stage 3.

Amend Stage 7 – Make Service Connections

3. Approved Plumbers Scheme certificate or Water Company Water Regulations

inspection pass Certificate of compliance from an approved contractor who is a

member of an Approved Contractors’ Scheme or Water Company Water Regulations

inspection pass

Our decision and reasons

We have considered the above issues and all supporting documentation provided to us by the

Panel and have decided to approve the change based on the Panel’s alternative approach

with a minor change to amend the definition of "WaterSafe" as set out below.

We agree with FWC and the Panel that there is a benefit to updating the Water Sector

Documents where names of organisations or schemes that are referred to in the documents

have been changed. We also agree with the Panel that there is benefit in avoiding references

to specific organisations when a more general reference to the organisation’s function could

be used in order to avoid having to update the Water Sector Documents whenever such an

organisation or its name changes. This also avoids the potential confusion, as raised by FWC,

of the Water Sector Documents only referring to specific organisations or schemes, when

there are acceptable alternatives that could be used. We therefore agree with the changes to

the Water Sector Documents recommended by the Panel. This aligns with the Code principle

of being ‘clear, complete and current’.

We have decided to make an alteration to one element of the Panel’s recommended changes.

The Panel recommended a change to section 5 of the Water Sector Guidance – Appendix 5 –

Design and Construction Specification to include a definition of ‘Watersafe’. We consider that

the Panel's proposed definition should be amended to provide a more accurate and future-

proofed description of the organisation. As such, we have decided to amend definition of

"WaterSafe" to the following:

“WaterSafe" - "WaterSafe is an online search facility that lists contractors in Approved

Contractor Schemes."

Decision notice

In accordance with paragraph 3.9.4 of the Code Ofwat approves this Change Proposal using

the alternative approach recommended by the Panel with a minor change to this

recommended approach to amend the definition of "WaterSafe" as set out above.

Code for Adoption Agreements: Change proposal 017

Emily Bulman

Director, Charges, customers and developer services