Cross-sectoral collaboration in water management to improve drinking water quality.
June 11, 2023, 10:36 a.m.

Under the Association Agreement between Ukraine and the EU, Ukraine has committed to implementing six EU water directives by gradually aligning its national legislation with EU legislation and policies on water quality and water management, as well as developing a sectoral strategy in this area, including the marine environment. Ukraine has committed to harmonising its water legislation with six EU water directives: Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy (WFD), Council Directive 98/83/EC of November 1998 on the quality of water intended for human consumption (Drinking Water Directive), Council Directive 91/271/EEC of 21 May 1991 concerning urban waste water treatment, Council Directive 91/676/EEC of 12 December 1991 concerning the protection of waters against pollution caused by nitrates from agricultural sources (Nitrates Directive) Directive 2007/60/EC of the European Parliament and of the Council of 23 October 2007 on the assessment and management of flood risks (Floods Directive) and Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 which establishes a framework for Community action in the field of environmental policy with respect to the marine environment.
Various powers in the field of management and control of water use and protection are exercised by the Ministry of Environmental Protection and Natural Resources of Ukraine, the Ministry of Agrarian Policy and Food, the Ministry of Community Development, Territories and Infrastructure, the Ministry of Health of Ukraine, the Ministry of Finance, the State Agency of Water Resources of Ukraine, the State Agency for Land Reclamation and Fisheries, the State Emergency Service of Ukraine, the State Service of Geology and Subsoil of Ukraine, the State Environmental Inspection of Ukraine, and the State Service of Ukraine for Food Safety and Consumer Protection.
The main comprehensive document in the water sector of Ukraine is the Water Strategy of Ukraine for the period up to 2050.
The following operational objectives are identified in the Strategy:
Objective 1. Ensuring equal access to safe drinking water and adequate sanitation and hygiene services
P.10 Objectives 5 Developing scientific guidelines for integrated water resources management by 2030.
The quality of drinking water is influenced by water sources: surface water and groundwater. 80% of drinking water in Ukraine comes from surface water bodies. The composition of water directly influences the choice of technology for its further treatment and preparation for consumption. Ukraine is currently undergoing a transformation of its water resources management system based on the basin principle. Significant powers are being devolved to local communities. Proposals for improving the water supply and sewerage network, water intake facilities, treatment plants, as well as facilities that may affect water resources (landfills, industrial facilities, etc.) are summarised in River Basin Management Plans (RBMPs), which will be approved after public discussions and will come into force in 2025.
Since one of the main tasks of local self-government is to improve the quality and length of life of the population in the relevant territories, they are particularly interested in creating a drinking water monitoring system, which is a factor influencing the health indicators of citizens.
Given the change in the powers of the public health system in Ukraine, medical statistics are mainly based on hospital data and therefore do not reflect the territorial factor and, as a result, make it impossible to identify the dependence of health indicators on environmental factors in a particular area. There is a clear need to develop local monitoring systems for factors affecting the health of residents, including drinking water.
The right to drinking water and its appropriate quality in Ukraine is guaranteed by the following laws of Ukraine: ‘On Ensuring Sanitary and Epidemic Welfare of the Population’, “On Environmental Protection”, “On Drinking Water and Drinking Water Supply”, “On Housing and Communal Services”, as well as the Water Code of Ukraine and the Code of Laws on Subsurface Resources.
The production of drinking water and its quality are regulated by a special regulatory document, namely the state sanitary rules and standards - DSanPiN 2.2.4-171-10 ‘Hygienic requirements for drinking water intended for human consumption’ (Order of the Ministry of Health of Ukraine dated 12 May 2010, No. 400, as amended on 15 August 2011, No. 2675 and on 18 February 2022, No. 341). After the adoption of this document in the same year, the former Soviet ‘GOST 2874-82 ’Drinking water. Hygienic requirements and quality control’ (Order of the Ministry of Health of Ukraine dated 19 July 2010, No. 26) ceased to be valid in Ukraine. Ukraine also has a state standard - DSTU 7525:2014 ’Drinking water. Requirements and methods of quality control’ (Order of the Ministry of Economic Development of Ukraine dated 23 October 2014, No. 1257), which is only recommendatory in nature.
DSanPiN 2.2.4-171-10 ’Hygienic requirements for drinking water intended for human consumption’ (hereinafter referred to as DSanPiN 2.2.4-171-10) are mandatory for executive authorities, local self-government bodies, enterprises, institutions and organisations, regardless of their form of ownership and subordination, whose activities are related to the design, construction and operation of drinking water supply systems, production and circulation of drinking water, supervision and control in the field of drinking water supply to the population, and citizens. This document establishes requirements for the safety and quality of drinking water intended for human consumption, as well as rules for production control and state sanitary and epidemiological supervision in the field of drinking water supply. It contains a list and permissible values of chemical and biological indicators that determine the epidemiological and radiological safety of drinking water and ensure high organoleptic (aesthetic) properties.
Compliance with the requirements of DSanPiN 2.2.4-171-10 is monitored by state sanitary and epidemiological surveillance in the form of preventive and routine inspections, which are carried out through scheduled random checks of compliance with sanitary legislation at water supply facilities, as well as unscheduled checks depending on the sanitary and epidemiological situation.
DSanPiN 2.2.4-171-10 established requirements for 76 water quality indicators, which were to be introduced in stages: monitoring of 53 indicators was to begin in July 2010, and monitoring of all 76 indicators was to begin in January 2015. - for 64 indicators, and from January 2020 – for all 76 indicators. However, by the end of 2019, it became clear that some of the standards could not be met by most water supply companies, mainly for objective reasons. Therefore, the deadline for its final entry into force was postponed to 1 January 2022 (Order of the Ministry of Health of Ukraine No. 2675 of 24 December 2019). By this date, an updated draft of state sanitary rules and regulations had been developed in Ukraine - DSanPiN 2.2.4-171-22 ‘Hygienic requirements for drinking water intended for human consumption’. However, during the discussion process, fundamental differences in views on this document emerged between its developers and water supply companies (which are required to comply with the established requirements). Due to the Russian aggression that began in February 2022, the discussion process was suspended and the issue remains unresolved.
The most important part of the regulatory document on drinking water quality is the list and values of indicators that are limited to a certain concentration level. There is a certain difference between the water quality indicators for centralised water supply systems according to DSanPiN 2.2.4-171-22 and the EU Directive 2020. It should be noted that the Ukrainian document provides for a gradation for different types of drinking water, in particular for tap water from surface and underground sources; from pipe and mine wells, spring catchments, bottling sites and drinking fountains. The EU Directive does not provide for a separate classification by water type, but only contains isolated references to certain indicators, specifying the particularities of their application.
The DSanPiN establishes eight microbiological indicators (two of which are determined as necessary) and two parasitological indicators, while the EU Directive provides for only two indicators (their values are set at the same level as in the DSanPiN) and three more in the indicative indicators.
Many regulatory acts, as well as local rules and decisions in the field of ecology and health, require the development of methods for determining the relationship between and improving the quality of public health through higher drinking water standards. In particular, the Law of Ukraine ‘On Environmental Impact Assessment’ provides for monitoring the quality of public health in the post-project period of implementation of measures and decisions that have an impact on the environment, but does not provide any methodology for determining its level.
June 11, 2023, 10:36 a.m.