Mr. Maurice Buckley:

I would like to thank the committee for the invitation to assist in your consideration of the issues raised in the petition regarding the installation of central heating systems and the ongoing standardisation work NSAI is undertaking in the area of plumbing services.

This is my first occasion before this committee and I am accompanied by my colleague, Ms Yvonne Wylde, manager standards technical, with expertise in construction and today we will endeavour to address any matters raised by the committee.

I am aware that the committee will be addressed by officials from the Department of Environment, Communications and Local Government and since that Department and agencies under its auspices have statutory responsibility for water services, water safety, water quality, building regulations and building standards generally I will confine my comments to NSAI’s role and its work on standardisation.

I am happy to take any questions from members but before doing so I would like to provide the committee with some background information on the NSAI and its standardisation role with particular reference to the plumbing issue in question.

NSAI, as the Irish national standards body, is responsible for developing technical specifications for products, processes and practices in the form of written standards, guides or codes of practice. While there are some differences in the character of each of these documents they are collectively referred to as ‘standards’ for the purposes of today's hearing.

Standards are generally voluntary but can be made legally binding when referenced as mandatory by legislation. Of the 1,500 or so national, European and international standards published annually by NSAI an increasing number are used to support legislation by providing the user with means of demonstrating compliance with legal requirements through using the standard. This type of reference establishes the standard as a preferred route of compliance without it becoming mandatory.

In the absence of any legal reference, standards remain voluntary to be used by businesses as a means of demonstrating state-of-the-art or best practice.

NSAI develops standards through its network of consultative committees. Committee members are drawn from industry, government and societal interest groups to work on matters of common interest. It is NSAI's role to act as a facilitator for that process.

There are currently two related consultative committees dealing with domestic heating and plumbing. These are the Building Services Consultative Committee, and the Water Supply Standards Consultative Committee. The Building Services Consultative Committee is dealing with the code of practice for domestic hot water and heating, and the Water Supply Standards Consultative Committee is dealing with a similar code of practice for cold water systems.

These committees currently comprise representatives from policy makers-regulators, manufacturers, trade associations, local authorities, academia, insurers, private water suppliers, consultants and installers. The two committees liaise through nominated members to ensure there is no duplication or overlap between their work and the necessary cross-referencing can take place.

There are normally five stages in the standards development process: identifying the needs and benefits of a standard; defining the scope, i.e. identifying the technical, environmental or safety specifications which need to be set; consultation with a view to achieving a consensus; a process of public inquiry; and finally, the publication of the finished standard.

As a member of the European and international standards organisations, NSAI can only undertake national standardisation work in the absence of suitable standards being published by those organisations. Furthermore, in the interests of global and EU trade, NSAI is obliged to adopt such European or international standards as national standards and ensure any existing national publications are compatible with their content.

In all European member states, the regulation of supply of drinking water and the quality of drinking water are matters for the appropriate agencies and bodies charged with those responsibilities. It is a well recognised fundamental design principle when designing, installing or maintaining water supply systems that potable water installations must be protected from contamination, such as backflow from central heating systems, which is the issue in question today.

Several Irish standards, developed through the European system, give guidance on this issue. They include IS EN 806, which is concerned with the specifications for installation inside buildings conveying water for human consumption. That standard, broken into five parts, was developed from 2000 to 2012. Another standard, IS EN 12828, from 2012, with an annex in 2014, addresses heating systems in buildings and the design of water-based heating systems. A further standard, IS EN 1717, from 2000, with a national annex published in 2011, deals with protection against pollution of potable water in water installations and the general requirements of devices to prevent pollution by backflow.

Both IS EN 12828 and IS EN 806, on the design of water and central heating systems, implicitly recognise that drinking water supplies can become contaminated by backflow, and the standards specify methods for addressing these risks. Part 2 of IS EN 806 recognises the existence of national or local regulations and requirements and the need to prevent the contamination of water.

The national annex, NA, to IS EN 1717 - I am sorry for quoting all these numbers, but they are important - provides guidance regarding backflow prevention in Ireland, taking account of the low-pressure ventilated mains water systems. The guidance notes the practice of having an unrestricted air gap to protect the incoming water supply against backflow, unless otherwise expressly permitted in writing by the appropriate responsible water authority. In other cases it recommends that a risk assessment be carried out in accordance with the standard.

In 2006 the need for an Irish code of practice for plumbers was identified to complement the existing European standards, with the project beginning in earnest in 2008. This project was aimed at developing a best practice guide for use by the trade, by drawing together the references to relevant standards with useful explanations in an easily readable form. The project was supported by key stakeholders including the Department of the Environment, Community and Local Government and the Sustainable Energy Authority of Ireland, SEAI, which committed funds to support the necessary work. A first-draft code of practice was published in 2010 for public comment. This consultation was met with great interest, resulting in the submission of more than 200 observations to NSAI. The public inquiry draft in 2010 took account of relevant local authority by-laws available at that time. Those local authorities, in general, required that water systems contain an adequate device or devices to prevent the occurrence of backflow. The draft code of practice drew together these requirements as best practice.

Following the 2010 public inquiry and further consideration, it was decided to split the very large draft standard into two parts to enable work to proceed more efficiently. These two parts are titled SR 50-1, for domestic hot water and heating, and SR 50-3, for domestic plumbing for cold water systems.

Due to the level of interest from the various groups involved, the prioritisation of other critical projects and the availability of key stakeholder input and internal resources, work on the project was put on hold until being reactivated earlier this year. The most recent review has identified a need for further work to address technical developments, changes in building practices, availability of updated European standards and related matters raised by harmonised standards under the EU construction products regulation. Irish Water, which was established in the interim, is also now engaged as a key stakeholder. The projects are progressing well, and it is expected that drafts of both documents will be issued for public inquiry during 2016.

As previously stated, standards are voluntary documents unless referenced as mandatory or as conferring a presumption of compliance through legislation. When the code of practice documents are published by NSAI, the relevant authorities may choose to reference them in whatever way they consider appropriate.