This guide is for local authorities in England who need to register a producer’s premises to bottle spring water from a spring or borehole in their area.

If you’re a producer, read guidance on producing spring water.

For local authorities in:

• Wales or Northern Ireland, you should read Food Standards Agency guidance
• Scotland, contact Food Standards Scotland

What counts as spring water

A product can only be described as spring water if:

• it comes from an underground water source that’s tapped at a natural or drilled exit
• it’s free of parasites and bacteria that cause disease
• the source is protected from pollution

BottlingThe mustwater takecannot placebe attransported thein springa orcontainer. borehole.See rules for transporting the water.

Producers can sell spring water directly to consumers in, for example:

• bottles
• tetra packs and cartons
• water coolers
• pouches

They do not have to state the composition on the label (although many producers choose to do so).

There are no forbidden treatments, but producers must follow rules for 5 particular treatments if they choose to use them.

Steps to register a producer’s premises for spring water

Bottled water producers may ask you to register their premises to produce spring water from a spring or borehole that sits in your local authority area.

Follow these steps to register the premises for spring water.

1. Check the producer has got a water abstraction licence. They must have this before they can take water from the spring.
   
   
2. Make sure the producer has gathered the evidence to prove the water is safe and meets standards.
   
   
3. Make sure the producer knows the conditions they must meet when exploiting the spring.
   
   
4. Check if the producer wants to use treatments on the water. There are 5 treatments where they must follow certain rules.
   
   
5. Make sure the producer knows the rules for labelling.
   
   
6. When you’re satisfied the producer meets the rules, register the producer’s business as a food establishment for spring water. If you need to refuse, you should put this in writing to the producer.
   

After registration, check the producer is complying with rules for exploiting the spring, treatments and labelling.

Evidence the producer must gather to get premises registered

The producer must test the water and make sure it complies with limits for chemical, pesticide, microbiological and radioactive substances.

For initial checks for registering a premises, you do not need to collect samples of the water. You can rely on the laboratory reports that the producer sends to you.

But make sure that the producer has used a UKAS accredited laboratory that uses recognised scientific methods for testing spring water.

For ongoing checks after registration, you’ll need to carry out your own checks.

Chemicals limits

The producer must test their water to make sure it complies with the following limits.

Chemical	Maximum limit	Details
	Antimony	5 micrograms per litre	-
	Arsenic	10 micrograms per litre	-
	Benzene	1 microgram per litre	-
	Benzo(a)pyrene	0.01 micrograms per litre	-
	Boron	1 milligram per litre	-
	Bromate (Br03L)	10 micrograms per litre	-
	Cadmium	5 micrograms per litre	-
	Chromium	50 micrograms per litre	-
	Copper	2 milligrams per litre	-
	Cyanide	50 micrograms per litre	-
	1,2-dichloroethane	3 micrograms per litre	-
	Fluoride	1.5 milligrams per litre	-
	Lead	10 micrograms per litre	-
	Mercury	1 microgram per litre	-
	Nickel	20 micrograms per litre	-
	Nitrate (NO3)	50 milligrams per litre	You also need to divide concentration of nitrate in milligrams per litre by 50. Add this to the concentration of nitrite in milllgrams per litre. Divide it by 3 - it must not be more than 1.
	Nitrite (NO2)	0.5 milligrams per litre	You also need to divide concentration of nitrate in milligrams per litre by 50. Add this to the concentration of nitrite in milllgrams per litre. Divide it by 3 - it must not be more than 1.
	Polycyclic aromatic hydrocarbons	0.1 micrograms per litre	This means the total of all individual polycyclic aromatic hydrocarbons found and measured during your testing should not be more than 0.1 micrograms per litre.
	Selenium	10 micrograms per litre	-
	Tetrachloroethene and trichloroethene	10 micrograms per litre	This means the total of tetrachloroethene and trichloroethene combined should not be more than 10 micrograms per litre
	Trichloromethanes	100 micrograms per litre	This means the total of all individual trichloromethanes should not be more than 100 micrograms per litre

Chemical limits: special conditions for acrylamide, epichlorohydrin and vinyl chloride

The water must not contain more than the maximum limits for these chemicals.

Chemical	Maximum limit
	Acrylamide	0.1 micrograms per litre
	Epichlorohydrin	0.1 micrograms per litre
	Vinyl chloride	0.5 micrograms per litre

If there’s any risk of the water exceeding these limits, you must check that the producer has sampled and tested the water. However, they do not need to analyse a sample of the water if you’re both satisfied that:

• the equipment in contact with the spring water is certified not to leak acrylamide, epichlorohydrin and vinyl chloride into the water
• they’ve not used any flocculants containing these 3 chemicals

The producer can demonstrate to you that any material used to come into contact with the water does not leak these chemicals into the water, by providing either a manufacturer’s:

• relevant certificate of conformity
• declaration of conformity
• declaration of performance

Pesticide limits

The producer must test their water to make sure it complies with the following limits.

Pesticide	Maximum limit	Details
	Aldrin	0.03 micrograms per litre	-
	Dieldrin	0.03 micrograms per litre	-
	Heptachlor	0.03 micrograms per litre	-
	Heptachlor epoxide	0.030 micrograms per litre	-
	Other individual pesticides	0.1 micrograms per litre	You only need to test for pesticides that are likely to be present in the water. (The maximum of 0.1 micrograms per litre applies to each individual pesticide you test for.)
	Total pesticides	0.50 micrograms per litre	Total of all individual pesticides you find should not equal more than 0.50 micrograms per litre.

Microbiological limits

The waterproducer must besend freeyou ofa parasitesreport andshowing bacteriatheir thatwater causeis disease.

Thefree producerof mustparasites. testThey theirshould watertest tofor makethis sureevery it6 compliesmonths withduring the followingperiod limits.for getting recognition.

ForThe initialproducer testing,must thesend produceryou musta havereport takento samplesshow both:

• atan source
• withinabsence of the firstfollowing 12bacteria hoursin afterthe bottlingtesting -conditions keepingset theout.

  They watershould atcarry betweenout -1°C andthese 4°Cbacteria beforetests theyevery send3 itmonths toduring the laboratory

period for getting recognition.

BacteriaProducer must show absence of these bacteria	MaximumTesting limitconditions
	Escherichia coli	0In per 250ml at 37°C and 44.5°C
Enterococci	Other coliforms	0In per 250ml at 37°C and 44.5°C
Pseudomonas	Faecal aeruginosastreptococci	0In per 250ml at any temperature
Faecal	Pseudomonas streptococciaeruginosa	0In per 250ml at any temperature
	Sporulated sulphite-reducing anaerobes	0In per 50ml at any temperature
Total

Microbiological reports: total viable colony count

The producer must test the total viable colony counts (TVCTVCs) every 3 months, both at source and after 72bottling.

Producers need to test the TVCs during the period to gather evidence for recognition and send you a report with the results. The TVCs are the total number of bacteria picked up by a test on the water.

Producers must collect samples within the first 12 hours after bottling. They need to keep the water at 22ºCbetween -1°C and 4°C before sending it to the laboratory.

The TVC, after bottling, should not exceed the following maximum limits.

100	Maximum perlimit	Testing mlconditions
100 per millilitre	TVCTest afterat 2420 to 22°C in 72 hours aton 37ºCagar-agar or agar-gelatine mixture
	20 per mlmillilitre	Test at 37°C in 24 hours on agar-agar

Check that the TVC after bottling does not change by more than 20% from the TVC shown at the source.

Radioactive limits

The producer must test the water to make sure it complies with the following limits.

For the initial testing, the producer should take samples at the point they bottle.

Test for	Maximum limit
	Radon	100 becquerels per litre
	Tritium	100 becquerels per litre
	Indicative dose	0.1 millisievert per litre

Check the producer understands the rules for exploiting the spring

Make sure the producer is aware of the rules they must follow once they’re registered and start to exploit the spring.

Rules for protecting the water at source

The producer must make sure that:

• any equipment they’ll use to collect the water, such as a pump, preserves the properties of the water and avoids contamination
• the source or borehole will be protected against pollution
• pipes and reservoirs are made from materials suitable for water, to food grade standards, and built to prevent any chemical, physio-chemical or microbiological change to the water

Rules for bottling or using containers

The producer’s bottling plant must be based at the spring.

The producer must:

• meet hygiene requirements when they bottle the water
• bottle in containers with lids, to avoid tampering or contamination
• use containers that are made to food-grade standards to avoid adverse effects on the microbiological and chemical characteristics of the water

If the water becomes polluted at any stage, the producer must stop bottling from the spring until they’ve removed the cause of the pollution.

Rules for transporting the water

Check that producers will transport their spring water from their plant in bottles or containers that the final customer will use.

The only exception to this is if, on or before 1713 JulyDecember 1980,1996, they were transporting water from the spring to a bottling plant further away, in containers not intended for the final customer. If they were, they can continue transporting using the same containers now.

Check and authorise treatments

A producer may want to use treatments to make their spring water taste better or to make it comply with the rules.

They may use any treatment for spring water. Producers must follow certain rules if they use:

• the authorised ozone-enriched air oxidation technique
• activated alumina

Ozone-enriched air oxidation treatment

Producers can use ozone-enriched air oxidation to separate compounds of iron, manganese, sulphur and arsenic from the water if they occur naturally at source.

They can only use this treatment if all the following apply:

• before they start, they’ve met the conditions for exploiting the spring
• the treatment does not have an accidental disinfectant effect
• the treatment does not alter the mineral, chemical and microbial composition of the water (apart from iron, sulphur and manganese)
• it does not leave residues in the water that could be a risk to public health

Any residues caused by this treatment should not exceed the following maximum limits.

Treatment residue	Maximum limit (milligrams per litre)
	Dissolved ozone	50
	Bromate	3
	Bromoform	1

You must authorise the producer to use this treatment. Before authorising, you should examine:

• the proposed method
• the proposed place of treatment
• samples for analysis

Authorised activated alumina treatment

Producers can only treat their water with activated alumina if :

• they’re aiming to remove fluoride
• they follow the technical rules

Any residues released into the water as a result of removing fluoride must be as low as possible and should not be a risk to public health.

You must check that:

• the treatment does not have an accidental disinfectant effect
• you give permission at least 3 months before the producer starts this treatment

Rules for labelling

Before you register the premises, check the producer understands the rules for labelling.

After registration, you’ll need to check their labels to make sure they’ve complied with the rules.

The producer must put the following on their labelling:

• type of product (also known as the sales description)
• name of spring and place where the water is exploited
• details of any ozone-enriched air treatment, if they’ve used this treatment

They can also put a trade description (sometimes known as the brand name) if they want to but it’s not legally required.

Type of product (sales description)

The words ‘spring water’ must appear on the labelling. This describes the product and is known as the sales description.

The producer cannot sell it as any other type of water, such as natural mineral water.

Name of spring and place where spring is exploited

On the label, the producer must put the name of the:

• spring - if the spring does not have a name, they must give it one
• place where the spring is exploited - for example, they could use the town or village name, or the postcode where the bottling plant is

If they’ve used an ozone-enriched air oxidation treatment

If they’ve used an authorised ozone-enriched air oxidation technique on their spring water, they must put the words ‘water subjected to an authorised ozone-enriched air oxidation technique’ on their labelling.

If they’ve used any other treatments, they do not need to put any wording on the label about them.

Trade description (optional brand name)

The ‘trade description’ is also known as the brand name. For example, Highland Spring, Pure Life or Harrogate.

The producer does not have to use a trade description for their spring water. But if they choose to have one they must follow the trade description rules set out in this section.

Trade description: using the town or place as a trade description

The producer can use the town or place as the trade description as long as the spring is located there.

They must not use a misleading place as their trade description. For example, they cannot name their water after a town in Somerset if their spring is in Devon.

If they use the town or place as their trade description then they must put the name of the spring elsewhere on the label.

And if they use the name of the spring as their trade description, then they must put the town or place elsewhere on the label.

Trade description: using a trade description that’s different from the name of the spring and place of exploitation

If producers want to do this, they must make the font for the name of the spring and place at least one and a half times the height and width of the largest of the letters used for their trade description.

Trade description: producers cannot have more than one

The producer must sell all spring water from the same spring or borehole using only one trade description. They cannot sell it under a second name.

For example, if they already sell ‘ABC Natural Mineral Water’ they’re not allowed to sell a new batch from the same spring using the name ‘DEF Natural Mineral Water’.

The only exception is if they want to sell their water to a retailer who will add their own branding to the labels, such as a supermarket, hotel, stadium, museum, venue or cafe.

The best practice way to do this is for the producer to sell the water with both:

• the producer’s own trade description
• the retailer’s own logo

If they do this, the retailer’s logo does not count as a second brand.

Alternatively, they can choose to not have their own trade description, remove their own logo and sell the water with the retailer’s logo instead. They can do this as long as the retailer’s logo is clearly separate from the sales description ‘spring water’.

Spring water as an ingredient in soft drinks

The producer can list the term ‘spring water’ as an ingredient on labelling if they’re producing soft drinks.

However, they can only do this if their water complies with the spring water rules in this guide, at the point they add the first extra ingredient, such as flavouring, to their spring water.

Ongoing checks

After you’ve registered a business to produce spring water, you must continue to monitor the water for the following:

• chemical limits
• microbiological limits
• indicators
• radioactive limits
• other limits

Unlike initial tests, you must take samples yourself and get a laboratory to check them.

When you test the water, take samples at the point the water is bottled.

Ongoing checks: chemical limits

Check the water for chemical limits at least once a year.

Your testing must give a representative picture of the safety and quality of the water.

So if you decide to analyse samples exactly once a year, take samples approximately the same time each year, rather than different months.

If you choose to test more often than once a year, take samples that are spread out evenly throughout the year. For example, take approximately every 3 months or 6 months

When the water is tested, it should not exceed the limits set out in this table.

Chemical	Maximum limit	Further details
	Acrylamide	0.1 micrograms per litre	-
	Antimony	5 micrograms per litre	-
	Arsenic	10 micrograms per litre	-
	Benzene	1 microgram per litre	-
	Benzo(a)pyrene	0.01 micrograms per litre	-
	Boron	1 milligram per litre	-
	Bromate	10 micrograms per litre	-
	Cadmium	5 micrograms per litre	-
	Chromium	50 micrograms per litre	-
	Copper	2 micrograms per litre	-
	Cyanide	50 micrograms per litre	-
	1,2-dichloroethane	3 micrograms per litre	-
	Epichlorohydrin	0.1 micrograms per litre	-
	Fluoride	1.5 milligrams per litre	-
	Lead	10 micrograms per litre	-
	Mercury	1 microgram per litre	-
	Nickel	20 micrograms per litre	-
	Nitrate	50 milligrams per litre	You also need to divide concentration of nitrate in milligrams per litre by 50. Add this to the concentration of nitrite in milligrams per litre. Divide it by 3 - it must not be more than 1.
	Nitrite	0.5 milligrams per litre	You also need to divide concentration of nitrate in milligrams per litre by 50. Add this to the concentration of nitrite in milligrams per litre. Divide it by 3 - it must not be more than 1.
	Pesticides - aldrin, dieldrin, heptachlor and heptachlor epoxide (each individual substance)	0.03 micrograms per litre	The limit of 0.03 micrograms per litre applies to each of these individual pesticides.
	Pesticides - any other individual pesticide	0.1 micrograms per litre	You only need to test for pesticides that are likely to be present in the water. The limit of 0.1 micrograms per litre applies to each individual pesticide.
	Total pesticides	0.5 micrograms per litre	The limit of 0.5 micrograms per litre applies to all individual pesticides added together.
	Polycyclic aromatic hydrocarbons (total substances)	0.1 micrograms per litre	This means the total of all individual polycyclic aromatic hydrocarbons found and measured during your testing should not be more than 0.1 micrograms per litre.
	Selenium	10 micrograms per litre	-
	Tetrachloroethene and trichloroethene	10 micrograms per litre	This means the total of tetrachloroethene and trichloroethene combined should not be more than 10 micrograms per litre.
	Trichloromethanes	100 micrograms per litre	This means the total of all individual trichloromethanes combined should not be more than 100 micrograms per litre.
	Vinyl chloride	0.5 micrograms per litre	-

Your laboratory can use any method of analysis. However, they must make sure they choose one that has an ‘uncertainty of measurement’ percentage that’s equal to or less than the percentages set out in the following table.

Chemical	Uncertainty of measurement percentage	Further details
	Antimony	40%	-
	Arsenic	30%	-
	Benzene	40%	-
	Benzo(a)pyrene	50%	If there’s no method of analysis for benzo(a)pyrene with an uncertainty of measurement of 50% or below, then use the best available method of analysis with an uncertainty of measurement of 60% or below.
	Boron	25%	-
	Bromate	40%	-
	Cadmium	25%	-
	Chromium	30%	-
	Copper	25%	-
	Cyanide	30%	The method of analysis must show the total cyanide in all forms.
	1,2-dichloroethane	40%	-
	Fluoride	20%	-
	Lead	25%	-
	Mercury	30%	-
	Nickel	25%	-
	Nitrate	15%	-
	Nitrite	20%
	Polycyclic aromatic hydrocarbons (each individual substance)	25%	-
	Polycyclic aromatic hydrocarbons (total substances)	50%	-
	Selenium	40%	-
	Tetrachloroethenes (each individual substance)	50%	-
	Tetrachloroethenes (total substances)	30%	-
	Trichloroethenes (each individual substance)	50%	-
	Trichloroethenes (total substances)	40%	-
	Trihalomethanes (each individual substance)	25%	-
	Trihalomethanes (total substances)	40%	-

Ask your laboratory to also take into account:

• minimum performance characteristics
• minimum performance characteristics: individual pesticides
• alternative minimum performance characteristics

Ongoing checks: microbiological limits

Check the water for microbiological limits at least once a year.

Your testing must give a representative picture of the safety and quality of the water.

So if you decide to analyse samples once a year, take samples at approximately the same time every year, rather than different months.

If you choose to analyse samples more often than once a year, take samples that are spread out regularly throughout the year. For example, take samples approximately every 3 months or 6 months.

When you test, check that the water does not exceed any of the following limits.

Bacteria	Maximum limit	Method of analysis your laboratory must use
	Escherichia coli	0 per 250ml	BS EN ISO 9308-1:2014-1:2017
	Enterococci	0 per 250ml	BS EN ISO 7899-2:2000, BS 6068-4.4:2000
	Pseudomonas aeruginosa	0 per 250ml	BS EN ISO 16266:2008
	Faecal streptococci	0 per 250ml	Not specified
	Sporulated sulphite-reducing anaerobes	0 per 50ml	Not specified
	Total viable colony count (TVC) after 72 hours at 22ºC	100 per ml	BS EN ISO 6222: 1999, BS 6068-4.5:1999
	TVC after 24 hours at 37ºC	20 per ml	BS EN ISO 6222: 1999, BS 6068-4.5:1999

Ongoing checks: indicators

You must monitor each of the indicators in the following table at least once a year.

Your testing must give a representative picture of the safety and quality of the water.

So if you decide to analyse samples exactly once a year, take samples at the same time each year, rather than different months.

If you choose to test more often than once a year, take samples that are spread out evenly throughout the year. For example, take approximately every 3 months or 6 months

If you find that any exceed the maximum limits, you need to investigate why and decide if the indicator poses a risk to human health.

Indicator	Maximum limit	Further details
	Aluminium	200 micrograms per litre	-
	Ammonium	0.50 milligrams per litre	-
	Chloride	250 milligrams per litre	The water must not be ‘aggressive’ (actively trying to take on minerals and metals).
	Clostridium perfringens and spores of Clostridium perfringens	0 in 100ml	You only need to check for this if the water comes from surface water, or is influenced by it. Use method of analysis BS EN ISO 14189:2016.
	Colour	-	Colour must be acceptable to consumers, with no abnormal changes.
	Conductivity	2,500 microsiemens per cm-1 at 20°C	The water must not be aggressive.
	Hydrogen ion concentration	9.5 pH units	The pH of the water must not be lower than 4.5. The water must not be aggressive.
	Iron	200 micrograms per litre	-
	Manganese	50 micrograms per litre	-
	Odour	-	Odour must be acceptable to consumers, with no abnormal changes.
	Oxidisability	5 milligrams per litre	This does not need to be checked if you’ve analysed total organic carbon.
	Sulphate	250 milligrams per litre	The water must not be aggressive.
	Sodium	200 milligrams per litre	-
	Taste	-	Taste must be acceptable to consumers, with no abnormal changes.
	Colony Count 22° C	-	No abnormal changes.
	Coliform bacteria	0 in 250ml	Use method of analysis BS EN ISO 9308-1:2014-1:2017 or BS EN ISO 9308-2:2014
	Total organic carbon		No abnormal change. This does not need not be checked for water supplies of less than 10,000m3 a day.
	Turbidity	-	Turbidity must be acceptable to consumers, with no abnormal changes.

Make sure the laboratory chooses methods of analysis that have an ‘uncertainty of measurement’ percentage equal to or lower than the percentages set out in the following table.

Indicator	Uncertainty of measurement percentage	Further details
	Aluminium	25%	-
	Ammonium	40%
	Chloride	15%
	Conductivity	20%
	Iron	30%
	Manganese	30%
	Oxidisability	50%
	Sodium	15%
	Sulphate	15%
	Total organic carbon	30%	The uncertainty of measurement must be estimated at the level of 3 milligrams per litre of the total organic carbon. You must use BS EN 1484: 1997 titled ‘Water analysis - guidelines for the determination of total organic carbon and dissolved organic carbon’ (ISBN 0 580 28372 0) published on 15 October 1997.
	Turbidity	30%	The uncertainty of measurement must be estimated at the level of 1 nephelometric turbidity unit in line with BS EN ISO 7027-1:2016 titled ‘Water quality — determination of turbidity. Part 1: Quantitative methods (ISO 7027-1: 2016)’ (ISBN 978 0 580 81961 2) published on 31 July 2016.

If there’s any other indicators you want to use but they’re not listed, sample and analyse the water for them. You must take into account the rules for any individual indicator on:

• methods of analysis
• minimum performance characteristics
• alternative minimum performance characteristics

Ongoing checks: radioactive substances

For radioactive substances, you must check:

• radon levels
• tritium levels
• indicative dose

Radon levels

Calculate the likely levels of radon in the water by looking at representative surveys.

You’ll need to consider underlying information which shows the likely exposure to radon, including :

• the geology and hydrology of the area
• the radioactivity of the rock types and soil types within your local authority area
• types of wells in varying locations in your local authority area
• other reliable information, for example, water authority monitoring and surveys

Once you have a likely radon level, check this table to find out what you need to do next.

Likely level of radon	Action needed
	Less than 100 becquerels per litre and this is not likely to change for at least 5 years	You do not need to monitor radon regularly but you can do so if you wish. If you choose not to monitor, you must apply to Defra for a monitoring exemption.
	Less than 100 becquerels but this is likely to change during the next 5 years	You must monitor radon levels regularly - use the volume table to work out how many samples a year you need to take. When you get the results from your volume table samples, check the actions needed.
	More than 100 becquerels per litre	You must monitor radon levels regularly - use the volume table to work out how many samples a year you need to take. When you get the results from your volume table samples, check the actions needed.

Radon: if you need to monitor regularly (using the volume table)

Use this table to understand what you need to do with the results from your regular monitoring.

Radon levels from your regular monitoring	Action
	Results are consistently below 100 becquerels per litre and no perceived risk to public health	You can reduce your monitoring. It’s for you to assess the risk yourself to decide how often you should test.
	Between 101 -1000 becquerels per litre on any single test (sample X)	Disregard sample X. This is because it may be a one-off. Take another sample immediately (sample Y). Then take further samples to get an average of the activity concentration of radon in the water over a 12 month period. The law does not set out how often or how many samples to get a 12 month average but you can use: - samples taken before sample X - sample Y - other samples after sample Y If the average level across your 12 month period is more than 100 becquerels per litre then you must take remedial action. If the average level is less than 100 becquerels, then you do not need to take additional action. Continue to monitor using the volume table instead.
	Over 1000 becquerels per litre	You must take remedial action immediately

Tritium levels

Calculate the likely levels of tritium in the water by looking at representative surveys. You’ll need to consider:

• monitoring data and other reliable information, for example, from a water authority
• likely exposure to man-made sources of tritium or other artificial radionuclides (chemical substances that exhibit radioactivity) that are present within the catchment area

Once you have a likely tritium level, check this table to find out what you need to do next.

Levels of tritium in the water	Action needed
	Less than 100 becquerels per litre and this is not likely to change for at least 5 years	You do not need to monitor tritium regularly but you can continue to do so if you wish. If you choose not to monitor, you must apply for a monitoring exemption.
	Less than 100 becquerels but this is likely to change during the next 5 years	You must monitor the tritium levels using the volume table to work out how many samples a year you need to take. When you get the results from your volume table samples, check the actions needed.
	More than 100 becquerels per litre	You must monitor the tritium levels using the volume table to work out how many samples a year you need to take. When you get the results from your volume table samples, check the actions needed.

Tritium: if you need to monitor regularly using the volume table

Use this table to understand what you need to do with the results from your regular monitoring.

Tritium levels from your regular monitoring	Action needed
	Consistently below 100 becquerels per litre and no risk to public health	You can reduce your monitoring. You should assess the risk yourself to decide how often you need to test.
	If any given sample exceeds 101 becquerels per litre on any single test (sample X)	Disregard sample X. This is because it may be a one-off. Take another sample immediately (sample Y). Then take further samples to get an average of the activity concentration of tritium in the water over a 12 month period. The law does not set out how often or how many samples to get a 12 month average but you can use: - samples taken before sample X - sample Y - other samples after sample Y If the average across the 12 months is more than 100 becquerels per litre then you must take remedial action. If the average level is less than 100 becquerels per litre, then you do not need to take additional action. Continue to monitor using the volume table instead. You must also now find out the indicative dose by asking your laboratory to: - work out both the gross alpha and gross beta activity of the water in sample Y - (follow the actions needed when you get these results) - test for the activity concentration for other radionuclides in any of your samples (check the actions needed when you get these results)

Indicative dose

The indicative dose shows the levels of radioactive substances a person would consume if they drank a particular supply of water over one year.

The indicate dose includes all radioactive substances present in the water, apart from:

• potassium-40
• radon
• tritium
• short-lived radon decay products

Calculate the likely level of indicative dose in the producer’s water by looking at representative surveys in your local authority area. You’ll need to consider:

• the geology and hydrology
• the radioactivity of the rock types and soil types
• different types of groundwater
• types of wells in varying locations
• other reliable information, for example, water authority monitoring and surveys
• presence of artificial sources of tritium and other radionuclides

When you’ve got your likely level, check it in this table to find out what you need to do next.

Likely level of indicative dose in the water	Action needed
	Less than 0.1 millisievert per litre and this is not likely to change for at least 5 years	You do not need to regularly monitor for indicative dose but you can continue to do so if you wish. If you choose not to monitor, you must apply for a monitoring exemption.
	More than 0.1 millisievert per litre	You must continue to monitor the indicative dose levels by carrying out all the following: - choose a screening strategy - use the volume table to work out how many samples a year you need to take - check the results for each sample you take and follow the actions needed

Choose a screening strategy for indicative dose

Take into account all the relevant information available to you and the likely sources of radioactivity in your area that may affect the water.

Then ask your laboratory to use any one of the following screening strategies to establish the indicative dose when you sample the water:

• gross alpha activity
• gross beta activity
• activity concentration for a single radionuclide
• activity concentration for more than one radionuclides

It is for you to decide which one you use.

When you’ve got the results, check what you need to do depending on if you used:

• gross alpha or gross beta activity
• activity concentration for one or more radionuclides

What to do with your results from gross alpha activity or gross beta activity

Results	Action needed
	0.1 or below becquerels per litre and other sources of information indicate that there are no specific radionuclides present in the water to make the indicative dose exceed 0.1 millisievert per litre	You can assume that the indicative dose for the water does not exceed 0.1 millisieverts per litre and you can just continue to monitor using the volume table frequency.
	Above 0.1 becquerels per litre	Take a new sample (sample Y) and calculate the ‘indicative dose determination’ of this sample. When you’ve got the result, follow the actions in the indicative dose determination table.

What to do with your results from the activity concentration for a single radionuclide or multiple radionuclides

Results	Action
	Activity concentration of any radionuclides does not exceed 20% of its derived concentration	You can assume that the indicative dose for the water does not exceed 0.1 millisievert per litre and you can continue monitoring using the volume table frequencies
	Activity concentration of any radionuclide in exceeds 20% of its derived concentration	Take a new sample (sample Y) and calculate the ‘indicative dose determination’ of this sample. When you’ve got the indicative dose determination result, follow the actions needed.

How to calculate the indicative dose determination

Follow these steps to work out the indicative dose determination for the water.

1. From your own records, make a note of the observed activity concentration of tritium and each radionuclide present in your spring water in becquerels per litre. This is known as the ‘ci(obs)’.
2. Find the derived activity concentration in the table for tritium and each radionuclide present in your spring water in becquerels per litre. This is known as the ‘ci(der)’.
3. For each individual radionuclide, divide the ci(obs) by the ci(der). This is also shown here in a formula.
   

4. When you have a divided value for each radionuclide, add them all together. This will give you the indicative dose determination.
5. Check your results in the indicative dose determination table to find out what action is needed.

Find the derived activity concentration for radionuclides

Origin	Radionuclide	Derived concentration in becquerels per litre
	Natural	U-238	3.0
	Natural	U-234	2.8
	Natural	Ra-226	0.5
	Natural	Ra-228	0.2
	Natural	Pb-210	0.2
	Natural	Po-210	0.1
	Artificial	C-14	240
	Artificial	Sr-90	4.9
	Artificial	Pu-239/Pu-240	0.6
	Artificial	Am-241	0.7
	Artificial	Co-60	40
	Artificial	Cs-134	7.2
	Artificial	Cs-137	11
	Artificial	I-131	6.2

If you cannot find any of your radionuclides in this table, you’ll need to follow these steps.

1. Go to ICRP Publication 119 entitled “Compendium of Dose Coefficients based on ICRP Publication 60”.

2. Find Annex F which contains a table labelled ‘Effective dose coefficients for ingestion of radionuclides for members of the public’.

3. Go to the last column of this table labelled ‘adult’. Find the dose coefficient for each radionuclide you need.

4. This dose coefficient is shown in sieverts so you’ll need to convert this to millisieverts (divide(multiply the sievert number by 1000).

5. You should now have a ICRP dose coeffecient in millisieverts for each radionuclide.

6. Multiply the millisievert number for each radionuclide you’ve found here by 730.

7. Divide 0.1 by the multiplied number you got in step 6 for each radionuclide. This is also shown here in a formula.
   

8. Go back to step 3 of working out the indicative dose determination and follow the steps from there.

Example

1. The vanadium 47 dose coefficient for an adult listed in the last column of the table in Annex F is 6.3E-11 Sv/Bq.

2. Convert this to millisieverts and you’ll get 0.000000063.

3. Multiply 0.000000063 x 730 to get a total.

4. Divide 0.1 divided by your total in step 3.

5. You should get 2174.4 becquerels per litre.

Check what to do with the results of the indicative dose determination

Results	Action needed
	If indicative dose determination is 1 or below	You can assume that the indicative dose for the water does not exceed 0.1 millisieverts per litre and you can continue to monitor using the volume table frequencies.
	If indicative dose determination is above 1	Take an extra sample immediately. Disregard Sample Y. Continue checking the indicative dose determination for the water for the next 12 months. The law does set out how often but you’ll need to get an average over a 12 month period. If your average indicative dose determination is 1 or below, no further action is needed. If your average indicative dose determination is above 1, you must take remedial action.

When you can reduce your monitoring of indicative dose

You can reduce the monitoring of indicative dose for the water if all the following apply:

• you’re satisfied that only naturally occurring radionuclides are present in the water
• your last indicative dose determination result was 1 or below
• you’re satisfied that reducing monitoring will not increase any risk to human health

If you reduce monitoring, but a change takes place that you believe is likely to influence the concentration of radionuclides in the water, you must choose a screening strategy.

Depending on the results of your screening strategy, you can either:

• carry on with reduced monitoring
• continue monitoring using the volume table to work out how many samples a year you need to take

Volume table

Average volume of spring water and bottled drinking water bottled each day within your local authority area	Number of samples you must take per year
	1,000 or less m3	1
	1,001 - 3,300 m3	2
	3,301 - 6,600 m3	3
	6,601 – 9,900 m3	4
	9,901 - 20,000 m3	5
	20,001 - 30,000 m3	6
	30,001 - 40,000 m3	7
	40,001 - 50,000 m3	8
	50,001 - 60,000 m3	9
	60,001 - 70,000 m3	10
	70,001 - 80,000 m3	11
	80,001 - 90,000 m3	12
	90,001 - 175,000m3	13
	175,001 - 200,000m3	14
	200,001 - 225,000m3	15
	250,001 - 275,000m3	16

Remedial action for radon, tritium and indicative dose

You must:

• identify the cause
• decide whether the levels pose a risk to human health that needs action
• get the bottled water producer to take action to restore the quality of the water if you think this is needed to protect human health
• notify the general public of the risks and remedial action taken
• advise the general public on any extra precautionary measures that may be needed to protect human health in terms of radioactive substances

How to get a monitoring exemption for radon, tritium or indicative dose

You must apply to Defra by email to bottledwater@defra.gov.uk for a monitoring exemption. You must apply within 3 months of deciding to not monitor.

Your application for an exemption must list all spring water and bottled drinking water sources in the area you’ve been monitoring.

Your exemption will lapse either:

• after 5 years
• at any time the levels exceed or you have reason to believe they exceed 100 becquerels per litre

Ongoing checks: other limits

You may believe or suspect that any of the following may be present in the water but have not been listed in this guide:

• properties
• elements
• substances
• organisms

If this is the case, you must take and analyse samples of the water on a case by case basis to check if any of these pose a risk to human health.

Tasks a local authority can delegate

A local authority can delegate the job of taking and analysing water samples to a company or other third party:

• as a one-off
• occasionally
• for a specific period of time

If you’re going to delegate testing to another party, you must follow certain rules.

You must explain to them:

• how to take samples and how often
• method of analysis that must be used, including any minimum performance characteristics that apply to any methods of analysis
• how to calculate the limits detected
• the uncertainty of measurement percentages needed
• validation and documenting of the methods of analysis used
• use of quality management practices

You must also make sure that the third party knows to tell you immediately if any limits have been exceeded during testing.

If limits have not been exceeded, they should give you the results within 28 days of getting them.