A primary goal of the EPA ETV Pilot Program is to bring a greater number of regulated small com-munities in the United States into compliance with the Safe Drinking Water Act (SDWA). Under this Program,the USEPA is building infrastructure to provide small communities, and the State Agencies that regulate them, with continuing sources of effective, compliant water treatment technologies. The developing infrastructure also provides lower cost, verified information,helping the communities to assess whether these tech-nologies can satisfy community needs. A benefit of this process to suppliers is that their interests are served by focusing efforts efficiently on meet-ing consensus requirements and by use of proven standard test methods and protocols to qualify technologies. These goals, and the infrastructure being developed to achieve them, subsume the greater goals of providing safe, wholesome drink-ing water to all people around the globe.

At present, expensive, repetitive testing of candi-date technologies is beyond the financial reach of many communities. The need for such testing is often justified on the basis that the quality of the drinking water source is unique site-to-site. As new technologies enter the picture, the amount of future testing promises to become unmanage-able. The successful Stakeholder companies will be those able to handle the significant expenses of qualification. By developing flexible and inno-vative strategies for testing, information dissemi-nation and promotion of the verification process, the EPA ETV Program has the potential to greatly reduce costs of repetitive testing and bring a high-er degree of consistency and continuity to the process of technology qualification. A current cost saving benefit of the EPA’s ETV PDWTS Pilot to both large and small companies is that ETV test protocols and assessment strategies for contami-nation removal performance and operation/main-tenance practicality are generally applicable to a majority of candidate treatment technologies.

To accomplish the ETV Program goals for the PDWTS it is required to have administration by an organization expert in the fields of standard test method development and third party testing. It appears appropriate that NSF International was selected by the USEPA for this job owing to its long, distinguished history of successful programs in drinking water product and materials certifica-tions (Standards 42, 53, 58, 60, 61). The need for third party administration by NSF International is inseparable from the disciplines of certification and verification and will continue. Organizations accredited by NSF to do third party testing to Standards also need continual training and audit- ing in these disciplines to enable the work to be done reliably and to maintain validity of verifica-tions resulting from their work.

Classes of Stakeholders in the EPA ETV PDWTS Pilot:

• U.S. Environmental Protection Agency, USEPA
• State Regulating Agencies, e.g. Departments of Health Services
• Equipment and Technology Suppliers
• Licensees/Owner-Operators
• Water Treatment Engineering Companies; Consultants
• Point-of-use Consumers

Since the work and expense of verification require constant justification within corporations, it is in the interests of the Stakeholders that the benefits of the Program be periodically reviewed,and also to provide a vision of its possibilities for the near future. After four years of ETV operations, appli-cation of NSF’s system of consensus committees for development of ETV test protocols and plans is progressing well. The reason appears to be that there is a broad and growing participation from the Stakeholders. We examine ways in this paper to further strengthen the Program especially from the point of views of Supplier, Licensee and Owner-Operator Stakeholders. As privatization of the Small System Package ETV Program nears, we are confident that NSF International can manage the Program in the best interests of all Stakeholders.

Since we will be talking about both verification and certification processes, we believe it is of value to anticipate questions about salient require-ments and consequences of EPA ETV PDWTS ver-ification versus certification to NSF Standards.

The EPA’s PDWTS verification processes and poli-cies provide for dissemination of test data and prod-uct information. They are intended to be simpler and less restricting than certification processes and provide the Suppliers and Licensee/Owner-Operator with verified performance facts relating to candi-date technologies.

Certification processes, in general, test products to a Standard and list the tested product only if it meets the requirements of the Standard. Product information provided to the third party certifica-tion organizations, e.g. NSF International, is held in confidence.

In the context of the drinking water treatment sys-tems qualification,verification and certification are largely complementary processes. Verification processes serve the needs of the customer for answering practicality and performance claims support questions. Certification to Standards addresses toxicological and safety questions.

ETV Program – Ongoing Challenges:

• Stakeholder participation
• Funds and time to complete Pilot development
• Streamlining the verification process
• Verified technology recognition
• Increasing the value of verification to Stakeholders
• Privatization of the ETV Program

Participation

The major work of developing and implementing test protocols and plans falls on the shoulders of a fairly appointed and technically balanced Steering Committee.Choosing members for potential long term service is helpful to establish continuity and stability of the verification Program and to opti-mize the roles of the membership as advisors to potentially transient Stakeholders who are cus-tomers for verification services. The ETV PDWTS meetings are typically also attended by a large group of Stakeholder participants, without voting rights, who have the opportunity to review devel-oping test plans and protocols, to offer input, and to pursue answers to their product or application specific questions. Experience with this gallery of Stakeholders shows that they often bring fresh views,revealing reasons that the developing, or rat-ified, protocols and plans don’t fit their technol-ogy, contradict results of other test methods, or overlook important issues relating to the end-use applications. For the most part, the main reason for participating is that these Stakeholders need to assess the value of the verification process as criteria for purchase of water treatment equip-ment. Taken together, such inputs can provide sound reasons for further development work. If not managed, these inputs can result in inertia at a time when ETV Program development should be accelerating and maturing. The consensus process for methods development available through NSF can harness the enormous resources of Stakeholder education and experience available in industry, among the regulatory community and at the munic-ipality to complete the job of development of the ETV PDWTS Pilot and effectively manage the future of the Program.

For the future, verification of water treatment tech-nology will be a dynamic process employing busi-nessmen, scientists and engineers from Stakeholder organizations who must respond quickly to change. Only a high level of responsiveness by these Stakeholder representatives to the unique needs of new technology and changing regulatory require-ments will make ETV verification practical to those who pay for the service. Every Stakeholder in the consensus process is a critical member of the team. Suppliers have the opportunity to develop prod-ucts to a prescription of criteria that are valuable to them only if accurately focused by the inputs of the other Stakeholders. Given a menu of proven verification test protocols, newcomers (e.g. Suppliers and Licensee/Owners-Operators) will need orientation from NSF International to choose an appropriate collection of available ETV tests adequate to support claims for performance and practicality pertinent to their candidate technologies for an end use. If appropriate test protocols are unavailable, the consensus process should be restarted to address the uniqueness of the candidate technology. The Regulatory Stakeholders must help decide what test methods are needed to adequately demonstrate compliance and how to interpret the results in terms of performance and practicality requirements for the end user. These strongly interdependent assess-ments are a valuable resource to drive the devel-opment of water treatment packages and thereby open a flourishing market to proven technology. In view of the continually expanding list of regulated contaminants,including newly discovered pathogens, it is not unreasonable to say that we are only at the beginning of the effort to learn how to stay current with the challenges. The consensus standards forum maintained by NSF International is ideally suited to coordinate the ongoing work and adapt to change.

Funding and Time

Additional development funding of the EPA’s ETV PDWTS Pilot is needed,along with more time to com-plete that job of establishing the infrastructure to maintain the Program for the future. As Stakeholders, we should petition legislators to continue the fund-ing that brought the Program to its current level of maturity. We should do this collectively because we recognize the contribution of the Program to maintaining human health and economic well-being in small communities. Suppliers and communities presently incur a heavy investment to comply with the Safe Drinking Water Act and anticipate greater expense in the near future to comply with regula-tory goals of the Federal Government. Federal sub-sidies are well spent on this Program,if the goals of decentralization of government are to be reached in the area of Drinking Water Treatment. The ETV Pilot, and the infrastructure it can build, has inter-national as well as national implications for the future. In addition,the EPA’s ETV PDWTS Pilot holds promise to develop the market for water treatment that can be implemented between the plant and the point-of-use in larger municipalities,which may help solve compliance-at-the-tap problems of cities where the distribution lines are beyond repair in the fore-seeable future. It is fair to say that NSF International already has adequate experience and infrastructure to effectively apply their protocols and standards for the residential point-of-use market,but ETV PDWTS protocols will also help address existing needs in the commercial and institutional point-of-entry markets. Time and funding will be needed to realize these potentials.

Streamlining

Another open challenge in the Program is to attract appropriate participants from the state agencies and the municipalities. Appropriate representatives are those who can expertly advise consensus com-mittees about streamlining the ETV Program and guide Program requirements with regard to inte-gration of different technologies into a variety of treat-ment trains, including those used for larger plants. For example, a desirable characteristic of a small system package is that it can grow with the com-munity and be compatible with existing and planned treatment trains suited to small community treatment needs.

Some technology can have a short life span in the marketplace, owing to factors such as competition and changing regulations,and therefore a large mea-sure of flexibility and responsiveness needs to be built into the ETV Program to qualify new tech-nologies in the most rapid way possible. It is very likely that the return on the ETV investment for a candidate technology is unknown and difficult to estimate at the time of submission for verification testing. Therefore, it is of interest to attract mar-keting experts to the committees who can provide market knowledge and direction to especially small Suppliers and Licensee/Owner-Operators about rea-sonable expectations for performance and eco-nomics of candidate technology. It may also strengthen the program to focus the efforts of Water Treatment Engineering firms on characterization of practicality and compatibility requirements and apply these assessments through the ETV program to candidate and verified technologies.

NSF International has a proven track record in man-aging Stakeholders to accomplish similar goals. It may strengthen the Program to focus the efforts of water treatment engineering firms on characteriz-ing aspects of practicality and compatibility and apply these assessments to candidate and verified technologies.

Streamlining may pertain also to providing a menu of test protocols that address real concerns of cus-tomers for verified equipment. For example,a new verification service area may be failure mode test-ing and analysis of candidate technologies, with feedback and follow-up statistical analysis of moni-tored field experience with the verified technolo-gies during service. This type of testing has the potential to alleviate the concerns of equipment buyers about the reliability and expected service life of new equipment. Removing such obstacles to smooth decision making can be a valuable function of the ETV Program for the future.

Recognition of Verified Technology

Development of protocols under the ETV Program should provide for guiding the Supplier to conduct qualifying testing comprehensive enough for the candidate technology to be of significant commer-cial value.The NSF forum is perhaps one of the few places in the world where the Stakeholders are ded-icated to addressing these goals at a scientific level with the expert input of esteemed representatives of organizations such as AWWA and NRWA.

Municipalities and regulators need to advise about what they want,or to seek help to define what they want. Ultimately, all Stakeholders must acknowl-edge whether or not identified goals are met through the Program. Inputs are needed to cover those aspects of operation and maintenance that will meet the special needs of a variety of small communi-ties. These communities may require community need characterization and technology fitting ser-vices. For example,Suppliers need to know whether testing for one,two or all seasons is needed to qual-ify their treatment equipment for physical removal of microbes to regulated levels. Ground Water might be expected to be more consistent in feed quality than Surface Water. Drought and storm effected Surface Water regions may require testing on worst case water quality to reduce tests for treatment sites in those regions. If verification testing is success-ful, the path should then be open to address service life and warrantee concerns via business agreements between the municipality (Licensee Owner-Operator) and the supplier. State agency and Licensee/Owner-Operator Stakeholders are urged to join the NSF ETV Forum in greater numbers to par-ticipate in this important work in the interest of reducing the burdens of site testing and to build recognition for valuable technologies that have ver-ified performance.

Recognition of the ETV Program may be advanced by provision of a direct source of updated, well managed information to alert Licensee/Owner-Operators to how and where to find the verified products resulting from ETV Program verification processes. In addition, that source of information should be designed to assist in the determination of the fit of a verified technology to specific com-munity needs.

In effect, recognition of excellence is achieved through verification. The more recognition received, the more enthusiastic the suppliers and end users will be and the more they will participate.

Increasing the Value of Verification

We have already addressed several ways to increase value of the ETV program. Let’s look at this subject more comprehensively. The value of the verification to the supplier is largely a function of return on investment. With or without ETV program creden-tials, suppliers currently have the option to run tests at the Licensee or Owner-Operator test site to demon-strate performance and to then use the gradually building portfolio of test reports to pursue additional business. Unless the amount and expense of these tests can be significantly reduced under the ETV Program progress will be slow and business will continue, as usual. Personal contact with the cus-tomer is important and, in the Program’s favor, can be much smoother if everyone is working from powerful consensus positions such as the ETV Program can offer. There are several ways to add value to the ETV PDWTS Program from the admin-istrative and regulatory side.

1. Promote regulator and Licensee/Owner-Operator recognition of the value of verification testing.
2. Educate at-the-tap consumers to achieve recog-nition of the value of ETV technologies and the role they can play in providing a reliable supply of safe water.
3. Institute regulatory requirements for use of con-sistent test methods for technology performance qualification. The Association of State Drinking Water Administrators is annually surveying munic-ipalities on this issue.
4. Define conditions for worst case service of regen-erable and disposable treatment technologies and test for a period just sufficient to give confidence of reliable service and performance under those conditions.
5. Enforce NSF Standard 60 and 61Certifications as a prerequisite for final verification of new prod-uct testing under the ETV.
6. Invest in information dissemination.
7. New ideas requiring significant work:

• NSF might assist suppliers, state regulators and owner-operators to access data and interpret the significance of verification test results by main-taining a public access database with capabili-ty for making/viewing comments and assessments from consensus Stakeholders and impartial, well-informed third party consultants. This information can be used as a resource for determining whether the current test methods are serving well and to prompt ETV Program participants to corrective action.
• The USEPA should share the results of their sur-veys of the state regulatory agencies,Licensees and Owner-Operators in the U.S., annually, to get their input about ETV listed systems – provid-ing a platform for showcasing excellence.
• International Suppliers may benefit if confor-mance to Standards 60 and 61 as well as the ETV PDWTS Pilot verifications are further developed to meet or exceed the qualifying requirements of foreign countries for candidate small package treatment systems.
• The USEPA and NSF International should arrange for Licensees and Owner-Operators to maintain certifications and verifications of regulated sys-tems throughout the service life of the equip-ment. This might help build a solid base upon which licensees can stay in-compliance and sup-pliers can build an after-market for service and supply to maintain well performing and safe treatment systems.
• The U.S. Government might assist to negotiate reciprocity of equivalent U.S. and Foreign Certification and Verification Protocols for import-export of drinking water treatment tech-nology.
• NSF might qualify as a recognized laboratory to test products against international standards,or develop universal NSF standards that incorpo-rate the requirement of all nations as certifica-tion/ verification options to International Suppliers.
• Many, not all, of the verified technologies can be manufactured in a full range of sizes that easily meet the needs of the growing and larger com-munities. The ETV PDWTS Pilot Steering Committee ( January 1999) has left the exten-sion of ETV performance test results to scale-up of systems to the consulting engineering firms. Assessments will not appear in the ETV protocols or the verification reports. Where extension of results of verification reports can be applied to larger systems it is recommend-ed that this assessment be routinely requested at the earliest stage of adoption of a technolo-gy by both equipment suppliers as well as Licensee/Owner-Operators in a separate report. By this means the investment in technology ver-ification may be made more manageable for suppliers and customers alike.

Owing to rapidly expanding technology devel-opment programs by suppliers, both the large and the small system package end users will be the ben-eficiary of a wider selection of new technologies in the future that meet a well thought out shop-ping list of needs. Such characteristics as small sys-tem footprint, system automation, remote monitoring, in-line/on-line detection for membrane integrity and contaminant monitoring are just a few examples. Verification of small system perfor-mance claims will become a fact in real-time throughout the service life of the package sys-tem. Some of these technologies may not be eas-ily scaled-up to larger municipal applications; other technologies will be.

Since several of these technologies may enter the market each year, the ETV consensus committees will need to maintain a full program to develop technology-specific test methods that adapt to serve the small, as well as the growing community. The significance of the integrity tests and in-line/ on-line monitors to assurance of performance is a new subject that should fit the ETV PDWTS charter for development of test protocols. The greater value of the certifications and verifica-tions, the more enthusiastic the suppliers and end users will be and the more they will participate. NSF serves an important role as administrator of certification and verification listings and as a qual-ified third party to conduct tests or to ensure proper conduct of testing to meet the require-ments of the Program.

The paths to the goals of bringing the ETV Program to full realization of its potentials are to be found in competent dissemination of needed information to the Licensee/Owner-Operator, expert consen-sus management of standards development, and accredited administration of the verification and certification processes. Never before in history has the world been better equipped for getting infor-mation to the places it is needed. NSF has all the tools required to carry out the ETV mission initi-ated and fostered by the U.S. Environmental Protection Agency. NSF International sites on the Internet currently provide continuous, updated information of com-mercial value.

Current sites:

• Listings
• Standards
• News

NSF may expand its information services to the community of Stakeholders and include a more comprehensive collection of services we have dis-cussed that apply to drinking water and waste-water treatment.

A potential for future NSF water treatment tech-nology sites might include:

• Training in standards (fee based).
• Links to available sites covering NSF Testing for international product qualification standards.
• ETV Verified Technology source page with links to supplier sites and supplier option to provide site access to verification test reports for view-ing or download (public database).
• Monitored Technology Cumulative Performance Data and Analysis – by water type/contami-nant/ unit-process in treatment train – feedback from monitoring verified technology in the field. May be designed to include goals of the Information Collection Rule.
• New technology alerts.
• Problem-opportunity statements – practical and scientific reporting – peer reviewed – (fee for access).
• Bulletin board for technology commentary (public database).

It is hoped that the international community will take a moment to realize that NSF International is a valu-able resource to accomplish both national and inter-national goals in qualifying appropriate equipment for treating drinking water. The potential for NSF to become even more valuable is self-evident. With the powerful resources available to all Stakeholders through NSF International,the oppor-tunity for the community or municipality to use con-sistent, peer reviewed test methods and data to reach a logical and reasonable decision in selecting drinking water treatment technology can be a real-ity. Purchase choices can be made by cross-refer-encing listings of verified and certified products. If additional testing is still required,a field of products can be narrowed to reduce the amount of testing overall, with a greater likelihood of success.

The opportunity for globalization of standards for qualifying drinking water treatment equipment has never been closer than it is today. NSF is actively involved with other approvals organizations such as AFNOR ANOR,KIWA (N.V.) and DWI (UK) and CEN (European Committee for Normalization). The time is coming when the differences in standards con-formance and approvals among nations will be small, or can be satisfied by supplementary testing. For the present,all world and government organizations concerned with drinking water quality regulations and safety assurance may participate in NSF Forums as equals. International corporations can be focused on the range of needs of small communities, glob-ally, and also heard regarding the issues of test pro-tocol design in which these suppliers are expert.

Small system PDWTS fit well into the descriptions of needs we hear discussed in this conference. It is important to take a broad view of the world and realize that small system opportunities will range from extremely cheap and simple to the most sophis-ticated systems available. There is perhaps a greater need for ETV verification at the lower end of this spectrum where the price will be a greater deter-minant in the technology employed. The test meth-ods developed under the ETV Program for Small System Packages will provide the measuring stick to determine whether the range of products are worth using at any price.

Corporations with international presence have a special interest in reducing the investment in cer-tification, approval and verification for the same technologies in different countries. The experience to date is that huge amounts of time and money are currently spent to repeat the qualifying processes in each country. The excessive repetitiveness of these processes is wasteful. The costs must be included in the price of the technology to the end user.

We are examining the possibility to build an inter-national Industry Forum for qualification of Small System PWDTS on the foundation of the ETV Program. We believe NSF International is the pre-mier organization to represent the International Suppliers of Small System PDWTS and for develop-ing internationally harmonized qualifying tests and performance protocols. NSF currently has the capa-bility to perform any test the supplier requires and to provide special categories of listings that may incorporate a combination of tests for conformance to different requirements. We are investigating fea-sibility of an NSF administered international con-sortium, which would institute a program whereby the qualification testing required by different coun-tries, can be harmonized into an NSF suite of stan-dards that will be granted recognition by the member countries.

As a first step, it is required that the excellent work accomplished under the ETV Program can be com-pared with similar high quality work of regulators and standards organizations in other countries, and then harmonized. In this way we may find that we can open the world to a high quality Small Package System trade to harvest the fruit of the enormous amount of work being done.

Realizing the Potential of the Environmental Technology Verification (ETV) Package Drinking Water Treatment Systems (PDWTS) Pilot Program in the United States and Globally (PDF: 60KB)