‘Suitable’ vs ‘Wholesome’ Drinking Water: What is best for school children?

Water supplies for English and Welsh school children appear to have differing standards – ‘suitable’ vs ‘wholesome’. 

It begs the question: What could this mean in terms of drinking water quality?

Leadinthewater.com has compared school drinking water provision in England and Wales. The article draws on the 2019 National Education Union ‘Standards for school premises’ (England here) and 2019 National Education Union ‘Standards for school premises (Wales here)’.

Suitable and Wholesome Water?

Schools in England and Wales must provide suitable supply of wholesome water to workers in a school building. 

The water provided to school pupils in England needs to be suitable.

In contrast to the English Standards for Schools, the Welsh Standard requires wholesome water provision for both workers and pupils in school premises.

Wholesome water can be defined as ‘fit for human consumption’. The drinking water inspectorate (DWI) for England and Wales explain ‘wholesomeness’ within their published guidance document (2018) (here). The guidance provides comprehensive quality parameters such as water being free of toxic chemicals and biological hazards. The extract below shows part of Regulation 4 which deals with wholesomeness of water.  

The drinking water provision in English schools differs from that in Welsh schools in relation to the classification of the drinking water supplied for children to consume. In Wales a school provides wholesome supply of water for domestic purposes and this provision can be used to support pupils’ access to drinking water. On the other hand, English schools provide ‘suitable’ drinking water facilities and wholesomeness of the water is not mentioned in the provision for pupils. 

A suitable supply of water is described in the school premises regulations (2012) as readily accessible and separate from toilet facilities, and cold-water supplies that are suitable for drinking must be clearly marked as such. The school premises (England) regulations (2012 – see here) state:

2. – (2) Any requirement that anything provided under these Regulations must be “suitable” means that it must be suitable for the pupils in respect of whom it is provided, having regard to their ages, numbers and sex and any special requirements they may have. 

Therefore, a suitable supply of water is more about quantity and requirements of the water in relation to the age, numbers, gender and any requirements they may have – which compares to wholesome water provided for children in Wales where wholesome water is specifically associated with water quality and is fit for human consumption. 

Why is the quality of drinking water ‘suitable’ in English schools and not ‘wholesome’?

The School Premises (England) Regulations 2012 replace the Education (School Premises) Regulations 1999. The National Education Union (2019) state: 

There are fewer regulations than previously, and they are less prescriptive, allowing schools more flexibility in how they use their premises and, as a result, offering less protection to staff and pupils than was previously the case.

Less protection to pupils may be exemplified in this paper as English pupils’ access to ‘suitable’ water that may or may not be fit for human consumption – however, it can be argued that if the drinking water for pupils in English schools were generally fit for human consumption then it would be described as wholesome and not ‘suitable’. 

The water undertakers have a statutory duty to supply wholesome water. The Water Management in Schools Research Report (1993 – see here) suggests that lead is virtually absent from the water supply when it enters the school building. However, the report is explicit about health-related risks from lead in school drinking water within the building, which seems to have been omitted in more recent studies and statutory documents:

There are a number of health-related issues regarding drinking water in schools. Lead in school drinking water is of particular concern because prolonged exposure to relatively low levels has been reported to cause potentially harmful effects, including behavioural changes in children. Lead is virtually absent from water entering supply but contamination by lead arises from lead pipework and lead-containing water fittings. 

English schools built after 1986, when lead solder was made illegal on both hot and cold-water distribution systems, are likely to have less exposure to contamination from lead than older school buildings.  

For older schools, there is a significant risk of water contamination from a number of sources such as legacy plumbing containing old lead or galvanised iron pipes, copper pipes with lead-solder fittings and drinking water taps made from brass which contain high levels of lead. Technical information from quality tap manufacturer Buelco (see below) describes how lead is often added to new taps during the manufacturing process to make it easier to work with. 

The European Drinking Water Directive is working towards lower lead content in the manufacturing of alloys and, in recent years, improvements have been made. Nevertheless, metallic materials, like drinking-water taps, still contain between 0.2% and 3.5% lead – the vast majority of the alloys tested have lead content less than 2% (see here).  

It is important for the responsible person for English schools – i.e. the person tasked with deciding on the type of plumbing product installed – to know that they may be held accountable for the type of product they specify for small works on school premises. The following extract from Ireland’s ‘Guidelines on Mains Water Distribution Systems in Post-Primary Schools (2014)’ clarifies the toxic risks from metals in school plumbing systems:  

It is highly possible that school pupils in England could be exposed to low-level poisoning from stagnant water from older school plumbing systems, which often contain carcinogenic toxins and substances dangerous to breast-feeding mothers and women of childbearing capacity. Lead is a reprotoxin that can cause neurological damage and other defects to children in the womb. 

It is our argument that a high proportion of schools in England are likely to have older toxic plumbing distribution systems and the streamlining of regulations to allow for flexibility are underplaying a significant toxic risk, which is likely to impact English school children’s health.

This paper is the fourth in a series for the World Health Organisation’s (WHO’s) ‘International Lead Poisoning Prevention Week 2019’. There will be more papers to follow that describe the risks of Legacy plumbing in buildings – such as schools, homes and hospitals – so be sure to check leadinthewater.com for more information.