“Freshwater” means many things to many people. For some, it’s the crisp, cold splash from a fridge-chilled bottle. For others, it’s the gentle flow of a Yorkshire beck, or the tap water used to make a morning cup of tea. But when it comes to managing water systems—especially in regulated environments—these everyday perceptions fall short of what’s needed to ensure safety, reliability, and accountability.
By Annette Davison and Sarah Loder
So, what is freshwater, really?
In researching information for this article, many definitions of freshwater emerged.[1] As a general rule, we can say that freshwater is defined by where it is found, and its characteristics in terms of dissolved salts (see box right). Rather than chasing a universal definition however, it’s more practical—and more powerful—to ask: Is this water fit for its intended purpose? This shift in thinking moves us away from vague notions of “quality” and toward a more functional, risk-based approach. In trade practices law, this is known as fitness for purpose, and it’s a concept that can transform how we think about, and manage water.
Freshwater
Water found in lakes, rivers, streams, ponds, and groundwater.
Contains low concentrations of dissolved salts (depending on reference, <1000 ppm or <500 ppm).
Water Always Has “Bits” in It
Water is rarely, if ever, sterile, unless intentionally produced as such. Even drinking water, which undergoes rigorous treatment, contains microscopic and solubilised constituents. That’s not a flaw, it’s a reality. The idea of “quality” often implies purity, but in water management, purity is not always the goal. In fact, pure H₂O is not very pleasant to drink, beneficial to your health, or suitable for maintaining water supply assets. For instance, let’s take a look at desalinated water. It must be remineralised, to make it fit for drinking and fit for sending into our distribution systems, so it does not cause impacts. So instead, we should be focussing on water’s characteristics: what’s in the water, how those “things” behave, and whether the water is suitable for its intended use.
A Framework for Fitness for Purpose
To manage water effectively, we need a standardised way to describe its intended use and assess whether it meets the necessary criteria. This is where we can learn from HACCP (Hazard Analysis and Critical Control Points)—a system widely used in food safety that focuses on identifying risks and controlling them at critical points. Below (Table 1) is a structured four-step example for a utility context, but it could apply to any water product including outdoor recreational water, recycled water or swimming pool water.
Table 1. Fitness for purpose framework for water products and services.
| DESCRIPTION | DRINKING WATER |
| Step 1: Product Description Firstly, product description sets out what the utility is actually producing, its “water products”. After all, a water utility is a manufacturer. |
Contemporary water utilities have a multitude of products, with drinking water usually being only one, so it is important to describe and differentiate those products, as each has its own fitness for purpose requirements. |
| Step 2: Intended Uses The next step is to define the “intended uses” of the products as well as clearly stating where the product may be unsuitable for use. |
For drinking water, it is usually the highest exposure uses whereas for something like “raw” (untreated) water, it may only be suitable for toilet flushing or irrigation. Although we have not always seen this in descriptions, it may be necessary for a utility to specify whether the water is intended as suitable for conveyance in standard distribution systems i.e. that it is acceptable for “normal” assets used in the construction of reticulated water systems. |
| Step 3: Intended Users It is important to define who can use the product. |
Drinking water, like our food and beverages, is not sterile or suitable for all end users. Even if you are generally well but recovering from an illness for instance, it may be advisable not to drink unboiled tap water until you are fully recovered. Utilities are generally not allowed to provide “health advice”, but from a due diligence perspective, it is important that you make clear who can and who cannot or should not be using your product. |
| Step 4: Product Criteria And finally, you need to set out the criteria to which you are producing the product, this is what determines fitness for purpose of the product overall. |
For drinking water, usually this will be the national drinking water guidelines as well as other contextual information such as state or territory-based guidance, codes of practice or operating licence requirements. Further, as climate impacts start to bite and water reticulation system temperatures start to rise, making sure the water at the handover point with a customer not only meets drinking uses but also uses that might have an inhalation exposure route (e.g. via aerosols generated from showering or maintenance work), should be considered, from an opportunistic pathogen perspective. Simply meeting “drinking water” guidelines may not be enough, should “exposure” or “WHS” guidelines also be applied? Certainly, something to think about. |
Why This Matters
By framing water management around fitness for purpose, we create a more transparent, accountable, and risk-aware system. It allows utilities, regulators, and consumers to understand not just what water is, but what it’s for—and whether it’s safe to use in that context. Water isn’t just “fresh” or “clean.” It’s a product with characteristics, risks, and responsibilities. And managing it well starts with asking the right questions. Feel free to reach out to us here at The Risk Edge Group – we’re always keen to learn more and help where we can.
Table 2. Example four-step “fitness for purpose” capture for example water products.[2]
| PRODUCT DESCRIPTION | INTENDED USE OF PRODUCT | ||
|
WeAllUseWater Utility produces two non-sterile products: • Drinking water. • Raw water. Drinking water is sourced from Really Big Dam via a weir extraction point on the Really Big River. Source water is treated at the Really Big Water Filtration Plant to meet drinking water quality criteria (see below). Raw water is sourced from Smaller Dam, is untreated, and supplies a raw water reticulation network. |
Drinking Water |
Drinking water is intended for the highest exposure uses at the handover point with the customer: • Drinking (general consumption). • Washing of bodies and clothes. • Preparation of foodstuffs. Ordinary drinking water may not be suitable for those people for whom a higher quality of water is required (e.g. certain industrial or commercial uses). Point of use treatment may be required where a higher quality is required. |
|
| Raw Water | Raw water is not intended for any of the high exposure uses identified above. It can be used for end uses such as toilet flushing and irrigation of gardens. | ||
| INTENDED USERS OF PRODUCT | PRODUCT CRITERIA | ||
| Drinking Water |
Drinking water is intended for use by the general population. There are people that are advised to provide additional point-of-use treatment before drinking the water based on specific medical advice and such patients are not necessarily the intended users. There may be industrial, agricultural or commercial uses for which ordinary drinking water is unsuitable and such customers are not necessarily the intended users. There are some parts of the drinking water supply (Small Village 1, Smaller Village 2) where the residence time in the reticulation network is long, and potable quality can no longer be guaranteed. These users are advised (via an annual letter with rates) that their water is not suitable for drinking purposes. Where premises are rented, owners are advised to pass on this information to their tenants. |
Drinking Water |
The relevant criteria for the drinking water product are: • State-based Safe Drinking Water Act and Regulations. • National Drinking Water Quality Guidelines (current version). • Operating Licence requirements relating to management of drinking water quality (WeAllUseWater Operating Licence 2019-2024, Clause 2). • State-based water quality criteria as stipulated by the local Health department (WeAllUseWater Utility and Department of Health Code of Practice). |
| Raw Water | Raw water users are those in the Small Village 3 area. These customers are advised (via an annual letter with rates) that their water is not suitable for drinking purposes. Where premises are rented, owners are advised to pass on this information to their tenants. | Raw Water | There are no formal water quality criteria for raw water. However, WeAllUseWater Utility does monitor cyanobacterial levels in the Smaller Dam and informs users when ‘amber alert’ levels are detected. Roles and responsibilities for quality monitoring are explicitly expressed in the supply agreements with these customers. |
[1] E.g., https://en.cubemos.com/sustainabilityglossary/suss-water-and-non-suss-water; https://ucmp.berkeley.edu/exhibits/biomes/freshwater.php; https://www.iisd.org/ela/blog/back-to-basics-what-is-fresh-water/
[2] Adapted from: Davison, A. (2020). Application of ISO 31000 to Drinking Water Quality Risk Management. A Practical Approach. ISBN 978-0-987-5560-0-4 Risk Edge Pty Ltd.