Indah Water – Sewerage Safety Plan (SSP) Framework





  1. Summary of the project, product, framework

Sewerage Safety Plan (SSP) is a framework for risk based management tool developed by IWK to protect the public and operators safety along the life cycle of sewerage system in a systematic manner. This framework will provide structure to identify the criticality of hazard and hazardous event which to be measured in asset risk assessment as well as to plan the right improvement plan based on the actual risks, promote safety benefits and minimize adverse safety impacts. SSP shall provide assurance by prioritizing and targeting risk assessment including its control measures that shall provide impact and to improve over time.

  • Description of project or framework addressing the assessment criteria

The operational and maintenance process will be considered as priority activities that consist of collection of domestic wastewater (sewage and sullage) from public using sewer network distribution, treatment process of untreated wastewater at sewage treatment plant (STP), reuse of by-products generated from the sewerage system and disposal of sludge to the designated landfill including discharge of treated wastewater to waterways. The safety elements for each activity shall be considered in ensuring the final product can be safely returned to the environment, be it discharge to the rivers/ coastal waters or recycle.

IWK serves a large number and various types of sewerage system including STP, network pump station (NPS), sludge treatment facility (STF) and its equipment as well as sewer network. For operations and maintenance purposes, the STPs were divided into 2 categories; manned and multipoint plant.

Manned plant was further divided into 3 classes :

  1. Class IA
  2. Class IB
  3. Class II

The characteristic of manned plant in each class is described in Table 1.

Table 1: Characteristic of Manned Plant

CriteriaDPE >100,000 PEMechanical Sludge Digester (MSD) and DigesterGas EngineSCADA and InstrumentationMini LabWater recycling facilityDPE >20,000 PEMSD SCADA and InstrumentationMini LabWater recycling facilityDPE >20,000 PEMSD or electricity >RM100,000/yearSCADA and Instrumentation (optional)Water recycling facility (optional)
FacilityManned Plant OfficeLocal SAP-EAM (with internet)Local data filingMini M&E WorkshopManned Plant OfficeLocal SAP-EAM (with internet)Local data filingMini M&E WorkshopManned Plant OfficeData filingSAP-EAM from UO (no local internet)Centralized M&E Workshop
ToolsTreatment Tools: DedicatedM&E Tools: DedicatedTreatment Tools: DedicatedM&E Tools: DedicatedTreatment Tools: Sharing (except MLSS meter)M&E Tools: Centralized
In-House ManpowerEngineer: DedicatedSupervisor: DedicatedM&E: Dedicated team. Report to M&E UOEngineer: DedicatedSupervisor: DedicatedM&E: Dedicated team. Report to M&E UOEngineer: Sharing Supervisor: DedicatedM&E: Centralized
MonitoringLiquid process sampling analysisSolid process sampling analysisEnergy consumption & profilingMicrobial analysisLiquid process sampling analysisSolid process sampling analysisEnergy consumption & profilingMicrobial analysisLiquid process sampling analysisSolid process sampling analysis (intermittent)Energy consumption & profilingMicrobial analysis (intermittent)
Performance AnalyticsEnergy Optimization (kwh/m3)Polymer Consumption (kg polymer/tonne)Polymer ConsumptionLoading Analysis (hydraulic/organic)Process Optimization AnalysisTrouble Shooting
ReportingHydraulic ProfileEnergy Consumption ProfileO&M Cost (per m3)GSR ReportCompliance ProfileSludge Generation & DisposalEquipment Performance OperabilityGas GenerationBio-effluent/ Bio-solid/ Biogas Recycled

This SSP is developed with the consideration of the below aspects:

  1. To comply with Water Services Industry Act (WSIA) 2006 (Act 655) and Environmental Quality Act (EQA) 1974 (Act 127).
  2. To be within IWK Business Plan and business coverage areas.
  3. To be in line with IWK’s Mission and Vision.
  4. To comply with ISO schemes under IWK’s Integrated Management System (IMS) including:
  5. ISO 9001:2015 Quality Management System (QMS)
  6. ISO 55001:2014 Asset Management System (AMS)
  7. ISO 14001:2015 Environmental Management System (EMS)
  8. ISO 45001:2018 Occupational Health & Safety Management System (OSHMS)
  9. To determine the SSP Objectives and its strategies to achieve the objectives.
  10. To identify the operational plan to manage the sewerage safety through risk assessment (hazard and hazardous event including its control measures).
  11. To identify the possible resources needed to ensure the safety of sewerage system-related.

This SSP will be further developed into separate guidelines according to the classification of manned plant. It is important for the organization to ensure the integrity of the collection of sewage and its treatment before being discharged/ disposed to the environment. In order to achieve that, specific measurable targets have been set to transform the required outcomes (product or service) as shown in Table 2.

Table 2: Measurable Target to Achieve SSP Objective

ISO SchemeObjectivePlan to Achieve the Objectives
Action RequiredResources Required/ Record
ISO 9001 QMS≥95% of customer’s complaints and inquiries are addressed within the LOSTo monitor customers complaint and enquiries on monthly basis by UOCustomer Enquiry Management System (CEMS)
Reduction of Operational Complaints per 1,000 Billed Customers (Nationwide ≤7.20)To monitor number of operational complaints per 1,000 billed customers on monthly basis at UOCEMS
ISO 14001 EMSCompliance to effluent discharge standards ≥97% (manned plant)To monitor process parameterTo monitor calibration of the equipmentEQA 1974, EQSR 2009
100% sludge tankered by IWK is treated at designated siteTo ensure all tankered sludge by DBU is handled at designated site for treatmentEnhancement in VMS for tanker activity monitoring to 171 approved sitesEQA 1974, EQSR 2009WSIA 2006, Desludging Services Regulations 2021
ISO 45001 OHSMSReduction incident: IWK shall not exceed 8 incident rates per 1,000 workersAudit and inspectionMonthly reporting of UO performance reportHealth & Safety Committee MeetingIWK Safety Plan
ISO 55001 AMSCompliance to Effluent Discharge Standards (all STPs) Nationwide ≥96%Aligned with IWK Business Plan on effluent compliance where all STPs shall meet the certain benchmark of the required effluent discharge standardsEQA 1974, EQSR 2009

In IWK, the operational complaints are divided into several types to suit with operational strategies and to address the customer’s complaints and inquiries in order to ensure an efficient and safe sewerage system. These operational complaints together with compliance are directly contribute toward SSP Objectives and subjective to the manned plant classification:

  1. STP/NPS Pump Not Working
  2. STP/NPS Overflow
  3. STP/NPS Odor
  4. STP/NPS Hole In Fence
  5. STP/NPS Damaged Fence
  6. STP/NPS Noise Nuisance
  7. STP/NPS Rubbish/Pest
  8. STP/NPS Overgrowth
  9. STP/NPS Structure Damage
  10. STP/NPS Damage(Utility)
  11. STP/NPS Damaged By External Factors
  12. STP/NPS Trespassing
  13. VPS Vacuum System Failure
  14. Public : Sewerline Blockage
  15. Public : Sewerline Collapse
  16. Premise Sewage Flooding
  17. Public : Manhole Overflow
  18. Public : Manhole Cover Missing
  19. Public : Manhole Cover Broken
  20. Public : Manhole Cover Uneven To Road Surface
  21. Public : Damage To Private Property
  22. Public : Damage To Local Authority Property
  • Opinion as to specific contribution made by the nominated individual/ team/ organisation

The SSP shall be consists of key person(s) who have the necessary skills to identify the problems, represent the whole system and drive improvements in all areas/ components activities of sewerage system:

  1. STP/NPS & STF: Defects
  2. STP/NPS & STF: Hydraulic Overloading
  3. STP/NPS & STF: Inadequate Buffer Zone
  4. STP/NPS & STF: Public Health and Safety
  5. STP/NPS & STF: Inundation
  6. STP/NPS & STF: Slope Failure
  7. STP/NPS & STF: Design Compliance with EQSR 2009/ EIA
  8. Sewer Network: Defects
  9. Sewer Network: Accessibility Limitation Issue
  10. STP/NPS & STF: Influent Illegal Discharge
  11. Sewer Network: Illegal Substance Dumping
  12. STP/NPS & STF: Theft Prone

The SSP team will be divided in 2 levels; SSP Steering Committee (SSPSC) for Management level and SSP Operational Committee (SSPOC) for Unit Operation (UO) level as shown in Table 3.

Table 3: Role and Responsibility of SSP Team

Team LevelAppointed CommitteeRoles and Responsibilities
SSPSCManagement LevelMaintaining and formulating the SSP framework as the ongoing management tool to manage the sewerage safety within its boundary.Setting and reviewing the SSP Objectives by determining specific measureable targets to ensure that the water ways (discharge areas) are safe for public health and environments.Monitor and review the implementation of SSP programs and initiatives at UOs.
SSPOCUO LevelLead the process of developing SSP in UOs as well as formulate the implementation strategy for achieving the SSP Objectives. Analyze and execute the corrective action taken.Review and develop recommendations to any issues related to sewerage safety within its boundary.Review procedures, work instructions and guidelines related to SSP priority activities at exposure points and how it affects the SSP system boundary areas with regards to its implementation.

The SSPSC shall conduct management review to ensure the SSP framework and implementation are continuing suitable, adequate, and effective and assessing the opportunities for improvement and changes required in the framework, including the objectives. The SSPSC Members will meet at least 2 times per year (during Q1 and Q3), meanwhile SSPOC Members will meet at least 2 times per year (during Q2 and Q4).

The output from the SSPSC review shall include any decisions and actions related to:

  1. Opportunities for improvement
  2. Any need for changes to the system
  3. Resource needs
  4. Its intended outcomes
  5. Any implications for the strategic direction of the organization

The SSPSC shall communicate the relevant outputs of the management review to workers/ employees representatives especially to the SSPOC.

Meanwhile, the SSPOC shall discuss:

  1. Highlights related issues to SSP progress/ update.
  2. Propose reviews in external and internal issues or requirements to achieve SSP Objectives.
  3. Relevant communication with interested parties, including complaints and incidents during the review of asset risk.
  4. Effectiveness of actions taken to address the asset risks and opportunities to achieve SSP Objectives.
  5. New potential opportunities for continual improvement in SSP.
  6. Need for changes to the existing system.
  7. Other relevant and interesting findings.

  • General comments you may wish to add

The identification of potential exposure groups aims at categorizing people that may be exposed to a particular hazard. From the system map, the potential exposure points is defined complete with the description as shown in Figure 1.

Figure 1: Sewerage System Map for SSP Boundary

  1. C1 – Collection of domestic wastewater through public sewer line
  2. C2 – Collection of domestic wastewater through private sewer line
  3. C3 – Collection of septage through desludging tank to STF
  4. T1 – Treatment of sewage at public STP/ NPS
  5. T2 – Treatment of sewage at private STP/ NPS
  6. T3 – Treatment of sludge at STF
  7. R1 – Reuse of bio-effluent as process water in public STP
  8. R2 – Reuse of bio-solids as nutrient/ energy
  9. R3 – Reuse of bio-gas for electric generated in public STP
  10. R4 – Reuse of treated effluent, bio-solids and bio-gas by third party
  11. D1 – Discharge of treated wastewater from public STP/ NPS
  12. D2 – Discharge of treated wastewater from private STP/ NPS
  13. D3 – Disposal of sludge from STF to landfill
  14. D4 – Disposal of gas (flare) to the environment

The coordinated activity of operations and maintenance (O&M) through work processes to monitor the control measures will reduce the need for much reactive or emergency maintenance as well as to improve the equipment life cycle. Improper O&M approach can lead to unsafe conditions, environmental violations and inefficient sewerage system performance.

In IWK, several work processes were developed by Operations and Maintenance Department (OMD) which consists of:

  1. Procedures – Standard Operating Procedures (SOP) & Operating Procedure Instructions (OPI)
  2. Work Instructions (WI)
  3. Guidelines

It is expected that IWK is to examine and report on its own SSP in terms of its effectiveness, the operation of its processes, the resulting performance against the objectives and the compliance to the related requirements. Internally, the audit is suggested to be conducted to achieve the objectives as follows:

  1. Determine the extent of conformity of the system to the related requirements.
  2. Determine the extent of conformity of activities, processes and services carried out by company with those documented in the related systems.
  3. Identify the areas for potential improvement of the related systems.

The audit program is to be planned with taking into consideration the status and importance of the activities and areas to be audited, changes affecting the organization as well as the results of previous audits.

Appointed auditors shall carry out audit according to the plan and summarizing in the audit report. Non-conformity and observation arose from the audit are to be reported in Non-Conformance Report (NCR) and Opportunities for Improvement (OFI) respectively. Respective auditees shall take appropriate correction and corrective action without undue delay corrective action on deficiencies found during the audit. Follow-up actions shall commence include the verification of the implementation of corrective action, and the reporting of verification results.

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