34September/October 2015
I
N, the Environmental Protection Agency (EPA)
established the National Inspection Plan for Domestic
Waste Water Treatment Systems. The National Inspec-
tion Plan (NIP) sought to encourage the correct
management of domestic wastewater treatment sys-
tems (DWWTSs) throughout Ireland by means of an annual
allocation of septic tank system inspections in areas acutely
vulnerable to contamination, and an extensive citizen-en-
gagement strategy. It was proposed by the EPA that the plan’s
instigation would help minimise the potential for environ-
mental and health impacts stemming from defective
DWWTSs.
The NIP has now been in place for over two years and
recently entered its second cycle (-). However, the
progress made by the plan thus far is believed by close
observers to be insufficient. Only slightly over half of the
septic tank systems inspected under the plan in the first year
achieved a pass grade and there is evidence to suggest that
any wider shift in attitudes and behavioural change among
DWWTS users has been marginal at best.
Although the onus is on the relevant public to adhere to
their responsibilities and demonstrate good practice, their
failure to do evidences several inherent flaws of the NIP that
require urgent remediation – in particular, its citizen-en-
gagement strategy.
The ramifications of exposure to untreated domestic
wastewater are well documented – especially where effluent
is allowed to enter drinking water supplies (e.g., private wells
and group water schemes) and public waterways. The result-
ing contamination of ground- and surface water can engender
outcomes such as pronounced environmental degradation,
widespread odour disturbance and proliferation of water-
borne diseases such as VTEC (a pathogenic strain of E. coli)
and cryptosporidium. The appropriate installation and main-
tenance of DWWTSs is thus vital.
Given the sheer number and volume of DWWTS in Ireland,
the risk of contamination is high.
There are currently over , DWWTSs (predomi-
nantly septic tanks) located across Ireland, the majority of
which are concentrated in rural Ireland due to its largely dis-
persed pattern of settlement.
Furthermore, over % of Irish households in rural areas
treat and dispose of wastewater on-site (accounting for over
Septic:
Tanks
EPAs ineffective National
Inspection Plan gave
only half of the systems
inspected in the first year
a pass grade.
By Simon Mooney
The failure
on the part of
EPA and local
authorities
to encourage
a significant
shift in the
behaviour of
our 500,000-
odd septic-
tank owners
living in the
areas most
predisposed to
contamination
was a
disappointing
blow
POLITICS Septic Tanks
most septic tanks do
not work properly
September/October 2015 35
one third of the national population)
with a similarly high percentage also
availing an of onsite groundwater
source for drinking water. These figures
confirm that rural households are
potentially a formidable source and
receptor of water contamination and
underscore the importance of the NIP
in potentially reducing this threat.
However, despite the NIP’s question-
able performance and the ensuing
repercussions, the plans implementa-
tion has received limited media
attention and criticism since its instiga-
tion. This can largely be attributed to
the pervasive perception of DWWTSs as
being a minor, rural-only issue. How-
ever, a mounting body of evidence
suggests that septic tanks are begin-
ning to constitute a principal cause of
water contamination in rural Ireland
and play a significant role in the rising
number of VTEC cases documented
throughout the country.
In order to fully identify and arm
the NIPs shortcomings, it is necessary
to recount the origins and development
of the plan.
The NIP was first put forward by the
Irish government in  in response
to the ruling of the European Court of
Justice (ECJ) over Irelands longstanding
circumvention of its obligation, under
the  EU Waste Framework Direc-
tive, to properly regulate domestic
wastewater generated in unsewered
(primarily rural) areas. Ireland had
previously been rebuked by the ECJ for
the breach in  but the govern-
ment’s slow pace in initiating an
appropriate registration and inspection
system for DWWTSs resulted in a
second, harsher ruling to which the NIP
responded. The inception of the NIP
was evidently reactive rather than
proactive.
The purpose of the NIP was outlined
in the government’s  Water Serv-
ices (Amendment) Act, which satisfied
the ECJs criteria. The NIPs core aspects
would be informed by the guidelines set
out in the act and the EPA would be
given the job of preparing and expand-
ing the plan. In most cases the
guidelines were firm and incisive, yet in
others they were markedly lenient,
neglecting to mention any binding pro-
vision for correct DWWTS design and
construction or consistent metrics for
the NIP. As a result, these facets were
given little attention in the finalized
plan.
The delivery of the bulk of the NIP
was assigned to local authorities, with
the EPA acting in a primarily supervi-
sory role. Local authorities would be
held responsible for initiating a register
of DWWTS, administering the annual
septic-tank inspections and overseeing
citizen engagement at the local level
while the EPA would direct and super-
vise local authorities, nominate and
train inspectors and help instigate citi-
zen engagement at the national level.
The government would meanwhile
play a smaller, albeit significant, part by
providing funding for the plan, enforc-
ing policy and administering a grant
scheme for septic tank repairs for
homeowners chosen for local authority
inspections.
It was decided by the EPA that a mini-
mum target of , septic tank
inspections would be undertaken each
year. The EPA availed of the S-P-R
(Source-Pathway-Receptor) model and
GIS maps to establish the areas most
vulnerable to septic-tank-contamina-
tion and subsequently apportioned
inspections to each county accordingly.
As to the NIPs engagement strategy,
following a period of consultation with
a number of representatives from envi-
ronmental, farming and rural
organisations, the EPA elected to centre
citizen engagement on a public infor-
mation campaign stressing the
importance of clean water. To this effect
a variety of engagement mechanisms
would be used – ranging from informa-
tive television segments on a national
scale to radio advertisements and
school visits at a local level.
The NIP’s engagement strategy was
rolled out in early  with inspec-
tions beginning on  July. Given that the
inspections would be situated in high-
risk areas, the results of first full year of
inspections would act as a useful
barometer to gauge the overall progress
of the NIP.
Unfortunately, out of the  inspec-
tions completed between  July 
and  June , only  (%) of
septic tanks passed. The failure on the
part of EPA and local authorities to
encourage a significant shift in the
behaviour of septic-tank owners living
in the areas most predisposed to con-
tamination represented a disappointing
blow and posed worrying connotations
as to the broader, national level of
behavioural change attained.
The inspection results can be attrib-
uted to several questionable policies.
For instance: the grant scheme for
system repairs only catered for sep-
tic-tank owners who had registered
as a DWWTS user before 1 February
In 2011 there
was a sharp
surge in VTEC
cases in
Ireland, with
37% linked to
exposure to a
private well
one-off housing,
Gweedore (no
impropriety implied)
36September/October 2015
2013 and consequently would have greatly reduced the
inclination for septic-tank owners who had not registered
by that date to properly maintain or remediate their
septic tank on their own initiative. However, the NIP’s
citizen engagement strategy must ultimately shoulder the
bulk of the blame as it has patently failed to adequately
communicate the degree of risk and provide adequate
information regarding septic-tank maintenance.
When formulating a citizen engagement strategy and
appended public information campaign, it is imperative to
take account current public attitudes and knowledge gaps. By
discerning the proclivities of the target public a baseline can
be established, providing scope for how the requisite infor-
mation might or might not be best communicated. If this
information is subsequently transmitted to the audience in a
manner sympathetic towards or conscious of their stance, the
likelihood of compliance will be maximised. In the case of the
NIPs first cycle (-), there is scant indication that the
EPA gave any concerted thought to the existing knowledge
gaps and attitudes among ordinary DWWTS users – despite
having access to recently accumulated data on the subject.
Shortly before the start of the NIPs engagement strategy,
the EPA became aware of an academic study involving the
circulation of survey questionnaires to DWWTS homeowners
to ascertain their views regarding all aspects of DWWTS. The
survey served as a useful insight into the current attitudes of
DWWTS users and pinpointed issues such as: a lack of con-
sistency concerning desludging, a lack of information
outlining system maintenance and a belief that recent
DWWTS legislation was motivated by EU compliance and
government revenue rather than protection of human
health and the environment. The study was published
online in  and funded by the EPA which commissioned
the authors to devise and disseminate a further set of similar
questionnaires midway through the first year of the NIP’s
instigation.
The second set of questionnaires would serve to indicate
the degree of change accomplished by the NIP’s engagement
strategy so far. However, regrettably for the EPA, the ques-
tionnaire results registered only a marginal (%) increase in
support for DWWTS regulations and a similar increase in the
amount of respondents who claimed that they had received
DWWTS maintenance information.
The results also indicated a stasis in attitudes pertaining to
desludging which, tellingly, was the main reason for failure
among septic tank inspections according to the EPA. Further
scepticism of the NIPs engagement strategy could be accrued
by reading the EPA’s reports on the progress of the plan,
which contain a palpable lack of detail and suggest the incon-
sistent use and application of engagement mechanisms by
local authorities.
To the EPAs credit, the proposed measures for the second
cycle of the NIP (-) have placed a more considered
focus on citizen engagement.
The EPA has recently established a working group compris-
ing a number of representatives from relevant organisations
such as the Health Service Executive (HSE) and the National
Federation of Group Water Schemes (NFGWS) in attempts to
compose a better-organised, holistic citizen engagement. The
EPA has also introduced a metric that determines compliance
by tracking the collection of DWWTS sludge by waste
collectors.
These recent measures represent a step in the right direc-
tion and a concerted effort to improve the NIPs efficacy.
However, these steps must by followed by discernible results.
With the Minister of the Department of Environment and
Local Government’s recent announcement that the NIP will
be reviewed at government level in early , it is clear that
the NIP will be thrust into the spotlight again sooner rather
than later. •
POLITICS Septic Tanks
The risk posed by domestic wastewater treatment
systems to human health in Ireland
The ramifications of exposure to untreated domestic wastewater are well doc-
umented – especially where effluent is allowed to enter drinking water
supplies (e.g., private wells and group water schemes) and public waterways.
The resulting contamination of ground- and surface water can engender out-
comes such as pronounced environmental degradation, widespread odour
disturbance and proliferation of waterborne diseases such as VTEC (a patho-
genic strain of E. coli) and cryptosporidium. The appropriate maintenance
and regulation of domestic wastewater treatment systems (DWWTSs) is thus
vital.
In the case of Ireland, there is a mounting body of recently conducted
research that suggests that many DWWTSs across the country have been
incorrectly installed or maintained and pose a very real and widely experi-
enced threat to human health.
A 2005 study undertaken by Trinity College, Dublin of
74 randomly located septic-tank systems in Leinster
revealed that only 5% were situated in soil conditions
conducive to adequate wastewater treatment and indi-
cated the likelihood of similar figures elsewhere in
Ireland. The prevalence of such systems was confirmed
five years later by the EPA, who discovered that approxi-
mately 25,000 DWWTSs in Ireland posed a risk to
groundwater while approximately 120,000 posed a risk
to surface water.
A study carried out by Trinity College researchers
between 2008 and 2010 analysing the quality of
groundwater in 262 private wells discerned that
DWWTSs posed the greatest contamination hazard for
private wells in rural Ireland. The study identified septic
tank location as a significant factor towards the occurrence of VTEC in private
wells. The brisk exacerbation of this threat could be attributed to a combina-
tion of a longstanding lack of regulatory enforcement regarding private well
and septic-tank siting and a glut of poorly constructed one-off rural dwellings
built during the 2000s decade.
Tellingly, a year after the completion of the Trinity College study in 2011,
the Health Protection Surveillance Centre (HPSC) reported a sharp surge in
VTEC cases in Ireland, with 37% linked to exposure to a private well. The
overall national VTEC incidence rate recorded the same year was almost eight
times higher than the EU average and the number of annual cases has since
continued to rise.
It is likely that the increased promulgation of such evidence outlining the
causal link between the growing frequency of episodes of water contamina-
tion and disease and defective DWWTS in Ireland, would result in a more
rigorous scrutiny and media coverage of DWWTS maintenance and regulation
throughout Ireland. Nevertheless, much of this data remains largely
unpublicised.
A 2005 study
revealed that
only 5% of
septic tanks
were situated
in soil
conditions
conducive
to adequate
wastewater
treatment

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