The Union of Municipalities of Montenegro submitted its comments to the Ministry of Health on the draft law on the provision of safe drinking water for human consumption.
The comments propose allowing water utility companies to conduct water sample analyses as part of the self-monitoring process for monitoring and ensuring the safety of drinking water, as this is not provided for in the draft law.
The Union of Municipalities considers that, given that this is a self-monitoring process and that some water utility companies have their own laboratories accredited to test water samples against the required parameters, there is no reasonable justification for preventing them from carrying out these analyses.
To ensure the reliability of the data, it is proposed that the Institute of Public Health, in accordance with the validation programme, verify the reliability of the results obtained by the laboratories of the water utility companies.
The Union of Municipalities also proposes that responsibility for carrying out risk assessments of catchment areas for water abstraction points and implementing risk management measures should rest with the public authorities responsible for hydrometeorological affairs and water management, rather than with water supply companies. Only where a water abstraction point has the status of a water resource of local importance should responsibility for implementing risk management measures lie with the competent local government authority.
In support of this proposal, the Union of Municipalities notes that, although the relevant European Directive provides that water utility companies should generally monitor the situation in this area, it also allows each country to establish a clear and practical allocation of responsibilities for the risk assessment process in accordance with its national legal framework.
Recognising the importance of this law for meeting the closing benchmarks under Chapter 27 of the EU accession negotiations, the Union of Municipalities conducted consultations with its member municipalities and water utility companies within a very short timeframe, and prepared and submitted these comments. The proposed amendments do not in any way affect the requirements laid down in the EU Drinking Water Directive.
