Rural Water Supply In India Policy Issues And .

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Water Safety Plans forRural Water Supply in IndiaPolicy Issues andInstitutional ArrangementsThe Water and Sanitation Program (www.wsp.org)is a multi-donor partnership administered by theWorld Bank to support poor people in obtainingaffordable, safe, and sustainable access to waterand sanitation servicesNovember 2010Report

DISCLAIMER:Water and Sanitation Program (WSP) reports are published to communicate the results of WSP’s work to the development community.Some sources cited may be informal documents that are not readily available.The findings, interpretations, and conclusions expressed herein are entirely those of the author and should not be attributed to theWorld Bank or its affiliated organizations, or to members of the Board of Executive Directors of the World Bank or the governments theyrepresent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominations,and other information shown on any map in this work do not imply any judgment on the part of the World Bank Group concerning thelegal status of any territory or the endorsement or acceptance of such boundaries.The material in this publication is copyrighted. Requests for permission to reproduce portions of it should be sent towsp@worldbank.org. WSP encourages the dissemination of its work and will normally grant permission promptly.

Water Safety Plans forRural Water Supply in IndiaPolicy Issues andInstitutional Arrangements

Water Safety Plans forRural Water Supply in India:Policy Issues andInstitutional ArrangementsContentsExecutive Summary5Assigning Roles and Responsibilities18Introduction6Available Knowledge and Experience19A Suggested Approach toDemonstration and Implementation20Modern Approaches to Water Quality ManagementWhat is a Drinking Water Safety Plan?Background to this Report8Previous Work and Justification for this StudyWater Safety Plans andService Improvement PlansObjectives of the StudyKey Policy IssuesA Pilot Demonstration in [xxx]Gram Panchayats in [xxx] Districts9Adopting Drinking Water Safety PlansEstablishing Roles And ResponsibilitiesWater Safety Plans as a Basis for InvestmentSetting Performance Targets toReflect Health ObjectivesOutputs from the StudyAnnex 1: Development ofDrinking Water Safety Plans22Annex 2: List of Planning Templates25Annex 3: Water Safety PlanSample Template26Policies on InterventionsList of FiguresFunctions to Support DrinkingWater Safety PlanningPolicy and StandardsEstablishing a ProgramReporting and AuditDistrict Planning CoordinationBaseline Surveys for Water QualityTraining13Figure 1: The Bonn Charter Framework6Figure 2: WHO Framework forSafe Drinking Water7Figure 3: Inverse Pyramid of Support9Figure 4: Functions to Support DrinkingWater Safety Planning13List of TablesTable 1: Functions and WhichOrganizations might Handle them in India18Awareness TrainingManagement of Water Supply SystemsTable A1: WHO Suggested Risk Scoring23Preparing a Water Safety PlanTable A2: Table for RecordingRisk Assessment Information24Table A3: Record of Action Limits, Monitoring,and Corrective Actions24Preparing an Operating PlanChecking the Operation ofDrinking Water Safety PlansVerification of Drinking Water Quality

Abbreviations and AcronymsAFPROAction For Food ProductionASHAAccredited Social Health ActivistBRCBlock Resource CenterCBOcommunity-based organizationCLTSCommunity Led Total SanitationDASCOHDevelopment Association for Self-reliance, Communication, and HealthDDWSDepartment of Drinking Water SupplyDESMEDepartment of Economics, Statistics, Monitoring, and EvaluationDWSMDistrict Water and Sanitation MissionDWSPDrinking Water Safety PlanERRAEarthquake Reconstruction and Rehabilitation AuthorityGISgeographic information systemGPGram PanchayatH2 Shydrogen sulphideHACCPHazard Analysis Critical Control PointIECInformation, Education, and CommunicationIRSPIntegrated Rural Support ProgramITNInternational Training NetworkIWAInternational Water l organizationNRDWPNational Rural Drinking Water ProgramNRHMNational Rural Health MissionO&Moperations and maintenancePIEDARPakistan Institute for Environment—Development Action ResearchPURCPublic Utilities Regulatory CommissionRMDDRural Management and Development DepartmentSHGself help groupSIRDState Institute of Rural DevelopmentSOsupport organizationsTSCTotal Sanitation CampaignVERCVillage Education Resource CenterVWSCVillage Water and Sanitation CommitteeWHOWorld Health OrganizationWSPWater and Sanitation Program4

Water Safety Plans forRural Water Supply in India:Policy Issues andInstitutional ArrangementsExecutive SummaryThis report outlines the key principles ofwater safety planning for rural watersupply in India. Water safety planningrepresents a change of emphasis fromend-of-pipe testing to the managementof risks of contamination from source tomouth. End-of-pipe testing is stillnecessary to verify that safe drinkingwater is being delivered.The focus of the report is on the policyissues concerning the adoption of watersafety planning and the institutionalarrangements (roles and responsibilities)needed to operationalize the approach.Recommendations are provided ondemonstrating and implementing theapproach to establish a full program.Key points are: The main policy matter is theadoption of the drinking Water SafetyPlan approach for rural supplies—this is strongly recommended; and Better management of drinking waterquality by preventing contaminationbefore it happens; Improved operations andmaintenance (O&M) through adoptionof control measures identified duringthe risk assessment; Emphasis on customer serviceimprovements linked to improvedpublic health, with improvedinfrastructure as a means to thatend; and Water Safety Plans are based on fieldsurveys (or sanitary surveys) thatdirectly link water supply, hygiene,and sanitation, for example, inaddressing issues such as opendefecation, solid and liquid waste, andsafe household storage and handling.There are four other policy matterswhich emerge from that decision: How to establish rolesand responsibilities; Whether to use Water SafetyPlan improvement programsas the basis for planningand investment; How to set performance targetsto reflect health objectives; and How to decide on interventionsto reduce risk.There are various benefits thatarise from the adoption of WaterSafety Plans:A Planning Coordination function iscritical when moving from pilotdemonstrations in a few villages to a fullprogram. The Planning Coordinationfunction is needed to interpret policy onservice standards and cost recovery, toreview village plans including theirimprovement programs, to makeinvestment decisions with prioritiesbased on local needs, to advise ontariffs and subsidies, and to monitorimplementation and performance.There is a need for well targeted fieldbased training programs, includingtraining of trainers (facilitators) whowould train technical and operationalstaff at the village level, as well asorientation and training for higher levelsupport functions. Training materialscan be prepared and tested duringpilot demonstrations, withparticipation and ownership byestablished training institutions ornongovernmental organizations(NGOs) or other supportorganizations (SOs).The recommended approach toimplementation of the institutionalarrangements is a combination ofdemonstration pilots within selectedvillages, together with advocacy andactivity mapping workshops at thedistrict and state levels, andworkshops to train the trainers.5

IntroductionModern Approaches toWater Quality ManagementThe approach described in thisreport to achieve safe drinking waterquality in rural areas is based oninitial work carried out in India, but isrelevant to rural water supply in otherregions. The approach is based ondrinking Water Safety Plans, and howthe institutional arrangements (rolesand responsibilities) needed tooperationalize the approach mightbe established within existinginstitutional frameworks.The emphasis on means of achievingsafe drinking water has changed.Internationally, in the past, there hadbeen a trend toward adding moreand more parameters to standardswith an associated requirement forsampling and analysis. This is anapproach which is still found in manycountries, including India.In the past decade, two workshopsinvolving key people concerned withdrinking water quality were held inBonn in Germany, one in October 2001and the other in February 2004, to seeka better way of achieving safe drinkingwater. The direct output was the BonnCharter1 and indirectly the revisedWorld Health Organization (WHO)Drinking Water Guidelines.2 Theapproach is encapsulated by the BonnCharter structure given in Figure 1.The key principle is to consider theentire supply chain from source tomouth, and to take a risk managementapproach through the development ofdrinking Water Safety Plans. Suchplans establish the key operationalcontrols at each stage in the supplychain. There is reference to‘verification’ and this is done bysampling and testing, which is stillimportant but is not seen as theprimary means of monitoring andcontrol. The Bonn Charter emphasizesthe need for clarity of roles andresponsibilities, for transparency, andfor sharing of information. The goal is‘good safe water which has the trust ofconsumers.’ This same approach isreflected in the WHO Guidelines, whichare summarized in Figure 2, and whichinclude health-based targets.Figure 1: The Bonn Charter frameworkThis approach is unlikely to increaseprotection of the public because,if there are immediate impacts onhealth from contamination ofdrinking water, people will havealready become sick before theanalysis is carried out and beforeremedial action can be taken. Incountries such as India, this isparticularly true in rural areas whereoften there are no competentlaboratories in the vicinity, or theprotocols for water quality testingare not well established.1The Bonn Charter, International Water Association,www.iwahq.org.uk2Guidelines for Drinking Water Quality 2006, World HealthOrganization, Geneva. http://www.who.int/water sanitation health/dwq/gdwq3/en/6Source: The Bonn Charter for Safe Drinking Water. IWA. September, 2004.

Water Safety Plans forRural Water Supply in India:Policy Issues andInstitutional ArrangementsWhat is a DrinkingWater Safety Plan?Figure 2: WHO framework for safe drinking waterA full description of the process ofdeveloping a drinking Water SafetyPlan is given in Annex 1. In essence itinvolves the following steps: Define the supply system andform a team from those peopleresponsible for each part of thesupply chain from sourceto mouth; Consider all potential hazards andestablish which ones constitutea significant risk to drinkingwater quality; Consider how each of these risksis controlled and whether thecontrols are adequate; As necessary, prepare animprovement program based onthe inadequacy of controls andimplement any aspects which canbe put in place immediately; For each existing control set anaction level, that is, a level atwhich there is concern that thecontrol is failing and that someother action needs to be taken toprotect public health; and Identify the monitoring of eachcontrol: who is responsible and atwhat frequency—the what,who, and when.Two further steps are required whichneed a higher competence ofoperational management, and in ruralIndia would require specific training ortechnical support:Source: Guidelines for Drinking Water Quality. Third Edition. WHO. 2004. Define what needs to be doneimmediately if an action limit isbreached; and Define how it can be verified thatthe reaction to a loss of a controlhas been successful.7

Background to this ReportPrevious Work and Justificationfor this StudyIn line with this evolving response towater quality management, variousagencies have been or are currentlypiloting the development of WaterSafety Plans in the South Asia region: In India, this includes UNICEF,WaterAid, and Action For FoodProduction (AFPRO) in rural areas,and WHO in urban centers; In Bangladesh, the VillageEducation Resource Center(VERC), WaterAid, and theDevelopment Association forSelf-reliance, Communication, andHealth (DASCOH), are working inrural areas, and WHO is working inurban centers; and In Pakistan, the Pakistan Institutefor Environment—DevelopmentAction Research (PIEDAR) andIntegrated Rural Support Program(IRSP) are working in rural areas inPunjab and Khyber–Pakhtunkhwa(KP), and the EarthquakeReconstruction and RehabilitationAuthority (ERRA) and UNICEFare supporting water qualitymanagement in emergencies anddisasters (inclusive of water safetyplanning) in a number of areas suchas Northern Areas and KP.Generic Water Safety Plans for themost basic rural water supply systems,namely dug wells, tubewells, rainwaterharvesting, and pond sand filters, havebeen developed by the InternationalTraining Network (ITN) Center inBangladesh. To complement thisexisting body of work, the work carriedout by the Water and SanitationProgram (WSP), which is presented inthis report, has focused primarily onrural piped schemes, ranging fromsimple gravity-fed schemes for a groupof houses to bulk supply for multivillageschemes. In India today, there isincreasing demand for piped watersupply as a result of both waterscarcity and depletion of groundwater,and demand for higher levelsof service.Work on Water Safety Plans carried outto date has been valuable in helping toset out what Water Safety Plans shouldlook like at the scale of a single watersupply system. The broader,institutional level, the assignment ofroles and responsibilities for waterquality management, the developmentof appropriate institutional incentivesfor stakeholders to undertake theirassigned roles, and the critical role ofindividual and collective behaviorchange are addressed in this report.Objectives of the StudyThere are three objectives:8 To consider policies for the deliveryof safe drinking water quality inrural areas; To provide a framework in which thevarious functions associated with achange of emphasis towardsmanaging risks to the safety ofdrinking water can be incorporatedinto existing institutional frameworks, in particular building on theinitiatives already taken in India toimprove monitoring and surveillanceof drinking water quality; and To suggest an approach todemonstrate and implement sucha framework.

Water Safety Plans forRural Water Supply in India:Policy Issues andInstitutional ArrangementsKey Policy IssuesThe most important policy issuerelates to the adoption of drinkingWater Safety Plans as the basis formanaging drinking water quality.This is discussed first; there are thenfour other policy issues which emergefrom adopting such a framework,the key one being roles andresponsibilities which is the maincontent of this report.Adopting Drinking WaterSafety PlansAlthough sampling and analysis isimportant to verify the quality ofdrinking water, it is not an effectivemeans of control especially for ruralsupplies. In India, the Department ofDrinking Water Supply (DDWS) hastaken steps to establish and equipdistrict and sub-divisional water testinglaboratories. Nevertheless, collectingsamples in rural locations takes timeand microbiological tests involve theslow process of ‘growing’ organismson a suitable medium. Therefore,during the time period betweensampling and reporting results, which inrural areas could be as long as amonth, unsafe water could have beenconsumed. The emphasis should,therefore, be on good operationalmanagement with controls based onrisk assessment from source to mouth.This involves the establishment ofdrinking Water Safety Plans andassociated support being given to localservice providers for their development,operation, audit, and verification. Establishing Rolesand ResponsibilitiesPlanning Coordination: Plansdeveloped by GPs/VWSCs haveto be considered by the districtauthorities through a periodicplanning process, managedat the district level forlogistical considerations.With the responsibility for servicedelivery resting with the village GramPanchayats (GPs) together with VillageWater and Sanitation Committees(VWSCs), they should be seen as thepivotal organizations with the ‘higher’levels of government, line departments,and training institutions providingsupport. This can be illustrated by aninverse pyramid of support as shown inFigure 3. The individual functions arediscussed in detail in Section 4, andSection 5 refers to appropriateallocation of functions.The planning process isrequired to interpretstate policy in terms ofdeliverables, provide planningtemplates and facilitate trainingand technical support, review andapprove village plans, integrateplans and manage convergenceof different developmentprograms, monitor progress onimplementation and operationalperformance, and provide reportsto the state showing the impact onservice performance.3Roles and responsibilities include twofunctions considered critical in movingfrom pilot demonstrations to a fullprogram, namely planning coordinationand training:Figure 3: Inverse pyramid of supportCitizens and Households:Water ConsumersGPs and VWSCs are responsible for providing water servicesBlocks provide technical supportDistricts facilitate financing, training, technical support, andsampling and analysis to check drinking water qualityDistricts also lead on the planning functionStates provide policies,financing, and trainingNational government provides policyguidance, standards, and financing3For more details see the draft Handbook for District Waterand Sanitation Missions for Planning Coordination andConvergence (DDWS and WSP, 2010).9

together with nonpipe methodsprovided by tankers and watervendors, and through self provisionsuch as shallow tubewellhandpumps. Some of the mostimportant risks to drinking watersafety arise from these alternativedistribution systems and otherdeficiencies in the quantity of watersupplied. Accordingly, the associatedimprovement programs provide agood basis for the identification ofinvestment priorities covering bothquantity and quality requirements,and should be built into theplanning and investmentdecision-making processes. Training: Training and capacitybuilding is critical for thedevelopment and implementation ofplans by GPs/VWSCs, and for theplanning process at the district level.These training/capacity buildingfunctions are discussed in outline inthis paper with details given inseparate handbooks andguidelines.4 Typically, planningtemplates can provide the basis fortraining of trainer programs targetingblock-level facilitators who would thentrain village-level representatives.Water Safety Plans as aBasis for InvestmentThe process of preparing drinkingWater Safety Plans identifies problemsdue to either no control of specificrisks or inadequate controls. Someimprovements can be made quickly atlittle or no cost but others require asignificant amount of investment.Although improved operation ofexisting controls will result in fewerincidents of unsafe drinking water, itcan be expected that the mainimprovements will arise from theintroduction of better controls.4See the Handbook for Gram Panchayats (DDWS andWSP, 2010), and the Training Manual for Village Water SafetyPlans prepared for Sikkim (Rural Management andDevelopment Department [RMDD] and WSP, 2010).10Drinking Water Safety Plans shouldinclude all parts of water distributionFor more sophisticated piped waterschemes, the Water Safety Plan canbe combined with a technical/financial survey which is used togather information on the conditionof assets, true operating costs, andcurrent performance. The informationcaptured by the survey and theWater Safety Plan then provides thebasis for preparing an Operating Plan(key operating functions, proposedstaff and maintenance costs,estimated income, and estimatedsurplus or deficit), and a ServiceImprovement Plan (a summary ofimprovement measures, proposedremedies, estimated costs, and initialprioritization or timeframe forimplementation). This informationalso supports more effectivereporting and monitoring, includingsimple performance indicators.Simple templates can be prepared inthe local language and used fortraining technical and operationalstaff. Annex 2 provides a full list of

Water Safety Plans forRural Water Supply in India:Policy Issues andInstitutional Arrangementstemplates that have been developedby WSP to support both villageplanning and district planningcoordination. Annex 3 provides asample template for a WaterSafety Plan.Setting Performance Targets toReflect Health ObjectivesThe WHO Guidelines (Figure 2) refer to‘health-based targets’ with a view tomaking interventions based on healthdetermined benefits. The WHOframework shows health-based targetsas an input to drinking Water SafetyPlans. It is known from a WHO study5that, in developing countries, thebenefits from investment in water andsanitation greatly exceed the costs, andit is possible to set simple operationaltargets which can be expected toachieve health improvements.In particular, it can be expected thatthere is a relationship between thepresence of E.coli in water, as anindication of fecal contamination, anddiarrheal disease. The presence of achlorine residual in treated water is anindication that the water is free ofcoliforms. So, in simple operationalterms, a health-related target can betranslated to a performance target suchas minimum chlorine residual. This thenbecomes an action level in a WaterSafety Plan (Annex 1). Where data onincidents of diarrheal diseases areavailable, it may be possible to observethe impact of continuously achievingthis action level through diligentoperations.6 In India, the developmentof improved water supplies at thevillage level should be carried out inpartnership with the National RuralHealth Mission (NRHM) to draw directcorrelations between implementationof Water Safety Plans, water quality,and incidence of water borne orwater-related diseases.The establishment of targets and theirsubsequent attainment provide apowerful means to support evidencebased decision-making. Elucidatingoperational, water quality, and healthimprovements over a sustained periodof time provides a basis for stronglyadvocating widespread implementationof Water Safety Plans.Policies on InterventionsDrinking Water Safety Plans are likely toidentify the need for improvements ateach stage of the supply chain, namely: Better protection of sources; Improved removal of contaminantswhether microbiological or chemical; Protection of distributionsystems; and Prevention of contaminationin households.Protection of sources: With a surfacewater source, this may require, iffeasible, control over activities(agricultural, industrial or recreational)within some boundary of a lake, streamor spring to prevent ingress of nutrientsor contaminants. This could applyequally to a well but in some cases thatmay simply require adequate fencing toprevent access by animals. Therequirement is good local knowledgecoupled with some professionalguidance. Locally, measures forrainwater harvesting and groundwaterrecharge, as well as advocacy for waterconservation, can be implementedpossibly in consultation with otherconcerned departments, for example,forestry. In India, the issue of arsenicand fluoride contamination (as well asiron, nitrate, and salinity) is given highpriority under the National RuralDrinking Water Program (NRDWP) with5Hutton, G. and Haller, L., 2004. Costs and benefits of waterand sanitation improvements at the global level (Evaluation ofthe). World Health Organization 2004, WHO/SDE/WSH/04.04.6For example, field visits to Pune, Maharashtra, where theHealth Department is responsible for water quality monitoringand surveillance, found that officials were analyzing results tocorrelate incidence of disease with water quality.11

the formal service providers regardthe other distributors as an integralpart of the water supply and developcontrol procedures with them.8 A keyprinciple of water safety planning isto have multiple barriers; it is unlikelythat just one remedy will preventcontamination but a combination ofcontrols can minimize the risks ofcontamination. The establishmentof a maintenance program thatregularly checks on the conditionand performance of piped networksand correlated maintenancerequirements is critical to ensurethat drinking water safety isnot compromised.emphasis on finding alternativesources, and conjunctive use ofalternative groundwater and surfacewater sources.Improved water treatment: Treatmentis required when it is not feasible in theshort term to achieve full protectionthrough ‘catchment’ measures, orwhere a contaminant occurs naturally inthe source, or as essential security onmicrobiological quality of water.Absolute priority should be given tomicrobiological quality and to concernsover any chemicals occurring at toxiclevels. Consideration should also begiven to other chemicals which are7This is done on log-reduction basis (each treatment processis rated in terms of some value of log-reduction that it canachieve). It is recommended that a guidance manual isprepared which could be used by those local engineerssupporting local service providers.8An example is the case of water tankers in Ghana. WaterTanker Service Guidelines. Public Utilities RegulatoryCommission (PURC), 2008.12present at levels above the existingnational standards (which should be setaccording to WHO guideline values, butit should be noted that most of theguideline values are based on a lifetimeof consumption with a large ‘factor ofsafety’ so small exceedances have littleimpact on health). WHO providesguidance on the effectiveness of themost common treatment processes inremoving various substances.7Protection of distribution systems:Pipe systems are generally not at riskwhere there are continuous supplies,as the pressurized system preventsingress. Where there are intermittentsupplies, checks should be made forpoints of potential ingress of fecalmatter. Other distribution systems suchas tankers and water vendors are morevulnerable and critically dependentupon the operators. It is suggested thatPrevention of contamination inhouseholds: This should be part ofan awareness campaign coveringwater, sanitation, and hygiene. InIndia, the Total Sanitation Campaign(TSC), and in particular theCommunity Led Total Sanitation(CLTS) approach, targetscommunity-level awareness raisingand behavior change to eliminateopen defecation and improvehygiene practices. Water SafetyPlans, with emphasis on source tomouth preventive controls, provide avery effective means of linking TSC/CLTS through water quality toimproved operational managementfor water supply. It is recommendedthat, where possible, water safetyplanning be implemented incombination with CLTS activities.This should consider safe storageand handling of water and simpleremedial actions (such as boiling) intimes when water safety may becompromised in the household.

Water Safety Plans forRural Water Supply in India:Policy Issues andInstitutional ArrangementsFunctions to SupportDrinking Water Safety PlanningThis report focuses on functionsrelated to drinking water qualitymanagement although other aspects,such as cost recovery policies whichaffect sustainability of water services,are critical in the delivery of safedrinking water. However, it doesdiscuss the improvement planningfunction since Water Safety Planshighlight those areas where controlsof risks to drinking water safety areinadequate, and improvementprograms need to be put in place.Figure 4: Functions to support drinking water safety planningThe functions to be carried out in thedelivery of safe drinking water aredescribed here with discussion on theknowledge and skills required toundertake them (Figure 4).Policy and StandardsNRDWP provides overall policyguidance in India. The development ofdrinking water quality standards(BIS10500) is also a national function(currently under the Drinking WaterSectional Committee, FAD 25).However, where there is significantvariability in water source conditions,it is states that should interpretnational standards appropriately and,where necessary, set interimstandards to focus attention on thoseparameters most affecting health.States must take decisions on policyapproaches to the achievement ofdrinking water quality standards,including decisions on the use ofdrinking Water Safety Plans.Guidelines on the preparation ofdrinking Water Safety Plans, basedinitially on experience elsewhere, andrefined later in the light of localexperience, are an early requirement.These are most appropriatelydeveloped within existing state traininginstitutions.9 There should also be somemeans of sharing experience betweenand within states, for example, fromexposure visits.States may wish to introduce incentiveschemes with progress based onperformance improvements beingrewarded. Water Safety Plans areconcerned with improved operationalmanagement, and performance targetscan be set to reflect this objective. Theresults would need to be published asleague tables to establish comparativecompetition. Such an approach wouldrequire effective audit procedures toensure level playing fields. As analternative to financial inducements,there can be incentives throughrecognized schemes in which awardsare given at publicized ceremonies.109For example, in Sikkim, the State Institute of RuralDevelopment (SIRD) was already carrying outtraining workshops related to water qualitymonitoring and surveillance, and sanitation as wellas training of GPs in their new responsibilities.10As under the Nirmal Gram Puraskar for sanitation.13

Establishing a ProgramHaving decided to implement a drinkingWater Safety Plan approach, there is aneed for programs to be establishedwhich focus on systems of greatestconcern, and to determine investmentpriorities. In practice, improvementprograms are developed bottom-upwith village plans aggregated withsupport from blocks int

Water Safety Plans for Rural Water Supply in India: Policy Issues and Institutional Arrangements 5 This report outlines the key principles of water safety planning for rural water supply in India. Water safety planning represents a change of emphasis from end-of-pipe testing to the m

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