Havelock North: The Rhetoric of Chlorination

Havelock North: The Rhetoric of Chlorination
Compiled by: Andy Kirkwood, Justine Flanagan, 2019.

Contact: [firstName] @ islandbooth.com.

Masthead 1 News FUD. 31 July 2019.


This is a working draft. Updated 10 December 2019.


The Te Mato Vai Project to update Rarotonga’s intakes and water-main includes Step 4: Disinfection to kill or inactivate micro-organisms. It is proposed to dose water at the intakes with chlorine solution.

At public consultations in May 2019, To Tatou Vai CEO Brent Manning made reference to the Havelock North (New Zealand) outreak incident which has led to sweeping revision of the country’s water management regulation legislation and policies. It can be seen that as development partner, New Zealand’s concerns have been imposed upon Rarotonga’s water supply upgarde.


Havelock North

At the May 2019 Community Disinfection Presentations (in Rarotonga, Cook Islands) the government Project Management Unit (PMU) drew attention to the August 2016 Havelock North (New Zealand) camphylobacter outbreak.

In this incident, an aquifer (groundwater source) was contaminated after heavy rain. Over 1,000 cases of gastro-illness were reported to the District Health Board, and 40% of the town population were reported as being affected by the illness. This figure is inclusive of secondary impacts such as businesses affected by staffing shortages: caregivers absent to care for sick family members. 45 people were hospitalised.

Media reports later suggested that 5,000 had been ‘affected’; and that three people had died due to the illness. However regarding the claims of death, the District Health Board submission to the Inquiry was that ‘in all three cases other medical conditions existed, and that the waterborne illness was unlikely to have been the sole cause of death’ [1].

A bacterial pathogen — Camphylobacter — was identified as the cause of the illness.

Stage 1 of the subsequent Inquiry found it probable that surface water flows contaminated an aquifer water source previously thought to be ‘confined’ (secure from contamination). After heavy rain, sheep feces flowed into a pond; contaminated water then penetrated the soil capping the aquifer.

Nationwide interest in the outbreak has led to revision of water standards and regulation in New Zealand with pressure from lobby groups to chlorinate all water supplies.

The outcome of Stage 2 of the Havelock North Inquiry did not lead to immediate mandatory chlorination of New Zealand’s water supply. Instead a set of guiding principles on Drinking Water Safety have been adopted.

  1. A high standard of care must be embraced.
  2. Protection of source water is of paramount importance.
  3. Maintain multiple barriers against contamination.
  4. Change precedes contamination.
  5. Suppliers must own the safety of water.
  6. Apply a preventative risk-management approach.

Nek minnit

The 51 recommendations made by the Havelock North Outbreak Inquiry Committee Stage 2 were forwarded to the Director-General of Health.

Relevant to the chlorination debate are Recommendations 20 and 21:

Mandate Universal Treatment
(20) Appropriate and effective treatment of drinking water should be mandated by law or through the DWSNZ for all supplies (networked and specified self-suppliers). This should include a residual disinfectant in the reticulation.
(21) Provision should be made for exemptions to mandatory treatment only in very limited circumstances. Any supplier seeking an exemption should have to discharge a heavy onus of satisfying an appropriately qualified and experienced body of the present, and ongoing, safety of the particular supply.
Recommendations made by the Havelock North Outbreak Inquiry Committee - Stage 2

The above description of ‘Universal Treatment’ is code for ‘chlorination’, as non-chemical disinfection methods such as UV irradiation and ozonation do not result in residual disinfection.

Immediately following the outbreak, the Havelock North reticulation was chlorinated, but was ineffective in maintaining residual disinfection levels across the network.

[187] A review of water testing results from the [Havelock North] reticulation from 1 September 2016 to 30 September 2017 [after the outbreak] showed that total coliforms were often found. While the percentage of positive samples is not high, contaminated water has been identified in ten of the thirteen months where data have been examined. The presence of total coliforms can indicate failure of primary disinfection, regrowth of organisms within the distribution system due to an inadequate residual disinfectant level, or ingress/backflow of contaminated water into the system. All of these failings can be rectified if the cause is identified.

Author’s note: The World Health Organisation does not recommend detection of total coliforms as a suitable indicator of potential contamination and reference to this value in the recommendations is not in keeping with international practise. More common is the use of E. coli detection as a regulatory standard, except in the tropics where E. coli detection is not a reliable method for assessing the sanitary quality of water supplies.

Submission 187 also highlights the purpose of regulatory standards such as the detection of E. coli; to alert authorities to potential contamination in order to then investigate and rectify failings with the water treatment methods. Water safety is not ensured by achieving a zero bacterial count; it is ensured by maintaining ‘a high standard of care’.

In July 2019 the Health (Drinking Water) Amendment Bill was passed with little-to-no resistance from the Opposition. Wording of the Bill and the movement toward a separate Water Services Bill foreshadows the formation of a regulatory body, a ‘drinking-water assessor’.

The tone of the debate is sympathetic to a statement that was issued in April 2019 by Water New Zealand CEO John Pfhalert regarding the need for water supply regulatory reform (standards and enforcement). The Hansard record is re-run of the Water New Zealand F(ear) U(ncertainty) D(oubt) campaign and chlorination disinfection rhetoric that bogged down the Havelock North Inquiry process, including the now standard inflammatory misrepresentation of the medical record as justification for a Universal/‘one-size-fits-all’ water treatment method.

The subsequent New Zealand Government media release fronted by Clark-and-Mahuta heralds the establishment of a (single) ‘dedicated watchdog for water quality’, however:

The scope, roles and institutional form of the regulator (including whether to include regulation of all three waters within a single regulator, or separate entities) will be the subject of further Cabinet consideration in September [2019]…
Three Waters Review, Department of Internal Affairs. Accessed 5 Aug 2019.

“Access to safe, clean drinking water is a birth-right for New Zealanders and a key concern for communities up and down the country. Wherever they live, consumers and communities expect to be able to turn on the tap and drink the water without fear of getting ill.”
David Clark, Minister of Health, July 2019.

Above (Havelock North?) Chlorine Free Water Stations.

The 1 News item announcing changes to the Health (Drinking-Water) Act was not accompanied by footage of healthy New Zealanders enjoying water direct from the tap, but rather driving to fill up jerry cans at chlorine-free water stations. (Evidently household pets have also not been swayed by the health benefits of chemically-treated water.)

“You feel as though this is almost third-world when you do this, but why not? … This is a lot better than trying to drink out of the [chlorinated] town supply.”

It’s now ten years since pro-chlorination lobby-group Water New Zealand’s Turnbull Group manifesto set out to commodify New Zealand’s water-resources under a single regulatory authority. In this time they have found a compelling angle on the rhetoric of water resources management. Fortify the threat to public health with cross-cultural understandings: ‘the health of the water is connected to the health of the people. We are one and the same. If the water is unhealthy, we are unhealthy.’[*].

Left unspoken is that Water New Zealand believes that ‘unhealthy’ water needs a ‘jolly good (chemical) disinfect’.

What is now evident — perhaps only through a distant-island lens — is the co-opting of culture to further commercial interests. Kare i te mea tupu ua — there are no coincidences.


Disinfecting the Realm

Water has been piped from the mountain streams to Rarotonga households since the 1960s, with only coarse filtration (through a ‘gravel bed’). Enquiries directed to Te Marae Ora (Ministry of Health) have been meet with acknowledgement that there are no public health record of mass-illness due to water-borne pathogens.

‘there are no public health records of mass-illness attributed to the presence of water-borne pathogens in the water supply.”

The Te Mato Vai system is not the first time chlorine disinfection had been proposed for Rarotonga. Concrete-block dosing sheds were built at the intakes in the 1960s and then abandoned due to lack of finance. There’s also recollection of chemicals being dumped directly into the streams (1970s?); the accidental discharge from the Kia Orana Processing factory that polluted the stream through Avarua town (1980s); and the short-lived system for Nikao where used of chlorinated irrigation water was discontinued after it killed the plantings around the airport.

Household Disinformation: How much (you are going to) pay?

In the wake of the United Nations International Waters Project in the early 2000s; and pressure for the Cook Islands to achieve Sustainable Development Goals (read ‘aid financing’), the prospect of chlorination once again washed ashore with a household survey as part of the 2009 ADB-funded Preparing the Infrastructure Development Project; which included proposed upgrades to the island’s water supply system.

…In the community survey of 330 households on Rarotonga, respondents were asked to indicate their willingness to pay (WTP) for water under 2 scenarios:
Option 1 – a supply with good reliability (good pressure, constant availability) but no water treatment, and
Option 2 – a supply with good reliability and treatment.
Final Report for Preparing the Infrastructure Development Project: Vol. 5: Household Survey (2008)

The phrasing of both questions presumed there to be a user-pays system / water charges; and that respondents understood what was meant by technical phrases such as ‘water treatment’:

For Option 1 [Reliable Supply], 39% indicated a willingness to pay, 49% indicated no willingness to pay, 10% didn’t know, and 2% did not respond to the question.
For Option 2 [Reliable Supply and Treatment], 55% indicated WTP, 22% no WTP, 19% didn’t know, and 4% made no response.

‘Water treatment’ is inclusive of any process that is used to change the quality of water for intended end-use; inclusive of chemical as well as physical methods.

When 23% of respondents are unable to answer, there’s something wrong with the question. Closer inspection shows that the survey options were likely to further distort findings. For Option 2: Reliable Supply and Treatment; repondents were offered the choice of:

  • Would stay connected and am prepared to pay something for water.
  • Would disconnect and find water elsewhere.

The choice is then between ‘pay-up’ or ‘have no household water’ when the status quo was a household connection supplying water of varying quality; (which was not presented as an option).

On the specifics of chlorine as a disinfectant (and once again presuming water charges):

…a significant objection to the taste of chlorine in water (44 percent objected, 9 percent were unsure, 30 percent had no objection to it and 16 percent would accept but prefer an alternative if practical).

The author of the report went on to conclude that 46% of the respondents were in favour of chlorination: 30% no objection + 16% would accept if there were no other choice. An equally valid interpretation is that 44-69% were not in favour of chlorination (44% + 9% + 16%).

So that’s settled it then. Chlorine for all?


Public Indoctri… ‘Consultation’

Resistance by the residents of Rarotonga to the use of chemicals for water treatment is well-documented, with the AECOM consultant who prepared the Te Mato Vai Master Plan (2014) offering the following comment:

Although the Master Plan sets out a number of recommendations in order to meet the goal of reliable potable water, ongoing local resistance to the use of chemicals in the water, such as chlorine, may limit the effectiveness of the water treatment.
-Te Mato Vai – Master Planning A Potable Water Supply For Rarotonga, Cook Islands. Colin Gerrard, AECOM, 2014.

The public response to government’s 2019 public presentations on disinfection decision options was – once again – ‘No chemicals’. This prompted the following statement from MP Mark Brown (as part of the June 2019 Parlimentary session).

“if it is determined that chlorination is the safest and best way to ensure our water is clean for our people to drink and if the information is based on sound scientific facts and not social media speculation, then we will make that decision because this is a government that is not afraid of making hard decisions.”
Mark Brown, Cook Islands Party, June 2019

Community group Te Vai Ora Maori formed soon after this comment due to concerns from residents regarding the unilateral approach evident in the disinfection consultation process. TVOM’s release established the areas of concern as the long-term impacts on human-heath, agriculture, biodiversity and the environment.

Alongside the release announcing the formation of TVOM, the Cook Islands (daily) Newspaper ran a column the questioned the claim of increased risk of cancer (Fact-checking: Does chlorine cause cancer?); in response TVOM supplied details of the supporting research report to the editor and reissued the release with references, originally published in the Cook Islands Herald.

The Cook Islands government in releases issued by the Te Mato Vai Project Management Unit, and new water authority To Tatou Vai, has since attempted to discount concerns that have been raised regarding chemical treatment as ‘un-scientific’ and ’scare-mongering’.

In negotiations with landowners regarding construction and water usage rights, information about the treatment process has been presented using highly-technical terms likely to mislead the casual reader. For example; a summary regarding use of the chemical polyaluminum chloride:

All parameters including colour and turbidity are marginal as to whether the water needs to be dosed with coagulant for colour during dry weather conditions. However, due to the speed of change of flows (and resulting sediment loading) it is likely that to achieve a consistent output (without powered monitoring devices and control), coagulant will be required most (if not all) of the year. The decision to treat all of the water all of the time is to optimise water quality (the sedimentation tank will not be needed for consistent periods of dry weather and the AVG would be kept operational).
-GHD, 1 Nov 2019

Put directly the above reads: ‘If you only collect streamwater in dry conditions, then polyaluminum chloride is not needed.’.

In December 2019, and without landowner consent, or the necessary environmental safeguards, the government directed contractors to begin commissioning using shock-chlorination, and trialling of the coagulant chemicals, starting with the Matavera Water Treatment Plant.

Fresh from tenure as president of water industry lobby group Water New Zealand (known for the post-Havelock roadshows), the CEO of To Tatou Vai has relied upon the Havelock North outbreak as justification for chemical treatment. He has not chosen to engage with the differences in geographical location (temperate vs tropical); source water (ground vs surface-water), lack of agriculture (none above intakes in Rarotonga), and extreme changes in flow condition; that make the two systems dissimilar. Indeed Rarotonga, an island barely 32km in circumference, with no industrial or agricultural pollution in catchment areas; isolated the middle of the South Pacific ocean has all of the attributes of a location that can and should be able to have chemical-free water supply.

The water authority CEO first came face-to-face with Cook Islands cultural practise regarding chemical-use when he fronted the (government) Project Management Unit disinfection presentations to landowners and the general public in May 2019. One of these presentations included a call from participants for a vote; with the majority against chlorine-disinfection.

This firm and clearly stated cultural objection has led to a wave of responses from various government agencies. Notable actions and releases in 2019 have included:

  • Ministry of Health: (Non-resident) Cook Islands doctors attending a public health conference on smoking, appeared on national television to offer comment on chlorine disinfection.
  • Ministry of Agriculture/Te Mato Vai: Media release claiming that chlorinated water is safe for horticulture and organics certification (when cited guidelines only make permit produce to be rinsed with chlorinated water).
  • The minister of finance and associate minister of agriculture making off-colour remarks at the expense of organics growers on talkback radio.
  • To Tatou Vai: Numerous public media releases regarding the same one-off ‘bad’ water test results from March and May 2019, or the public health tests of village water stations; not yet supplied by the new (filtration) treatment system.
  • To Tatou Vai: Claims by a board member of waterborne illness (recalling the register of the reporting on the Havelock North outbreak); however claimed deaths were not corroborated either by medical record or public outreach — the same board member, latter attributed illness to substandard construction processes and not the source water quality; in the revised account, contractors had not cleaned out pipes prior to connecting the public supply.

Despite the unsubtle approach, this charm-offensive by government (aided an abetted by some questional editoral decisions that have been made by the daily paper), has returned dividends and served to undermine perceptions of Rarotonga’s source water. At the 9 Dec 2019 Te Vai Ora Maorai Water Protest, an elderly senior public servant heckled protestors with ‘[so you want] mimi and tiko in your water!?’; despite having grown-up drinking from only coarse-filtered and non-disinfected supply; with no ill-effects. It appears that the public may be more comfortable with invented threat when it comes with an off-the-shelf chemical solution, than trust their own life experience.

…there has been no bacteriologically confirmed water-borne bacterial or viral illnesses reported to Te Marae Ora…
Release, Te Marae Ora, July 2019


When it Rains

If there is any truth to the water authority CEO’s claim of ‘bad’ water, is it that when it rains, the water does gets muddy, and bacterial counts will more-than-likely increase. However this observation is one that can be used to inform the design brief for the water treatment system; along with companion considerations of cultural values and practices, environmental impacts and (lastly), the economics of implementation. This is all part of arriving at a sustainable solution; as in the Sustainable Development Goals that the Cook Islands government is setting out to achieve.

Physical water treatment methods including UV-irradiation result in the same end-water quality, but without the chemical cost, chemical waste, and chemical dependence.

Threatening the local population with non-science in order to achieve dull compliance is a tatic best consigned to the days of colonisation.


References and Further Reading

Classification/subjects: Havelock North, outbreak, Te Mato Vai, To Tatou Vai, chlorination, drinking water standards, monitoring water quality, Rarotonga, Cook Islands, South Pacifc, water monitoring, pathogens, waterborne illness, FUD: fear, uncertainty, doubt, public health.

Working Draft. Updated: 10 December 2019.


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