Why Some Important Water Testing Requirements Are Still Missed
In Ontario, commercial property owners must follow several laws related to water safety and water quality. Despite these requirements, many important water testing obligations are still overlooked.
Missing these requirements can lead to:
- health risks,
- legal penalties,
- reputational damage, and
- costly compliance issues.
Water safety involves more than occasional sampling. Property owners and facility managers must understand:
- regulations,
- industry standards,
- testing schedules, and
- best practices.
This article highlights five commonly missed water testing requirements and explains how to reduce risk and improve compliance.
1. Legionella Testing in Cooling Towers and HVAC Systems
Legionnaires' disease bacteria can grow in warm, stagnant water found in:
- cooling towers,
- boilers,
- HVAC systems, and
- other building water systems.
Under Ontario’s Occupational Health and Safety Act, employers must take reasonable precautions to protect workers from health hazards.
Industry standards such as:
- ASHRAE Standard 188
recommend routine Legionella monitoring and water management programs.
Risks of Non-Compliance
- Legionnaires’ disease outbreaks
- Fines and legal claims
- Business disruption
- Damage to reputation
- Liability for illness or death
Recommendation
Test:
- at system startup,
- after maintenance, and
- seasonally for high-risk systems.
2. Lead Testing in Older Buildings
Older commercial and multi-residential buildings may still contain lead plumbing components.
In Ontario:
- schools and childcare facilities must test for lead under O. Reg. 243/07,
- but many commercial buildings are not legally required to test.
Even without a legal mandate, lead exposure remains a serious health concern.
Why This Is Often Missed
Many property owners assume:
No testing requirement = no risk
This can create a false sense of security.
Risks of Non-Compliance
- Long-term neurological health effects
- Tenant and employee concerns
- Increased liability
- Insurance complications
Recommendation
Perform annual drinking water lead testing, especially in buildings built before the 1990s.
3. Post-Construction Water Testing
Construction and renovation work can disturb:
- pipe interiors,
- sediment,
- biofilm, and
- old plumbing materials.
This may increase the risk of:
- bacterial contamination,
- metal leaching, and
- poor water quality.
However, post-construction water testing is often forgotten during project closeout.
Why This Is Often Missed
Testing is frequently excluded from:
- commissioning checklists,
- turnover procedures, and
- contractor scope documents.
Risks of Non-Compliance
- Tenant complaints
- Unsafe water conditions
- Legionella growth
- Compliance issues
Recommendation
Always complete water quality testing before occupancy or reopening a renovated area.
4. Testing Decorative Water Features and Irrigation Systems
Decorative fountains, pools, irrigation systems, and water features can support bacterial growth when:
- disinfectant levels are low,
- water becomes stagnant, or
- systems are poorly maintained.
Some systems can produce aerosols capable of spreading Legionella bacteria.
Why This Is Often Missed
Many people incorrectly assume non-potable water systems are low risk.
Risks of Non-Compliance
- Aerosolized bacterial exposure
- Public health concerns
- Potential outbreak investigations
- Legal liability
Recommendation
Include:
- regular cleaning,
- seasonal inspections, and
- routine water testing
in your maintenance program.
5. Testing Non-Municipal and Backup Water Supplies
Some commercial facilities rely on:
- private wells,
- cisterns,
- storage tanks, or
- emergency backup water systems.
These systems may fall under Ontario’s:
- Safe Drinking Water Act, 2002
Testing often decreases after the system is initially approved.
Why This Is Often Missed
Backup systems are often:
- rarely used,
- difficult to access, or
- forgotten during routine maintenance.
Risks of Non-Compliance
- Contaminated emergency water supplies
- Unsafe drinking water
- Regulatory penalties
- Serious reputational damage
Recommendation
Perform quarterly testing and maintain detailed documentation for all non-municipal water systems.
Stay Ahead of Water Quality Risks
Overlooked water testing requirements can create serious operational, health, and legal risks.
Proactive testing helps:
- protect building occupants,
- reduce liability,
- support compliance, and
- improve overall water safety.
At Canadian Water Compliance, we help organizations manage water quality risks through:
- Legionella testing,
- lead testing,
- microbial analysis,
- water safety audits,
- risk assessments, and
- compliance support.
Our Services Include
- Legionella and microbial water testing
- Lead and heavy metal analysis
- Water safety audits
- Risk assessments
- Compliance documentation and reporting
Book a consultation to strengthen your water safety program and reduce compliance gaps.



