Free Water Refills  - Water Hygiene Considerations!

by Water Hygiene Centre, on 16-03-2018
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Articles such as this one in the Guardian newspaper highlight the initiative driven by industry body Water UK and campaigners Refill, to make free drinking water refill stations widely available to the public in order to reduce plastic waste.

refill is a national

The campaign is rightly driven by environmental concerns in respect to single-use plastic bottles which are expensive to produce; using up finite natural resources in both manufacture and transportation and also creates huge amounts of waste.


Used bottles often end up as landfill or litter and, as we know, can be responsible for vast marine plastic pollution.


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Added benefits of the scheme include significant cost savings to those who regularly buy bottled water. 

Refill - How it Works?

Users can find refill stations using the “Refill app” from their smart phone. The app displays on a map the nearest refill point. Businesses with publicly accessible mains-fed water outlets are encouraged to add their location to the app and each refill station is approved by moderators prior to acceptance.


Water Hygiene Concerns

Water supply companies go to great lengths to ensure that water delivered through the mains distribution network is fit to drink without risk to public health. The main concerns in respect to refills are related to contamination, such as:

  • User’s hands are dirty;

  • User’s bottles for refilling are dirty;

  • Dirty and / or unsuitable cleaning materials.

It is worth noting there is already guidance [HTM04-01 – specific to healthcare properties] recommending tight controls on design, installation and maintenance of drinking water fountains and chilled-water dispensers. HTM04-01 also recognises these devices as a potential source of illness. There are also industry standards and codes of practice relating to maintenance of such devices.

For the purpose of this blog we sought confirmation on the selection criteria for refill stations and what liability lies with the station provider. Gus Hoyt, Refill Programme Manager replied to our email, his reply detailed:

Essentially we try and sign-up cafés who have hygiene training for staff but for others we have this advice:

  • Ask the person refilling to take the lid off the bottle;
  • Do not touch near the opening of the bottle;
  • Do not let the bottle and tap/jug come into direct contact with the bottle;
  • You must always wash your refillable bottle – you wouldn't just keep drinking out of the same unwashed glass at home;
  • The Refill Station has the right to decline if there's any health concerns.

Based on these requirements suitable locations for refill points might include:

  • Fast food outlets;
  • Cafés / coffee shops;
  • Public houses;
  • Restaurants.

Such locations will already employ suitable skills & hygiene regimes to properly maintain the refill stations. Unsuitable locations could include unsupervised or intermittently-used public areas such as parks, town centres or public toilets [the vicinity of]. Bearing in mind the risk of contamination the latter may need to be avoided [again these locations would be approved by moderators].

Considerations for Refill Station Providers

Guidance from industry bodies, manufacturers, the Department of Health and the Health & Safety Executive is available for water dispensers. Those organisations considering registering their location on the Refill app may need to think about the following:

Design & Installation:

  • The water supply source should be mains-fed or otherwise of reliable potable quality;

  • All components should be Water Regulations Advisory Scheme (WRAS) approved;

  • Suppliers and installers should be affiliated with the Watersafe approved plumbers’ scheme, either fully approved or as a limited scope contractor for point-of-use drinking water supplies;

  • Outlets and/or dispensing units should be selected for ease of cleaning;

  • If accessible to the public, the dispenser / outlet nozzle design should ideally be non-touch with adequate signage instructing users on correct usage to avoid cross-contamination from used water bottles;

  • The Department of Health’s HTM04-01 guidance states that drinking water outlets should only be installed upstream of frequently used outlets and on a supply spur of no more than 3-metres is length. They should not be installed in hospital areas where patients are especially vulnerable to infection;

  • In non-healthcare environments installers should consider the level of supervision/visibility required to protect unmanned installations from the risk of vandalism and/or malicious contamination, for example staff presence or CCTV coverage;

  • Stations should only be installed where they are likely to receive frequent use ensuring a regular flow of water through the unit and associated pipework. Infrequent use is a common cause of unsatisfactory water quality;

  • Installations should be risk assessed by a competent person or team of people.

Operation & Maintenance:

  • A comprehensive asset register should be maintained indicating the location and type of equipment in use for each refill station;

  • The responsibility for operation, maintenance and hygiene of each refill station should be clearly defined;

  • Ideally, chilled drinking water units should only be purchased with an accompanying service contract, or otherwise with a suitable in-house PPM regime carried out by competent personnel, to ensure maintenance as per manufacturer and sector-specific guidance;

  • Operators must ensure that staff are competent to use and maintain the facilities. Staff should be given water hygiene training and allowed sufficient time to clean the equipment and/or supervise those doing the cleaning.

  • Outlets should be maintained daily ensuring that external surfaces and dispensing taps are cleaned and disinfected and that drip trays are emptied, cleaned and disinfected.

  • In addition, industry guidance recommends that chilled water dispensing machines are sanitised (including internal reservoirs and waterways) every 6-months or every 3-months in healthcare premises.


It’s not the first time environmental initiatives have resulted in a solution that raises water safety concerns.  For example, water saving initiatives including use of flow restrictors, rainwater harvesting and greywater recovery systems can all have an impact.


Ensuring that initiatives can be applied safely requires informed decisions to be made following a suitable risk assessment. A suitable risk assessment is one carried out after gathering the knowledge necessary from a range of sources: knowledge of the installation, knowledge of the microbiology and knowledge of the operational needs. This reinforces the need for organisational governance and management that incorporates this knowledge into day to day operations.


Increased participation and awareness of refill stations is likely to have a beneficial effect on water hygiene, as increased use of well sited and well maintained outlets will result in a beneficial increase in water throughput.


To learn more about becoming a Refill Station click here to go to Refill’s ‘add a station’ page.


For more information about Water Hygiene Centre and our independent advisory services click here.

Editors Note: The information provided in this blog is correct at date of original publication - March 2018. 

© Water Hygiene Centre 2019


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About the author

Water Hygiene Centre

The Water Hygiene Centre was established in 2009 to address the lack of independent water hygiene consultancy within the industry. From our humble beginnings, we have established ourselves as a market leader, helping clients identify and minimise the risk of waterborne contamination and disease, whilst improving compliance performance.

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