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Developing a Cross Connection Control Program for a Small Utility
This article was prepared in 1999 by Bonnie Waybright, P.E., former Cross Connection Program Coordinator for the Oregon Health Services.
Introduction
Establishing a cross connection control program for a small water utility can be a daunting task. The responsibility of creating and implementing the program will often fall on the operator, who will most likely be responsible for water, sewer, roads, parks and other public work projects as well. This can seem overwhelming, but with an organized approach an effective program can be established.
What is a Cross Connection?
Before anyone can start a cross connection program, he or she must understand what cross connections are, why they are dangerous, and how they can be corrected. Therefore, the first step must be education. The approach to learning about cross connection control will vary depending on time and funding constraints.
The best approach will be to attend a training course that is specifically designed to teach cross connection control practices for public water systems. If this is not possible, then the operator will have to pursue other avenues. Some agencies and organizations offer training courses that include sessions on cross connection control for little or no cost. Some areas have committees, associations or other groups dedicated to cross connection control. These groups can be a great source of information and networking. Many cross connection control publications and videos are available. It is also advisable for the operator to contact neighboring water utilities for information on their cross connection control programs.
Legal Authority
Once the operator has a good understanding of cross connection control, the next task will be t o prepare a written document that will establish legal authority for the program. This may be in the form of an ordinance, resolution, by-law, etc., depending on the organization of the water system. This document will define the utility's cross connection control requirements, such as what circumstances will require the installation of a backflow preventer; who will be responsible for the installation, testing and maintenance costs; program enforcement; approval of backflow preventers and installation requirements. This document must avoid conflicts with other agencies.
It is important to consider the requirements of local building, plumbing and fire codes in addition to Health Services requirements. It is useful to obtain copies of ordinances from nearby utilities and consider their requirements. It is preferable for utilities to have similar requirements when possible. This will minimize confusion for those who work in several districts and are expected to be familiar with local requirements, such as backflow assembly testers, plumbers and vendors. It will also help avoid critical comparisons between utilities.
"The Board"
The cross connection ordinance will be useless without the approval of the board of directors or city council. This fact can present problems of its own. As is often the case, the operator will be given the responsibility of running a cross connection control program but will not have the authority to create and enforce the ordinance. For this reason, it is extremely important to have the support of the board. Board members must be educated about cross connection control. They need to understand the hazards cross connections present to the safety of the water supply, and the liability they are vulnerable to in the event of a backflow incident. Once they understand the importance of a cross connection control program, they can be strong allies in adopting an effective ordinance and implementing the program.
Organize the Program
Once an ordinance has been adopted, it must be implemented. This requires an organized approach. The responsibilities of each person involved in the program must be clearly defined; a system for coordinating with other agencies must be developed; a plan to educate the public must be in place; an efficient system for keeping records is critical; and various form letters and notices will need to be developed.
Work Responsibilities
It is important to identify who is responsible for each element in the cross connection control program. Who will determine when a backflow preventer is required? Who will prioritize installations? Who will verify the correct installation of the backflow preventer? Who will test backflow preventers? Who will send out letters and notices? Who will track the testing and maintenance of the backflow preventers in the system? Who will respond to customer inquiries and complaints? These are all questions that need to be answered before the program is presented to the customers.
Agency Coordination
Working with other agencies can be a great benefit to the cross connection control program. The local building department plan review process can be a useful tool. If an agreement can be made to include the water utility in the plan review process, any needed backflow preventers can be included in the planning stage. A good relationship with local plumbing inspectors can be a great benefit to the program. They can serve as extra eyes to spot any variations from building plans that might create a need for backflow prevention. Working with fire officials is extremely important. The installation of backflow preventers on fire lines will increase the pressure loss, and this needs to be considered in the system design. Good working relationships with these officials will eliminate the headache of retrofitting a new building, and the bad publicity that follows a lack of coordination between agencies.
Public Education
Public education is an important aspect of cross connection control that is too often overlooked or minimized. This can have disastrous consequences. If a customer receives a notice to install a backflow preventer with no explanation, they will often have a negative response. It is important to educate the customers to the dangers of cross connections and the importance of installing backflow preventers when needed. It is also very important to explain the program priorities so the customers don't feel singled out. If one customer is notified to install a backflow preventer and their neighbor isn't, they will want to know why. It is better for the utility to answer these questions with public education, rather than leave the customers wondering, or worse yet, doubting the sensibility of the cross connection control program. Most customers will be willing to support the cross connection control program when they understand that the safety of their drinking water is at stake.
Record-keeping, Forms and Notices
An active cross connection control program will generate information that must be organized and tracked. It is important to give careful consideration to record keeping methods before information begins to accumulate. Once information is stored, changing the format becomes quite difficult. A system needs to be in place for notifying customers when backflow preventers must be installed, tested or repaired, and for tracking the responses. Backflow preventers must be tested regularly, so a system of tracking due dates is needed in order to send notices on time. Certain letters will be sent out frequently, so it is helpful to have a standard form prepared for these occasions. Cross connection software is available to assist with this aspect of the program. The software is available in a wide range of prices and capabilities.
Cross Connection Program Implementation
Once these preparations have been completed, the cross connection control program is ready for implementation. Public education can be initiated to gain customer support for the program. The operator will be ready to identify cross connection hazards in the system and begin the process of eliminating or isolating them. As the program begins to function, the utility will be prepared to handle the paper flow and phone calls that are generated.
Summary
Creating an effective cross connection control program is an important and challenging responsibility. An organized approach in the beginning will help avoid many problems and conflicts once the program begins to function. Once the program is established, the utility can take pride in the knowledge that they are taking an active role in protecting the public water supply from potentially life-threatening contamination.
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