Cross-connections between the customer’s plumbing system and the purveyor’s public water system pose a potential source of contamination to the public water supply. The public water system can become the conduit for the spread of a contaminant to the water system’s customers, threatening public health. The purpose of a cross-connection control program (CCCP) is to protect the public water system from such contamination, thereby safeguarding public health.
A CCCP is initiated by the authority having jurisdiction (AHJ) to administer and regulate the selection, installation, testing, and maintenance of backflow preventers. The AHJ is typically the water purveyor and may include involvement from municipal building and/or plumbing officials, other departments or agencies, and the health authority.
When it comes to cross-connection control, the water purveyor’s responsibility typically ends at the point of delivery where the purveyor no longer has control of the water. Once water leaves the control of the purveyor i.e. leaves the public water system, the water purveyor must consider that the water could become contaminated and, under the right hydraulic conditions, backflow into the public water system.
The AHJ’s CCCP should be based on the following assumptions:
■ All customers pose a risk to the public water system.
■ Customers plumbing systems must be isolated at the property line (typically at the water meter or water service connection) with an approved backflow preventer or air gap, unless the AHJ is satisfied with the level of internal backflow protection provided by the customer.
See Chapter 6 for a list of typical facilities requiring premises isolation.
Note: The public water system begins at the source and ends at the service connection. It includes all treatment processes, storage tanks, valves, and the purveyor’s water supply piping.
A successful CCCP includes two important factors:
■ Establishing a relationship with all entities involved in the program (e.g. water system purveyor, federal and local health authorities, the water customer, etc.).
■ The effectiveness of the AHJ’s public education program. When water users understand the importance of cross-connection control and their responsibilities, they are more likely to comply with the AHJ’s requirements.
This chapter gives an overview of the types of cross-connection control programs and discusses their key elements.
Note: An additional resource for starting a cross-connection control program is the publication:
“Potable Water: Methodology for Setting a Cross-Connection Control Program”. This publication was developed through a partnership between the Federation of Canadian Municipalities, the National Research Council and Infrastructure Canada and is available for free on line.
Types of Programs
There are several types of CCCPs. Before choosing the type of program to implement, the AHJ should understand what regulations govern cross-connections in their service area. AHJs should know where their liability begins and ends, and what their relationship is with other entities involved in implementing the program.
When developing a written CCCP plan, the AHJ can choose between the following types of programs:
■ Premises isolation program: An approved backflow preventer or an approved air gap is installed at or near the point of delivery where the water supply enters the premises and before any other branch connections. This isolates the customer’s water system from the water purveyor’s public water system.
■ Internal (Individual, Area and Zone) Isolation Program: Approved backflow preventers or backflow prevention methods are installed/applied at the point of hazard inside the customer’s premises.
■ Combination program: A CCCP that requires both premises isolation and internal isolation backflow preventers to protect the water supply system.
Premises Isolation Program
The history of cross-connection control has provided regulatory authorities with sufficient information to establish lists of premises where the potential health hazard is so great that it is mandatory for these premises to be isolated from the water purveyor’s system. For a listing of various types of premises and their hazard classifications, see Table 6.2 in Chapter 6.
Recommended mandatory lists are not comprehensive. Therefore, AHJs need to determine whether any properties in their service area that are not on the recommended mandatory list may warrant premises isolation through a survey process. Premises with irrigation systems, fire systems and/or medical/industrial equipment that use chemicals are also examples of health hazard properties.
The AHJ should assess all premises individually to determine the degree of hazard and the appropriate type of backflow prevention required. Premises of the same kind do not necessarily require the same type of backflow protection. For example, a business identified as a mortuary that only facilitates funerals is considered to be a mortuary in name only and may not need a backflow preventer at the service connection.
A premises isolation program protects the AHJ’s distribution system, but does not protect the occupants of the facility or premises. The AHJ should inform the property owner/water user that the occupants may not be protected, and that the owner has a responsibility to comply with the plumbing code. Depending on how the AHJ’s cross-connection program is structured, the AHJ may conduct a survey of the premises, or recommend that the owner hire a cross-connection inspector or a plumbing inspector or contractor to perform an internal survey, and recommend appropriate backflow protection at all cross-connections in accordance with the AHJ’s program requirements.
A premises isolation program protects the AHJ’s distribution system, but does not protect the occupants of the facility or premises.
Advantages of a premises isolation program:
■ provides the greatest level of protection for the public water system
■ reduces the AHJ’s and property owner’s legal liability
■ decreases the amount of resources spent tracking internal backflow preventers that will need to be tested, repaired and maintained
Disadvantages of a premises isolation program:
■ does not protect the occupants of the premises. A good public education program explaining this fact is essential for the health of the consumer.
Internal (Individual, Area and Zone) Isolation Program
This type of CCCP allows the backflow preventer to be installed at the point of hazard to provide protection to the AHJ and facility occupants. Examples would include installing a backflow preventer on the make-up lines to a boiler or an irrigation supply line.
This type of program is effective in protecting the occupants of the premises, but is much more difficult for the AHJ to monitor the installation, testing and maintenance of backflow preventers. Customers can create cross-connections without the AHJ’s knowledge. If the correct permits and inspections are not obtained and frequent surveys are not performed, the public water system may not be protected.
Advantages of an internal isolation program:
■ protects the consumer to the last free-flowing tap
■ customer avoids the cost of a larger premises isolation backflow preventer
Disadvantages of an internal isolation program:
■ may increase time and cost to the AHJ to implement and maintain
■ jurisdiction or right of enforcement issues on customer’s premises may be limited
■ AHJ will have to ensure that re-surveys are performed to ensure no additional cross-connections have been created or that no backflow preventers have been removed
Combination Program
AHJs that implement this type of program rely on premises isolation and internal isolation (individual, area, zone) to protect the public water system from contamination.
In a combination program, the AHJ:
■ must require premises isolation where mandated
■ may rely on a combination of premises isolation and internal protection for individual facilities where premises isolation is not mandated
■ may solely rely on internal protection where premises isolation is not mandated
A combination program allows the AHJ to implement the most appropriate method of cross-connection control at any particular facility. Where premises isolation is required, the advantages and disadvantages of a premises isolation program apply. Where the AHJ relies on internal protection, the advantages and disadvantages of an internal isolation program apply.
For individual facilities where premises isolation with an RP is not mandated, AHJs may require a DCVA to be in.stalled at the meter (premises isolation) to provide an additional level of protection for the public water system. The AHJ then relies on internal protection at the point of hazard for all hazards found on the customer’s plumbing system. In this way, the AHJ’s water system is protected by a combination of the DCVA or RP at the meter (premises isolation) and from health hazards at the “point of use”
(internal protection).
The AHJ’s in-premises risk assessment should include the potential for the customer’s plumbing to be changed without the AHJ’s knowledge. For example, strip malls with frequent changes in tenants pose an increased risk to the public water system. A book store could be replaced by a medical or dental facility without the AHJ’s knowledge. This would increase the risk to the AHJ’s system. The AHJ would need to conduct re-surveys of the mall to ensure that new cross-connections are detected.
Note: A Combination Program relies on both premises isolation and internal isolation for protection of the public water system.
Due to frequent tenant changes, the AHJ may want to require an RP or DCVA to be installed for premises isolation for multi-tenanted facilities.
Part of the overall hazard assessment should also include an assessment of the complexity of the building’s plumbing. As the complexity of the piping increases, the risk of not identifying a crossconnection increases.
It is important for the AHJ to understand that this type of program may require more time and appropriately trained personnel.
Advantages of a combination program:
■ affords maximum flexibility for the AHJ
■ provides better public health protection than an internal protection program alone
■ may be more cost-effective for the property owner
■ may provide greater health protection for the occupants in the facility
Disadvantages of a combination program:
■ plumbing could be changed and cross-connections created without the AHJ’s knowledge.
■ customers may challenge the AHJ’s right of enforcement if it is not addressed sufficiently in the bylaw.
■ time and cost to the AHJ
Whichever program the AHJ chooses, it is important to remember that the AHJ is responsible for preventing contamination of the public water system. Unless a backflow preventer is properly installed and maintained at the service connection, the public water system is still vulnerable due to possible changes to the customer’s plumbing.
Program Administration
The first step in developing a CCCP is for the AHJ to formally establish what type of program they will adopt (i.e. premises, internal, or combination). Once the program type is decided, the following commitments need to be made:
■ Select a program administrator.
■ Employ and train appropriate staff.
■ Establish policies that reduce risk and liability issues.
■ Set program goals.
■ Incorporate program elements into daily operations.
■ Adequately fund the program.
A successful CCCP includes the following:
■ Management support. A complete understanding, acceptance and support by water system management and staff on the program’s importance. All water system personnel must be informed about the program and its requirements.
■ Timeliness. Establish compliance schedules and follow up in a timely manner.
■ Education. The education of everyone involved with the program is crucial. This includes not only water system staff, but also “decision makers” such as municipal council members. It is especially important to educate water customers by giving them clear and concise information.
■ Consistency. Implement the program policies and procedures consistently and treat all affected customers equitably.
■ Flexibility. When working with customers, allow time for budgeting and other options when possible.
■ Coordination. Involving engineering, health, plumbing and building departments and other agencies is vital.
Elements of a Cross-Connection Control Program
The elements described in the sections below are essential to establish a successful CCCP. Establishing the program on a strong foundation assists with the implementation and maintenance of a cost-effective and legally defensible program. An additional overview of the elements of a CCCP for small water systems can be found in Appendix I.
Element l : Establishing Legal Authority
Many provinces, territories and/or health authorities require that water systems establish legal authority to develop and implement a CCCP. This legal authority can be established through a written enforcement document or other legal instrument such as a bylaw.
Before implementing a CCCP, the AHJ’s management team must formally establish the program. This should include the following steps:
■ Committing to employ personnel to administer the program.
■ Establishing policies and procedures to reduce risk and liability.
■ Setting program goals.
The AHJ should designate one person as the CCCP manager responsible for coordinating the development and implementation of the program. This may include work performed by different water department staff, consultants, or contractors.
The AHJ should periodically evaluate the effectiveness of the CCCP to determine if the goals and objectives are being met. The AHJ may then need to modify the program procedures and policies based upon the results of the evaluation.
The enforcement document should clearly define the responsibilities of the water system customer and the AHJ. Enforcement documents may include, but are not limited to, the following provisions:
■ Defining the goals of the program.
■ Providing an outline of the program.
■ Including definitions associated with cross-connection control.
■ Referencing provincial, territorial and/or health authority rules and regulations pertaining to cross-connection control.
■ Referencing applicable plumbing codes.
■ Defining the obligation of the customer to maintain a safe plumbing system and to protect the public water supply (AHJ’s system) from contamination as a condition of service.
■ Defining the AHJ’s compliance options, including conditions for termination of water service (or other compliance actions) when customers fail to comply with the AHJ’s program requirements.
■ Stating the penalties for water user’s non-compliance such as:
– Charging or fining customers when they fail to comply with the AHJ’s program requirements (or as a standard implementation policy).
– Authorizing whether the AHJ can place a lien on the property for non-payment of fees or fines associated with the cross-connection control program.
■ Identifying the person or position responsible for administration of the program.
■ Identifying the authority responsible for enforcing the applicable building codes such as plumbing, fire, and mechanical codes.
■ Establishing who (usually the customer) is responsible for the costs associated with the purchase, installation, testing, maintenance and repair of backflow preventers.
■ Establishing the source of funding to operate the program.
■ Providing installation guidelines, lists of approved backflow preventers or assisting the customer with locating information (plumbing code, local regulations or other industry standards).
The authority having jurisdiction (AHJ) refers to the local official, board, council, department, organization or agency that has jurisdiction over internal plumbing and can administer and enforce the requirements of a code, standard or enforcement document and approve equipment, materials, installations or procedures.
The AHJ’s legal department can assist in determining program elements that should be addressed in the enforcement document and in a written program plan, Standard Operating Procedures (SOP) manual, or administrative manual. Enforcement documents are more difficult and costly to amend or revise than operations manuals because the enforcement documents must be adopted or approved by the governing body. Circumstances that may require the AHJ to take enforcement action, such as the requirement for approved backflow preventers, testing by certified testers, access for surveys, etc., should be addressed in the enforcement document. How to conduct a survey or installation clearances should be addressed in the written program plan or SOP manual.
AHJs need to establish legal authority to implement a CCCP because the program may impact individual customers directly and significantly, and may not impact all water system customers equally.
Element 2 : Public Education
A CCCP’s success may depend on the customer’s understanding of the public health concerns presented by cross-connections. Most people dislike being told what to do without being given the reasons why; an educated customer will usually be a more compliant customer. Fewer customers would connect potentially hazardous plumbing fixtures or other equipment to their drinking water systems if they knew doing so could contaminate their drinking water.
AHJs should tailor their public education programs to the customers served. As a minimum, the AHJ’s public education program should include an explanation of the:
Water purveyor’s responsibility to protect public health by preventing contamination of the public water system.
Health risks posed by actual or potential cross-connection hazards.
Customer’s responsibility to prevent contaminants (from their plumbing system) from entering the public water system.
Regulatory requirements regarding cross-connection control (provincial/territorial and/or health authority) the purveyor must comply with.
The AHJ’s policies and procedures relating to cross-connection control.
Distributing Public Education Information
The following entities should receive public education information regarding the CCCP:
• Suppliers (home improvement stores, pipe, plumbing and supply companies)
• Water system staff
• Organizations, groups, agencies, and departments affected by this program, including municipal plumbing inspectors.
• Industrial, commercial and residential customers
The public education information can be distributed in a variety of formats, including the following:
• Presentations to civic groups and organizations
• Utility bill stuffers
• Newspaper articles or advertisements
• Displays at malls, fairs, trade shows, etc.
• Special training sessions for water system personnel, fire and plumbing officials, public health officials and inspectors, engineers, contractors and meter readers
• ‘Lunch and Learn’ seminars for large industry personnel (e.g., hospitals, manufacturing facilities)
• Educational on line videos
• Websites and social media
The AHJ should ensure that the person answering their phones knows where and to whom calls regarding cross-connections must go. Whoever is assisting customers or the general public with their questions and concerns must be knowledgeable.
Element 3: Tester Training, Certification and Licensing
Certification
Basic to any AHJ’s CCCP is the requirement that personnel engaged in testing backflow preventers are adequately trained and certified. Education and certification of such personnel normally falls into two categories:
■ Program managers, cross-connection inspectors or surveyors
■ Backflow prevention device testers (aka testers)
It is ultimately the AHJ’s responsibility to establish education and certification requirements of those working within the AHJ’s area. At a minimum, the AHJ should require that tester certification through a Canadian Section of the American Water Works Association (AWWA) be mandatory for those testing backflow preventers.
Licensing
To track and monitor certified testers, the AHJ will typically require that testers be licensed before they can test in their area of jurisdiction. To get licensed, the tester must provide documentation of their certification credenti als. Licensing ensures that all testers in an area are adequately trained, certified and using appropriate calibrated equipment. The AHJ should also require certified testers to provide documentation that their test equipment is accurate i.e. a current calibration report (as per CSA requirements).
See Element 7 below for more information on testing programs and Chapter 7 for more information on testing & test equipment.
Note: Canadian Sections of the AWWA administer a tester certification program with national reciprocity. This certification program promotes the development of adequate and consistent cross-connection control training programs throughout Canada. See Appendix B for more details.
Element 4: Purveyor Employee Training
One staff member should be delegated the responsibility for organizing and carrying out the cross-connection control program. This person should have related work experience such as a waterworks operator, plumber or plumbing inspector and have specific training through recognized courses and seminars in cross-connection control. For large systems, additional personnel should receive training in cross-connection control to provide:
■ Assistance in surveying facilities (two-person teams work better for surveying a facility with complex plumbing or confined spaces).
■ Continuity in the program to accommodate personnel changes.
■ Information about potential cross-connections from other water system work groups (e.g. information from meter readers about lawn irrigation systems or violations noted by public health inspectors).
For small systems, additional assistance may be obtained from:
■ Qualified personnel in nearby water systems with cross-connection control programs.
■ Cross-connection inspectors (surveyors) or specialists (test ers) acting as consultants that provide program development and implementation services to AHJs (such as hazard assessment surveys).
Element 5: Hazard Assessments or Surveys
Existing Facilities
Older plumbing systems found in many existing facilities tend to pose greater cross-connection risks. Therefore, retrofitting of existing plumbing will sometimes be required. Unprotected cross-connections within a facility can constitute a health hazard, regardless of the age of the facility or the existence of any previous policies.
When surveying existing facilities:
■ Compile a list of all existing facilities (both purveyor-owned and customer-owned) and categorize them by suspected degree of hazard and hydraulic condition. The list should be prioritized according to health risk, beginning with the highest risk categories. See the Hazard Classification Guide in Chapter 6, Table 6.2.
■ Establish and prioritize a list for the initial survey and periodic repeat surveys of facilities. Include the list in the AHJ’s written program plan. Follow the list, except in circumstances that require a special survey of a facility, such as a response to a water quality complaint or a backflow incident.
■ Initiate a survey by setting up an appointment to meet the owner or owner representative of the facility to be surveyed. Explain the customer’s responsibility to protect the public water supply, the AHJ’s conditions for service and the applicable local regulations. Request that the customer or maintenance person familiar with the plumbing system accompany the AHJ’s staff.,
■ Explain to the customer that the AHJ must protect the public water system from contamination. Clarify that the purpose of the survey is to assess the overall risk to the water system and not to perform a complete plumbing inspection.
■ Locate cross-connections and explain the AHJ’s concern about the potential health risk. Take photographs and notes to document all protected and unprotected cross-connections so they are easily located in subsequent surveys.
■ Complete a survey report form (see Appendix G) and provide a copy to the customer as soon as possible. The survey report should state the following:
– Assessed hazard
– Reason for the assessed hazard
– Required backflow protection (type of backflow preventer) to protect the public water system
– Where to install the backflow preventer, for example, at the meter (premises isolation) or at the fixture (individual protection) if required under the AHJ’s cross-connection control program
The survey report should include a copy of the AHJ’s installation standards and provide a resource for a list of approved backflow preventers.
New Construction and Renovations
Including the AHJ in the building plan review process can be very beneficial in addressing backflow protection for both new and existing services. By reviewing plans at the time of new construction, renovations, fire sprinkler upgrades or water service upgrades, the AHJ can identify and stipulate the needed backflow protection before construction is completed.
For new construction and renovations:
■ All applications for new services and resizing existing services should be routed through a staff member trained in cross-connection control.
■ The piping and mechanical plans (and the plumbing fixture schedule if attached) should be checked for actual and potential cross-connections and appropriate backflow protection.
■ When reviewing the plans for cross-connections, reference your requirements and any additional applicable publications, such as the plumbing code.
■ Once the plans have been reviewed, list the hazards found including potential cross-connections and the backflow protection required. Irrigation systems may not appear on the building plans, so be sure to ask.
■ The location and type of backflow preventers required by the AHJ to protect the public water system should be noted on the final plans before the plans are approved.
– If the AHJ accepts backflow preventers within the customer’s premises in lieu of premises isolation, or as a condition of accepting a lesser degree of backflow protection for premises isolation, those backflow preventers should be clearly identified.
– The AHJ should state that the plan approval does not relieve the customer of the responsibility to comply with the requirements of other agencies having jurisd iction. This could include a requirement to install additional backflow preventers or make other modifications deemed necessary in the final survey of the facilities prior to providing water service. If changes in the customer’s water use increase the degree of risk to the AHJ, additional backflow protection may be required.
■ It is important that the AHJ provide the customer with the following information:
– Thermal expansion information when premises isolation is required (to be noted on the plans)
– Clear guidelines on the type of backflow preventer or method required
– The AHJ’s installation standards for backflow preventers and test requirements
Water service to the premises should not be turned on until the customer complies with all of the AHJ’s cross-connection control requirements. The AHJ may provide water service on a provisional basis to allow a certified tester to satisfactorily test all testable backflow preventers protecting the public water system.
Element 6 : Installation of Approved Backflow Preventers
The AHJ’s enforcement document should require the installation of approved backflow preventers to protect the public water system. Chapter 4 discusses approved backflow preventers in more detail.
AHJs need to decide whether the installation and ownership of backflow preventers is the responsibility of the customer or the AHJ. Typically, the customer is responsible for installing and maintaining backflow preventers that protect the public water system.
AHJs should adopt installation standards such as those found in Chapter 6. In Canada, backflow preventers must be approved by the Canadian Standards Association (CSA) or meet their standards. A list of approved backflow preventers can be found on the CSA’s website.
Element 7: Backflow Preventer Testing Program
The regular testing of backflow preventers is one of the most important aspects of a CCCP. The purpose of testing is to ensure that the backflow preventer is operating properly to prevent backflow. The AHJ’s testing program requirements should include the following:
■ All backflow preventers required by the AHJ to protect the AHJ’s public water system should be tested by certified testers at the following intervals:
– upon installation,
– after repair or re-location,
– annually thereafter, and/or
– as required by the AHJ.
■ All approved air gaps required by the AHJ to protect the public water system should be inspected a minimum of annually. Air gaps are easy to alter.
■ The testing of backflow preventers and the inspection of air gaps should be:
– performed by Canadian AWWA-certifled testers, and
– submitted to the AHJ on a report form provided by, or acceptable to the AHJ.
■ When the AHJ receives the test report, the test results should be reviewed by a person knowledgeable in cross-connection control. The review should include the following:
– The information on the report should be compared to previous test results.
– Any discrepancies should be queried by the AHJ and appropriate follow-up action taken.
– When the field test report shows that a backflow preventer has failed, the AHJ shall require that the device be taken out of service, repaired or replaced, and returned to service.
■ Testers should submit written verification of the accuracy of their test kits to the AHJ annually. Verification should be done in a manner acceptable to the AHJ.
Testing Program Approaches
There are two approaches for implementing a testing program:
• AHJ contracts out the testing
• Customer contracts out the testing
AHJ-Contracted Testing Programs
A number of AHJs hire independent testers to conduct backflow preventer tests that protect the public water system. A contracted testing program offers the advantage of dramatically increasing the percentage of devices tested annually and theoretically results in greater protection for the public water system.
Contracted programs reduce the “hassle factor” for customers since they are relieved of the burden of scheduling tests. In addition, a significant amount of time and money may be saved by both customer and AHJ.
AHJs who plan to implement a contracted testing program should consider:
■ Possible liabilities involved with the testing of private backflow preventers.
■ Understanding that the customer is still paying for the test-the cost is usually added to the customer’s water bill.
■ Testers may oppose contract programs since it may adversely impact their business.
■ Understanding that a hired contractor is representing the AHJ.
Customer-Contracted Testing Programs
With this more common testing program, the AHJ sends out notices to customers requiring backflow prevention device testing. This places the responsibility for the backflow test onto the customer, eliminating the possible liability issues that exist with the contracted program.
AHJs who plan to implement this more common testing program should consider:
■ More of the AHJ’s time and money may be spent sending out notices and following up to make sure tests or repairs are completed.
■ The compliance rate for annual testing may be lower.
Remember that all customers must be treated in an equitable manner for either the AHJ or customer contracted testing programs.
Element 8: Testing Quality Assurance/Quality Control Program
AHJs should develop a quality assurance/quality control program for the testing of backflow preventers that protect the public water system. This program should:
■ Ensure backflow tests are completed and reports are submitted by certified testers.
■ Ensure the type of test kit used is acceptable to the AHJ and that the test kit has been verified for accuracy within the last year i.e. calibrated/re-calibrated.
■ Specify the minimum content of test reports.
■ Establish procedures for reviewing test reports.
■ Establish a timeframe for submitting the completed test reports to the AHJ.
A person with the training to assess test report details may be able to identify critical information, such as:
– When a backflow preventer is wearing out and needs to be repaired or replaced.
– If the tester improperly tested the device or falsified the test results.
– When a backflow preventer was replaced without receiving a test report.
Most AHJs maintain much of this tester quality assurance information in their CCCP databases.
Program managers who have this tester information readily available can more effectively and efficiently administer their CCCPs. For example, some systems enter the certification numbers for each tester into their databases so that any test reports submitted by non-certified testers will automatically be rejected. The person managing the AHJ’s program should have the training and experience to review test reports for quality assurance purposes.
Element 9: Backflow Incident Response Plan
AHJs need to be aware that water quality complaints may indicate that a backflow incident has occurred. The AHJ should develop policies and procedures to ensure that personnel trained in water quality and cross-connection control are:
■ immediately notified of a possible backflow incident;
■ and available to respond in a timely manner.
In the event of a possible or suspected backflow incident, the following general steps should be taken:
■ Obtain as much information about the location and type of complaint as possible.
■ AHJ’s field staff visits site to investigate cause and extent of problem.
■ Identify and isolate potential sources of the contaminant.
■ Collect samples for on-site analysis and laboratory analysis.
■ Determ ine and notify affected customers. Determine if public notification is required.
■ Notify administrative authority such as public health authorities and building officials.
■ Take corrective action, such as flushing and disinfection, to restore water quality in the affected parts of the public water system. (Note: Flushing may not remove all contaminants.)
■ Re-sample to ensure that the contaminant has been removed.
■ Take steps to prevent future contamination (e.g., require installation of an appropriate backflow preventer).
■ Complete a backflow incident report form (see Appendix H for example form) and submit to the appropriate authorities.
A written procedure for responding to a backflow incident should be developed as part of the AHJ’s emergency response plan. This helps ensure that a plan is already in place when a backflow incident occurs. An AHJ’s failure to have a plan and respond to a backflow incident may:
■ significantly increase the number of person’s exposed to a health hazard;
■ increase the AHJ’s efforts (costs) to contain a contaminant and remove the contaminant from the public water system; and
■ expose the AHJ to increased liability from a claim for punitive damages due to negligence.
Note: Each backflow incident is different, and the AHJ may need to adjust these steps as appropriate. Several of the steps are performed concurrently.
The AHJ should require the affected customer to test their backflow assemblies following any backflow incident.
Element 10: Enforcement Procedures
When the AHJ provides well designed public education material on cross-connection control to customers, many customers will voluntarily comply with the requirements. For non-complying customers, the AHJ should anticipate the need to take some form of corrective or enforcement action.
AHJs should be proactive and establish their enforcement policies before any enforcement action is required. The AHJ’s management staff and legal counsel should be involved in establishing the enforcement policy. The policy lays out in detail the enforcement procedures to be followed by the cross-connection control program manager.
The AHJ’s enforcement procedures should address:
■ The number of subsequent notices to be sent (after the initial notice) before the AHJ takes an enforcement action.
■ The compliance time interval between notices.
■ Use of registered mail for subsequent or final notices.
■ The wording of notices (e.g., a polite reminder for the first notice, a firm reminder for the second notice (if used) and an ultimatum for the final notice).
■ Which enforcement procedure to take for the various assessed degrees of hazard.
Figure 8.2 illustrates a possible sequence of notices that an AHJ might take. The actual number of notices and the interval between them will vary depending on the AHJ.
AHJs need to be aware that the failure of a backflow preventer to pass the initial or annual field test doesn’t establish for certain that the device will fail to prevent backflow. Failure may only indicate that the desired level of reliability is not present. When laying out enforcement procedures, AHJs should make the enforcement action appropriate for the degree of hazard.
Terminating the supply of water to a customer may cause a health hazard, a safety hazard and/or a financial loss. AHJs should have enforcement tools other than water termination available, such as installing or testing the backflow preventer and billing the customer.
Element 1 1 : Written Procedures and Program Plan
A written plan is imperative for a successful CCCP because it addresses all aspects of the program and helps to maintain consistency during events such as staff turnover or when there are enforcement issues.
The following administrative procedures should be developed and reviewed by the water system’s legal department and all affected participants within the system. The procedures must align with any provincial or territorial regulations.
■ Determine which department the AHJ will select to carry out the CCCP (water quality, engineering, building or plumbing inspections, operations, etc.). Assign overall program management coordination and administration to one staff member within that department.
■ Establish a relationship between the other departments. Also, establish relationships with outside departments or agencies, such as the local plumbing or health departments and other jurisdictions or administrative authorities. Establish procedures to resolve any conflicts that may arise between jurisdictions.
■ Establish written administrative procedures to document the above.
■ Establish written administrative procedures concerning the:
– Priority for surveying existing premises and the periodic repeat survey of premises.
– Enforcement action for the failure to comply with the bylaw.
– qualifications for certified testers and cross-connection surveyors submitting reports to the AHJ.
– Guidelines to be followed for the appropriate selection, installation, maintenance, and testing of backflow preventers according to the CSA 864. 1 0 Series.
To maintain credibility, the AHJ should be prepared and committed to following through with any enforcement actions communicated to a customer.
Safety
Cross-connection surveyors and backtlow prevention device testers perform their work on active construction sites, in trenches, vaults, high-rise buildings and tunnels. They are exposed to the energy forces of electricity, water pressure, heat, steam, and hydraulic lines. They may come in contact with toxic substances, explosive atmospheres and areas lacking oxygen. Often, they are in an unfamiliar setting with hazards unique to a particular industry or facility. In other cases, they may be exposed to
vermin such as rats or mice, other feral animals, and insects. In some areas of the country, crossconnection surveyors and testers may work in areas that may have active infestations of bed bugs, ants, termites, cockroaches and others. It is vital to be aware of your surroundings and be educated on ways to mitigate unwanted exposure to these types of pests.
The responsibility for safety rests on the shoulders of the individual person. Each individual must make use of available safety programs and equipment but, most importantly, have a personal awareness and attitude to protect themselves against injury at all times.
It is essential that personnel obtain the understanding, knowledge and skills (and certification, if required by the AHJ) necessary for the safe performance of their duties. WHMIS and MSDS awareness, container and piping labeling, lock-out tag-out procedures, CPR, first aid, and confined-space regulations should all be included as training for personnel involved in the cross-connection control program.
Prior to entering a facility to perform a survey or test a backtlow preventer, the on-site safety officer should be consulted for safety procedures specific to the facility or industry.
Thermal expansion is another safety concern in the backtlow industry. When a backtlow preventer is required for premises isolation, a closed plumbing system has been created. All liquids and gases expand when heated. When they expand, pressure increases. If proper thermal expansion protection has not been installed as required in the plumbing code, the potential for the pressure to find a weak link in the plumbing system (i.e., causing the water heater to leak or rupture) becomes an increased risk. Where premises isolation has been required, AHJs should notify all customers of the potential for thermal expansion.
Additional detailed safety information is presented in Chapter 6.
Summary
A cross-connection control and backflow prevention program must be developed, implemented and maintained. Implementing the 1 1 elements presented in this chapter will help ensure a robust program that protects the public water system and public
health. Starting or restarting a program can be expensive and may cause the AHJ to lose credibility. Points to remember:
■ Be consistent and fair.
■ Follow up in a timely manner.
■ Have an active public education program.
■ Involve the decision makers.
■ Train several people to ensure there are always knowledgeable personnel available.
