Once while conducting an ordinance writing course, I asked each person to stand if they were responsible for a cross-connection control program. About half of the thirty plus people stood up. I then asked each person, what percentage of your time is actually involved with supervising your program? A few individuals indicated that running their program took one hundred and ten percent of their time. There was a regulatory official from the state in the classroom and we were both shocked to hear that most individuals claimed that only ten to twenty-five percent of their time was devoted to their cross-connection control programs. My experience has been much different.
In 1982, I was asked to take on the responsibility of a cross-connection control supervisor for the local utility company. Being naive and knowing that a small promotion plus a new pickup truck were part of the deal, I said yes. I had worked in government most of my life so I was not prepared for the enormous amount of work involved with managing a cross-connection control program.
Decisions I had to make at that time are the same ones an effective program manager will have to make today:
- Who will INSTALL backflow prevention assemblies?
- Who will TEST backflow prevention assemblies (utility personnel, private contractors, or both)?
- Who will REPAIR backflow prevention assemblies?
- Must testers be CERTIFIED?
- What TYPE OF PROTECTION will be required for health vs. non-health hazards?
- Which TYPE OF BACKFLOW PREVENTION ASSEMBLY will be used at each hazard location?
- What RECORDS will be kept on each backflow preventer?
- What SPECIFICATIONS and STANDARDS will be used to delineate an “approved” assembly?
- How will TRAINING be provided to employees and customers?
- Which employees will receive training?
- What timetable will be established for completing the survey and retrofit program?
- How will the SURVEY and RETROFIT PROGRAM will be conducted?(1)
- If your city is small (less than one thousand metered customers) it is conceivable that you, as the cross-connection control supervisor, also serve as the public works director and you may share the same office with the police chief.
- If you work in a larger city you should be too busy running the cross-connection control program to take on any additional duties. To do your job effectively you will be a very busy person and you will need some help. If your system is large enough (50,000 metered customers or more), you should be able to justify a administrative clerk, an inspector, and a couple of backflow technicians
Lets take a closer look at some of the items you will be responsible for:
Preparing a written ordinance or service contract if you do not have a program in place. If you already have a written ordinance or service contract you will need to review this document to determine if it is current and does not conflict with other ordinances, policies, or plumbing codes. You must determine if your ordinance or service contract contains all of the elements of your state’s drinking water regulations. Remember that your ordinance can be stronger than your state’s regulations but never weaker. Your ordinance can also be stronger than your adopted minimum plumbing code.
Reviewing the plans for new construction. The developer, architect, engineer, etc. of any new construction must be informed of your utility’s requirements concerning backflow protection.
Accessing plumbing permits, building permits, and zoning changes. Single-family houses are often converted to professional offices. These changes can not occur without a change of zoning. Any new construction on existing structures normally requires a building or plumbing permit.
Testing new installations of backflow prevention assemblies. You should be informed of every new water meter that is installed in your system.
Annual testing of backflow prevention assemblies and devices. Whether your utility employees or the local contractors perform the tests, you are responsible for insuring that the tests are performed accurately and on time. How will you make sure that the customers are not being taken advantage of by a dishonest tester? Remember, that beauty shop owner could be a city commissioner.
Deciding who is eligible to repair backflow prevention assemblies. You will decide what type of training and how much training will be required. You should stay in constant contact with your contractors. You must insist that they repair assemblies not just replace them.
Remaining visible in the community. You must be seen in your vehicle “making the rounds.” Contractors need to know that you do not just sit behind a desk in an office.
Keeping records of all backflow assemblies and devices in your system. If you work for the utility company, you may be responsible only for those assemblies installed on service connections. If you work for the building or plumbing inspection department, you are responsible for all backflow preventers past the point of service.
Inspecting each building built before you started your program. You should inspect each building for cross-connections and you will find many cross-connections. You will decide how to accomplish this monumental task, how many inspectors you will need, and where they can get training. You will have to decide which customers are the most hazardous to your system.
Deciding which individuals should receive training other than the inspectors. You will decide how much training and where will they receive the training.
Deciding how you will generate funds to operate your program. One possibility is to require a permit fee for the installation, testing, or repair of the backflow preventer.
Educating your customers.
This involves making contact with each customer. You can utilize:
- face to face contact,
- letters,
- bill stuffers,
- door knob hangers, and
- advertisements in the local newspaper.
You must inform each customer who has a backflow preventer installed on their service about the hazards of thermal expansion.
Generating a written plan for emergency procedures. This will involve contacting all individuals who be part of the emergency team and brief them on their duties.
Maintaining credibility. You must clean up your own backyard first. Inspect your utility company’s properties and have the appropriate backflow prevention assembly installed. Your utility company must comply with your ordinance, policy or service contract before you can ask your customers to install backflow preventers. Do not forget to inspect your water plant.
Finding help to run your program. Here are a few people who can help you.
Utility personnel involved with water services.Individual(s) who accept applications for new services.
- Contractors:
- plumbing and pipefitting,
- fire protection,
- lawn irrigation,
- mechanical (HVAC), utility, etc.
- Engineers: civil, mechanical, fire sprinkler, etc.
- Health officials
- Plumbing inspectors: city, county, state, federal, etc.
- Utility inspectors
- Code enforcement officials
- Customers
Suggestion:
You should make friends with all of these people. You will be busy visiting with each of these groups, explaining your program and enlisting their help.
If you are able to accomplish all of the above tasks and still have time for lunch, there is still no guarantee that you will not have a cross-connection incident in your community. After all, you can’t be everywhere at once. Your best bet is to accomplish as much as possible and to document everything that you do. You want to be prepared for the day that you may have to defend your program to a judge. If you have done your job effectively, you can hold you head high and be proud that you have done everything in your power to protect the health and welfare of your customers.
