Your public water system (PWS) is required by Idaho Code to have a Cross Connection Control Program
in place and to implement and enforce that Program (IDAPA Code 58.01.08.552.06).
Wondering where to start? The material below should provide all you need!
Follow these steps:
1. Establish your Cross Connection Control Program. Have the City Council, HOA Board of Directors, or Administrators of your system officially adopt a Cross Connection Control Policy (CCCP). The most important component of a Cross Connection Control Policy is the ability to enforce annual testing of backflow prevention assemblies. Most PWS choose to do this through termination of water services to those customers that do not comply. IRWA has a CCCP template you may use! This template includes all the state-required elements of a Cross Connection Control Program.
2. Survey your customers. You will need to establish where cross connection risks exist within your drinking water system. Your customers may have potential cross connections on their property that need to be addressed. Identifying those potential risks is crucial to having a successful program. Send out a survey with your monthly bills and request your customers fill it out and return it to you.
3. Perform an inspection of the property. Your Backflow Certified Operators may want to inspect any properties that have potential cross connection risks to establish which type of backflow assembly is required. For very large systems this might be unreasonable; however, addressing small sections of the community each year is a good start. New construction should always be inspected (include this as an element in your CCCP). IRWA recommends using an inspection form to document your inspections.
4. Provide contact information to your residents. If this is a new program for your community, your residents may not know who to contact to install and test backflow prevention assemblies. Providing a list of local plumbers that can perform these services would be helpful to get them started. A quick Google search should pull up installers and testers in your area. Here are a few lists:
5. Require annual testing of backflow assemblies. The most important component of your Cross Connection Control Program is enforcement. As water purveyors, you need to ensure your PWS is protected from backflow incidents that could introduce potentially harmful substances into your drinking water system. After identifying where backflow assemblies are needed at homes and business connected to your drinking water system, you have the authority to require installation and annual testing of those assemblies. IRWA recommends requiring annual testing around the same time each year. An easy way to do this is to send out a testing letter with the monthly water bill and include numbers for local testers. The property owner should submit proof of testing to you.
6. Enforce repercussions for non-compliance. As mentioned above, your Cross Connection Control Program will only be effective if it is enforced. Your CCCP should outline consequences for customers that do not perform annual testing of their backflow assemblies. Your city may need to adopt a Cross Connection Control Ordinance to allow for termination of water services. If your PWS is an HOA or Water Corporation, authority to terminate services may already be written into your by-laws. Perform some research on this matter for liability purposes. Contact IRWA if you need assistance.
7. Document everything. It is a good idea to document what your water system is doing to prevent cross connections and backflow events. This will serve you both in showing you meet regulations and in the case of any liabilities. Remember, backflow can cause serious illness, and in some cases, death. Your PWS will want to show that it has been doing everything possible to prevent such events. Keep records of the annual testing letters you send out, the responses you get, any site investigations you perform, and any hazard assessments you make. It is also a good idea to keep an inventory of cross connection risks within your system. After receiving the survey results (step 2), create an inventory of which properties will require which backflow devices. This can be done in a simple spreadsheet. Here are some helpful documents for your files:
8. Provide information. It never hurts to educate your customers about cross connections and backflow. There is a good chance most of them don’t know what it is and what their responsibilities are as property owners. IRWA can help your water system provide customized brochures, mailers, and handouts that are specific to your CCCP or local code. Feel free to use these pamphlets and handouts in your community: