Editor’s Note: This article was originally published on October 2, 2024. It has since been updated to reflect current best practices and evolving standards.
Snapshot:
To achieve sanitary survey compliance, public water systems must maintain adequate cross-connection control (AKA strategies that prevent contaminated water from flowing back into the drinking water system). Inspectors often focus on this area during a sanitary survey, making it essential for water systems to be prepared. Below, we highlight common questions about cross-connection control and offer five strategies to help ensure sanitary survey compliance.
Cross-Connection Control Programs: The Essentials
Common Cross-Connection Control Questions for Sanitary Survey Compliance
What questions should you be ready to answer regarding cross-connection control during your sanitary survey? Understanding your program, outlining your processes, and gathering critical data help you prepare with confidence to answer auditors’ questions.
- Does your water system have a cross-connection control program? Inspectors will assess whether your public water system has a formalized cross-connection control program. To achieve sanitary survey compliance, your program must be well-documented, clearly outlining policies and procedures to manage backflow risks.
- Are backflow prevention devices regularly tested and maintained? For sanitary survey compliance, it’s crucial that backflow prevention assemblies are properly installed at high-risk locations and tested regularly (in most states, these assemblies must be tested at least annually). Surveyors will ask for testing records and proof of routine maintenance to ensure the backflow preventers are functioning correctly.
- Do you conduct cross-connection surveys? A thorough cross-connection survey is an important step toward sanitary survey compliance. Inspectors will want to see evidence that your system has been surveyed for potential contamination hazards and that these service connections, particularly high-hazard properties, are re-inspected regularly.
- What efforts are in place to educate your customers on cross-connection risks? Educating customers, especially those with high-risk water uses, is often a part of sanitary survey compliance. Inspectors may look for programs that raise awareness about cross-connection dangers and customer responsibilities for preventing backflow incidents.
- How is cross-connection compliance enforced among your customers? To achieve sanitary survey compliance, a water system must enforce its cross-connection control policies. This can involve requiring customers to install backflow prevention devices and to comply with local testing and maintenance ordinances.
Prepare For and Align Your Program With Regulations
Regardless of the perceived stance or level of enforcement from your state, aligning your cross-connection control program with an adequate budget, support, and activities will help you achieve compliance in your next sanitary survey. Remember: Responding to a backflow contamination event or having to reactively take corrective actions after an audit is far more costly than improving or implementing a comprehensive, proactive, and preventive approach.
5 Steps to Ensure Cross-Connection Control Compliance for Sanitary Surveys
The central elements of a cross-connection control program can keep you compliant. While a comprehensive program covers a wide variety of activities, it doesn’t have to be complex. The key is to stay organized, prioritize well, and keep consistent and accurate documentation–all of which will help when sanitary survey season rolls around again.
- Update or implement a comprehensive cross-connection control program. A written, formal cross-connection control program is the foundation for sanitary survey compliance. The program should outline clear roles and responsibilities, define backflow prevention measures, and establish requirements for routine testing and maintenance of backflow preventers.
- Perform regular cross-connection surveys at set frequencies. Regular, scheduled cross-connection surveys are essential for identifying potential contamination hazards in a water system. Conducting these surveys and keeping service connection data up to date is a critical step toward sanitary survey compliance, ensuring that any risks are identified and corrected.
- Maintain backflow prevention test records. Routine testing and maintenance of backflow preventers are necessary for sanitary survey compliance. Water systems should inform building owners of their mandatory responsibility to provide backflow preventer test results completed by certified professionals, and maintain accurate records of all tests and repairs. This demonstrates compliance with regulatory requirements and ensures the ongoing effectiveness of backflow preventers.
- Educate customers on cross-connection control. A robust customer education program is key to achieving sanitary survey compliance. Providing information on the importance of cross-connection control, backflow prevention device testing, and customer responsibilities helps ensure everyone involved understands their role in maintaining water safety.
- Keep detailed documentation and compliance records. Proper documentation is crucial for sanitary survey compliance. Water systems should maintain detailed records of cross-connection surveys, backflow preventer installations, test results, and maintenance activities. These records will be reviewed during sanitary surveys to verify compliance.
Depending on state scrutiny and existing regulations, cross-connection control may be a central focus for achieving sanitary survey compliance. By preparing for common inspection questions and implementing a comprehensive program, public water systems can safeguard their water supply and meet–or even exceed–requirements. Regular testing, customer education, and meticulous recordkeeping are essential steps to ensuring compliance and preventing contamination.
