Cross-connection control plays a critical role in securing public water systems, yet no federal regulation mandates a cross-connection control program. Instead, each state determines its own requirements and enforcement protocols. As a result, sanitary survey processes and cross-connection control standards can vary significantly from state to state.
Sanitary surveys, conducted by state regulatory officials, are essential evaluations of a public water system’s ability to provide safe drinking water. These surveys, in addition to other key elements, may focus on cross-connection control. Sections 12.1 and 12.2 of the 2019 EPA Sanitary Survey Field Reference Guide specifically relate to cross-connection control and backflow prevention, including:
- A written program
- Identification of significant deficiencies related to cross-connections.
These sections highlight the need for public water systems to maintain robust and enforceable cross-connection control programs to prevent contamination risks. State officials conducting sanitary surveys may use this guide as a standard reference.
A Written Program
Section 12.1: Does the Water System Have a Written Cross-Connection Control Program?
- Does the public water system have a written cross-connection control program?
- Is the cross-connection control program active and effective in protecting against cross-connections and backflow conditions?
- Does the cross-connection control program address areas of specific concern for cross-connection and backflow in the water system’s service area?
Meeting Section 12.1
A well-structured and enforceable cross-connection control program is the foundation of backflow prevention efforts and the protection of public drinking water. State regulators assessing compliance will evaluate whether a written cross-connection control program is in place and is both active and effective. Specifically, inspectors will look for:
- Active protection against cross-connections and backflow conditions: A cross-connection control program requires active implementation—it’s not just a document on file. This means conducting regular inspections, enforcing testing requirements, and promptly addressing non-compliance.
- Comprehensive coverage of at-risk areas: Certain service areas within a public water system pose higher risks for cross-connections, including industrial and healthcare facilities, agricultural sites, and residential irrigation systems. A complete cross-connection control program should clearly outline strategies to manage each of these risks.
Failure to demonstrate a documented and enforced cross-connection control program can result in non-compliance during sanitary surveys, leading to regulatory action and heightened scrutiny.
Identifying & Documenting Deficiencies
Section 12.2: Possible Significant Deficiencies for Cross-Connections
- Customers with private wells interconnected with premise plumbing.
- Hospitals, extermination businesses, industrial customers, etc., with no testable backflow prevention assemblies.
- Backflow prevention assemblies are not tested, or no surveillance/enforcement program exists for usage and testing requirements (e.g., for home irrigation systems in addition to the usual businesses).
Meeting Section 12.2
Sanitary survey officials categorize cross-connection deficiencies based on the potential for contamination. The EPA Sanitary Survey Field Reference Guide identifies several specific and recurring deficiencies:
- Private wells interconnected with premise plumbing: Some customers within a public water system’s jurisdiction may have private wells that are physically interconnected with their plumbing. Without proper backflow prevention, the public supply is at high risk of contamination.
- High-risk facilities without verified backflow prevention: Certain customers—such as hospitals, extermination businesses, and industrial operations—are at a heightened risk for backflow incidents. If these facilities lack proper backflow prevention assemblies, devices, and methods, they pose a significant threat to water quality due to internal pressure and flow changes and the complexity of their potable water plumbing.
- Lack of testing or enforcement for backflow prevention assemblies: An effective cross-connection control program should require regular testing and maintenance of backflow prevention assemblies, particularly for residential irrigation systems, businesses, and other facilities where backflow risks are prevalent.
Knowing the Standard
The EPA’s 2019 Sanitary Survey Field Reference Guide underscores the importance of cross-connection control in maintaining safe drinking water. While federal regulations do not dictate cross-connection control program requirements, state regulators assess a public water system’s program as part of routine sanitary surveys. A documented, active, and enforceable program—along with vigilant enforcement of backflow prevention requirements—ensures compliance and, most importantly, safeguards public health.
For public water system operators, staying ahead of potential deficiencies by proactively addressing cross-connection control vulnerabilities is the key to passing sanitary surveys and upholding water system integrity. Always consult local state regulatory officials for localized sanitary survey procedures and compliance requirements.
Ready to learn more about how HydroCorp can support your public water system’s cross-connection control efforts?
