The sanitary survey: Where does it come from and what does it entail?
Mandated by the EPA at the federal level, state regulatory agencies are responsible for conducting sanitary surveys. But the reporting goes all the way back up to the EPA. By definition, a sanitary survey reviews “the design, operations, maintenance, and management of distribution systems” with an eye toward preventing contamination and ensuring safe drinking water.
Ready to Pass Your Next Sanitary Survey?
How to Defend Your Cross-Connection Control Program
Behind the Sanitary Survey
When we get down to brass tacks, what do sanitary surveyors look at? Sanitary surveys cover the entire breadth of water system operations, with eight topic areas:
- Source water
- Water treatment
- Distribution system
- Finished water storage
- Pumps (including pumping facilities, well houses, and other places where the system is pressurized)
- Monitoring and reporting
- Management and operations
- Operator compliance (including continued education)
For our purposes, we want to talk about where cross-connection control fits into the equation: within the “distribution system” portion of the sanitary survey.
Cross-Connection Control Questions
Often, sanitary surveyors will look for cross-connections in utility-controlled facilities and equipment: Think filtration plants, pump stations, emergency generators, and hydrant connections. These connections are the ones that you, as the utility, control and are responsible for protecting. At public water system facilities, sanitary surveyors may uncover:
- Submerged inlets
- Water pipes tied to chemical feed tanks
- Missing backflow preventers
- Bypasses around backflow preventers
From a larger perspective, a sanitary survey could (but doesn’t necessarily always) investigate all aspects of your utility’s cross-connection control program. Depending on your surveyor, their training, and instructions from the state regulatory body, these cross-connection control questions could start coming up more frequently.
They’ll want to see:
- Identified cross-connections and resolved deficiencies
- Documentation of hazard identification
- Accurate backflow preventer test records
- Evidence of active program oversight
- Enforcement history and follow through
Don’t assume that just because your last sanitary survey didn’t cover cross-connection control, your next survey won’t either. Prepare your program in true alignment with state requirements instead of focusing only on specific questions your utility has previously answered. A proactive approach is one that protects your water system and your compliance status.
Violations
Odds are, your first infraction won’t necessarily be a full-blown violation that results in enforcement from the state. Typically, sanitary surveyors and state officials want to work with public water systems to ensure safety and compliance. But the longer you wait, the higher the risk of a documented violation, as opposed to a warning or advisement.
What triggers enforcement from the state? Gaps in your program, observed cross-connection violations, and missing documentation are the obvious ones. But other factors can play a role:
- Repeat backflow contamination events
- New sanitary surveyors with varied experience, training, or instructions
- Increase in regional enforcement
Preparing Your Program
If your next sanitary survey is right around the corner, how should you prepare? Start by reviewing your program plan and activities against state requirements. Make sure your utility can demonstrate action—to validate service connection inventory and protection status, identify unprotected cross-connections, and enforce compliance.
Prepare documentation around:
- Your cross-connection control program plan
- Your municipal ordinance that provides for enforcement authority
- Inspection forms (if required)
- Backflow test records
Identifying & Addressing Gaps
So, what do you do if your program doesn’t measure up to state regulations? The steps to compliance are simply the steps to a robust and effective cross-connection control program:
- What if your utility has unknown service connections or missing service connection data? Conduct on-site, visual surveys to gather the information you need to effectively protect the distribution system.
- What if your backflow test records are incomplete? Validate and reconcile test records; automate scheduling of test notifications to align with the frequency required by state code.
- What if you don’t have any historical documentation of enforcement? Implement an enforcement workflow that includes a documented notification and shut-off process.
These are just a few examples that help you create a comprehensive program that you can demonstrate with clear, consistent documentation.
A defensible cross-connection control program requires established authority, the right data, and proven processes to find and correct risks. If you’re not surveying, you’re not finding problems. And if you’re not documenting, you can’t enforce or prove that your program is working. A few proactive steps ensure that your community’s drinking water is safe and your utility is ready for your next sanitary survey.
Ready to learn more about how HydroCorp can support safe drinking water and compliant cross-connection control programs?
