You drafted your cross-connection control program in line with the California Cross-Connection Control Policy Handbook (CCCPH) and got it approved by the State Water Resources Control Board. What’s next? How do you get from an approved plan to a functioning and compliant program?
From Plan to Practice:
Implementing Your California Cross-Connection Control Program
Assessment & Activation
The first step in implementing a CCCPH-compliant program is to assess the current status of any existing cross-connection control activities and the data you have for each service connection. A complete compliance record should include:
- A record of the two most recent hazard assessments and any findings
- Inventory of backflow prevention assemblies, including hazard, location, type, manufacturer, model, size, installation date, and serial number
- A record of backflow preventer performance history, including previous test results and any repair, replacement, or relocation
- Customer contact information and program communications, including notice dates, testing schedules, enforcement actions, and corrected hazards
Meeting the Admin Burden
Utilities often miss the administrative aspects of cross-connection control when planning and assigning resources to their program. While on-site activities carry many demands that are obvious from the planning stage, administration—from notices to approvals to reporting—hides in plain sight.
- Legal Authority: The California State Water Resources Control Board approved your program plan, but you need to establish the legal authority to implement and execute it. A local ordinance should give your utility the authority to discontinue service; cause installations, inspections, or testing and recover costs; and use other enforcement methods to resolve non-compliance such as fines or fees.
- Public Awareness: Education begins before program activities begin. Provide examples of possible backflow contamination, outline the realistic results of your program, and what they can expect from your utility.
- Notices: Once you have the legal authority and you’ve begun educating your customers, you need to send notices that outline what responsibilities property owners, managers, and tenants have. These notices should reference your ordinance, outline next steps (i.e. scheduling a hazard assessment or calling a licensed plumber to conduct a backflow assembly test), and provide a deadline for action.
- Approvals: Someone needs to review and approve survey and test results for accuracy and move the customer on to the next stage, whether that’s being marked compliant or transitioning to enforcement. The more surveys you complete and tests you receive, the greater the administrative work required.
Emptying the Backlog
How do you prioritize service connections in your community for both safety and compliance? Start with what you know presents the greatest risk of contamination and work your way down:
- Known or suspected high-hazard connections that include auxiliary water, chemical use, or other hazards as outlined in the CCCPH
- Complex commercial or institutional premises with uncertain records, a shift in operations, or a change in ownership
- Low-hazard premises with outdated assessments or unverified devices
- Service connections supported by current, complete assessments and verified protection
As you establish your program, this backlog should decrease, allowing you to maintain complete compliance records and continuously verify protection. On-site hazard assessments aren’t just triggered from a schedule. Your utility also needs to look for cross-connections at properties with new or reconnected service, erroneous or unreliable prior assessments, and account or plumbing changes.
Conducting Hazard Assessments
Before you can start conducting on-site hazard assessments, ensure you have the correct service account information—address, account type (e.g., residential, commercial, industrial), owner or tenant contact(s), and access constraints. You should also gather facility information regarding existing backflow prevention assemblies and their associated test records, on-site hazards and piping systems, and any evidence you need captured.
While on-site, surveyors must answer, at minimum, three questions:
- Are there any actual or potential cross-connections present?
- What is the degree of hazard of the cross-connection(s)?
- Does the existing protection match the hazard?
Enforcement
When your utility discovers hazards, you need to be ready to follow-up—with enforcement notifications and by verifying the correction on-site. That might mean re-inspecting or re-testing and documenting the results. Don’t forget to factor in both the administrative (i.e., notices, scheduling, reviews and approvals) and on-site resources required to close the loop on compliance.
Corrective action notices must:
- Describe the hazardous condition, its location, and why existing protection falls short
- Outline acceptable backflow prevention installation, repair, or testing and the required documentation
- Provide a clear due date in line with adopted procedures and risk level, along with the escalation process and appeal contacts if action is not taken
The enforcement workflow for your utility’s cross-connection control program should mirror other enforcement workflows, such as that for unpaid water bills. Follow a similar escalation process and establish how it works ahead of time with written documentation.
The timeline to compliance will have bumps for at least some of your customers. Maybe they can’t find a contractor to do the work or they’re struggling to meet the deadline. Be accessible, be helpful, and be flexible where possible. And always document any extensions granted.
Checking in on Program Health
You can’t conduct all your hazard assessments at once. You won’t receive all your backflow prevention assembly test results at the same time. How do you know if you’re making progress and whether your program is on the right track?
First, set attainable goals—monthly, quarterly, and annually—that you want to track and measure progress against. These goals should be based on the staffing and resources your utility can devote to cross-connection control. Your goals may not look like those of neighboring utilities.
Measure things like:
- Coverage: How many service connections have you completed hazard assessments for, compared to the number of assessments your utility planned? What does your backlog look like?
- Protection: What are your open, non-compliant cases?
- Testing: How many assemblies are due for testing? How many tests have been completed? And how many assemblies have failed and been repaired and retested, or are still delinquent?
- Program Controls: Are your staff qualified? Do you have a certified cross-connection control specialist either in-house or through a partner? What does outreach look like? Have there been any backflow incidents?
The bottom line: If you’re not finding unprotected cross-connections, that’s a red flag. Finding and correcting cross-connections is the purpose of your program; these discoveries demonstrate your efforts and provide quantifiable results that build community trust and keep you compliant with the CCCPH.
