Complex water piping systems—by nature—lend themselves to cross-connection hazards. Facilities, as businesses with employees on-site, have a responsibility to provide clean, uncontaminated drinking water under OSHA 1910.141. To successfully protect drinking water, facilities must take a multi-faceted approach. That approach should always include cross-connection control: understanding what hazards exist in your facility and how to address them.
Is There a Cross-Connection Hazard in Your Facility?
How to Know and What to Do About It
Cross-Connection Hazards Facing Facilities
Facility water systems might include potable cold water, process hot water, product water, condenser water, process cooling water, and more. When you consider whether your facility has unknown hazards and whether you need to conduct a cross-connection survey, ask questions like:
- Do we know where all shut-off valves are located and what they shut-off?
- Could recent renovations have created any unprotected cross-connections?
- Are all process water systems properly isolated from potable water?
- Could our staff quickly and effectively respond to a backflow contamination event?
Cross-connection hazards crop up regardless of facility purpose or industry, from renovations or expansions, and in equipment of all kinds connected to water systems. We find cross-connections in every facility we survey—usually high-hazard connections that could result in serious health and safety concerns. Across industries, these hazards include cross-connections with:
- Product water; clean-in-place (CIP) systems (Food & Beverage)
- Purified water; chemical feed systems (Pharmaceutical)
- Process cooling systems; equipment using chemicals (Manufacturing)
- Starch systems and machines; process water systems (Pulp & Paper)
The Surveying Solution
Cross-connection control surveys provide an avenue to gather water system knowledge, develop response plans, and, ultimately, find hazards so you can address them and prevent contamination.
Surveys are more than practical, too. Often, your municipal water supplier requires some form of survey and reporting to protect the greater distribution system from backflow.
What & How
These cross-connection surveys identify:
- All existing testable and non-testable backflow preventers, including their location, use, and compliance status
- “Containment” status with the public water system, including backflow prevention details at the service connection(s)
- Locations where corrective action is required (i.e., missing, incorrect, or improperly installed backflow prevention)
How do you find these issues and record them? It starts with an understanding of applicable regulations at the federal, state, and local level, as well as plumbing codes that dictate what type of backflow prevention is needed and where. Next, obtain architectural background drawings or floor plans to guide your survey efforts. Review any legacy pipe drawings and existing backflow test records to get a picture of what you already know and where knowledge gaps exist.
Ahead of the actual on-site work, make sure you plan for locked or sensitive areas. You need to survey the entire piping system across the facility to get a complete picture of hazards and deficiencies. Finally, visually trace the pipes from the service connection(s) with the city water service and survey room by room, documenting all cross-connections and backflow prevention.
Correction & Protection
The most common cross-connection hazards surveys uncover in facilities include:
- Missing backflow prevention on hose connections
- Process water systems (e.g., boilers, chillers, cooling towers) with inadequate backflow prevention
- Potable water fixtures (e.g., eyewashes, emergency showers, water coolers) plumbed to non-potable piping systems
- Incorrect pipe labeling
- Inconsistent zone isolation
Every hazard can (and should) be categorized as high, medium, or low. This categorization helps you prioritize deficiencies, deadlines, and budget. For any given facility, that categorization might look something like:
- High hazard: Unprotected cross-connections between the potable water system and process water, waste water, or equipment using chemicals
- Medium hazard: Insufficient or minimal pipe labeling
- Low hazard: Missing backflow prevention on beverage equipment
Piloting a Policy
Many facilities develop a policy to guide cross-connection control activities, often as part of a greater water management program. A policy might include regulation and code citations; directives on recordkeeping, certifications, and credentialing; and emergency response plans.
Your policy should also cover cross-connection surveys—including frequency, surveyor qualifications, the method of data collection, and a system for deficiency prioritization. Some facilities take these efforts a step further and develop comprehensive piping schematics with a schedule for regular updates.
Finally, any cross-connection control policy should cover approved backflow preventers and testing requirements. The policy might require a current inventory of backflow preventers, set the timeline to repair and retest failed assemblies, outline how records are maintained and submitted to the authority having jurisdiction (AHJ), and specify certified tester requirements.
Proactively implementing a policy and conducting surveys keeps you ahead of the curve, protecting people and product as well as your business.
Ready to learn more about how HydroCorp can support your facility’s cross-connection control, water management, and piping documentation efforts?
