Cross-connections crop up in South Carolina, just like everywhere else. And state law and regulations mandate the elimination or protection of those cross-connections. Public water systems must be prepared to demonstrate compliance with a comprehensive cross-connection control program.
South Carolina Cross-Connection Control Compliance:
What Regulators Expect & How to Prepare
South Carolina’s Cross-Connection Control Landscape
The Department of Environmental Services (DES) issues the regulations that guide public water system operations and conduct the sanitary surveys that verify compliance. For our purposes, we need to discuss what South Carolina regulations cover cross-connection control and what they entail.
State Regulations 101
DES Regulation 61-58.7 governs cross-connection control in the state and requires, at a minimum, a viable cross-connection control program that:
- Locates and eliminates unprotected cross-connections
- Maintains records of backflow prevention assembly locations, types, sizes, and test results
- Prohibits the creation of unprotected cross-connections
The regulation itself doesn’t specify many details around program activities for each public water system. Many of the specifics—especially regarding the types of backflow prevention required and testing frequencies—are outlined in the International Plumbing Code (IPC) which South Carolina has adopted. Cross-connection control is additionally required under the state’s Safe Drinking Water Act, meaning it’s provisioned under both law and DES regulation.
The most important takeaway: You need a tailored cross-connection control plan and program for your water system. Every water system is unique, with varied customers, different high-hazard connections, and distinct environmental factors.
What DES Evaluates
The DES looks for program viability, as specified in R61-58.7. This includes elements like:
- A written cross-connection control plan
- Enforcement authority (established by local ordinance)
- Consistent documentation
- On-site surveys
- Evidence of non-compliance follow-through
Your written plan establishes the policies and procedures for cross-connection control activities within your public water system. Align your plan with the IPC: For example, all backflow preventers need to be “accessible.” What does that mean? That’s for you to specify in your written plan and city ordinance. Testers and technicians will reach out to you to confirm the proper backflow prevention for different scenarios, proper installation, and more. Have that documentation ready ahead of time to support compliance and program activity.
Sanitary Surveys
Today, the DES increasingly enforces cross-connection control requirements. Sanitary surveys are the primary compliance checkpoint for public water systems by the state—these occur at least every three years. Note: If previous inspectors haven’t asked about your cross-connection control program before, they will now. DES has implemented new initial and continuous education for sanitary surveyors that includes backflow testing, cross-connection control, and more.
So, what do sanitary surveyors look for? You can expect questions around how many connections (residential and non-residential) you have in your system and how many backflow prevention assemblies you’re tracking. The question at its root: Do you have an accurate inventory of backflow preventers in your system, can you effectively manage and track their testing, and are you conducting surveys to maintain up-to-date data? DES is essentially looking for evidence of consistency, documentation, follow-through, and enforcement.
Getting into Compliance
If your program isn’t up to snuff, don’t fret. DES can help you take steps before enforcement occurs, providing a timeline with milestones to steer you toward compliance. “We don’t expect you to go from no program to a complete program in 90 days,” explains Steve Fox, the cross-connection control program coordinator at DES.
If you’re worried about compliance at your next sanitary survey, be proactive! Reach out to DES to get support in implementing a compliant program ahead of time. You can’t stop enforcement steps if you wait to get started and don’t take advantage of the resources the state provides.
Building a Successful Program
In a successful cross-connection control program, your utility should be regularly identifying issues, documenting and tracking them for follow-up, and, ultimately, correcting them. Documentation, in addition to keeping you on track with program activities, allows you to prove the efficacy of your program during sanitary surveys. Make sure these records are accessible and current so you have true visibility into your system. Enforcement actions should be consistently applied in a way that aligns with your written plan and ordinance.
Cross-connection control and compliance with South Carolina regulations doesn’t need to be complex. Small steps, taken consistently lead you down a path of protection and regulatory compliance.
Ready to learn more about how HydroCorp can support your utility’s cross-connection control program?
