“The state hasn’t about our cross-connection control program.” While that may sound reassuring, don’t confuse lack of state enforcement with evidence that a program is complete, current, or actively reducing risk.
State Enforcement (or the Lack Thereof)
Cross-connection control regulations vary significantly from state to state. Some agencies have detailed requirements, dedicated staff, and annual reporting to guide and validate compliance, and frequent oversight. Others face limited resources and must prioritize drinking water responsibilities beyond cross-connection control. The result is that the level of enforcement—and how often the state identifies cross-connection control program deficiencies—can vary just as much as the regulations themselves.
Unfortunately, some utilities begin to view the absence of enforcement as proof that everything is fine. But it’s not.
Cross-Connection Control Programs:
The Essentials Guide
Addressing More than Compliance
Utilities with the strongest cross-connection control programs don’t wait for a sanitary survey warning or violation before taking action. They continually evaluate their program, adjusting activity based on the presence of potential cross-connections, conducting field surveys for hazard assessments, monitoring local corrective actions of non-compliant building owners, and verifying that protection matches actual risk. These utilities recognize that protecting public health is an ongoing operational responsibility, not something that happens only when the EPA-mandated sanitary survey occurs.
State enforcement plays an important role in ensuring accountability, but it was never intended to be the primary driver of a utility’s cross-connection control program. Regulators simply cannot be everywhere, and the absence of a citation should never be mistaken for the absence of risk.
A Better Question for Every Public Water System
Rather than ask what your utility can get by with (and without), consider: If the state didn’t inspect your cross-connection control program for another five years, would you still be confident that you’re protecting your drinking water system today?
Utilities that can confidently answer “yes” have moved beyond simply preparing for sanitary surveys. They’ve built programs focused on continuously identifying and reducing risk before it becomes a violation, or worse, results in a contamination incident.
Ultimately, the goal of public water system cross-connection control isn’t to avoid an enforcement letter from the state. It’s to prevent contaminated water from reaching the public water supply and harming members of the community. That happens when utilities choose to be proactive, not because they’re required to, but because protecting public health demands it.
