12VAC5-590-600 Cross connection control program requirements 

D. Instead of annual operational tests (12VAC5-590-600 C) and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), the owner may provide a public education program to residential and commercial consumers whose premise plumbing is not complex and where there are no known or suspected high hazards as identified in Table 630.1. For all other residential consumers, the department may approve a public education program provided by the owner as part of the CCCP.

This statement can be misconstrued and could lead to a dangerous situation.  This could lead an owner to implement a program in which backflow prevention assemblies are not required to be tested annually. All backflow prevention assemblies need to be tested annually! These devices are required to be installed in systems meeting the criteria, so why would it not need to be tested if it is installed? If a device is required, it's required for a reason, and therefore, should be tested to ensure it's working to prevent "the reason".

Evidence has shown these devices fail periodically. A failed device can fail to prevent the cross connection of hazardous conditions into the water system. 

The use of the term "high hazards" in this statement is ambiguous. The table referenced can be interpreted many different ways. Since the types of hazards are not specifically listed in the table, an owner could interpret a specific hazard to be "low", simply to avoid implementing a proper program with record keeping of annual testing of devices. The "public education program" could be used as a loophole for owners who may not have a proper program in place or choose not to implement one.

1. The public education program shall be designed to prompt consumer self-assessments, increase the awareness of cross-connections, and inform the consumer of the public health hazards of backflow.

As someone in the industry for over 20 years, I have never seen such a program. Should such a program be implemented, even in it's most effective method, it should be apparent to any objective party that "consumer self-assements" is an unrealistic ask. If we were to rely on consumers to "do the right thing" then why would any of these regulations even exist? It needs to be up to the owner, not the consumer, to ensure the owner's system and the public's safety is protected from hazards.

For all other residential consumers, the department may approve a public education program provided by the owner as part of the CCCP.

I don't understand this statement. The previous statement references consumers where there is no known or suspected high hazard. This would imply that "all other residential consumers" means those where there are known or suspected high hazard present. Does this mean the department will approve the public education program, in lieu of, annual testing records and a proper CCCP even for consumers with high hazards!? I may be reading it incorrectly, but it's ambiguous at best.

In summary, please consider eliminating or rewording this entire section ...

12VAC5-590-600 Cross connection control program requirements 

D. Instead of annual operational tests (12VAC5-590-600 C) and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), the owner may provide a public education program to residential and commercial consumers whose premise plumbing is not complex and where there are no known or suspected high hazards as identified in Table 630.1. For all other residential consumers, the department may approve a public education program provided by the owner as part of the CCCP.