Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Waterworks Regulations [12 VAC 5 ‑ 590]
Action Amend and update the Waterworks Regulations
Stage Proposed
Comment Period Ended on 1/10/2020
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1/10/20  7:22 pm
Commenter: Dan Maloy, Backflow Partners, Inc.

Lawn Irrigation; Education is a complement to annual testing
 

Thank you to the team for their time and hard work on this document.

I agree with the numerous posts advocating for the classification of lawn irrigation systems as “High Hazard” in table 630.1.  To classify as “Low Hazard” would be a dangerous reversal.

I support public education programs as a vital component of a successful CCCP; however, it is a complement to annual inspections to confirm the operation of the backflow assemblies (12VAC5-590-600C).

  • When you eliminate the requirement for annual inspection of backflow assemblies, even for a limited subsegment of consumers, you increase the risk to the owner and ultimately the consumers.
  • When you eliminate the requirement for annual inspection of backflow assemblies, even for a limited subsegment of consumers, you immediately diminish the importance of the CCCP.
  • Consider this analogy - with all the education provided, we have learned the dangers of speeding.  Everyone chooses to obey or not obey the posted speed limits.  Some choose to obey because of the education, and some obey because there is someone monitoring compliance.  Regardless of the reason, we are all safer because of their compliance.
CommentID: 78847