As discussed in EPA’s Cross-Connection Control Manual, “cross- connections which are defined as actual or potential connections between a potable and non-potable water supply, constitute a serious public health hazard.” It goes on to say that “There are numerous, well documented cases where cross connections have been responsible for contamination of drinking water, and have resulted in the spread of disease.”
In Code of Virginia, Chapter 590. Waterworks Regulations, there are specific requirements related to Cross Connection Control and Backflow Prevention. Some are as follows:
12VAC5-590-580. General.
Article 4. Cross Connection Control and Backflow Prevention in Waterworks
The purpose of this article is to require as a condition for the issuance and continued use of the operation permit for the waterworks that each owner of a waterworks establish and enforce a program of cross connection control and backflow prevention for each waterworks. The cross connection control and backflow prevention program shall be approved by the division prior to issuance of the operation permit
12VAC5-590-600. Responsibilities.
2. Suggested elements of this program are contained in Appendix I. The purveyor has full responsibility for water quality and for the construction, maintenance, and operation of the waterworks beginning at the water source and ending at the service connection.
3. The purveyor shall have thorough inspections and operational tests made at least annually of backflow prevention devices which are required and installed at the service connection
The proposed Virginia Waterworks Regulations includes the following text:
12VAC5-590-630 (D) Starting January 1, 2022, persons testing and repairing backflow prevention assemblies and devices shall be certified by a Commonwealth of Virginia tradesman certification program (identified by DPOR as backflow prevention device workers). Until January 1, 2022, persons testing and repairing backflow prevention assemblies and devices shall be qualified to perform such work as demonstrated by possessing a certification or license from a local or state agency having legal authority or shall possess a certificate of completion of applicable vocational training acceptable to the owner.
The EPA Cross-Connection Control (CCC) Manual, as well as the VA Dept. of Health’s Waterworks Regulations clearly defines the backflow standards. Chapter Six of the EPA CCC Manual states that cross-connection (or backflow prevention) programs, should include the preparation of “a listing of all testable backflow devices” and “insure that they are tested by certified test personnel”.
The most well written and well enforced Cross-Connection, or Backflow Prevention, Programs in our state are only as robust as the Training and Certifications of those who determine if the required assemblies are operating properly, and who are also able to confirm that said assemblies have been installed, repaired, and maintained correctly. As such, it is very important to require sufficient levels of training, along with the certification of individuals as professional VA DPOR Licensed Backflow Prevention Device Workers to perform initial and annual testing, repairs, and inspections. If we allow non-professionals to perform this work, we have no control over its quality, which puts the general public at risk.
What is proposed falls far short of the state’s responsibility towards protecting the public water and its citizens, either by allowing a reduction in the required training hours or the elimination of the certification of Backflow Prevention Device workers. The City of Lynchburg actively supports the continuance of the certification program for Backflow Prevention Device Workers by the Department of Professional and Occupational Regulations (DPOR), as well as a minimum of 40 hours of vocational training for those with 4 to 7 years of experience in water distribution systems.