Responsibility
Under the provisions of the Safe Drinking Water Act of 1974, the Federal Government has established, through the EPA (Environmental Protection Agency), national standards of safe drinking water. The states are responsible for the enforcement of these standards as well as the supervision of public water supply systems and the sources of drinking water. The water purveyor (supplier) is held responsible for compliance to the provisions of the Safe Drinking Water Act, to include a warranty that water quality provided by his operation is in conformance with the EPA standards at the source, and is delivered to the customer without the quality being compromised as a result of its delivery through the distribution system. As specified in the Code of Federal Regulations (Volume 40, Paragraph 141.2, Section (c)) “Maximum contaminant level, means the maximum permissible level of a contaminant in water which is delivered to the free flowing outlet of the ultimate user of a public water system, except in the case of turbidity where the maximum permissible level is measured at the point of entry to the distribution system. Contaminants added to the water under circumstances controlled by the user, except those resulting from corrosion of piping and plumbing caused by water quality, are excluded from this definition.”
Figure 43 depicts several options that are open to a water purveyor when considering cross-connection protection to commercial, industrial, and residential customers. He may elect to work initially on the “containment” theory. This approach utilizes a minimum of backflow devices and isolates the customer from the water main. It virtually insulates the customer from potentially contaminating or polluting the public water supply system. While it is recognized that “containment” does not protect the customer within his building, it does effectively remove him from possible contamination to the public water supply system. If the water purveyor elects to protect his customers on a domestic internal protective basis and/or “fixture outlet protective basis,” then cross-connection control protective devices are placed at internal high hazard locations as well as at all locations where cross-connections exist at the “last free-flowing outlet.” This approach entails extensive cross-connective survey work on behalf of the water superintendent as well as constant policing of the plumbing within each commercial, industrial and residential account. In large water supply systems, fixture outlet protection crossconnection control philosophy, in itself, is a virtual impossibility to achieve and police due to the quantity of systems involved, the complexity of the plumbing systems inherent in many industrial sites, and the fact that many plumbing changes are made within industrial and commercial establishments that do not require the water department to license or otherwise endorse or ratify when contemplated or completed.
In addition, internal plumbing cross-connection control survey work is generally foreign to the average water purveyor and is not normally a portion of his job description or duties. While it is admirable for the water purveyor to accept and perform survey work, he should be aware that he runs the risk of additional liability in an area that may be in conflict with plumbing inspectors, maintenance personnel and other public health officials.
Even where extensive “fixture outlet protection,” cross-connection control programs are in effect through the efforts of an aggressive and thorough water supply crossconnection control program, the water authorities should also have an active “containment” program in order to address the many plumbing changes that are made and that are inherent within commercial and industrial establishments. In essence, fixture outlet protection becomes an extension beyond the “containment” program.
Also, in order for the supplier of water to provide maximum protection of the water distribution system, consideration should be given to requiring the owner of a premise (commercial, industrial, or residential) to provide at his own expense, adequate proof that his internal water system complies with the local or state plumbing code(s). In addition, he may be required to install, have tested, and maintain, all backflow protection devices that would be required—at his own expense!
The supplier of water should have the right of entry to determine degree of hazard and the existence of crossconnections in order to protect the potable water system. By so doing he can assess the overall nature of the facility and its potential impact on the water system (determine degree of hazard], personally see actual cross-connections that could contaminate the water system, and take appropriate action to insure the elimination of the cross-connection or the installation of required backflow devices.
To assist the water purveyor in the total administration of a cross-connection control program requires that all public health officials, plumbing inspectors, building managers, plumbing installers, and maintenance men participate and share in the responsibility to protect the public health and safety of individuals from crossconnections and contamination or pollution of the public water supply system.