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High Hazard Cross Connections - Significant Deficiencies
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In response to the federal Safe Drinking Water Act Ground Water Rule (GWR) and recent incidents in Minnesota, the Minnesota Department of Health (MDH) has adopted high-hazard cross connections that are not adequately protected as a Significant Deficiency (SD) for all Community Public Water Systems (CPWSs).
For the purposes of CPWS Unit program implementation, SDs will be defined as high-hazard cross connections that would require a Reduced Pressure Zone (RPZ) backflow preventer or air gap. However, CPWSs can adopt a more comprehensive approach, addressing all cross connections as part of a cross connection control program.
July 1, 2011-December 31, 2012
MDH will notify CPWSs that suspect or known inadequately protected high-hazard cross connections will need to be identified in their next Sanitary Survey.
Starting January 1, 2013
It is expected that CPWSs will be continuously building a documented inventory of high-hazard cross connections. While doing so, the most immediate priority should be given to identifying inadequately protected high-hazard cross connections in these locations:
- RPZ backflow preventer in inappropriate location or lacking testing;
- Waste and/or reclaimed water pipes and handling facilities, i.e. wastewater treatment plants;
- Chemical dispensers and/or feed lines, i.e. licensed food, beverage, and lodging establishments, and food processing facilities;
- Car wash pump feed lines;
- Health care facilities and providers and funeral parlors, i.e. air conditioning, fire protection, hazardous waste systems.
CPWSs will be asked at each Sanitary Survey if they know of any inadequately protected high-hazard cross connections in their distribution system.
If the answer is “Yes” and the CPWA has not made progress in addressing the cross-connection, the CPWS must identify the location(s) and submit a Corrective Action plan within 120 days to address the cross-connection(s). Below are examples of various Corrective Action plans:
- Initiate development of a Cross Connection Control Program that includes:
- Authority to implement the program – city ordinance
- Certification of backflow assembly testers
- Reporting and recordkeeping
- Public notification of backflow events
- Authority to enforce the program – city ordinance
- Meet with owner within 30 days of receiving SD notification;
- Request owner address cross connection within 30 days of meeting; and
- Confirm cross connection has been addressed within 60 days of meeting.
- Notify responsible licensing authority for business with suspected or known high-hazard cross connection within 30 days of receiving SD notification, i.e. MDH for Food, Beverage, or Lodging Establishments and Health Care Facilities and Providers; MDA for In-Store Delis, Grocery Stores, Butcher Stores, Bakeries, Convenience Stores; USDA for Food Processing Facilities; and
- Confirm cross connection has been addressed within 90 days of notifying responsible licensing authority.
- Adopt local enforcement authority for plumbing code within 90 days of receiving SD notification;
- Notify owner of plumbing code violation within 30 days of adopting local authority;
- Require owner address cross connection within 30 days of being notified of plumbing code violation; and
- Confirm cross connection has been addressed within 30 days of owner notification.
- Meet with owner within 30 days of receiving SD notification; and
- Test RPZ backflow preventer annually and rebuild device every five years.
If the answer is “No,” the CPWS must document what specific actions were taken to come to that conclusion, i.e. talked to local plumbers, talked to the local plumbing authority, met with owners of possible high-hazard cross connections, and/or tracked RPZ backflow preventer installation and maintenance records.
If the answer is “I’m not sure,” the CPWS must take action to locate any suspect or known inadequately protected high-hazard cross connections prior to the next Sanitary Survey (within 18 months).
- American Backflow Prevention Association
- League of Minnesota Cities
- Minnesota American Water Works Association
- Minnesota Department of Health
(grant opportunities and fact sheets)
- Minnesota Department of Labor and Industry
- Minnesota Rural Water Association
(templates and helpful hints for implementing cross-connection control programs)
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