Entries for the 'Safety' Category

27
I was at the Alabama Rural Water Association Conference a few weeks ago and there was a really interesting talk by a lawyer for an Alabama utility.  The utility is being sued by a few of their customers for poor water quality even though their water meets all health standards.  If a water supply provides water that meets all of the health standards and their operation meets all of the regulatory requirements, should their customers be able to sue them if they percieve there are water quality problems? Thats a tricky question for sure.
 
Safe Harbor
A safe harbor law basically protects someone from civil suit if they are meeting all of the legal and professional requirements for the services they provide.  For instance, a prosecutor in a district attorney's office has immunity from civil action, even if they help put an innocent man in jail.  For a water system, this type of law would mean that your customers cannot sue you for percieved water quality problems if you are meeting all of the requirements of the Safe Drinking Water Act and your state regulations.  Alabama currently does not have such a law.
 
What's Happening In Alabama
Because of the lawsuit currently going on in Alabama, there is a push to pass a "safe harbor" law as an amendment to the Alabama SDWA. It's going through their state legislature now and appears to have alot of support.  In the ongoing lawsuit, 10 homeowners that are spread throughout a 53 home subdivision, claim their water has oil and grease in it.  Testing by the utility and extensive testing by the Alabama Department of Environmental Management show there are only normal, background levels in the water (a trip blank even had similar levels in it).  I don't want to get into the details, but 3000 customers use water from the same main, and some of the allegations (like their water catches fire), are hard to understand if the water is meeting all of the SDWA standards. 
 
What It Means
I'm not a judge or jury, but I do believe that if a utility is meeting its legal obligations and works with their customers fairly and openly, there should be some reasonable expectation that the utility met its obligation and has their customers best interests at heart. As the speaker said, without this legislation, any customer could sue any utility and that could lead to a jury setting water standards in that state, "regulation by litigation" is the term he used.  Can water systems afford litigation because of unhappy customers? 
 
How about you?  Does your state have "Safe Harbor" legislation attached to its SDWA rules?  Do you think it's a good idea?

 

09

A few years ago I shadowed a Maryland Department of the Environment sanitary survey of a small system in western Maryland. It was an eye-opening experience, especially since I was pretty green in the industry at the time. One thing really stuck with me: the importance of a cross connection control program. I also learned that this is one of the most commonly noted deficiencies in sanitary surveys.

A cross connection occurs whenever there is an actual or potential physical connection between the public drinking water system and any possible source of contamination.

We have documents from many states in our database (including specific regulations and requirements); these below are some of the most helpful introductory materials. What is included is not only helpful for water system operators, but also the public. Homeowners and businesses in your community play a large role in backflow prevention and this is not commonly understood by the general public.

Cross Connection Control: A Best Practices Guide
from US Environmental Protection Agency

This 4-page document is a fact sheet answering common questions about backflow and cross-connection control. It also contains information about the risks of cross-connections and well as some preventative advice. Technologies that are available to control cross-connections and prevent backflow are also covered.

Backflow Prevention and Cross-Connection Control: Protecting our Public Water System
from Ohio Environmental Protection Agency
This 2-page flier presents information on backflow prevention. It discusses what it is, concerns associated with it, how it occurs and what it causes, and what can be done to protect the system. Some specific topics discusse include auxiliary water systems and booster pumps.

Cross Connections Can Create Health Hazards
from Washington State Department of Health
A 2-page brochure that explains what cross connections are, how contaminated water can flow backwards into a consumer's plumbing and the public water system, and where to get help to prevent backflow from occurring. It is intended for consumers and also mentions 12 common places that cross connections are found.

Cross Connection and Backflow Prevention
from National Environmental Services Center
This 4-page tech brief examines the problems associated with cross connections and backflow and provides practical solutions for controlling or eliminating them. Some of the common questions that are answered include: What is a cross connection? What is a backflow? What about terrorism and water security?

Commercial Cross-Connection Survey Form
from Nebraska Rural Water Association
This 2-page document is a survey conducted by utilities to assist customers in reporting potential backflow hazards and to comply with regulations. It is intended for consumers to fill out and return to their water providers. This form must be filled out every five years by consumers.

Further Reading
For additional technical support in developing your program, we recommend US EPA's Cross Connection Control Manual. This 50-page guidance manual contains information on cross connections, backflow prevention, system management and public health. It describes the health significance of cross-connections, how back flow events occur, how to prevent backflow and backsiphonage, how to test preventers, how to develop a cross-connection control program, and information on ordinances.

SmallWaterSupply.org's Document Search can help you find valuable references, resources and educational materials to make your job easier.
 

28
This is the 3rd post covering the communication toolbox, a new tool available from CDC on how to prepare, deal with, and learn from situations where you need to (precautionary) or have to (mandatory) communicate with your customers to advise them of a drinking water situation in your community.  The 1st blog post provided an overview of the toolbox, the 2nd blog post discussed the introduction section of the toolbox, which explained some of the basics about when and why you should communicate with the public. Today, we'll provide you with some suggestions they provide for small systems.
 
For Small Systems Using the Toolbox
The toolbox was written for water systems, both large and small.  But, it was developed with both in mind.  We've already mentioned that we think the toolbox is one of the most complete tools available to help you with communicating with the public during an emergency, and on page 13, they offer some suggestions for small systems, recognizing that sometimes small systems may not have the capacity to implement all of the suggestions listed in the toolbox.  Basically, these are the things every small system should do to be prepared, regardless of the emergency.
 
1. Identify and prioritize specific tools or sections in the toolbox to use.  The toolbox is worth going through, cover to cover, to really understand what it means to communicate with your customers and to be prepared in an emergency.  In doing so, you will find many great ideas that will help you prepare, act, and recover from an emergency situation.  Pick and choose what you think will work for your specific situation and within the capacity of your system and community.
 
2. Incorporate water advisory protocol planning into regular activities, such as sanitary surveys and updating emergency response plans.  I'm sure some of you think this is "beyond" what you can do, and may not even have an emergency response plan in place for your system.  That is a great place to start and there are some great templates available from RCAP and Rural Water that walk you through development of a plan.  Do that first, and you will understand why its important to be prepared and think ahead, rather than react to an emergency. (call or email us, we can help, as can your local TA providers.  See the links to the templates below).
 
3. Build water advisory protocols into regular communication, such as customer updates.  Again, some of you may look at this and say, I never send stuff to my customers.  Why not?  When operators tell me their customers want "free" water, and don't value what they do, I tell them to start marketing to their customers, help them understand what a service you provide, how important safe water is to your community. Operators can't just do the technical stuff anymore, they have to engage their communities to understand the need and importance of safe water.  Along with that is the importance of dealing with emergency situations.
 
4. Partner with local public health and neighboring water systems. Planning for an emergency means working with others outside your community.  When a real disaster happens, you need to know what to do, who you can call, who you can rely on for help.  You need to ask yourself, what does your community deserve? Doing it all on your own usually ends up hurting your community when a disaster occurs. It's the responsible thing to do, and best for your system and customers.  This would also be a good time to mention your state's WARN program.  Look into it, consider how it might benefit your community.
 
Getting Started
Remember these suggestions as you go through the toolbox.  Find the pieces that you think will work for you.  It states that many of the actions you can consider taking, as described in the toolbox, shouldn't require outside support from consultants or others.  It also says building a network of partners and organizations to work with in an emergency is the key to success.  We agree.
 
Should you have any questions, let us know. We will gladly help you navigate through the material and find resources that you can use with your customers for both emergency response and just for marketing the value of your water system.
 
Below are links to some of the resources mentioned above:
 
Rural Community Assistance Partnership (RCAP)
 
National Rural Water Association (NRWA)
 
Water & Wastewater Agency Response Networks (WARN)
(click on the "WARN Regions" tab to find your state WARN program)

 

How To Run Your System Like A Business is a series at SmallWaterSupply.org, appearing on Monday.

 

31
The Centers for Disease Control (CDC) has released a new document, the Drinking Water Advisory Communication Toolbox.  This 162 page document was a collaborative effort among 6 organizations that all work in the drinking water and environmental health fields.
 
What Is It?
The Toolbox provides protocols for communicating with stakeholders and the public about water advisories and has practical information on how to plan for, develop, implement, and evaluate drinking water advisories.
 
How is this document different?
It is to date, the most far reaching effort to help prepare and assist drinking water systems in dealing with drinking water advisories to their customers that we have seen. The document recognizes the degrees of severity where advisories might be needed, from a drop in pressure,to a hurricane, and everything in between. It has practical solutions that affect the types of tools, planning, and communication needed for specific situations.
 
More importantly, it was developed by consensus among a tremendous number of stakeholders, industry folks, water systems, and technical assistance providers.  The list of acknowledgements is over 3 pages long and includes over 50 water systems.  They really did their research, compiling over 500 documents related to advisories, and conducting over 100 interviews.
 
What does that mean for me?
It means it will be a useful tool that you can use when you need to prepare a drinking water advisory. It also means the document is well thought out, organized, practical, and useful.  
 
That's a lot to read!
We agree, the problem is that it is 162 pages long.  We hope to help with that aspect by breaking the toolbox down in subsequent blog posts and highlighting the things we feel are most relevant for small systems.  Stay tuned for more, but if you get the chance, take a look.  You can find the report here.   
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