Request to Allow Reduced Frequency of Certain Cross Connection Device Inspections
We are writing in response to G. M. Loupassi’s petition requesting that the State Board of Health amend the regulations contained in Virginia’s Waterworks Regulations governing cross connection control and backflow prevention. We disagree with the verbiage that erroneously depicts any individual homeowner’s lawn irrigation systems as a lower risk connection. As these systems are continuously subjected to innumerable chemical, microbiological, and serious physical contaminants, which include, but are not limited to pesticides, fertilizer, animal and insect droppings, rusting pipe, etc., the classification of a low risk involved with these systems is inaccurate. Even the systems of those individuals who choose to irrigate without any chemicals are subject to those contaminants and pollutants that are commonly and naturally found outdoors, such as bacteria, viruses, algae, fungi, parasitic helminths (worms), and protozoa.
Given that most Americans take clean tap water for granted and are not privy to all that is required to maintain its quality, the petitioner’s perception of low risk with these systems may appear sound. We genuinely hope that the aforementioned information refutes this misconception; irrigation systems are well recognized as a high hazard in the water industry. In the August 2011 issue of Reader’s Digest, the Head of the Environmental Protection Agency, Lisa Jackson, commented that “Almost 290 million people in this country depend on 50,000 water systems for safe water. We don’t pay attention to this system, because it works—about 92 percent of Americans drink water that meets federal safety standards. Where we don’t meet the standards, we know what we have to do to get there.”
One critical standard in maintaining safe water is found in an effective backflow prevention program that requires the installation and monitoring of assemblies that have been approved and tested for specific hazards. The industry consistently recommends the highest level of protection for irrigation systems. With regard to the petitioner’s plea to tier the requirements, in relevant part, it is important to note that backflow prevention assemblies are mechanical devices. As such, they are subject to stresses which may cause failure, creating an opportunity to negatively affect the health and well being not only of the homeowner and their family, but others as well. We all understand the need to maintain other mechanical devices in our lives, such as vehicles, home appliances, etc. The 2009 American Society of Sanitary Engineering publication, Cross-Connection Control Professional Qualifications Standard asserts the following pertaining to field testing requirements, “At a minimum; backflow prevention assemblies shall be tested upon installation, annually and immediately after repair.”
In response to the petitioner’s comment that “perhaps there are solutions that I am unaware of” we have listed a few options below that may make this situation less onerous.
1.Utilize a lawn service/irrigation contractor that has a certified backflow tester on staff. Annual testing may then be performed at the time of the initial startup of the system; this option also eliminates fees paid to a tester as a trip charge.
2.Secure an annual service contract with a negotiated cap on rates for tests and/or trip fees. This process is less burdensome, as contractors contact you when the annual test is due.
3.Work with neighbors, friends, or local businesses to negotiate volume pricing for tests and trip fees. Most testing entities will only charge one trip fee daily for all tests performed within a specific radius.
4.Contact your water purveyor to remove connections on inactive or underutilized systems. This should negate the need for annual tests. If one desires to reconnect in the future, this is generally simple and inexpensive as the service lines are still available.
We appreciate the fact that the State Board of Health recognizes that irrigation systems pose a high level of risk to everyone within a water distribution system and call for annual testing of the mechanical assemblies that afford protection to all.
Respectfully,
Timothy A. Mitchell, P. E.
Director of Utilities
City of Lynchburg
