Virginia Regulatory Town Hall
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Department of Professional and Occupational Regulation
 
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Board for Professional and Occupational Regulation
 
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9/30/20  9:53 pm
Commenter: Philip Jones, Isle of Wight County - Cross-Connection Control Inspector

STRONG SUPPORT for continued regulation of Backflow Prevention Device Workers (BPDWs)
 

"Is the water safe to drink?" This question is asked around the world by people in 2nd and 3rd world countries, because they are often unaccustomed to having safe drinking water at every tap. But in America, until recent years, water has been assumed to be safe at nearly every tap. However, public water supplies have been increasingly contaminated to deplorable and reprehensible conditions, causing the public to lose confidence in their drinking water and in those responsible. Sadly, "Is the water safe to drink?" is being asked more and more in this country. Without backflow preventers being tested and maintained by certified and licensed professionals, such water quality debacles could increase, turning the assumption of safe water into wishful thinking.

Protecting the drinking water supply requires a joint effort between waterworks owners, code & regulatory enforcement professionals, backflow preventer manufacturers, and Backflow Prevention Device Workers (BPDWs). It takes all of them working together to ensure safe drinking water. It would be unthinkable to allow waterworks to supply unsafe, unregulated water. It would be unimaginable to eliminate backflow prevention requirements from plumbing codes and waterworks regulations. It would be ridiculous to allow manufacturers to build and sell nonfunctional, unapproved backflow preventers. It would also be inconceivable to not require backflow testing by qualified professionals--BPDWs. Removing any one of these aspects of backflow prevention is a recipe for disaster, and risks a breach of the public trust. But the proposal at hand does just that, by seeking to eliminate BPDWs and their oversight by DPOR.

Backflow is not some far-off statistical anomaly; it is a hydraulic certainty, that happens frequently in both plumbing and water distribution systems on a regular basis. Simply put, when the water pressure drops below minimal levels in a water supply system, or the regular pressure is overcome by a higher source of pressure, backflow occurs. The only safeguard protecting the drinking water from chemical, biological or radiological contaminants is a functional backflow preventer. When (and not "if") the backflow preventer becomes fouled, deteriorated, damaged, or otherwise fails, it no longer protects the water. Much can go wrong with improper testing, maintenance or repairs. Only regular testing and maintenance of backflow preventers by qualified BPDWs ensures that they are indeed functional.

The safety of Virginia’s drinking water supply systems is at stake, and cannot be entrusted to unqualified, unregulated persons. BPDWs must be certified, licensed, and regulated by DPOR, to ensure the safety of the drinking water supply. While there is always room for improvement, the DPOR system works well. Seeking to remove DPOR regulation of this vital trade is a move in the wrong direction. Continued DPOR regulation of BPDWs is absolutely necessary to ensure safe drinking water, to protect the public health, and to ensure consumer confidence--not only in Virginia's water supply systems, but in its government. Very few issues cause panic and outcry as quickly and completely as a breach of public trust, especially over something as essential and assumed as safe drinking water. DPOR must continue to regulate this important trade, and would do well to never consider proposals to deregulate BPDWs in the future.

A backflow industry anecdote illustrates the point: “When backflow prevention professionals do their job to keep the water safe, people often complain, “Why do we need all these regulations, backflow preventers, and tests?” But when someone gets sick or dies from drinking contaminated water, people demand to know, “Whose job was it to keep us safe?

Respectfully,

Philip Jones
Codes Compliance Inspector - Cross Connection Control & Backflow Prevention
Isle of Wight County Public Utilities

CommentID: 87163