Who is Responsible for Controlling Cross-Connections?

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There are many individuals and agencies responsible for controlling cross-connections. To control cross-connection and protect the public health they must all work together. It all starts with a regulatory authority such as the state agency responsible for the implementation and enforcement of the drinking water program or the state or local agencies responsible for plumbing code enforcement. State or local agencies responsible for fire code enforcement may also have standards regarding the control of fire sprinkler system cross-connections. Since controlling cross-connections is a public health issues related to drinking water and the intent of the SDWA is to provide water to consumers that is safe, the public water system must act as the primary entity responsible for initiating and implementation a program for controlling cross-connection to the last free flowing outlet. There are some state drinking water regulations that require the public water system to take on such responsibilities. Other state drinking water programs only require the public water system to protect the water in the public water distribution system. To ensure that the consumers are drinking water that is safe, the public water system will have to coordinate this program with other individuals or agencies also responsible for control cross-connection within the public water system service area. If the public water system is not mandated by the state drinking water program requirements to control cross-connection to the last free flowing outlet of the consumer of water, the pubic water system to reduce the risk domestic plumbing systems pose to the consumer of water, the cross-connection control program should include public education. Unprotected cross-connections are a health hazard and if left unprotected could cause harm to individuals consuming the water. Therefore, to protect all consumers, the public water system cross-connection control program should include coordination with all local authorities, particular health and plumbing officials. All parties need to participate and share in the responsibility to protect the public health and safety of the consumer of water. The public water system in the administration of a cross-connection control program requires the assistance of the public health officials, plumbing inspectors, building owners, plumbing installers, and maintenance personnel.

Federal and State Responsibilities

The United States Environmental Protection Agency (EPA) pursuant to the Safe Drinking Water Act (SDWA) is the regulatory agencies responsible for establishing and enforcing standards relating to the quality of potable water delivered to the consumer by public water systems. The EPA established requirements for contaminants regulated by the National Primary Drinking Water Regulations (NPDWR).

The EPA grants primary enforcement responsibility (primacy) to the states for the implementation of the NPDWR. The Requirements for State Primacy (from 40CFR142, Subpart B):

  • The State must have regulations for contaminants regulated by the national primary drinking water regulations that are no less stringent than the regulations promulgated by EPA.
  • The State must have adopted and be implementing procedures for the enforcement of State regulations.
  • The State must maintain an inventory of public water systems in the State.
  • The State must have a program to conduct sanitary surveys of the systems in the State.
  • The State must have a program to certify laboratories that will analyze water samples required by the regulations.
  • The State must have a laboratory that will serve as the State’s “principal” lab that is certified by EPA.
  • The State must have a program to ensure that new, or modified, systems will be capable of complying with State primary drinking water regulations.