This article was originally printed in Louisiana Civil Engineer magazine, May 2011, Volume 19, No. 3.
So the question becomes, “Why is it so difficult for water systems to comply with this regulation?” Perhaps it is because the answer is complex. Regulations regarding cross connection control and backflow prevention can be found in the Louisiana Administrative Code, Title 51, Part 12 and the Louisiana State Plumbing Code in Chapter 6 and Appendix D (Note: the Louisiana State Plumbing Code has been incorporated into the Louisiana Administrative Code effective February 20, 2013). Additional issues that prevent compliance are an incomplete understanding of the scope of a program, political ramifications (this is not a popular program), a general lack of knowledge due to the relative newness of the industry, and financial constraints. While the backflow industry is not technically complicated, it is complex due to the “issues” previously mentioned. Many communities in the United States have separate departments that oversee their backflow prevention program – much like there are separate water, sewer, gas, human resources, purchasing, etc departments. Most of these departments are not managed by engineers but by personnel trained in cross connection control and backflow prevention.
Looking at these issues separately, it is of course vital to understand the regulations. Many municipal engineers in Louisiana will likely be charged with bringing their client’s system into compliance. The Administrative Code regulations essentially require water systems to protect the potable water supply by providing containment protection (in the event of an incident, contain the incident to the premise where the incident occurred so as not to affect all customers connected to the water system). It is important to understand that the regulations not only call for cross connections to be protected, but that potential cross connections be protected as well. This is accomplished by determining the degree of hazard3 associated with each cross connection or potential cross connection. Once the degree of hazard is determined, regulations within the Louisiana State Plumbing Code can be used as a guide to determining what type (if any) backflow preventer is required at a particular service connection. Specifically, Table D104 of the State Plumbing Code provides a guide to the selection of backflow preventers; however, the code specifically states that Table D104 is not all inclusive. Other reference sources for the guide to selection of backflow preventers, relative to the degree of hazard, (the degree of hazard is a term derived from an evaluation of the potential risk to public health and the adverse effect of the hazard upon the potable water ) are available in the Plumbing Code.
Experience shows that purveyors generally have an incomplete understanding of the work effort involved in setting up a complete and comprehensive backflow prevention program. The industry average is that 5% to 10%, typically around 7%, of all water system customers will require some sort of backflow prevention, regardless of whether the system is rural or urban. The general procedures for implementing a backflow prevention program are as follows: a written program is established – complete with an ordinance, a review of water system records is performed, a cross connection control survey is performed on certain customers to determine degree of hazard, a determination of who is required to have backflow preventers is made, a permitting system is prepared and implemented (for quality control), plumber monitoring is performed (not all plumbers are allowed to work with backflow preventers), letters are prepared and sent to customers requiring the installation of backflow preventers, and follow-up inspections are performed. In order to implement a comprehensive program, each water service must be evaluated in order to determine if hazards exist. Most service connections will not require backflow prevention assemblies due to the fact that state regulations target high hazard locations. In many cases, the evaluation may simply be a review of water system customer records. In other cases, a cross connection control survey must be performed by a qualified individual. For the operator or engineer charged with this responsibility, the work effort can be extensive, if only for a brief period of time. The difficulty in getting the program implemented can be further complicated by the general lack of understanding of the backflow industry.
Perhaps the biggest issue in implementing a backflow prevention program is the political ramifications. As stated previously, this can be a very unpopular program, primarily due to the lack of education and the cost to the customers. Backflow prevention is generally a new concept that is not easily grasped, particularly in more rural areas. However, the most recent documented cases of backflow incidents in Louisiana have primarily occurred in rural areas! Nevertheless, the result of implementing a program may have consequences to the local electorate.
Financial commitments by water systems toward getting a program implemented are difficult to obtain due to a general lack of knowledge about the backflow industry. Elected officials and board presidents have a difficult time appropriating funding for a program that they cannot comprehend and is often viewed as unnecessary. In addition, the financial component of implementing the program is very real to those customers requiring backflow preventers. It is difficult for a customer that may have operated a business for decades to understand why it is now necessary to install a backflow preventer. The truth is the regulation may have been in place longer than the business has been in existence; however, enforcement actions by DHH are necessitating that the installation and testing occur to bring the water system into compliance. Furthermore, state regulations require backflow preventers be tested annually and that the cost of all backflow preventer work be borne by the owner of the premise where the hazard exists.