Since the middle of the last century, purveyors and building authorities have worked together to deliver water safely and efficiently. But accidents causing sickness, disease, and death have occurred with unsettling regularity over the period and public reaction has led to increased oversight by federal regulators, namely the Environmental Protection Agency (EPA). In 1973, as part of the Clean Water Act, the agency published the first Cross Connection Control Manual (CCCM) with continuing revisions until 2003. The guidance in this manual has been adopted throughout the nation and because of the EPA’s authority; penalties to purveyors for non-compliance are severe, including revocation of authority to distribute water. As introduction to the CCCM, the American Water Works Association (AWWA), the nation’s water purveyors’ authoritative body, offered the first evidence of opposing views between purveyors and building authorities in its ‘Statement of Policy on Public Water Supply Matters’. Central to that statement is the following excerpt:
“…. The return of any water to the public water system after the water has been used for any purpose on the customer’s premises or within the customer’s piping system is unacceptable and opposed by AWWA. …”
Opposing Views Due to Separate Duties
The statement above separates the responsibilities of purveyor and building authority. The building authority is responsible for the safety of the citizens inside the building. By extension, the plumbing authority, working under the jurisdiction of the building authority, is responsible for the safety of the drinking water inside the building. The purveyor, on the other hand, has a duty to all its customers to ensure that the water being delivered to every address is pure and safe. Think of a building’s water meter as a gate between two different sets of accountabilities. The local water utility is charged with the responsibility of maintaining clean water within the public water distribution system. That’s the water running down the big water pipes under the street. Alternatively, the local plumbing authority is responsible for the water that flows through the building’s pipes after it leaves the public water distribution system. The water meter then is truly a dividing point for two independent sets of duties: for the purveyor, the water between the meters, for the plumbing authority, the water beyond the meter.
Public Water: Public Duty
Protection against cross connection within a premise is critically important for the safety of those workers and visitors on site and every precaution must be taken to ensure the highest level of protection. But given the guidance of EPA, the protection against ‘the return of any water’ is more important when measured by lives affected. Said another way, contamination within a building is bad. Contamination of a city block is catastrophic. This is the fundamental principal of containment. Rather than contaminate a city block or even worse, the water purveyor must take measures to contain, or isolate, any possible contamination to the location where it occurred. Only then has it met its duty under the EPA statute. Theoretically, if there was no separation of building authority and purveyor, we could accomplish water safety by simply making sure there were no cross connection violations in any building at any time, ever. That would be great if only possible! Getting things done correctly the first time is hard enough for any building authority. To then add the unrealistic burden of policing every property on a daily basis would require budgets that will never be feasible. Thankfully, our forebears had the wisdom to understand that a separation of duties was necessary in order to protect the public good. Moreover, the waterworks industry came up with just the thing to make their obligation possible. It is a gathered group of valves that together create the desired effect. It’s known as a backflow preventer assembly (BPA). Placing it immediately after the water meter does the trick. And as many things in the world today, you can get it in regular or extra-strength.
Having defined the containment doctrine and the need for it, it’s easy to understand why this separation of powers is essential and must remain intact.