Does This Make Any Sense?

I think we all agree that backflow prevention is an important part of any plumbing or water system design or installation. If a cross-connection requires a backflow prevention device or assembly to be installed as isolation or containment protection, then it makes logical sense that a hazard is present and a danger exists. If we are all still in agreement, can we also agree that if protection is needed, then it should also be tested and maintained to ensure that the assembly or device would operate as designed in the case of an actual hydraulic condition? If we are still on the same page, I’d venture to say that you’d agree that the most important goal for us is the installation and testing of backflow prevention assemblies. In many areas, that is not the case.

What are we instead focusing on in many areas? It varies, but I would say some of the concerns include:

1. What field test procedure or procedures should be approved?
2. Can we create a single test report form for use in every area?
3. What tester certification body is accepted?
4. Who should be allowed to test, install, or repair backflow preventers?
5. Should water suppliers be allowed to mandate a specific company or group to do testing in their jurisdiction?
6. Should residential properties have the same cross-connection requirements as commercial customers?
7. What should the test of a backflow prevention assembly cost?
8. How often should cross-connection control surveys be conducted and who should conduct them?
9. Should permits be required to test backflow preventers?
10. Is it possible, and does it make sense, to allow grandfathering of existing services and systems?

Some of these concerns are very valid, but none as important as the installation and testing of the proper cross-connection protection on every system. That is where our primary focus should remain as we look at the other issues. Below are my thoughts on the ten issues I listed. Each of our industry stakeholders will look at this list through a different lens. Feel free to reach out to me with your thoughts and concerns and we can continue the discussion. I can be reached at sean.cleary@iapmo.org.

What field test procedure or procedures should be approved?

This is a topic that brings the passion out of many in our industry. I teach classes in different areas of the country, so I see many different recognized field testing procedures. I have found that when used correctly, the One Hose, ASSE, USC, NEWWA, and TREEO field procedures are all valid. Some are less complicated, but they all confirm the proper or improper operation of the assembly. People tend to focus on the procedure that they were first trained on and insist that that procedure is the only one that should be accepted, but I have found that each will give proper results.

Can we create a single test report form for use in every area?

I think the simple answer is, and will always be, no. Different purveyors look for different information on the forms. Some purveyors require the actual form to be completed and mailed in its original form and signed by the tester. Others request the information through an online, web-based platform. There is no one-size-fits-all solution.

What tester certification body is accepted?

A few years ago, several industry groups got together and released a position paper that laid out minimum standards for training. The issue of program acceptance, at times, is an area where politics within the industry works against itself by creating kings and kingdoms to protect certain groups at the expense of the industry as a whole.

Who should be allowed to test, install, or repair backflow preventers?

In my humble opinion, the answer to this question is, “It depends.” As a licensed master plumber, I think it is important that installation and repair of backflow preventers that are part of the plumbing system be installed by plumbers. On fire protection systems, it makes sense that sprinkler fitters work on the valves. Some areas of the country do not have licensing, so it is impossible to mandate who will install, test, and repair – but, we should insist on trained, certified individuals doing this work.

Should water suppliers be allowed to mandate a specific company or group to do testing in their jurisdiction?

Monopolies are never a good idea in any circumstance. If a water supplier is paying for the testing, then they have a right to contract this service to a specific company. However, if consumers are paying for this service, then they should have the right to hire the tester of their choice.

Should residential properties have the same cross-connection requirements as commercial customers?

The simple answer here is yes. The laws of physics are the same in either type property, so the installation and testing requirements should be identical.

What should the test of a backflow prevention assembly cost?

Pricing for testing should be between the consumer and tester. Testing companies have overhead, which includes office staff, truck expenses, insurance, salary, health insurance, pension costs, and the list goes on. The cost may vary from area to area, so as with test procedures and report forms, there is no one-size-fits-all answer.

How often should cross-connection control surveys be conducted and who should conduct them?

Surveys need to be done on a continuous basis. In areas that use isolation-only programs, it is even more critical. Without a containment program in place to protect one consumer’s water service from the next, any changes to a customer’s internal water system may put the public system at risk. Small changes within a facility’s water piping system may be done without permits and inspections and can result in unprotected cross-connections. That is why surveys are critical to ensuring that systems are properly protected and should be done on a regular schedule. These surveys should be conducted by certified individuals who understand the hydraulics that may exist in buildings and facilities.

Should permits be required to test backflow preventers?

I agree with a permit process to allow for the tracking of assemblies, and their testing and possible repair. Permit fees should be used to fund and expand the cross-connection program.

Is it possible, and does it make sense, to allow grandfathering of existing services and systems?

The answer to this question should be no. How can we grandfather safety? I understand the thought that if the protection was not required when the building was constructed, it is difficult to ask the owner to update the system. However, the protection of the public system is too important to allow hazards to exist. Installation and testing requirements should be identical and should match the potential hazard, no matter when the structure was built. We are in the backflow prevention business – our mission is to stop possible problems from occurring, not clean up after the damage is done.