Protecting Our Communities from Backflow Contamination 2024 by BCWWA

PROTECTING OUR COMMUNITIES FROM BACKFLOW CONTAMINATION

A Review of Cross Connection Control Programs in British Columbia

ABOUT THIS REPORT

This report was developed by the BC Water & Waste Association (BCWWA) to provide clarity regarding the state of community cross connection control (CCC) programs in British Columbia.

The BCWWA believes that a robust and sustainable community CCC program is an integral part of providing clean, safe drinking water. As such, the organization embarked on a research project that involved surveying and interviewing municipal CCC programs, speaking with post-secondary institutions that offer backflow testing certification, reviewing the regulatory environment and consulting with our technical and advisory committee members The report is a culmination of these findings to provide insight into the challenges and best practices in implementing a community cross connection control program and how current data can inform policy and decision-making at multiple government levels

This report is intended as a resource to support the implementation and success of community cross connection programs, to share best practices regarding backflow testing processes and certification and to promote an ongoing dialogue to recognize and support the CCC programs that work tirelessly to protect their communities from water contamination events.

ACKNOWLEDGEMENTS

This report was written by BCWWA staff with support from several contributors.

The BCWWA would like to thank its Cross Connection Control (CCC) Technical Committee for their assistance in developing the survey. Additionally, we would like to thank the following representatives from both the CCC technical and CCC education committees for their work as reviewers of this report:

Paul Allen

Dylon Fellner

Laith Furatian

Kurtis Hartwell

Trevor Hoff

Raj Samra

Bob Shuck

Special thanks to the Capital Regional District and the City of Parksville for sharing your experience as case study communities

Thanks to our American Water Works Association (AWWA) section counterparts who also contributed to this report, including Western Canada (WCWWA), Ontario (OWWA), Réseau Environnement, and Atlantic Canada (ACWWA)

Most importantly, the BCWWA would like to thank all the respondents of the survey for volunteering their time, experience, and expertise in support of this project 27 communities participated in this research project, including:

City of Abbotsford

City of Burnaby

City of Castlegar

City of Chilliwack

City of Coquitlam

City of Delta

City of Duncan

City of Grand Forks

City of Nanaimo

City of Parksville

City of Pitt Meadows

City of Prince George

City of Salmon Arm

City of Surrey

City of Terrace

City of Vancouver

City of West Kelowna

City of White Rock

Capital Regional District

Clearbrook Waterworks District

District of Lake Country

District of Squamish District of Central Kootenay

Regional District of North Okanagan

Scott Point Waterworks District

Township of Langley

University of British Columbia

If you would like further information about this project or would like permission to use this report in whole or in part, please contact the BCWWA at contact@bcwwa org

EXECUTIVE SUMMARY

INTRODUCTION

The BC Water & Waste Association (BCWWA) has played an integral role in the development of community cross connection control (CCC) programs and certification for over 40 years in British Columbia and the Yukon

According to the Provincial Health Officer’s Drinking Water Report (2024), cross connection control is an important component of the multi-barrier approach used to ensure safe, clean drinking water

As part of the commitment to continuous improvement of Association programs and supporting Association members, the BCWWA conducted a review of community CCC programs in British Columbia with the intention of identifying themes related to both successes and challenges among the participants

WHY IS CROSS CONNECTION CONTROL IMPORTANT?

Cross connection control is the series of activities that ensure non-potable water is prevented from contaminating potable water systems (backflow)

In 2006, the Committee on Public Water Supply Distribution Systems (National Research Council), through a series of workshops and literature reviews, compiled a list of issues in securing distribution system integrity, based on historical data of health incidents The number one identified risk was cross connection control.

Backflow incidents have a direct effect on the health and safety of the public and the trust that the public has with their community leaders.

Each community increases their risk of liability from an adverse event when they do not manage their backflow hazards. Cross connection control programs are the structures that support communities in ensuring that backflow risks are identified, mitigated and monitored.

2005 – STRATFORD, ONTARIO CAR WASH BACKFLOW INCIDENT

An illegal water bypass installed in a car wash resulted in a cleaning substance entering and contaminating the city’s water supply

The contamination impacted 30,000 residents, with 19 reports of residents requiring medical care Schools were closed, affecting 6,000 students The business owner was fined $75,000

WHAT DID WE REVIEW?

RESEARCH PROCESS

The BCWWA conducted a research project comprising of a survey and interviews with 27 communities around British Columbia. The survey comprised of 45 questions and an interview was used to clarify responses within the survey.

REGULATORY ENVIRONMENT

The regulatory environment in British Columbia is complex and involves multiple jurisdictions and different applications This includes federal standards, provincial legislation, regulation and codes, health authority permits and orders and municipal bylaws

Application varies depending on where the cross connection exists, whether it’s part of a building permit and whether additional restrictions have been applied to the community As a result, there is inconsistency in how communities interpret and apply these regulations

Cross connection control crosses both potable and non-potable regulations, which only increases complexity For example, applications such as rainwater capture and reuse are becoming increasingly important for new and existing facilities and are subject to regulations from multiple ministries

Respondents expressed concern at the confusing regulatory landscape and the increasing backflow risks in the community They expressed a desire to have clear regulation regarding cross connection control programs

CROSS CONNECTION CONTROL PROGRAMS

The research reviewed several aspects of cross connection control programs, including the scope of the programs and how the programs incorporate the recommended components of a cross connection control program For the purpose of this research, cross connection control programs were divided into six areas: backflow hazard surveys, backflow device testing, records maintenance, enforcement, emergency preparation and education

This report also pulls themes from the findings to explore factors such as staffing, software solutions, financial sustainability, knowledge sharing, education and awareness, and certification programs Overwhelmingly, communities expressed a desire for consistent expectations regarding cross connection control programs and the financial support to enact them

EDUCATIONAL INSTITUTIONS

BCWWA staff toured the province to meet with post-secondary institutions regarding their backflow certification programs The result is additional context about student intake, relationships with nearby community programs and the changes in the cross connection landscape

WHAT DID WE HEAR?

CROSS CONNECTION CONTROL IS NOT WELL UNDERSTOOD.

Cross connection control serves an important function in protecting public safety. However, the risks that exist are not well understood. Decision-makers, property owners and the general public can all benefit from learning about the risks posed by cross connections and how to avoid them

CROSS CONNECTION CONTROL IS A SHARED RESPONSIBILITY.

Backflow events occur across the spectrum, from municipal water distribution systems to private irrigation systems to facility installations, such as sprinkler systems or devices such as a beverage carbonator Preventing backflow incidents is a shared responsibility between the community, the property owners and the public

CROSS CONNECTION CONTROL IS AN EVOLVING AREA REQUIRING REGULAR UPDATES.

As new technology and innovation are introduced into buildings, industry, agriculture and commercial establishments, individuals associated with backflow prevention need to stay current. For example, rainwater reuse systems often connect with potable water systems as supplemental water. Commercial food systems, such as coffee machines and drink carbonators are attached to potable water supplies.

THE REGULATORY LANDSCAPE IS CONFUSING AND OPEN TO INTERPRETATION.

Because backflow prevention is referenced in across legislation, regulation, codes and permits, the requirements for cross connection control programs are open to interpretation. This leads to inconsistencies in application, scope and priority.

WHAT DID WE HEAR?

CROSS CONNECTION CONTROL PROGRAMS ARE INCONSISTENTLY APPLIED BETWEEN COMMUNITIES.

Communities benefit from consistent messaging regarding their cross connection control responsibilities. Some communities have defined expectations on a Drinking Water operating permit, while others do not, resulting in programs ranging dramatically in scope and application.

CROSS CONNECTION CONTROL PROGRAMS ARE OFTEN NOT FUNDED PROPERLY.

Because cross connection control is not well understood, it is also not always funded in a way that supports a complete program. Often the program is run “off the side of the desk” and is deprioritized. This is especially true in smaller communities. Decision-makers are often not educated about cross connection control which means that business cases are harder to make convincing.

SMALLER COMMUNITIES NEED MORE SUPPORT.

Cross connection control programs are more difficult to implement in smaller communities Communities that are not incorporated do not have access to municipal grants The program responsibilities are the same as larger communities; however, they have access to less funding, resources, knowledge and expertise

SUPPORT FROM ELECTED OFFICIALS IS CRITICAL.

Cross connection control programs thrive or wither depending on the support they have from elected officials From voting on changes to bylaws to backing regulation changes that may not be supported by the public, elected officials need to have good information to make decisions supporting public health

WHAT MADE PROGRAMS SUCCESSFUL?

After reviewing the feedback from respondents, the following factors were identified to contribute to successful cross connection control programs

1. Cross connection control is a written requirement.

2. Municipal and operational leaders understand the importance of cross connection control.

3. There is a cross connection control bylaw that contains specific language regarding enforcement.

4. The cross connection control program is funded sustainably.

5. The community has an in-house champion on staff that advocates for the program.

6. The cross connection control program is well integrated with related departments.

7. The cross connection control program has an effective mechanism to identify and track backflow prevention devices, backflow device testers and hazardous environments.

8. Bylaw enforcement is used effectively to compel the use and ongoing testing of backflow devices.

9. Program staff are well supported both within their organization and with their municipal counterparts.

RECOMMENDATIONS

1. CODIFY CROSS CONNECTION CONTROL

Communities want consistent expectations. The requirement for cross connection control programs to exist in all communities should be written into provincial regulations to ensure consistent application throughout the province. Additionally, this requirement should outline the minimum requirements of a cross connection control program and include consideration for all hazards and the use of certified backflow device testers.

2. ESTABLISH FUNDING TO SUPPORT THE IMPLEMENTATION, REVIEW AND EXPANSION OF CROSS CONNECTION CONTROL PROGRAMS

Having adequate funding sources was seen as one of the biggest barriers to being able to build a complete cross connection control program Grants should be provided to communities setting up cross connection control programs to ensure best practices and program consistency are encouraged and that sustainable funding mechanisms are established

Additionally, grants should be provided to existing communities Often programs are “held together” with one passionate employee and are at risk of dissolving should that employee leave the organization Providing funding to enable communities to review their existing programs against best practices and sustainability planning becomes an investment in public health

3. SUPPORT NEW AND EXISTING CCC PROGRAMS WITH MECHANISMS TO SHARE BEST PRACTICES AND TEMPLATES

While knowledge sharing mechanisms do exist, they are not broadly available across the province. Focus should be made on providing greater access to guides, templates, peer mentoring, information sharing and other resources.

Importantly, resources that provide education to decision-makers, program administrators and property owners should be made available to ensure maximum buy-in for the program.

RECOMMENDATIONS

4. SUPPORT SMALLER COMMUNITIES WHO DO NOT HAVE THE SAME ACCESS TO FUNDING AND RESOURCES

Create support for communities who fall outside of the municipal infrastructure Support for these communities can include guides and templates designed specifically for their circumstances, funding to establish a program and peer mentoring

Resources can be distributed through the different communication mechanisms already established in the province, including the BC Small Water Systems Community Network, the Small Water Systems Online Help Centre and Health Authorities

5. ESTABLISH PUBLIC EDUCATION CAMPAIGNS

It is important to support educating the public on backflow hazards within their own properties and the cross connection control programs that protect their health and safety on a larger scale. It also has the greatest cost for community programs.

The provincial and federal governments can be important conduits for this activity, building public awareness campaigns that cross many community boundaries. Larger municipalities and regional districts can also play a big role.

6. RECOGNIZE THE BCWWA AS THE CERTIFICATION BODY FOR CROSS CONNECTION CONTROL

With consideration to provincial consistency in the first recommendation and the established certification infrastructure, the BCWWA should be recognized as the certification body for cross connection programs In doing so, competency standards will remain consistent with Canadian counterparts and the existing infrastructure of post-secondary institutions and tester databases can continue to serve the cross connection control community

7. REVIEW THE ROLE AND CERTIFICATION OF THE BACKFLOW INSPECTOR/SURVEYOR

Given the changing cross connection control environment and new technologies, especially related to water reclamation, it is worthwhile to consider reviewing this certification and ensuring that it meets the needs of the community.

ABOUT THE BC WATER & WASTE ASSOCIATION

The BC Water & Waste Association (BCWWA) is a not-for-profit organization that represents over 4,000 water professionals who are responsible for ensuring safe, sustainable, and secure water, sewer and stormwater systems in BC and the Yukon. Our members work every day to keep our water systems clean and safe – from source to tap to drain and back to the environment. They include water and wastewater facility operators, utility managers, engineers, technicians and technologists, consultants, government policy and regulatory staff, backflow assembly testers and cross connection control specialists, researchers and suppliers.

The Association delivers professional development, certification and advocacy programs and services to ensure that our water systems continue to protect public health and the environment.

As a not-for-profit organization, any net proceeds generated from membership fees or our programs and services are reinvested into serving the needs of our members and water community.

The BCWWA represents the American Water Works Association (AWWA) and the Water Environment Federation (WEF) for the region of British Columbia and the Yukon. Through these relationships, the Association collaborates with other regional associations and has access to resources from across Canada and the United States.

The BCWWA has played an integral role in the development of community cross connection control (CCC) programs and certification for over 40 years in British Columbia and the Yukon and across Canada, working with counterparts nationwide through the National CCC Committee. The Association manages backflow tester certification, coordinating with postsecondary institutions and with CCC program administrators to provide a real-time tester database.

According to the Provincial Health Officer’s Drinking Water Report 2024, “In BC, the BC Water and Waste Association is the recognized administrative body for the voluntary certification of backflow assembly testers and cross connection control inspectors.”

The strength of the BCWWA certification program lies in the trusted network of training institutions and community programs that have been nurtured through the years. The BCWWA has certified over 9,800 backflow testers since 2010, averaging just over 750 annually. Working closely with Approved Training Institutions (ATIs), instructors and exam proctors also ensures consistent standards around equipment and programs.

The BCWWA supports community CCC programs through the BCWWA CCC Technical Committee, which monitors changes to regulations. The BCWWA Education Committee is the mechanism for post-secondary institutions to agree upon common approaches to certification programs.

WHAT IS CROSS CONNECTION CONTROL?

Throughout the pipes, pumps and other infrastructure that transmit potable water from the water source to the consumer, there are opportunities for contaminated water to enter back through the pipes into the potable water supply.

When a backflow incident occurs, there is a risk of contamination or pollution entering the potable water system and subsequently transmitting unusable or unsafe water to the public for consumption. Severe health consequences can occur, especially for vulnerable populations.

The mechanisms for a backflow incident are backpressure, where downstream pressure is greater than the supply pressure, and back siphonage, where a vacuum or partial vacuum causes a negative pressure. Backflow preventer devices are used to mitigate these risks. Standards such as the Canadian Standards Association (CSA) B64.10 identify mitigation to various types of hazards that can cause a backflow incident.

The efficacy of a backflow preventer device is critical for the ongoing assurance of backflow prevention, and periodic testing of the device to accurately reflect the status of the device is required

While the installation of backflow preventers is part of new build standards (BC Building Code), the postinstallation monitoring of those devices sits within the purview of municipalities and their by-laws.

Because the risks of cross connection occur both within utility water distribution systems and within public and private buildings and properties, cross connection control is a shared responsibility between communities, businesses and residents. Cross connection control programs provide the structure to educate, monitor and hold accountable parties who have backflow hazards.

Backflow prevention is evolving

MACHINE COOLANT IN DRINKING WATER

During water main maintenance, a machine coolant back siphoned into the potable water pipes in a building

An employee took a drink of water from a water fountain and immediately vomited

The Canadian Standards Association (CSA) works regularly with stakeholders regarding the classification of cross connection examples Cross connection hazards are appearing in new situations For example, water reclamation is becoming more common in both public and private facilities Often, these facilities utilize water reclamation for functions that previously came from potable water and still use potable water as a backup

Heat pumps are being encouraged as a replacement for gas furnaces and air conditioners These devices utilize water that cycles through a closed system with several chemicals There is a mechanism for adding water to these devices that requires backflow protection and could cause severe health impacts if non-functional

WHAT IS A COMMUNITY CCC PROGRAM?

Community CCC programs are the mechanism for ensuring the public is continuously protected from backflow events contaminating their drinking water. They exist primarily to support the requirement of periodic testing of backflow preventer devices and ensure an accurate inventory of cross connection risks within the community. These programs exist in communities of all sizes and have a diverse scope of oversight.

At minimum, programs oversee public water distribution systems and publicly owned buildings. They also commonly cover private facilities with hazard risks identified through the Canadian Standards Association (CSA) B64-10 standard.

The requirement to have a cross connection control program in provincial regulation is vague at best, with reference only in Section 15 of the Drinking Water Regulation. The text includes cross connections within Assessment Response Plans. Subsequently, what a cross connection control program looks like, whether it meets the needs of the community and whether there is any oversight are all variations between communities

The Foundation for Cross-Connection Control and Hydraulic Research, in their Manual of CrossConnection Control, tenth edition, identified five components of a cross connection control program These include:

AUTHORITY

Ensure a program is enforceable.

BACKFLOW PREVENTERS

Ensure cross connections are protected with backflow preventers.

CERTIFIED TESTERS AND SPECIALISTS

Ensure a program is supported by individuals who are qualified to both identify/classify backflow hazards and test the backflow prevention devices

DEFENSIBLE AND DETAILED RECORDS

Ensure a program’s information is well managed so that it can be used in cases of tracking, enforcement and dispute

EDUCATION AND TRAINING

Ensure the community has access to cross connection control and backflow prevention information.

A complete program fulfills these components when it includes surveying backflow hazards, testing backflow prevention devices, records management, enforcement with property owners, education programs and emergency preparation.

WHAT ARE CROSS CONNECTION CONTROL INSPECTORS?

Cross connection control inspectors are individuals who conduct cross connection risk assessments on drinking water supply systems. The cross connection control inspector identifies and provides recommendations for existing and potential cross connections (outside the scope of the Building Code), assigns a hazard classification to each potable water connection, and recommends the method or device required to eliminate or prevent backflow.

Cross connection control inspectors also review plans, physically inspect the premises for potential or actual cross connections, educate customers and develop and enforce bylaws.

The BCWWA developed the Cross Connection Control Inspector Certification in 2012 in collaboration with post-secondary institutions who had been running similar curricula. The program includes a manual and certification exam. Once developed, this program was made available to all sections of the AWWA across Canada.

For further information, go to Cross Connection Control Inspector Certification on page 47.

WHAT ARE BACKFLOW ASSEMBLY TESTERS

Backflow prevention devices use various mechanisms to ensure that non-potable water does not flow back into the potable water system. These mechanisms may lose calibration over time, break or, in some other way, can become ineffective.

Backflow assembly testers are trained to complete assessments of existing devices using very specific steps and protocols. Without the proper completion of these steps, results cannot be trusted to verify that a device continues to be doing its job.

“In British Columbia, the BC Water & Waste Association is the recognized administrative body for the voluntary certification of backflow assembly testers and cross connection control inspectors.”

(PHO Drinking Water Report, 2024)

When backflow devices are improperly assessed, an opportunity for an adverse event opens up and both the community and the property owner are exposed to liability and risk

Backflow assembly tester certification grew from the realization that testing needed to be done by individuals who are specifically trained and current in their application. Training for backflow assembly testers is done through post-secondary institutions and certification exams are administered through the BCWWA.

For further information, go to Backflow Assembly Device Tester Certification on page 45.

PROVINCIAL HEALTH OFFICER’S DRINKING WATER REPORT

The Drinking Water Protection Act requires the Provincial Health Officer to report on activities that fall under the Act The most recent release, Clean, Safe, and Reliable Drinking Water: An Update on Drinking Water Protection in BC, 2017/18 to 2021/22, was published in 2024 This report provides an update to indicators and recommendations identified in previous reports while highlighting progress, new developments and new recommendations to continue the advancement of drinking water protection The previous report was published in 2019 and addressed the years 2012/13 to 2016/17

Within these reports are recommendations specifically regarding cross connection control These include:

(2019) Recommendation 16: Distribution System Integrity and Maintenance

(Develop provincial guidance for drinking water officers for the review and assessment of distribution integrity, management and maintenance that considers the varying sizes, capacities, and complexities of water systems (Lead: Ministry of Health in consultation with the regional health authorities )

Because cross connections are a known typical hazard within water distribution systems, they need to be part of this recommendation. In 2019, this was marked “In Progress.”

The 2024 follow-up report indicates that “Having a cross connection control program and/or backflow prevention devices in place” is a key indicator to address this recommendation.

(2019) Recommendation 18 Ensure water supply systems have appropriate plans/procedures in place to proactively identify and address cross connections. Encourage all local government water purveyors to have an enforceable cross connection control program.

(Lead: Regional health authorities)

The 2024 follow-up report identified that some of the health authorities have begun working towards understanding the landscape of CCC in their locality while others have yet to begin. It also identified that CCC programs are more often found in communities with larger water systems, while smaller water systems are limited in their ability to implement a cross connection control program.

These reports provide important context regarding cross connection control within the province, and the importance that is placed by the Province of British Columbia

ABOUT THIS REPORT

The Protecting our Communities from Backflow Contamination: A Review of Cross Connection Control Programs in British Columbia report is the culmination of learnings from the municipal CCC program survey, visits with post-secondary institutions that offer backflow testing certification, literature and a BCWWA technical committee The report is intended to provide some aggregate information to contribute to informing policy and decision-making at multiple government levels

In 2023, the BCWWA embarked on the Community CCC Program survey to serve the following goals:

1. Provide insight regarding how cross connection control programs are being implemented within the province.

2. Provide insight into how the BCWWA can better support community CCC programs.

3. Provide the opportunity to report back to municipal, regional and provincial entities aggregated data regarding the community CCC programs.

27 communities participated in the research project, providing insights from both large and small communities dispersed throughout the province Additionally, the BCWWA Cross Connection Control Technical Advisory Committee was engaged to provide additional context and technical support

As a result, a robust set of data has been compiled, providing important insight into the barriers and best practices that drive successful cross connection control programs

Survey Process

The research involved having respondents complete a survey and then participate in a followup interview to expand on survey responses All respondents were given the opportunity to review the notes from their follow-up interview to ensure that all information was correct

During the survey process, participants were asked 45 questions related to the following areas: components of their program, inventory of cross connections, bylaws, staffing, certified backflow testers, program funding, enforcement, program support and resources The results of this information gathering process have been incorporated and have become the basis for recommendations in this report

There are a variety of legislation and regulations that govern cross connection control in British Columbia They span from federal to local jurisdiction and include required and optional requirements While each serves its purpose, there are challenges

During the interview and survey processes, respondents were able to comment on the regulatory environment and expressed concerns regarding different areas This section provides insight into the regulations and the impact on the respondents

FEDERAL STANDARDS

TITLE APPLIES TO NOTES

Canadian Standards Association (CSA) B64 Series

National Plumbing Code of Canada

All backflow prevention devices Contains recommendations for grading backflow prevention devices, certifying testers and creating bylaws for the approval, selection process, installation and recommended testing procedures of backflow preventers.

All plumbing installations Includes the arrangement of piping, protection from contamination and the size and capacity of pipes Also specifies how potable water systems shall be protected from any source of pollution or contamination

Table 1: Federal Standards

Canadian Standards Association (CSA)

The Canadian Standards Association has a working group focused on cross connection control. Through this working group, sections B64-10 and B64-10.1 are reviewed and updated. The B64-10.1 standard includes non-binding recommendations and guidelines.

The standards identify hazard classifications and remedies. These hazards run from small appliances to water utilities. As such members of this working group include representatives from industry, plumbing and cross connection control.

The CCC National Committee works to keep a member on this committee both to represent cross connection control programs and to provide a balanced voice regarding new technologies.

The CSA standards are updated every four to six years. Transitioning between standards takes time. As a result, different codes and regulations that refer to these standards may not be aligned with the most recent standards. Additionally, certified backflow assembly testers as the skillset for device testing, is only referred to in the B64-10.1 guidelines section. Both conditions open the standards to interpretation and lead to inconsistent application.

National Plumbing Code of Canada

The Canadian Plumbing Code is used by the plumbing industry as the defacto site for plumbing applications The Code identifies how potential cross connections shall be addressed and references CSA B64 10, “Selection and installation of backflow preventers ”

PROVINCIAL REGULATIONS

TITLE

BC Drinking Water Regulation (Drinking Water Protection Act)

APPLIES TO

All water purveyors

BC Municipal Wastewater Regulation (Environmental Management Act) Reclaimed water systems

NOTES

Provides guidance to water purveyors regarding their water systems

Provides guidance to purveyors of wastewater systems

BC Building Act All new building permits Ensures consistent approaches to building standards across BC.

BC Building Code All new building permits Identifies standards used within BC. References the BC Plumbing Code.

BC Plumbing Act All new building permits Identifies plumbing standards used in BC For backflow prevention devices, the BC Plumbing Code references the CSA and the National Plumbing Code of Canada.

Table 2: Provincial Regulations

BC Drinking Water Protection Act and BC Drinking Water Regulation

The BC Drinking Water Regulation sits within the BC Drinking Water Protection Act. It serves to guide water utilities in their responsibilities regarding clean, safe drinking water.

Backflow prevention is referenced in the BC Drinking Water Regulation (Section 15) as being a required component of Risk Assessment Plans. The regulation states that all water purveyors must identify and manage backflow risks.

Second, the BC Drinking Water Protection Act grants the Health Authority (Drinking Water Officers) the ability to require a community to have a cross connection control program through their drinking water permit as a component of risk plans.

The BC Drinking Water Regulation does not go into detail regarding the level of cross connection control that would be acceptable. Instead, it relies on the Drinking Water Officer to make that determination. As a result, some communities only focus on premise isolation to meet their obligation.

BC Environmental Management Act and BC Municipal Wastewater Regulation

Traditionally, potable water has been utilized for functions that do not require clean, treated water For example, toilets, water hydrants and irrigation systems do not require potable water for their use but they have been traditionally hooked up to the potable water supply The changing climate and reality of water shortages encourage innovation in water reclamation as a way to minimize this practice

The BC Municipal Wastewater Regulation requires reclaimed water distribution systems, such as rainwater capture, irrigation and other mixed environments, to ensure that the individual operating or maintaining the site must be a person certified in cross connection control inspections As reclaimed water systems increase, so too will the need for certified cross connection control inspectors/surveyors

BC Building Act

The BC Building Act states that all new permits for buildings must follow the same standards and refers to the BC Building Code and BC Plumbing Code to define those standards. Administrative functions, such as ongoing maintenance and monitoring of backflow prevention devices, are managed by local bylaws.

When the update to the BC Building Act in 2015 occurred, there was some confusion within the cross connection control community, especially regarding who is able to conduct backflow device testing. Previously, the device testing was to be done by a certified backflow assembly tester, as identified in the municipal bylaw; however with the 2015 update, the responsibilities blurred because the referenced CSA standard only identified a certified backflow assembly tester as recommended (B64.10.1). As a result, new installations have different criteria for device testing.

BC Building Code and BC Plumbing Code

The BC Building Code and the BC Plumbing Code are the references used by tradespeople and municipalities to ensure that buildings and installations meet a consistent standard across the province Both references refer to standards set forth by the Canadian Standards Association and the National Plumbing Code of Canada

One of the challenges with these reference documents is the version of standards for the BC Codes may not align with the most up-to-date national standards When these standards are inconsistent, there is an increased potential for confusion and interpretation For example, the BC Codes are mainly based off of the 2020 National Codes, which reference CSA B64 10 and B64 10 1 2011 standards, even though the standards were updated in both 2021 and 2024

Currently, there is no requirement in the standards to use a certified backflow tester to do a test on a newly installed device The Building Code Appeals Board confirmed this opinion (BCAB #1773) The risk is that the person signing off on the installation may not actually be qualified to test the device Devices that are not performing as required can be a risk to public health Certified backflow testers must maintain their credentials every five years to ensure that they are performing the tests correctly

DRINKING WATER PERMITS & HEALTH ORDERS

TITLE

Drinking Water Operating Permits

APPLIES TO NOTES

All water purveyors

Health Orders All water purveyors

Requirements for cross connection control programs are variable throughout BC and at the discretion of the permit issuer

Some communities are served with health orders from the Health Authority placing cross connection control as a condition.

The primary mechanism for compelling a community to have a cross connection control program is the drinking water operating permit that is provided by health officers from the different health authorities as a condition of use Alternatively, sometimes the condition is placed in a health order as a separate document

The Drinking Water Protection Act specifies that a Drinking Water Officer can place terms or conditions on a community’s water operating permit and has become the mechanism for adding cross connection conditions to specific permits There is no specification that cross connection control MUST be a condition of water operations or how it is stated As a result, there is provincial inconsistency regarding the application of cross connection control requirements

For example, in the communities that did have a condition of cross connection on their permits, some conditions simply stated, “Must have a CCC Program,” whereas other conditions guided the requirement with stipulations and stressed the importance of having a robust CCC program to protect the public health of the population and drinking water supply

Of the communities interviewed, about half have a CCC program identified as a condition of their Drinking Water operating permit or on a health order

When there are no clearly stated requirements for a cross connection control program either by a Drinking Water Permit condition or other mechanism, any existing cross connection control program is at greater risk, and the likelihood of a community implementing a cross connection control program is vastly reduced When the requirement exists, the case for funding, staff time and any other required resources becomes more apparent

Respondents described that without an external requirement, their program becomes reliant solely on the knowledge and commitment of decision-makers to fund the program or the commitment of the program champion to do the work “off the side of their desk ” These programs can become deprioritized against competing organizational priorities

Respondents with explicit conditions on their permits or with a health order described more support for their programs by decision-makers.

Table 3: Drinking Water Operating Permits

Notes:

Numbers reflect only respondents This is not indicative of the entire municipal population Community sizes: large (100,000 + ), medium (30,000-99,999) and small (1,000-29,000). 1 2

1 Capital Regional District (CRD) is covered by two Drinking Water permits that do not have cross connection control identified within An Island Health Order (2004) does provide the requirement for a robust cross connection control program. The CRD encompasses 412,500 (2023) residents over 13 municipalities and three electoral areas on Southern Vancouver Island and the Gulf Islands

2 Based on 2021 census data from Statistics Canada

Figure 1: Drinking Water Operating Permits and Health Orders by Health Authority

MUNICIPAL BYLAWS

TITLE

Bylaws

APPLIES TO NOTES

Existing structures and backflow prevention devices

Table 4: Municipal Bylaws

Municipal bylaws address the ongoing maintenance of existing backflow prevention devices

Because monitoring existing backflow prevention devices is considered an administrative function within the BC Building Act, communities accomplish this by creating or updating a bylaw to provide jurisdiction to the municipality regarding cross connection control, identify expectations and enforcement.

The BC Drinking Water Regulation does state that all water purveyors must include backflow prevention as part of their assessment response plans. 89% of respondents identified that their community had a bylaw that spoke to backflow prevention, despite only half of respondents having a requirement for a cross connection control program on their drinking water operating permit.

Of the respondents who stated that they did have a bylaw with cross connection control, 54% identified that it was inserted into a larger waterworks bylaw. 46% identified a separate standalone bylaw. The language of the bylaws also varied across respondents. Some had no enforcement mechanism identified Others outlined backflow prevention requirements in great detail

Respondents identified that having a stand-alone bylaw was preferable, as the changes were more straightforward The stand-alone bylaws also tended to have more information regarding the program and processes This is important because of the changing cross connection control environment that may require updates to bylaws over time

The Canadian Standards Association (CSA) B-64 10 1 provides guidelines around creating bylaws and the component parts Additionally, some municipalities shared their bylaw language with their counterparts

Figure

CCC Bylaw Configurations

REGULATORY CHALLENGES

Regulation Authority

The different Acts and Codes that relate to cross connection control can be confusing to navigate Some regulations apply to only a portion of cross connection control scenarios

Much of the regulation is specific to new and modified building permits The BC Building Act specifically applies to new permits and relegates maintenance to the administration portion of the Act Administration is delivered by municipalities at their own discretion None of the Building Act or related codes require an administrative monitoring program

Government oversight of cross connection control crosses several ministries and agencies. The BC Ministry of Health identifies backflow prevention in the Drinking Water regulation; however, it does not define what is included in a cross connection control program. Additionally, the Ministry is not responsible for enforcing the regulation. Instead, the Health Authorities are responsible and are given the authority to use their discretion in enforcement.

The BC Ministry of Housing is responsible for ensuring there is proper representation of cross connection control in plumbing standards but does not provide any guidance towards what makes someone qualified to test devices.

Other ministries, such as the BC Ministry of Environment and Climate Change Strategy, have jurisdiction over reclaimed water usage and require cross connection control inspectors to control the backflow risks.

As a result, there is no clear regulatory authority that looks holistically at backflow prevention and the responsibilities of the communities to ensure protection of public health through cross connection control programs.

Best Practice vs. Requirement

Guidelines and best practices are less convincing than regulation. Respondents described how this gap made communicating to leaders and decision-makers about the importance of cross connection control programs much more difficult.

The inconsistency of the Drinking Water operating permits – whether a cross connection control program is required and what it contains was also identified as problematic.

Some respondents identified that they had difficulty communicating the importance of certified backflow testers because they are stated in (CSA B64.10.1) guidelines only. Having trained personnel to do hazard surveys is also a best practice instead of a requirement in most situations.

When expectations are inconsistent, developing the business case to implement a robust cross connection control program becomes much more difficult. When all communities are subject to the same requirements, it is much easier to communicate requirements and the reasons behind those requirements.

Requiring Certified Backflow Device Testers

Ensuring that devices are tested accurately from the first installation to repairs and throughout their lifespan requires competent, up-to-date individuals.

The inconsistency in the different codes and applications, depending on whether it is a new permit or in maintenance stage, exacerbates the confusion expressed by respondents.

For example, the BC Building Act, through its referenced codes, makes it clear that a plumber or plumbing apprentice must install backflow prevention devices. Building or plumbing inspectors or a licensed engineer at that point can sign off on the installation, even though they are not required to be trained in cross connection control or to maintain any currency in testing protocols.

Device testing post-installation falls into the administration component of the Building Act and is the purview of the municipalities. The Canadian Standards Association provides guidelines and best practices for establishing a program; however, it is at the discretion of each community regarding the extent that they choose to follow the guidelines.

Certified backflow device testers are endorsed as best practice by respected industry organizations, including the Foundation for Cross-Connection Control and Hydraulic Research (University of Southern California), the Committee on Public Water Supply Distribution Systems (National Research Council), the Federation of Canadian Municipalities and the Canadian Standards Association.

OVERVIEW

The research project focused primarily on how respondents implemented their cross connection control programs and environmental conditions that helped or challenged their programs. This section reviews the programs from three different perspectives.

How the program is defined

It became apparent during this project that communities define the parameters of their cross connection control programs in different ways This was divided into two components:

Departmental responsibility

Program scope

Program components

The components of each cross connection control program can be divided into six areas. The extent to which each community developed these areas varied considerably.

Backflow hazard surveys

Backflow device testing

Records maintenance

Enforcement

Emergency preparation

Education

Overall program themes

During the research process, the following overarching themes were identified:

Program health

Staffing

Software solutions

Financial sustainability

Knowledge sharing

Education and awareness

Certification programs

Each of these topics will be discussed in greater detail in this section.

DEPARTMENTAL RESPONSIBILITY

Ensuring that a department has a clear responsibility to achieve the goals of the cross connection control program is very important. While several departments may have resources whose roles integrate with the cross connection control program objectives, having a department that “owns” the program ensures that there is a clear agreement on responsibility and oversight. Additionally, how the program is funded may be impacted by the department where the program is situated.

Respondents identified a variety of departments where the cross connection program was positioned. Some of the larger programs identified that they were positioned within the Engineering and Planning departments, which provided proximity to decisions regarding new projects.

Other programs were positioned within the waterworks department. In doing so, the program could be funded through water rates. The challenge with this decision, however, is ensuring that the program does not stop at the property line, as is the case with water distribution systems.

Still, other programs were positioned with the building and plumbing inspectors.

Some respondents identified shared responsibility between a few different departments, including operations, parks and facilities, public works, facility maintenance and bylaw enforcement.

How the departments collaborated differed as well. Some communities have departments that position the cross connection program in isolation from other departments whereas others have components of their cross connection program spread across a few departments and are somewhat or very collaborative with other departments.

The size of community also played a role in how the programs were positioned. Smaller communities tended to have fewer departments covering more responsibilities, whereas larger communities were more likely to have more targeted departments.

PROGRAM SCOPE

Because conditions on drinking water operating permits or health orders do not necessarily have specificity in how a cross connection control program is delivered, the interpretation of the requirement is left to the community. Depending on the resources available, the support of leadership and other similar factors, decisions are made regarding the scope of the program.

Most important is the extent to which backflow hazards are assessed and monitored through the program. There are two ways to look at program scope: the types of properties included and how those properties are monitored.

Types of Properties

Figure 3: Types of Properties Covered by Cross Connection Control Programs

When drinking water operating permits or health orders lack clarity regarding the type of property being monitored, program decision-makers will determine the types of properties that are in and out of scope Copyright© 2024 BC Water & Waste Association

The demographics of a community will play a role in determining program scope. For example, there may not be any agricultural properties within the community boundaries.

Respondents to the question of the scope of their program did view “include” in different ways. For example, while the above figure shows that most community programs identified a wide variety of areas where backflow devices are inventoried, when respondents were asked if they include a regular survey intended to inspect and/or audit existing ICIA (industrial, commercial, institutional or agricultural) properties, only 52% said that they did.

Isolation Scope

There are two types of hazard inclusions that need to be considered within a cross connection control program hazard assessment survey: internal isolation and property isolation.

Internal Isolation

The backflow hazard risk for a facility is dependent on the type and number of cross connections it contains. This will be different between types of facilities and the types of equipment used on the property. Risks can range from irrigation systems to sprinkler systems to carbonation machines to industrial equipment. Each cross connection is assigned a risk designation in CSA B64.10 and is used as a reference for determining the risk hazard rating.

Property Isolation

Property isolation utilizes backflow prevention devices situated outside of a building, with the objective of keeping any backflow from entering the water distribution system and isolating the issue to the one property. Property isolation is an extremely effective method for keeping an adverse incident from spreading throughout a community.

Survey Scope

Hazard assessment surveys are most effective when they combine internal isolation with property isolation. Complete surveys that include all backflow risks provide a comprehensive picture of the community and the buildings and facilities within it. This provides opportunities to promote device testing, focus education programs, prepare for emergencies and, most importantly, to inform decision-makers about the scope of cross connections in the community.

Respondents who did combine internal and property isolation into their hazard assessment surveys were more likely to have cross connection control inspectors on staff. Smaller communities hired external consultants to complete the task on a scheduled basis. Not all respondents indicated that they completed assessments of internal and premise isolation. Some respondents indicated that they only focus on premise isolation. While serving to protect the broader population from backflow entering the water distribution system, there are disadvantages to this approach.

Understanding the level of severity of risk comes from performing an internal isolation hazard assessment. Without this step, a property may be over or under-assessed for its backflow risks, resulting in property isolation devices that may be over or under-installed. By placing appropriate backflow preventers in the building, property owners may be able to avoid more costly property isolation devices.

Most importantly, it is a critical step in mitigating negative health outcomes for the users of the property. Individuals within a building are not protected from a backflow incident through property isolation.

Finally, the act of performing a backflow assembly test on a premise isolation device can prompt a backflow incident within a building due to changes in pressure. When the internal risks are understood, the tester can work with the property owner to mitigate any issues that occur during testing.

While the combined approach to monitoring may have more upfront costs, it is also the most effective, protects the public and has the greatest potential to mitigate liability or public perception of liability in the event of an adverse backflow incident.

PROGRAM COMPONENTS

There are six main components to cross connection control programs.

The way that cross connection control programs are implemented and how different components of the program are designed varied among all the respondents.

4: Cross Connection Control Program Components

1. Backflow Hazard Surveys

Section 22 of the Drinking Water Protection Act states that all water purveyors must provide a hazard assessment plan, and included in it, the identification and remediation plan

Surveys are used to inspect and audit existing properties for hazard levels These may include industrial, commercial, institutional and agricultural (ICIA) properties, as well as residential buildings like apartment complexes They are an important tool in ensuring a robust cross connection control program

Based on respondent feedback, there is currently no consistency regarding how surveys are conducted The main difference is inclusion criteria (i e , who to survey and how often surveying is completed) 52% of communities stated that they do regular surveys Of those communities, 50% identified a five-year review cycle Most of the remaining communities cited cycles of up to ten years One surveyed community performed annual surveys

Among the respondents who stated that they did not do regular surveys, several identified alternate mechanisms to gather information This included surveying new properties or properties with changes to their hazard level

Figure

Other communities admitted to surveying but with no set schedule Others noted stopping the survey program altogether based on the limited perceived value of the information being gathered

Some respondents described relying heavily on the inspections made during the permitting process instead of performing separate surveys This approach is problematic – allowing for gaps in the information, as changes are often made to a system or connection unbeknownst to the inspection department

The ability to achieve the expected survey schedule was dependent on several factors, such as ensuring surveying was part of policy, staff capacity and resources Planning was identified as critical to ensuring that any cyclical activity, such as surveying, was implemented with the appropriate resources and staff support

2. Backflow Device Testing

At the heart of any cross connection control program is the verification that all high and severe-risk cross connection hazards are identified and existing backflow prevention devices are verified to be working as they should. To achieve this, programs need to have tests performed on the existing backflow prevention devices by a qualified backflow tester.

Backflow device testing has several inconsistencies across communities. To begin, some communities choose to employ backflow testers, while others rely on contractors.

Testing reports contain data that indicates the device is in good working order. This report is submitted to the cross connection control program as proof of verification. The Backflow Tester is required to sign off on the verification as part of the report. Currently, there is no consistent report template across programs This becomes an issue especially in areas where there are multiple cross connection jurisdictions, such as the Lower Mainland Testers need to ensure they are using the correct template for each community

The frequency of testing is also inconsistent between programs The availability of resources is often the largest factor in determining how often reports are submitted

Figure 5: CCC Program Components - Backflow Hazard Surveys

3. Records Maintenance

Cross connection control programs require a consistent mechanism for tracking backflow hazards and testing results. Processes and consistent documentation are required to demonstrate due diligence and to protect the organization in case of dispute. Clear documentation around the device testing process, enforcement escalation process, backflow tester validation, report auditing and communication are only a few of the processes that a cross connection control program may utilize.

Additionally, programs need to ensure that they have consistent documents to support the processes. These may include backflow tester reports, complaint reports and bylaw enforcement as examples.

Test reports should be maintained not only to monitor compliance but also to provide background information and mitigate liability should an adverse event occur. Ensuring that reports are filed and available for review is an important function of records maintenance. This allows for auditing the tests done, the testers for qualification and the property for compliance.

ANNUAL TEST REPORT COLLECTIONS/NOTICES

Tester Report Audits

Respondents identified auditing tester reports as an important function of the cross connection control program. This included reviewing reports for proper completion and even retesting devices to ensure the results were similar. They also expressed a desire to share information about processes and templates, wanting to avoid “reinventing the wheel” where possible.

Gauge Calibration Monitoring

Calibration monitoring involves ensuring that the gauge used for testing backflow assembly devices is calibrated correctly. When incorrectly calibrated, test results are not accurate. 59% of communities have established gauge calibration monitoring processes, whereas 30% have nothing in place. Those with established gauge calibration processes varied depending on whether they were monitoring internally or externally.

Communication

Communication is an important aspect of the records maintenance program component Many respondents indicated that they proactively reached out to property owners regarding their upcoming device testing requirements These communications, whether in letters or by email, served as a mechanism for increasing testing compliance and providing back-up for any enforcement activity

Additional communication can also be educational to inform property owners of their responsibilities regarding backflow prevention

4. Enforcement

The enforcement process varied considerably across communities and was dependent upon a variety of factors, such as staff and resource availability and whether enforcement was included in the bylaw used to drive the program.

Not all bylaws are the same. Some bylaws do not outline enforcement mechanisms. This increases the difficulty in a cross connection control program being able to ensure compliance. Most community bylaws do include an enforcement clause, which supports any need to escalate when faced with property owners who are unresponsive or unwilling to comply with backflow testing requirements.

Communities tend to use a multilayered approach, attempting options of least resistance first before employing stronger strategies. Some communities applied an “educate and regulate” approach. Others utilized tracking and communication processes such as sending out notices. Conducting inspections or sending advanced notices based on staff knowledge was also common. Approximately half of the communities use ticketing as a mechanism of enforcement and only a few communities use water shut-off.

Stronger enforcement mechanisms require more resources to enact. The work required to document and ticket a site is vastly greater than sending information in a flyer.

Respondents identified that using the information and reminder tactics as part of their strategy minimized the number of escalations, thereby having a direct impact on the number of resources required to run the program

Respondents did highlight the value of having enforcement mechanisms in place through bylaws, policy and staff support. Being able to effectively address escalations enabled more available resources to support the entire cross connection control program.

Those communities without bylaws expressing enforcement mechanisms were considerably hindered in their enforcement options

Figure 7: CCC Program Components - Enforcement

5.

Emergency Response Planning

The Drinking Water Protection Act (Section 10) requires every water supply system to have an Emergency Response and Contingency Plan (ERCP). While not specifically stated, cross connection is implied through its reference to the Drinking Water Regulations.

Respondents indicated a wide range of readiness with ERCPs. This may be an indicator of the level of resources assigned to cross connection control programs and the time available to complete this type of activity It may also be an indicator of limited access to templates that may help the planning process

Several respondents suggested that their ERCPs tended to focus on more general activities and didn’t highlight cross connection control specifically

EMERGENCY RESPONSE PLAN FOR A BACKFLOW INCIDENT

6. Education Programs

Education programs are used to gain compliance and buy-in from different stakeholders They also are an important component of keeping the public safe by ensuring that property owners understand their shared responsibility regarding cross connection control

Education programs can also include information sharing with the public Only one-third of respondents indicated having education programs established However, other communities were in the early or middle stages of development A scan of several municipal program websites showed information about the program, backflow prevention and other related topics

PUBLIC EDUCATION / AWARENESS PROGRAMS

Figure 8: CCC Program Components - Emergency Response Planning

Figure 9: CCC Program Components - Public Education and Awareness Programs

PROGRAM HEALTH

When respondents were asked to describe the state of their cross connection control program, 41% indicated that they did not have a fully active program. While initially surprising, this indicates the importance of having staff that are able and willing to run the program.

Program Champions

Respondents were very clear that their cross connection control programs were often energized by one passionate individual who became the key factor in the success of their program, both in program implementation and ongoing sustainability These champions often pushed program progress forward regardless of the status of cross connection control as a condition on a community’s water operating permit

HOW WOULD YOU DESCRIBE THE CURRENT STATE OF YOUR CROSS CONNECTION CONTROL PROGRAM?

Figure 10: State of CCC Programs

This enthusiasm is extremely valuable as a mechanism for growing the cross connection control program, most importantly when there is support for this “champion” individual from leadership. Strong champions lead to innovative and robust approaches for running the cross connection control program.

Leadership support is not a given. Several program leads, who were often champions themselves, described moving their programs forward despite having adequate resources, working “off the side of their desk” or having any kind of back-up. As a result, the program stalled during vacations and leaves.

Program Resilience

Some respondents identified challenges related to complacency and fragmented authority, which may impact access to required resources. Inadequately funded programs are not able to dedicate time toward program development.

Regulatory direction is important. Without clear direction on the necessary components and lack of consistency in legislation around minimum requirements for a CCC program, as little as possible is often done.

The different states for the programs shown above may indicate changes in staffing, leadership or funding and the subsequent lack of resilience to these changes. For example, if one person is leading the program and then retires, the organization may be delayed in hiring a replacement or may choose to hold off as they conduct an assessment about the need for the program. Momentum is stalled and the program slides. This is particularly the case when a program is present only due to the passion of one individual.

STAFFING

Cross connection control programs require resources to accomplish multiple tasks. These include administrative activities, such as communicating with property owners and tracking reports. Other activities involve surveying properties and doing risk assessments and conducting backflow device testing. Finally, enforcement activities for non-compliant property owners need to be performed.

Depending on the structure of the program and the size of the community, respondents indicated very different approaches to staffing.

PROGRAM STAFFING

Less than 1 0 FTE

30%

NOTES

Tends to be partial FTE across one or multiple staff Role is most often a technician or coordination within the utilities or engineering department.

1-3 FTE 52%

More than 3 FTE 19%

Table 5: Staffing Approaches Based on FTE

Both clerical and technical staff. Common combinations of administration assistant or program coordinator, an operator or plumbing and a supervisor or manager

Generally comprised of multiple staff with different roles, including managerial or supervisory, data and administration, operators and plumbing inspectors

The number of staff involved in the cross connection control program differed as well depending on whether they hired staff to perform tests or required property owners to hire contractors Over half of the communities used external, contract or third-party for their program

Programs that identified less than one staff member tended to extend the duties of an existing employee to include the cross connection control program As a result, only a small percentage of time is dedicated to building and sustaining the program in the long term Additionally, the “off the side of the desk” approach led to challenges around contingency planning and program consistency

Formalizing job descriptions was seen as a valuable step in ensuring that the cross connection control program developed into a formalized program within the organization They were also viewed as an important tool for finding qualified individuals to fulfill the roles

Several respondents regularly utilized external contractors to mitigate the issue of capacity or as a tactical decision based on the demographics of the jurisdiction This approach introduces different challenges and ensures that clear direction for the contractors is an important mitigation

Program Administrators/Coordinators

Program administrators/coordinators are responsible for ensuring the cross connection control program is run effectively. Depending on the organization, administrators may originate from the operations function or the administrative function. They may or may not have formal training of cross connection control.

The program administrator will be able to do more aspects of the cross connection control program if they have an education aligned with cross connection control. Having CCC inspector and/or backflow assembly tester certifications are valuable designations as they provide credibility with the other program participants and enhance the reach of activities, such as hazard surveys and report audits.

Clerical Staff

Some communities retain a clerical position or partial position for the purpose of managing the record keeping process. This could include sending out communications and filing reports. Other communities incorporate these functions into the program administrator/coordinator's role.

Cross Connection Control Inspectors

It is important to complete cross connection control surveys correctly to ensure that all backflow hazards have been identified, classified and inventoried The Cross Connection Control Inspector Certification ensures that the surveys are completed correctly and comprehensively

Research completed in 2016 by the BCWWA suggested that only some communities chose to keep a certified CCC inspector on staff Other communities chose to contract external consultants to complete the survey on a one-off or scheduled basis Others utilized individuals designated as building or plumbing inspectors to do the work

For further information regarding the Cross Connection Control Inspector/Survey Certification, see Cross Connection Control Inspector Certification on page 47

Certified Backflow Testers

All communities that have cross connection control programs require certified backflow testers to test backflow devices. These testers can be staff or contractors that test public buildings and water systems or testers hired by the property owner to complete and submit a testing report.

The BCWWA supports the ongoing development of backflow testers by administering and adjudicating certification offered through post-secondary institutions throughout the province. The certification program is developed and maintained in partnership with AWWA sections across Canada. Updates to the exam, the manual and certification requirements occur through the National Committee.

A real-time list of active testers is available to community CCC program administrators through the BCWWA website to ensure that backflow device tests are done by qualified individuals. The BCWWA also works with vendors who provide tracking programs for cross connection control programs to ensure consistency between their software and the BCWWA active tester database.

For more information about the BCWWA Backflow Assembly Tester program, see Page 45.

Bylaw Enforcement Officers

Bylaw enforcement officers are often used as a part of the enforcement mechanism to compel property owners to install, maintain and test their backflow devices. Often, bylaw officers are not aware of cross connection control and need to be trained to understand the purpose of the bylaw and the mechanism for enforcement.

Bylaw enforcement officers often work closely with program administrators when moving through an enforcement process.

Building and Plumbing Officials

Building and plumbing inspectors provide important expertise in the cross connection control program They are required by legislation to ensure that buildings and plumbing installations meet regulations Their expertise is most often triggered by permit applications, although they may also be used by bylaw enforcement officers

Good collaboration with the building and plumbing inspectors and the cross connection control program contributes to a more complete inventory of cross connection hazards in the community

The extent to which these roles are used to conduct cross connection hazard surveys is dependent on the community, role description and capacity

Engineers and Planners

Engineers who review permits have an important role in ensuring that backflow prevention devices are considered as part of the review process. Some respondents identified that their cross connection control program was based out of the engineering and planning department for that reason.

Capacity

Consistently, respondents commented that their program was limited by the staff that were available to do the work

Cross connection control programs that are below capacity in staffing affect the ability for key activities to occur both in the short-term and long-term For example, a community may have a policy in place to audit a property periodically but meeting this timeline depends heavily on whether there are staff to conduct the audit

Surveying is another task heavily reliant on staff resources. Surveying potential backflow hazards is a proactive way to inventory cross connections, mitigate risks and to educate the property owners in the community. This is a required activity; however, responses varied from surveys being done daily to not at all. Surveying may be impacted both by overall staffing capacity and by having staff that are trained to perform surveys – available through the Cross Connection Control Inspector/Surveyor Certification.

The Capital Regional District partners with Camosun College throughout the year to run Q&A sessions. The sessions highlight the importance of backflow maintenance and testing and the risks associated with the lack of it.

Backflow assembly testers are available throughout British Columbia. As of December 2023, there were 2,300 active testers in British Columbia and the Yukon. Additionally, of the respondents only three identified that they had a minimal number or not enough testers. This indicates a satisfactory level of testers generally across the province.

Post-secondary institutions throughout British Columbia encourage their students to complete the certification as part of the plumbing apprenticeship program Some schools partner with their local community program to discuss employment opportunities

Sustainability

Several respondents identified that their programs were at risk because they were reliant on one individual. Losing these individuals not only slows program momentum but also places a higher risk for program collapse.

When the cross connection control tasks are part of a larger set of roles and responsibilities, they are subject to prioritization against other programs. This was identified as an issue by respondents.

The most successful programs appeared to integrate or coordinate well between departments, utilizing the existing skillsets.

For communities that are smaller or have fewer formal programs, long-term planning, contingency planning and sustainability strategizing require an even greater emphasis.

The City of Surrey emphasizes coordination between departments:

Engineering department and program administration.

Bylaw department and enforcement of the Cross Connection Control (CCC) bylaw. Operations departments and the testing and maintenance of Cityowned backflow prevention devices.

Building department and enforcement the plumbing code and the City’s CCC standard and specifications for permitted plumbing work.

SOFTWARE SOLUTIONS

Most communities surveyed rely on the use of a software data-collection system for their backflow device test results. This not only streamlines the process of collection but allows for less time spent on administrative tasks and record keeping.

Out of the 27 respondents, 19 use third-party software and two use in-house developed software. The rest of the communities used other mechanisms for record-keeping, such as spreadsheets.

The use of the software itself does not always come without challenges. Those that use third party software still commented on having specific challenges based on their needs and being at liberty of the updates and changes from the third-party. For others, software use alleviates the challenges they had before using a third-party product.

Respondents expressed a desire to work with other communities to share information about the benefits and pitfalls of the different technologies being used.

DATA COLLECTION SYSTEM FOR BACKFLOW TEST RESULTS

Figure 11: Software Data Collection Systems

SOFTWARE

FINANCIAL SUSTAINABILITY

Adequate funding is a key factor in ensuring a robust, successful program. This includes dedicating enough staff and resources to maintain a program in the short- and long-term.

There are several considerations when funding a cross connection control program. First, there will be an initial cost for program implementation, including outside consultants, hiring staff and conducting initial surveys and implementing tracking mechanisms.

Operational expenses include ongoing staffing and technology. Depending on the model of program developed, there may also be expenses related to conducting surveys, inspections and tests.

FUNDING MECHANISMS

Respondents identified different mechanisms for funding cross connection control programs These include:

Water billing rates

Fee for test result submission

General operations budget

Figure 12: Funding Mechanisms

The largest group of respondents identified water billing rates as their primary source of funding. Attaching the program to this funding mechanism draws the connection with ensuring a healthy community through clean, safe drinking water.

Some respondents identified using a fee-per-test result submission model. The value of this approach was the ability to scale based on the number of properties inventoried in the jurisdiction. Some communities also identified this method to partially cover costs.

The rest of the communities identified other mechanisms for funding, often from within the general budget. The risk to this approach is the prioritization of this program over all of the other priorities in the organization. In this case, having a champion at a decision-making level is extremely important.

Building a Business Case

Making the business case for investing in cross connection control programs is most effective when focusing on regulatory compliance, risk mitigation and contingency planning

Ensuring that decision-makers are well educated on the importance of cross connection control programs and the opportunities to mitigate risk and remain in compliance with government requirements is important for success When senior leaders understand cross connection control and the impact on public health, the business case becomes easier

KNOWLEDGE SHARING

All communities are in different stages of development, implementation and operationalization of their CCC programs. The type and level of support differs depending on the stage the program is in.

Guides and Resources

There are several resources that are available regarding best practices in developing cross connection control programs, applicable standards and other topics

When asked about the types of resources that respondents felt were valuable to them, over half identified guidebooks and health authority-specific support This stems from the inconsistencies in the regulatory and legislative environment and the definitive authority of the health authorities

Appendix B provides a list of resources that were identified during the development of this report

Templates

Respondents indicated that they were very interested in learning what other community programs were doing and whether they were willing to share resources. Two examples of templates came up throughout the survey process.

Job descriptions are a great tool to share between program administrators. For those communities just setting up a program, it helps to determine the skillsets required to run the program successfully. Additionally, consistency in job titles and descriptions makes posting positions easier – applicants have a better sense of what is required of them.

Backflow Assembly Test reports are the documents of record that indicate that a backflow device test was completed When they are inconsistent across community programs, it becomes more challenging for testers to ensure they are filling out the reports completely and correctly This becomes even more apparent in regions such as the Lower Mainland, where testers serve several community programs

Outsourced Experts

Expert advice is especially valuable when a program is in the early stages of implementation. This may come from a neighbouring community program administrator, a post-secondary institution or a consulting firm.

The City of Nanaimo identified attending quarterly meetings hosted by their software provider as a good way to connect with other communities, discuss software and share ideas regarding administering their CCC program.

Community Knowledge Sharing

Survey respondents saw sharing information with peers as important. Communities have expressed the desire to connect with other communities to learn and support their own decision-making. However, several were not aware of mechanisms that would facilitate this activity. Knowledge sharing includes the combination of sharing experiences, templates, guides and ideas.

Utilizing expert advice can reduce missteps and ensure that the CCC program developed is best set up to achieve the intended goal.

Third-party experts can be important partners in a community program. Not only do they provide insight from multiple programs, but they can also help connect community programs.

The Capital Regional District has hosted information sharing sessions since 2018 that include representatives from Island Health The intent is to discuss common questions, get support from peers, and discuss potential activities over the year ahead

The needs of communities span beyond general connection, and there are many specific topics that require support and knowledge sharing and have the potential to be addressed industry wide

In-house software data collection systems for tracking purposes and how they are being developed to meet the needs of the community

Standard processes for surveying potential new cross connections and recommending solutions

Advanced metering infrastructure and how this can be used for CCC

Interpretation of codes, acts and current regulations/legislation and how this impacts program implementation and what can be outlined within a bylaw

Knowledge sharing has been available to the cross connection control community in several different forms

Some vendors who provide expertise and software services to the cross connection control community also host meetings with their clients to share best practices on program administration and software utilization.

Regionally, communities have hosted sessions to inform the community and individuals involved in cross connection control programs. Functionally, there are some opportunities to share information. For example, the Lower Mainland Plumbing Committee through the Building Officials Association of BC was identified as a great opportunity to discuss technological developments, including new devices and their potential hazards.

BCWWA Communities of Practice

In the past, the BCWWA has utilized in-person meetings to facilitate discussion about cross connection issues This is in the process of transitioning to a model of a community of practice, where individuals can seek out information from other CCC program administrators

This online platform will include opportunities to have live meetings both virtually and in person and will provide the opportunity to share ideas, expertise, templates and documents

An additional community of practice, focused on cross connection control, is also being developed This will focus on technology, changes to the standards, problem-solving and other related topics

Team Meetings

Some respondents stated that they are already having regular team-wide meetings to discuss topics related to cross connection control. This is an especially effective mechanism when resources responsible for the program are integrated across multiple departments. These types of meetings can focus on non-compliant properties, identifying changing hazards and devices found in the community or other related topics to ensure all team members are well prepared

Additionally, team meetings can be used to “table-top” emergency situations related to backflow prevention in their community Working with their emergency management counterparts, teams can prioritize hazard areas in situations of fires, floods and other potential situations

EDUCATION & AWARENESS

One of the biggest challenges to cross connection control programs is ensuring that backflow prevention is understood by all levels of decision-makers, staff and the public. While backflow prevention is an important health concern, awareness is not generally high. When the importance of backflow prevention and the risks to public health and safety are not well understood, cross connection control programs become de-emphasized over other community priorities.

Without support from leadership, cross connection control programs exist only through the passion of the program administrator or not at all. Several respondents explained how their programs would go on hold if they were on vacation or unable to work.

To be successful, education and awareness campaigns should be directed at the intended audience. The content and focus will vary accordingly.

Ministry and Health Authority Staff

It is important for the policy makers to understand cross connection control. While cross connections are understood within the plumbing community, they are not always involved at the Ministry level.

For those individuals who have cross connection control as part of their oversight, there is a benefit in seeking some education on the scope of cross connection, including best practices from elsewhere.

This is especially important for those individuals who are responsible for water permits, both on the potable and non-potable side. Drinking water officers and environmental officers would benefit from understanding cross connection control programs and the benefit of safeguarding public health.

Health inspectors can also play a role in cross connection control, as they enter establishments that may not immediately be identified as containing a hazard risk. By understanding potential opportunities for cross connections, such as carbonation machines, dishwashers, coffee machines, etc., they can educate property owners regarding their backflow risks, in addition to potentially sharing information with the cross connection control program administrator.

Elected Officials and Senior Leadership

Ensuring a successful and sustainable cross connection control program starts with good decisions made at the elected officials and senior leadership levels. Passing new or amended bylaws to properly identify backflow prevention and enforcement requires officials to understand the purpose, benefits and implications of the request. Positioning funding of the program with predictable revenue sources, such as water rates and backflow testing fees is achieved with support from senior leadership. Copyright

Education programs that focus on decision-makers should emphasize the connection with public health and safety. Risk mitigation topics can be highlighted with examples of adverse backflow events and public health implications. Ensuring decision makers understand their regulatory responsibilities is also important.

Operations Leaders and Staff

Because cross connection spans through several departments, it is important that operations leaders and their staff are aware of backflow prevention as it pertains to their roles. For example, bylaw officers need to understand what they are looking for when addressing compliance and building inspectors should understand the importance of collaborating with program administrators to ensure the inventory of backflow prevention devices and hazards is maintained. Water operators should understand the role of backflow prevention and the mechanisms in place within their systems. Some operators may also choose to become certified backflow testers.

Educational focus for operational leaders and staff should emphasize the importance of cross connection control as one part of public health and safety, the intersections with their own role and processes to support cross connection control from their positions.

Operational leaders would benefit from fully understanding their regulatory responsibilities, the impact of backflow prevention and how the different roles within the departments intersect so that they can facilitate and promote the most effective cross connection control program.

Engineering Firms and Contractors

It is important for engineering firms and contractors who work in building development and renovation to fully understand backflow prevention and the best methodologies to address these problems. The decisions made by these stakeholders can directly impact project costs.

Engineering firms and contractors would benefit from cross connection control awareness training and dialogue with cross connection control inspectors.

Backflow Hazard Property Owners

Respondents identified a need for property owners to know what cross connections are, what backflow prevention devices are, where they are used and why they require testing They commonly found property owners questioning the purpose of testing and testing requirements

Gaining compliance from property owners can be challenging when they do not understand why monitoring backflow devices is important Providing clear rationale regarding the importance of maintaining and monitoring their backflow devices and their role in public safety can mitigate resistance from property owners to comply

The City of West Kelowna has been focusing on working with their ICIA properties and upgrades to old infrastructure. Their Agricultural Advisory Committee meets on a monthly basis which has provided municipal staff involved in the cross connection control program to present at the meeting around what cross connection is, why it is being required and the importance of protecting their water system.

Awareness pamphlets and communications for property owners should explain what backflow hazards are, how they occur, the impact on health and safety and how they can be prevented.

General Public

Educating the public regarding backflow prevention has several benefits

First, backflow prevention devices are becoming more prevalent in the average household and small business. Heat pumps, rainwater capture equipment, irrigation systems and bidets are only a few of the increasingly available equipment that increase a backflow risk to a common household. Most installations do not require a permit and, therefore, bypass any opportunity for mitigation. The prevalence of DIY exacerbates this issue as a red seal plumber may not be involved at all.

A program administrator from a drought-affected area expressed concern about the increasing backflow risk coming from the number of rainwater capture/reuse installations that were being installed through DIY and without plumbing expertise oversight.

Second, the public pays for programs Providing information about the purpose of cross connection control programs and the benefit to community health influences public support that enables decision-makers to adequately fund cross connection control programs

Finally, public awareness assists the community in its communication, issue mitigation and public relations efforts should an adverse event occur

From the perspective of optimizing public health, public awareness campaigns are a good first step Awareness pamphlets, backflow demonstrations at open houses and even school presentations are all potential approaches to sharing information about backflow prevention

The curriculum could be added to schools, from elementary to high school, demonstrating vacuums and pressure.

Climate change and water scarcity issues have created an opportunity to introduce cross connection control as a concept and incorporate it into water reclamation topics.

CERTIFICATION PROGRAMS

There are currently two certification programs designed to ensure that all people involved in cross connection control have the tools required to be successful

CERTIFICATION TYPE

Backflow Assembly Tester KEY POINTS AUDIENCE

Validating that backflow prevention devices are in working order, filling out test reports

CCC Inspector Identifying/inventorying cross connections both inside facilities and on properties, assessing hazard risk, educating property owners, recommending backflow prevention devices

Table 6: Certification Programs

Backflow Assembly Device Tester Certification

Plumbers Water Operators

Building/Plumbing Inspectors

CCC Program Administrators

CCC Inspector

Backflow Assembly Testers

CCC Program Administrators

Building/Plumbing Inspectors/Officials

Drinking Water Officers

Environmental Officers

Health Inspectors

The Backflow Assembly Tester certification program came out of an identified need to standardize the approach to testing backflow prevention devices and to ensure that the individuals performing duties related to device testing had the current skills and knowledge

The Backflow Assembly Tester certification program is a nationally recognized certification program that was developed by the Canadian sections of the American Water Works Association (AWWA) The BCWWA, representing the BC Section of the AWWA, has been the recognized certification body for backflow assembly testers in British Columbia and the Yukon for several decades

The program is currently offered through nine post-secondary institutions in the province As of the end of 2023, there were 2,300 active testers practicing in British Columbia and the Yukon Certification consists of both a written theory-based exam and a practical evaluation Certification remains valid for five years before testers are required to recertify

The Backflow Assembly Tester certification program is a collaboration between AWWA sections throughout Canada, with program content, exams and certification requirements being determined through a National Committee

The national standardization of competencies for backflow testers through this certification program provides consistency for organizations hiring testers and allows testers to practice in other jurisdictions through the inter-provincial reciprocity agreement.

AUDIENCE CERTIFYING BODY

CERTIFICATION TYPE KEY POINTS

BC Water & Waste Association (BCWWA) (representing the BC Section of AWWA)

Western Canada Water and Wastewater Association (WCWWA)

Ontario Waterworks Association (OWWA)

Réseau Environnement

Atlantic Canada Water and Wastewater Association (ACWWA)

JURISDICTION

British Columbia Yukon

Alberta Saskatchewan Manitoba Northwest Territories

Ontario

Quebec

New Brunswick Nova Scotia Newfoundland and Labrador Prince Edward Island

Table 7: Backflow Tester Certifying Bodies in Canada

Cross Connection Control Inspector Certification

Section 22 of the Drinking Water Protection Act states that all water purveyors must provide a risk assessment plan Additionally, the Municipal Wastewater Regulation of the Environmental Protection Act states that a certified CCC inspector is required to oversee any water reclamation facility

The Cross Connection Control Inspector certification program was developed in response to a lack of education available surrounding identification and classification of cross connection hazards The program was created in 2006 in collaboration with existing training partners

The certification program was re-evaluated in 2016 and de-emphasized due to an overall low interest from the cross connection control community It continues to be offered at one postsecondary institution in British Columbia Currently there are approximately 150 certified cross connection control inspectors in British Columbia

In recent years, students of this program come from communities with dedicated cross connection control surveyors, CCC program administrators, drinking water officers, operations personnel from wastewater reclamation sites and backflow assembly testers This program is also beneficial for building and plumbing inspectors

There isn’t a clear consensus regarding the CCC inspector certification Some respondents were unclear but interested in the program; others felt that plumbing officials could do the job or felt that by focusing on property isolation it was unnecessary to do facility-based surveys Other respondents utilized CCC inspectors regularly

Given the changing cross connection environment, with new technologies and water usage approaches, it is worth reviewing this certification program to ensure that it is meeting the needs of the cross connection control community and to determine if it needs to be emphasized more.

FACTORS FOR PROGRAM SUCCESS

The following have been identified by respondents as factors that contribute to success in both setting up and running a cross connection control program. While not an exhaustive list, it does speak to the issues identified in this research project.

1. CROSS CONNECTION CONTROL IS A WRITTEN REQUIREMENT

When a health authority representative provides a condition on the drinking water operating permit or health order requiring a cross connection control program, the water purveyor is compelled to comply with that condition and creates the space and opportunity for a community to allocate resources for such a program This is the largest external factor in creating a cross connection control program

2. ELECTED AND OPERATIONAL LEADERS UNDERSTAND THE IMPORTANCE OF CROSS CONNECTION CONTROL

Municipal staff or officials may learn about the importance of cross connection control through their function, the requirement for a drinking water permit or have even experienced the fallout from an adverse event The extent to which the organization’s leadership believes in and supports a program will determine important factors for its success, such as funding, integration with other departments and long-term sustainability

The next largest factors supporting the implementation of a community CCC program are risk protection, drinking water protection and due diligence around public safety These factors demonstrate the responsibility that educated staff understand while working on other drinking and wastewater activities

FACTORS FOR PROGRAM SUCCESS

3. THERE IS A CROSS CONNECTION CONTROL BYLAW THAT CONTAINS SPECIFIC LANGUAGE REGARDING ENFORCEMENT

Community bylaws related to CCC programs tend to be positioned in one of two ways: integrated into the water utility bylaw or pulled out separately. Respondents indicated that bylaws, where CCC was integrated into a water utility bylaw, were less likely to have an enforcement mechanism Additionally, municipalities were less likely to push for bylaw changes when bylaws were integrated because it would require the entire bylaw to be reviewed

Respondents expressed a preference for the cross connection control program to be pulled out as a separate bylaw

4. THE CCC PROGRAM IS FUNDED SUSTAINABLY

Cross connection control programs appear to do better when they are funded by mechanisms related to their function, such as water bills and backflow testing fees

When a CCC program is rolled into the general municipal budget, it can be easily cut back or minimized, especially when decision-makers are not educated in the requirement, purpose and value of cross connection control programs

5. THE COMMUNITY HAS AN IN-HOUSE CHAMPION ON STAFF THAT ADVOCATES FOR THE PROGRAM

Respondents identified the importance of having qualified, passionate and knowledgeable staff in-house to advocate for the development of a cross connection control program. The most common reason cited for implementing a municipal CCC program was due to an in-house champion.

These individuals have experience with cross connection control and recognize the importance of monitoring backflow devices as part of mitigating public safety. Their expertise and experience often result in their leading the program.

Important, however, is the support of leadership and decision-makers that the champion has to run the program. A program with a champion but without support is at the greatest risk of collapsing.

FACTORS FOR PROGRAM SUCCESS

6. THE CCC PROGRAM IS WELL-INTEGRATED WITH RELATED DEPARTMENTS

Cross connection control is related to a variety of functions within a municipal organization. These include building permits, housing and plumbing inspectors, bylaw enforcement and the water utility. Creating a program structure that enables clear communication and coordination with all related departments, instead of as a stand-alone program, contributes to the implementation of a successful program.

7. THE CCC PROGRAM HAS AN EFFECTIVE MECHANISM TO IDENTIFY AND TRACK BACKFLOW PREVENTION DEVICES, BACKFLOW DEVICE TESTERS AND HAZARDOUS ENVIRONMENTS

Cross connection control programs can become cumbersome depending on the scale of backflow prevention devices in the jurisdiction Respondents indicated that utilizing technology to manage processes associated with backflow prevention positively influenced the program’s success

8. BYLAW ENFORCEMENT IS USED EFFECTIVELY TO COMPEL THE USE AND ONGOING TESTING OF BACKFLOW DEVICES

Ensuring compliance with backflow device testing bylaws is an important requirement for the CCC program Because backflow device testing is not often a priority with property owners, educating the public of the importance of device maintenance and enforcing non-compliance are important components of a successful program

9. PROGRAM STAFF ARE WELL SUPPORTED BOTH WITHIN THEIR ORGANIZATION AND THEIR MUNICIPAL COUNTERPARTS

Respondents identified the importance of connecting with experts in the field when implementing a CCC program This could be through a consultant or through counterparts in other municipalities Importantly, there was greater success when the program was developed using shared knowledge and expertise One of the final key factors communities listed as contributing to the successful implementation of their program is third-party support

RECOMMENDATIONS

After completing the research for this report, some recommendations have become apparent.

These recommendations are grounded in the fundamental assertion that strong cross connection control programs not only mitigate risk and liability to communities but are also an important component of the multi-barrier approach to public health.

The ownership required to enact these recommendations spans across several jurisdictions, including government, health authorities and sector associations.

1. CODIFY CROSS CONNECTION CONTROL

The requirement for cross connection control programs to exist in all communities should be written into provincial regulations to ensure consistent application throughout the province. Additionally, this requirement should outline the minimum requirements of a cross connection control program and include consideration for all high and severe hazards and the use of certified backflow device testers.

2. ESTABLISH FUNDING TO SUPPORT THE IMPLEMENTATION, REVIEW AND EXPANSION OF CROSS CONNECTION CONTROL PROGRAMS

Additionally, grants should be provided to existing communities Often, programs are “held together” with one passionate employee and are at risk of being dissolved should that employee leave the organization Providing funding to enable communities to review their existing programs against best practices and sustainability planning becomes an investment in public health

RECOMMENDATIONS

3. SUPPORT NEW AND EXISTING CROSS CONNECTION CONTROL PROGRAMS WITH MECHANISMS TO SHARE BEST PRACTICES AND TEMPLATES

Importantly, resources that provide education to decision-makers, program administrators and property owners should be made available to ensure maximum buy-in for the program

4. SUPPORT SMALLER COMMUNITIES WHO DO NOT HAVE THE SAME ACCESS TO FUNDING AND RESOURCES

Create support for communities that fall outside of the municipal infrastructure. Support for these communities can include guides and templates designed specifically for their circumstances, funding to establish a program and peer mentoring.

5. ESTABLISH PUBLIC EDUCATION CAMPAIGNS

RECOMMENDATIONS

6. REVIEW THE ROLE AND CERTIFICATION OF THE BACKFLOW INSPECTOR/SURVEYOR

Given the changing cross connection control environment and new technologies, especially regarding water reclamation, it is worthwhile to consider reviewing this certification and ensuring that it is meeting the needs of the community, both in audience and content.

7. RECOGNIZE THE BCWWA AS THE CERTIFICATION BODY FOR CROSS CONNECTION CONTROL

The Provincial Health Officers report identifies the BCWWA as the “recognized administrative body for the voluntary certification of backflow assembly testers and cross connection control inspectors.” This, however, is not documented in regulation.

With consideration to provincial consistency identified in recommendation one and the established certification infrastructure, the BCWWA should be recognized as the certification body for cross connection programs. In doing so, competency standards will remain consistent with Canadian counterparts and the existing infrastructure of post-secondary institutions and tester databases can continue to serve the cross connection control community.

NEXT STEPS

The BCWWA will continue to be an advocate for all the CCC programs in BC. Completing this project and through the process of surveying and interviewing communities from around the province has provided insight into the nuances that the cross connection control landscape brings.

Importantly, through this research process, we have learned the following:

Cross connection control is not well understood.

Cross connection control is a shared responsibility.

Cross connection control is an evolving area requiring updates.

The regulatory landscape is confusing and open to interpretation.

Cross connection control programs are inconsistently applied across communities.

Cross connection control programs are challenged to be properly funded.

Smaller communities need more support.

Support from elected officials is critical.

The BCWWA would like to invite stakeholders to engage in a dialogue about how the recommendations presented in this report can be acted upon with a goal of creating a safer British Columbia

APPENDIX A: CASE STUDIES

CAPITAL REGIONAL DISTRICT

The Capital Regional District (CRD) has a broad, sweeping and well-established cross connection control program that encompasses several communities.

Population: 432,062 (2021)

Location: The CRD is the regional government for 13 municipalities and three electoral areas on Southern Vancouver Island and the Gulf Islands. The traditional territories of many First Nations span portions of the region.

Scope of Program: Backflow preventers within the municipal water distribution system, on private water distribution systems, within municipal/public buildings and on privately owned buildings (industrial, commercial, agricultural, institutional, multi-family residential and single-family residential)

The CRD has a well-established cross connection control program Implemented in 2006, the program is often used as an example of industry standards The program, anchored to CRD Bylaw 3516, is diligently administered by five trained and dedicated staff members, ensuring the safety of the Greater Victoria Drinking Water System

Every year a cross connection roundtable is hosted with attendance from all municipal plumbing and building inspectors, representatives from the local health authority and any others involved in the CCC program The roundtable offers the opportunity to plan for the year ahead, discuss common questions inspectors may have and ensure all parties are working together in an informed way

Although fully established, the CRD continually upgrade and redevelop components to improve their program Their biggest focus has been on and will continue to focus on public education and awareness There is consensus that the region benefits from a collaborative and safely run cross connection control program

APPENDIX A: CASE STUDIES

CITY OF PARKSVILLE

The City of Parksville is a smaller community with a fully established cross connection control program.

Population: 13,642 (2021)

Location: The City of Parksville is located on the east coast of Vancouver Island. Parksville is about 38 kilometres north of Nanaimo.

Scope of Program: Backflow prevention within the municipal water distribution system, on private water distribution systems, within municipal/public buildings and on privately owned buildings (industrial, commercial, agricultural, institutional, multi-family residential and single-family residential).

The City of Parksville has a well-established cross connection control program. The strength of their program truly comes from the dedication of a single staff member as well as support from senior levels of management. In addition, a requirement set by their local health authority over a decade ago significantly moved the program forward. It ultimately led to the development of the City’s Cross connection Control Bylaw (Bylaw No. 1592), outlining responsibilities for community members and allowing for enforcement mechanisms to be used. This bylaw is instrumental to the City’s success in operationalizing an effective CCC program within their community.

Despite the City’s CCC program being fully established, there are still areas they are considering expanding in the future to continue improving their program. In the future, the City is looking to focus more on the inspection of industrial, commercial, institutional and agricultural properties that are potentially at a higher risk.

APPENDIX B: CCC PROGRAM RESOURCES

Australian Building Codes Board (ABCB), March 2019. Cross-connection control Handbook, https://www.abcb.gov.au/sites/default/files/resources/2023/NCC-2022-Cross connectioncontrol-Handbook-FA.pdf

Federation of Canadian Municipalities and National Research Council, October 2005. Methodology for Setting a Cross-Connection Control Program, https://fcm.ca/sites/default/files/documents/resources/guide/infraguide-methodologysetting-cross connection-control-program-mamp.pdf

Government of British Columbia, February 16, 2024. Resources for water system operators, https://www2.gov.bc.ca/gov/content/environment/air-land-water/water/waterquality/drinking-water-quality/resources-for-water-system-operators#source-to-tapassessment

Government of British Columbia, March 5, 2024. BC Drinking Water Protection Act, https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/200 2003

LIST OF FIGURES

Figure 1: Drinking Water Operating Permits and Health Orders by Health Authority

Figure 2: CCC Bylaw Configurations .............................................................................................

Figure 3: Types of Properties Covered by Cross Connection Control Programs .........................

Figure 4: Cross Connection Control Program Components

Figure 5: CCC Program Components - Backflow Hazard Surveys ...............................................

Figure 6: CCC Program Components - Records Maintenance .....................................................

Figure 7: CCC Program Components - Enforcement

Figure 8: CCC Program Components - Emergency Response Planning ......................................

Figure 9: CCC Program Components - Public Education & Awareness Programs ......................

Figure 10: State of CCC Programs

Figure 11: Software Data Collection Systems

Figure 12: Funding Mechanisms ....................................................................................................

TABLES

Table 1: Federal Standards ............................................................................................................

Table 2: Provincial Regulations .....................................................................................................

Table 3: Drinking Water Operating Permits

Table 4: Municipal Bylaws ............................................................................................................

Table 5: Staffing Approaches Based on FTE ................................................................................

Table 6: Certification Programs

Table 7: Backflow Tester Certifying Bodies

REFERENCES

Building Code Appeals Board, March 24, 2016. BCAB #1773 - Required Qualifications for Testing Backflow Preventers, https://www2.gov.bc.ca/gov/content/industry/constructionindustry/building-codes-standards/building-code-appeal-board/building-code-appeal-boarddecisions/bcab-1773

Committee on Public Water Supply Distribution Systems, 2006. Drinking Water Distribution Systems: Assessing and Reducing Risks. Washington, DC: The National Academies Press. https://nap.nationalacademies.org/catalog/11728/drinking-water-distribution-systemsassessing-and-reducing-risks

Foundation for Cross-Connection Control and Hydraulic Research, University of Southern California, 2009. Manual of Cross-Connection Control, Tenth Edition

Government of British Columbia, April 2, 2024. BC Building Act, https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/15002

Government of British Columbia, March 5, 2024. BC Drinking Water Protection Act, https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/200 2003

Government of British Columbia, March 5, 2024. BC Drinking Water Protection Regulation, https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/200 2003

Government of British Columbia Drinking Water Officers’ Guide: Part B Best Practices and Technical Assistance, https://www2.gov.bc.ca/assets/gov/environment/air-land-water/dwog-part-b.pdf

Government of Ontario, June 23, 2006. ‘Festival U Wash’ and manager fined total of $75,000 Stratford, https://news.ontario.ca/en/release/83024/festival-u-wash-and-manager-fined-totalof-75000-stratford

National Research Council. 2006. Drinking Water Distribution Systems: Assessing and Reducing Risks. Washington, DC: The National Academies Press. https://doi.org/10.17226/11728

REFERENCES

Office of the Provincial Health Officer, Government of British Columbia, June 2019. Clean, Safe, and Reliable Drinking Water; An Update on Drinking Water Protection in BC and the Action Plan for Safe Drinking Water in British Columbia, Provincial Health Officer’s Drinking Water Report:2012/13-2016/17, https://www2.gov.bc.ca/assets/gov/environment/air-land-water/water/documents/pho-drinkingwater-report-2019.pdf

Office of the Provincial Health Officer, Government of British Columbia, February 2024. Clean, Safe, and Reliable Drinking Water; An Update on Drinking Water Protection in BC and the Action Plan for Safe Drinking Water in British Columbia, Provincial Health Officer’s Drinking Water Report: 2017/18-2021/22, https://www2.gov.bc.ca/assets/gov/health/about-bc-s-healthcare-system/office-of-the-provincial-health-officer/reports-publications/drinking-waterreports/drinkingwaterreportupdateweb.pdf

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