ABPA Discussion

[Elwood Stagakis]

DO WE HAVE HALF PROTECTION OR HALF FAILURE

RE: ABPA NEWS July/August 2009, Volume 22 Issue 4 "Administration of a Cross-Connection Control Program".

We are made fully aware of the cause of the backflow industries failure, to protect the public health, by this article. We know it but just don't want to admit it.

The "Code of federal Regulations, Volume 40, Paragraph 141.2 C Maximum contaminant level, means the maximum permissible level of a contaminant in water which is delivered to the free flowing outlet of the user of a public water system........"

No where in the law is the water purveyor given an election to work initially on the "Containment Theory" as stated by the author of this article!

Federal law clearly places primacy to protect the public health upon the state and local health authorities. This responsibility cannot be passed on from the state health departments to the local water purveyors. The function of cross0connection control may be assigned by the health departments to the water purveyors but primacy remains with the health suthorities.

Containment Theory and Isolation Theory or "Fixed Outlet Protection Basis" cannot be viewed as two seperate functions. State, City, Town & Water Jurisdictions attempts to divide these two theory's into seperate functions is the root cause of the backflow industries failure to protect the public health. We have half protection, containment, and half failure, isolation.

The backflow industries failure is obvious from Fig. 43, presented in this article, and stated by the author. "Fig. 43 depicts several options that are open to water purveyors when considering cross-connection protection to commercial, industrial and residential customers. He may elect to work initally on the containment theory'.

STOP! WHAT ELECTION? WHAT OPTION?

Primacy has no election option! If the health authority has assigned the cross-connection control program to the water purveyor then both containment and isolation responsibilities rest with the water purveyor. If the functions were split then the health department must perform the isolation function. This is were the backflow industry failure has occured. Few if any health departments are performing survey, installation, testing, repair and maintenance of backflow assembly devices. Periodic inspection and testing of existing isolation devices is vertully non-existent. Fig. 43 has crashed and the water purveyors are responsible. The public has been deceived and lulled into sleep thinking that installing a containment backflow assembly will protect them from backflow poisonings. We all know that this only protects the water purveyor; at his own expense.

It makes no economic sense for states, city's and towns to have seperate cross-connection control programs; one for containment and another for isolation. All plumbing systems need to be surveyed for backflow hazards and the degree of hazard determined. All backflow devices need to be installed, tested, repaired and maintained. The obvious need is for one organization to perform both functions of containment and isolation. The ficticious division of these functions has caused the entire backflow industry to fail in it's very reason for existence. We have performed the easy half of the job, containment, for more then 60 years. It's time to address the more dangerous and complex half of the job, isolation.

Elwood Stagakis 603-529-6534 elwood989@netzero.net

[Michael (Mick) Fostaty]

[Gerald Flis]

Elwood,

Here in Michigan, YES to both questions.... The State and County Health Departments started "isolation" cross-connection inspections in 1972, out of necessity... Ongoing backflow incidents resulted in Health Department intervention/inspections of facilities, revealing hundreds/thousands of improperly or totally unprotected cross-connections (many local purveyors have also begun isolation BFP programs since).... See some pictures I've taken over the years here:
Cross-Connection Hazards Illustrated http://abpa.org/bb/viewtopic.php?t=100

Our position has been that across the board meter containment is "overkill" and a huge expense, not needed in most cases... We do require containment at high hazard facilities such as hospitals, chemical plants, most auto plants, complex piping situations etc... But also of course meter to last outlet protection at ALL facilities....

Why would anyone require a RPBP (or DCVA) at a shoe store or other such facility?? Even places w/ boilers, fire sprinklers, lawn sprinklers and such can be easily protected w/ isolation devices only!!

See more discussion here: Ordinances and Policies http://abpa.org/bb/viewtopic.php?t=30

[Elwood Stagakis]

Hi Mick;

Yes my poll question was improperly worded.

This was my first Poll. I do not see how to ask more then one question on a poll or how to edit or change a question.

I do not have any data to back-up my opinion on the lack of isolation protection device testing here in New Hampshire but; there seems to be little to none.

Studying the backflow incidents published in the EPA Cross-Connection Control Manual and Watts Backflow News, indicates to me that most recorded backflow incidents were Isolation problems and not Containment.

We have been mainly doing containment for 60 years; now is the time to get on with the other (and more dangerous) half of the backflow problem.

Because of our industries negligence in addressing the whole problem the public is coming to the conclusion that Backflow Protection is just another goverment mandated scam. They only see the water jurisdiction protecting themselves, at the customers expense. When a problem arises and it's a isolation problem then, and only then, is the customer made aware that the device they paid to install & test only protects the water purveyor.

It's unbeliveable to me that we would operate two seperate govermental organizations to perforn the backflow protection function; The Water Purveyor - containment and Health Department - isolation. This is wasteful duplication of equipment, time, services and manpower.

The water industry made a bad decision maney years ago to concintrate on containment and essentially neglect isolation. The thought was it was easy'er to get containment first then go to isolation. However here we are some 60 years later still not completing the containment theory and still neglecting the isolation theory.

Dividing these theorys into two seperate functions has not worked and probably will never work. We need to accept our responsibility to protect the public health to the last free flowing outlet; not just protect the water purveyors distribution system.

Elwood Stagakis

[Gerald Flis]

Elwood said:

[Elwood Stagakis]

Survey is just the begining; determines what, if any protection is needed, the degree of hazard and location were protection needs to be placed.

Who does the installation, inspection, periodic testing, sends out test notices, records & files the test records, repairs, replacement, periodic survey and enforces compliance and shuts-off the water for non-compliance? Not the water purveyor!

Here in NH no one does it. Health Department's assume the water purveyors containment takes care of all the requirements. Plumbers are licensed to install & repair but few are certified to survey or test. Water purveyors monitor the distribution systems containment protection but no one ever looks at or tests isolation devices after initial installation.

I am trying get the state law changed to allow certified surveyors and inspectors-testers to do the complete job. I suggested that we have certified technicians who are licensed to survey, install, test, repair, maintain records, send out notices and report non-compliance.

Enforcement must remain with the state, city, town or water purveyor.

Most plumbers have no idea whats inside a backflow assemmbly; so when they fail or leak they just replace it. Good $ for them but costly for the consumers.

Elwood Stagakis

[Gerald Flis]

Elwood said:

[Michael (Mick) Fostaty]