Backflow Prevention. Background and Purpose of Requirements. Assembly Approval: Assembly Approval: Washington State s Perspective

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1 Mission Assembly Approval: Washington State s Perspective Terri Holderman-Notestine CCC Program Manager Office of Drinking Water To protect the health of the people of Washington State by ensuring safe and reliable drinking water. Public Health - Always Working for a Safer and Healthier Washington 2 Presentation Overview Purpose of DOH assembly approval requirements Historic/current CCC rules Acceptance of assemblies approved by organizations other than USC DOH update Public Health - Always Working for a Safer and Healthier Washington 3 Backflow Prevention Assembly Approval: Background and Purpose of Requirements 4 What Does Approval Mean? The backflow prevention assembly meets a performance-based standard. A Performance-Based Standard 1. Defines what the backflow assembly is supposed to do 2. Identifies procedures used to test or evaluate the backflow assembly 3. Defines criteria used to pass or fail the backflow assembly Public Health - Always Working for a Safer and Healthier Washington 5 Public Health - Always Working for a Safer and Healthier Washington 6 Office of Drinking Water - 1

2 A Performance-Based Standard (cont.) Relies on objective pass/fail criteria to approve or not approve an assembly (is not a rating system) Pass Fail Public Health - Always Working for a Safer and Healthier Washington 7 Why Require Approved Assemblies? To protect the health of consumers served by public water systems Helps ensure assemblies: Meet minimum design standards Comply with minimum performancebased standards Will reliably prevent backflow under a variety of expected field conditions Public Health - Always Working for a Safer and Healthier Washington 8 Washington s Third-Party Assembly Approval Requirements Why Require Third-Party Approval? Department of Health (DOH) doesn t have the technical expertise, resources, or facilities to evaluate assemblies in the lab or field When determining which third-party approvals to accept, helpful to review DOH criteria for the approval process 9 Public Health - Always Working for a Safer and Healthier Washington 10 Third-Party Approval Criteria Impartial evaluations Consistent and objective criteria Organization/lab has recognized expertise in assembly evaluation Lab subject to periodic audit and certification Public Health - Always Working for a Safer and Healthier Washington 11 Third-Party Approval Criteria (cont.) Monitoring of on-going performance of approved assemblies Complaint follow-up procedures Periodic review of assemblies - third party either renews or rescinds approval Public Health - Always Working for a Safer and Healthier Washington 12 Office of Drinking Water - 2

3 USC s Approval Process University of Southern California - USC Foundation for CCC and Hydraulic Research Offered third-party assembly approval services since 1948 Historical Perspective: Assembly Approval Requirements in Washington State USC meets all DOH third-party assembly approval requirements Public Health - Always Working for a Safer and Healthier Washington CCC Regulation History 1970 drinking water rules Established first CCC Program requirements for water purveyors Required departmentapproved assemblies Approved assembly requirement has remained in effect since 1970 Public Health - Always Working for a Safer and Healthier Washington CCC Regulations State would approve assemblies that passed performance tests of either: University of Southern California Other testing laboratory satisfactory to department (rules did not define) Unknown whether State developed a related policy to establish criteria to accept labs other than USC Public Health - Always Working for a Safer and Healthier Washington 16 CCC Regulations Option to approve non-usc listed assemblies remained in effect from 1970 until 1983 In 1983, rule changed to USC only (basis for change unknown) USC approval requirement remained in effect until 1999 Public Health - Always Working for a Safer and Healthier Washington 17 CCC Regulations 1999 Revisions Re-introduced option to accept assemblies approved by entities other than USC State Attorney General s Office recommended rule change In 2000 DOH developed policy to complement regulations Public Health - Always Working for a Safer and Healthier Washington 18 Office of Drinking Water - 3

4 Current Assembly Approval Requirements in Washington WAC Current CCC Regulations 1999 rule language still in effect Approved backflow prevention assembly definition still contains other third-party language Department-approved assemblies still required 19 Public Health - Always Working for a Safer and Healthier Washington 20 WAC Definitions Defines approved backflow prevention assembly Assembly of make, model, and size approved by DOH Assemblies on current USC List or other entity acceptable to DOH are DOH-approved Public Health - Always Working for a Safer and Healthier Washington 21 WAC (5)(a) Assemblies that protect public water systems must appear on the current list of assemblies approved for use in Washington DOH-Approved Assemblies List available upon request Use USC List as basis for DOH List Public Health - Always Working for a Safer and Healthier Washington 22 Assemblies Not on Current List Purveyors may rely on assemblies not on current DOH-Approved List Must meet all conditions in drinking water rules Must replace assembly, if moved or conditions not met Public Health - Always Working for a Safer and Healthier Washington 23 Conditions for Continued Use DOH-approved when installed Appropriate for degree of hazard Inspected/tested annually Properly maintained Repair using spare parts from original manufacturer Public Health - Always Working for a Safer and Healthier Washington 24 Office of Drinking Water - 4

5 DOH CCC Policy on Acceptance of Assemblies Approved by Third-Party Organizations Other than USC Policy Complements Rule Goal is to ensure assemblies approved by Others are equivalent to USC-approved assemblies Equivalent in: Design Lab and field performance Reliability under varying operating conditions Public Health - Always Working for a Safer and Healthier Washington 26 Impartial, Objective Evaluations Other third-party lab/staff evaluating assembly must be independent of the assembly manufacturer Conflict of interest for manufacturers to evaluate their own assemblies in their own labs Public Health - Always Working for a Safer and Healthier Washington 27 Field Evaluation Required Process must include both: Laboratory evaluation Field evaluation Field evaluation must be mandatory (not optional) Field evaluation must be one year in length Public Health - Always Working for a Safer and Healthier Washington 28 Comments re: Field Evaluation USC data shows importance of one-year field evaluations 30% assemblies that pass the lab evaluation fail initial field evaluation 65% failures occur in second six months of field testing Public Health - Always Working for a Safer and Healthier Washington 29 Evaluation Protocols/Criteria Must include objective assembly: Design standards Performance-based standards for lab and field evaluations Must be at least as stringent as USC s for: Obtaining initial approval Maintaining/renewing approval Public Health - Always Working for a Safer and Healthier Washington 30 Office of Drinking Water - 5

6 Additional Requirements Verify assembly approval with DOH at least annually Notify DOH of change in approval within 30 days of receiving notice No new installations, if approval rescinded by other third party USC vs. ASSE Approval Issues for Consideration Public Health - Always Working for a Safer and Healthier Washington ASSE Assembly Approval ASSE = American Society of Sanitary Engineering ASSE has: Backflow assembly standards Assembly approval program ASSE has contacted other states requesting acceptance of ASSEapproved assemblies Public Health - Always Working for a Safer and Healthier Washington 33 Oregon s Recent Experience ASSE submitted request to Oregon in 2012 Concluded ASSE s program was not equivalent to USC s Oregon retained requirement for USC-approved assemblies Public Health - Always Working for a Safer and Healthier Washington 34 Oregon s Concerns USC vs. ASSE Evaluations Significant differences between ASSE and USC Differences in: Laboratories/staff conducting evaluations Laboratory test criteria Field evaluation requirements Field evaluation criteria Public Health - Always Working for a Safer and Healthier Washington 35 Evaluations USC ASSE Conducted in laboratory independent of assembly manufacturer Conducted by staff independent of assembly manufacturer Include mandatory field evaluation (one-year) after successful completion of lab evaluation phase Yes Yes Yes Not necessarily* Not necessarily* No *Allows testing by ASSE-recognized labs, which could include a manufacturer s lab/staff. 36 Office of Drinking Water - 6

7 CCSs Should Be Aware Summary Approved assembly standards differ Uniform Plumbing Code allows ASSE-approved assemblies PWSs with combination programs In-premises assemblies that directly protect the public water system must be USC/DOH-approved Public Health - Always Working for a Safer and Healthier Washington 37 Since 1970, Washington has: Required Department-approved backflow prevention assemblies Relied on USC s third-party assembly approval program Current rules allow DOH to accept assemblies approved by entities other than USC Public Health - Always Working for a Safer and Healthier Washington 38 Summary (continued) DOH CCC policy outlines conditions for acceptance of non-usc approved assemblies Other approval program must be at least as stringent as USC s DOH-Approved Assemblies List Update and Reminders To date, DOH has not received a request from ASSE Public Health - Always Working for a Safer and Healthier Washington DOH-Approved Assemblies List Published 2013 DOH List in January Available for free in CD format to legitimate requesters Order DOH publication # online from Office of Drinking Water USC List - Big Changes Coming USC-Approved Assemblies List will soon be available to public at no cost Transition scheduled for April 2013 No need for DOH to publish List in future or issue periodic updates Public Health - Always Working for a Safer and Healthier Washington 41 Public Health - Always Working for a Safer and Healthier Washington 42 Office of Drinking Water - 7

8 Policy on Assemblies Assemblies must be delivered for installation completely assembled by the original manufacturer with all components as approved Consider shutoff valves and test cocks integral parts of assembly Modifications and Approval Install and maintain assembly in configuration and orientation in which evaluated and approved by USC Field modifications invalidate an assembly s approval Public Health - Always Working for a Safer and Healthier Washington 43 Public Health - Always Working for a Safer and Healthier Washington 44 Assemblies List Reminders Assembly model information must exactly match List to be approved Approval s valid only if original approval date or renewal date is within 3 years of current date Assemblies must be installed only in orientation shown on List Public Health - Always Working for a Safer and Healthier Washington 45 Lead (Pb) Content Column Y in the <0.25% Pb column Means assembly meets the lead-free requirements in California, other states, and new federal rule New federal rule effective 1/4/2014 Public Health - Always Working for a Safer and Healthier Washington 46 Shutoff Valve Designations USC evaluates assemblies with specific shutoff valves (shown in parentheses) List shows other valves with similar performance characteristics Use of shutoff valves other than those listed invalidates assembly s approval Public Health - Always Working for a Safer and Healthier Washington 47 Detector Bypass Assemblies USC evaluates detector assemblies with a specific bypass assembly List shows bypass assembly information Use of bypass assembly other than those listed invalidates assembly s approval Public Health - Always Working for a Safer and Healthier Washington 48 Office of Drinking Water - 8

9 Detector Assembly Meters Spare Parts Only Column USC evaluates detector assemblies with a specific water meter (shown in parentheses) List shows other meters with similar performance characteristics Use of any water meters other than those listed invalidates assembly s approval Public Health - Always Working for a Safer and Healthier Washington 49 Y in Spare Parts Only column Means assembly no longer being produced, but parts still available Use of spare parts other than those of the original manufacturer invalidates assembly s approval Public Health - Always Working for a Safer and Healthier Washington 50 Notes Column Remember to check Notes especially if can t find assembly make, model, and size on List Provide valuable information For example, Notes show: Old model names/numbers Serial numbers for lead-free versions of same model Public Health - Always Working for a Safer and Healthier Washington 51 Office of Drinking Water CCC Webpage Enhancements Public Health - Always Working for a Safer and Healthier Washington 52 Proposed Enhancements Plan to add CCC topics from A to Z to enhance webpage Frequently asked question format CCSs and BATs welcome to submit: Suggestions for topics Specific questions Uniform Plumbing Code Update Living document - easily updated Public Health - Always Working for a Safer and Healthier Washington 53 Public Health - Always Working for a Safer and Healthier Washington 54 Office of Drinking Water - 9

10 2012 UPC Recently Adopted State Building Code Council (SBCC) Recently adopted model codes including 2012 UPC amended for Washington Effective July 1, 2013 WAC documents amendments Public Health - Always Working for a Safer and Healthier Washington UPC CCC-Related Sections Chapter 2: Definitions Chapter 6: Water Supply and Distribution Chapter 16 - Alternate Water Sources for Nonpotable Applications Chapter 17- Rainwater Catchment Public Health - Always Working for a Safer and Healthier Washington UPC CCC-Related Amendments Uses DOH BAT definition (WAC ) Requires DOH-approved assemblies for protection of the public water system per WAC Requires AHJ to coordinate with the water purveyor on CCC issues Requires DOH-certified BATs to test assemblies. Clarifies that annual testing is the minimum. Requires AHJs to ensure the testing of assemblies not relied upon for PWS protection Allows DCVAs on irrigation systems without chemical addition when approved by the purveyor and AHJ Requires AGs or RPBAs on steam or hot water boiler make-up lines UPC CCC-Related Amendments (continued) Requires RPBAs on potable water supply to carbonated beverage machines. Must locate RPs to allow access for testing, maintenance, and repair. Prohibits copper piping downstream of RPBA Prohibits backflow preventers from being located in any area containing fumes or aerosols that are toxic, poisonous, infectious, or corrosive Exempts (from backflow prevention) residential flowthrough or combination fire sprinkler systems piped in materials approved for potable water. Chapter 16 Chapter 17 Rules for use of reclaimed water, gray water, and on-site treated water for non-potable applications. Rules for rainwater catchment systems. 58 UPC Resource Information Need 2012 UPC + state amendments Purchase UPC from either: Washington Association of Building Officials (WABO) IAPMO See SBCC s website for Washington amendments to UPC Public Health - Always Working for a Safer and Healthier Washington 59 For More Information Terri Holderman-Notestine WA State Department of Health Office of Drinking Water terri.notestine@doh.wa.gov (360) Public Health - Always Working for a Safer and Healthier Washington 60 Office of Drinking Water - 10