Backflow Device Testing and HB25-1077

In January and February 2025, the Water Quality Control Division (WQCD) provided testimony to the Colorado legislature in support of HB25-1077 that would allow certified cross-connection control technicians to inspect, test, and repair backflow prevention devices as they had up until the 2024 Colorado legislative session. House Bill 24-1344, which became effective on July 1, 2024, included a change that required licensed plumbers to inspect, test, and repair backflow prevention devices. The WQCD received widespread concern from public water systems and certified cross-connection control technicians about the legislation. CDPHE Executive Director Jill Hunsaker Ryan sent a letter to the Colorado State Plumbing Board requesting that the Board prioritize public health by delaying disciplinary actions against certified cross-connection control technicians (who are not licensed plumbers) that test and repair backflow prevention devices, per longstanding practice. The letter also underscored the risk to public health, as it is estimated that approximately 200,000 devices are subject to Regulation 11, but there are only 2,400 certified cross-connection control technicians in Colorado, and only approximately 20% of these certified technicians are also licensed plumbers. An estimated 20% of existing devices fail testing on average, and 80% of new devices fail testing due to remnants such as teflon tape and plumbing putty. Failed devices can allow water systems to become contaminated, which underlines the importance of this overall effort. The State Plumbing Board responded to the request in July 2024 by issuing a temporary enforcement policy to allow the administrative dismissal of complaints against certified cross-connection control technicians until April 1, 2025. In February 2025, the State Plumbing Board extended the temporary enforcement policy until June 1, 2025 (policy statement dated February 26, 2025 at Section 2.4.9).

Amendments to HB25-1077

Two amendments were presented to and passed by the House Committee on Business Affairs & Labor. Amendment L.002 establishes that installations of backflow prevention devices on stand-alone fire suppression systems would not require a licensed plumber. Amendment L.004 requires tagging of devices with certain information when services are performed, starting on July 1, 2025. This requirement applies when licensed plumbers install, test, inspect, repair, or reinstall backflow prevention devices, as well as when certified cross-connection control technicians or licensed plumbers with a cross-connection control technician certificate test or repair a backflow prevention device. The amendment also specifies information that must be included on the tag: the name and contact information for the business, the date the service was provided, a description of the service, and the ASSE or ABPA certification number of the cross-connection control technician. If the certified technician who performed the service is also a licensed plumber, the tag must include the plumber’s license number, along with the plumbing contractor’s registration number or the license number of the master plumber attached to the contractor.

What does this mean for my water system?

Consistent with Section 3 of Amendment L.004, the WQCD does not intend to perform inspections or enforce the tagging requirements. WQCD Field Services inspectors frequently observe testing tags on backflow devices while conducting sanitary surveys; however, we also recognize that tags can be removed or fall off. Upon HB25-1077 becoming law, CDPHE encourages water systems to check that the licensed plumbers and certified cross-connection control technicians are complying with the tagging requirement as they have their own devices in water treatment plants and other facilities serviced. 

What happens next?

HB25-1077 was signed into law by Governor Polis on March 28, 2025 and the bill can be seen here. This is a major win for safe drinking water in Colorado. Water suppliers are encouraged to continue to implement their Backflow and Cross Connection Control Programs (BPCCC) utilizing certified cross-connection control technicians to test and repair devices to ensure they are protecting the public. For any questions or concerns about BPCCC please email our Field Services team at cdphe_wqcd_fss_questions@state.co.us. Thank you for all your efforts to protect public health!

➽Heather Young, PE, CWP, Field Services Section Manager

Go with the Flow: Your Guide to Becoming a Certified Water Operator

Imagine you are a small business owner operating a water system that is located in a remote area of Colorado, away from major population centers. You have a certified water operator running your water system, and you’re planning on opening another business, but your trusted contract operator just told you that they cannot take on any more work. You got to thinking - maybe we can move operations in-house? What would it take to get someone on my team who lives in the area certified as a water operator? Here’s what it takes!

Remember, proper operation of a water system is vital to protect public health. It takes considerable knowledge and skills, but these can be gained with a reasonable amount of time and effort. On average, it takes about 6-12 months to become certified, depending on how much time you can invest in the process. This article includes the following information relevant to becoming a certified operator in Colorado:

1. Regulations governing drinking water (DW) and wastewater (WW) operators.
2. Obtaining an operator ID from the Colorado Certified Water Professionals (CCWP).
3. Minimum qualifying experience.
4. Training resources to prepare for an operator certification exam.
5. Training Units (TUs).
6. Operator certification exam.
7. Compliance assistance - CDPHE’s Drinking Water Portal, sampling and resources.

1. Regulations governing drinking water (DW) and wastewater (WW) operators

Regulation 100, Water and Wastewater Facility Operators Certification Requirements,  specifies the pertinent information about being an operator, including owner & operator duties, facility classifications, certification qualifications, education, experience, and fees. Colorado-certified operators are subject to the Colorado Certified Water Professionals Code of Conduct and are also responsible for being knowledgeable of the Water and Wastewater Facility Operators Certification Board (board) Policies and Guidance documents, which you can find on the board’s website. 

If you are thinking about becoming a drinking water operator, you will want to develop an understanding of Regulation 11. This document houses the state of Colorado’s primary drinking water regulations. It is not expected that you memorize this information, however, this regulation is a good resource to understand why requirements are put into place at specific water systems. 

2. Obtaining an operator ID from the Colorado Certified Water Professionals

After reviewing the above information, your first step will be to create a Colorado Certified Water Professionals (CCWP) Portal account and obtain an Operator ID number. The instructions on how to do so and how to apply for certification and sit for an exam can be found on CCWP's website. You can also find helpful videos on operating the CCWP Portal. 

If you need assistance setting up your operator account in the CCWP Portal or entering your information into your portal account, please contact CCWP at (719) 225-7339 or info@coloradocwp.com.

3. Minimum qualifying experience

Applicants for entry-level certification examinations (Class D, Class 1, or Class S) must satisfy a one-month experience requirement or the successful completion of an approved training course of study that is designed to prepare the operator to operate Class D or Class 1 facilities. Per 100.14.5(k)(i), Regulation 100, experience needs to be obtained under the supervision of a certified operator in responsible charge.

The division provides other free training opportunities that include various online options. You can also find several other training providers in Colorado that provide approved courses by simply Googling "water operator training Colorado." All approved courses can be found in the Course Catalog, and you can also filter for those courses that have been "Approved for regulatory water training" and "Approved as substitution for entry-level operating experience." All individuals seeking their professional water operator certification are required to have either 30 days of relevant operational experience, or the substitutive educational credit. The CCWP portal will allow you to calculate your relevant experience and educational hours to determine that you have met the requirements. Please reach out to CCWP if you have any questions about this process.

4. Training resources to prepare for an operator certification exam

The CCWP Need to Know Criteria Page contains information on the exam and study resources to prepare for your exam. It is recommended that you work in the CCWP portal and contact the CCWP office to see how your previous work experience translates. CCWP staff are extremely knowledgeable and more than happy to assist in understanding the portal application process or to answer any questions on whether information is being accurately represented on an application.

The CCWP’s Certification Exam Guidance outlines the certification requirements necessary for becoming an operator.  It covers the education, training, exam review process, and exam procedures. Be sure to identify what level of certification your facility will require. If you are a small business owner, many small systems may require a Class “D” treatment certification & Class “1” distribution system certification, which would mean you will be applying for entry-level certification. Depending on the population served and treatment & distribution requirements, you may also be able to obtain a Class “S” or small systems certification per regulation 100.10.5 (d).

Some free resources for training and exam prep include: 

• EPA training system on Drinking water
• EPA Resources for small systems
• WaterOperator.org
• Water Professionals International 
• CDPHE offered free training courses 
• WPI exam prep website
• Sacramento State Drinking Water Manuals
• New Mexico Water System Operator Certification Study Manual

There are some at-cost options for training as well, such as the American Water Works Association (AWWA), which has an operator certification exam prep app to prepare for the examination.

5. Training Units (TUs)

Certified operators are required to obtain Training Units (TUs) to obtain their initial certification; they are also required to meet continuing education requirements to maintain each certification. To determine the appropriate number of training units required for certification renewal, please refer to table 100.16.7 provided in Regulation 100. 

You will be required to sit for a Mandatory Regulatory Training (MRT) course to apply for a certification.  Once you have your Operator ID. The CDPHE has contracted with Indigo Water group, you can also take the free, on-demand virtual Mandatory & Regulatory Training courses by following the instructions provided on the MRT website. 

6. Operator certification exam

Once you have met all of the certification and training unit requirements, and you feel adequately prepared to take the exam, schedule your exam at one of the ten locations or online. You will get a registration email from CCWP for this step. The exam will take the better part of the day, but you worked so hard to prepare, so don’t be nervous. You can do it!

This handbook for Colorado candidates breaks down all of the expectations for taking the exam. You can find additional information from CCWP about the exam process here. 

7. Compliance assistance - CDPHE’s Drinking Water Portal, sampling, and resources

You will want to be familiar with the CDPHE's Drinking Water Resources for Water Systems page. This page houses many of the links that you will find yourself regularly using in your interactions with the state. The Compliance Assurance page can help you find your Compliance Specialist for your water system, sign up for a Drinking Water Portal account, and find guidance for a variety of topics. The Drinking Water Portal is where you will submit all of your water systems’ documentation to the state. Your compliance specialist is your direct contact at the State for all things drinking water regulations and can help you with any questions you may have. We’re here to assist you!

Another important page is the monitoring schedule page, which outlines all required testing for your water system. This is where you can check if your sample results have been received or if there are any upcoming deadlines for your water system. Since your primary duty as an operator is collecting and reporting samples, here is a list of certified laboratories approved for testing and information on appropriate sample reporting to the state. You can find many other resources on operator certification in our Aqua Talk Articles.

If it's the right time for you or someone on your team, we salute the choice to become a member of the respected certified operator community and wish you the best of luck as you navigate this new challenge. We welcome you as you take on a new role in helping us meet our public health protection mission and helping assure that drinking water is always safe.

➽ Leah York, Drinking Water Compliance Specialist

➽ Lisa Pietrangelo, Drinking Water Compliance Specialist

Small Victories - Our Culture of Health in Action!

Culture of Health in the drinking water industry means that we look at our daily routines and emergencies through a lens of protecting people’s health. We are an industry that works 24 hours a day to provide safe drinking water to everyone, and crucially to maintain societal functionality for sanitation and fire fighting. As we continue to promote our culture, we would like to share with you small examples that demonstrate how we put our culture into action! 

Newly Regulated Water System

Recently, we identified a newly registered public water system that was not disinfecting. The water system had indicated to the department that they would not be installing the disinfection system until they received approval from the department for the permanent design. Representatives of the water system reached out to the department to inquire if they could remove the two bathroom sinks in order to not provide human consumption and therefore not be regulated. While the department does not enforce the plumbing code, we are aware that not having sinks in the bathroom could create other sanitary health risks. We worked with the local public health officials and the city having jurisdiction to evaluate the situation further. We notified the water system that if the bathroom sinks were removed, the facility would be in violation of local building codes by not providing running water for sanitation in the bathrooms. The system decided to not remove the bathroom sinks. They installed the chlorination system and added a barrier to help lower bacterial contamination risk in their system. This is a small example of how we utilize our resources and partner with everyone involved to make sure that our water systems are well-informed. 

Broken Well Casing

During a sanitary survey, one of our inspectors identified that a water system's well was leaking significantly. The well cap was split open where an active electrical connection was penetrating the cap. The well was cycling every two minutes, causing water to pour out of the cap every time the well ran. The well pad and well cap was covered with water, algae, and leaves. When the well was not pumping, it was possible that water containing contaminants could leak back into the casing. This led to a concern that contaminated water could be entering the protected groundwater source. 

Our inspector referred the findings to our acute drinking water response team and coordinated with our compliance assurance section to evaluate the situation and identify a path forward. The system prioritized the well casing repair. However, we wanted to identify if there was an imminent health risk present. We requested that the system provide bacteriological samples from the source and at the entry point, increase the chlorine residual, and that the leak be addressed as soon as possible especially given an upcoming inclement sub-zero weather event. The next day, we followed up with the system to confirm that they had collected their samples as they were working to identify a repair contractor. All of the bacteriological samples came back absent for coliform and the water system repaired their casing very promptly. While the regulations officially allowed for a longer timeframe to respond, this quick action by everyone involved aligned with our culture of health and helped minimize risk to the public. 

➽ Drinking Water Compliance Team

Fluoride: A public health benefit and the role of the CDPHE

The Centers for Disease Control and Prevention (CDC) named fluoridation of drinking water one of the 10 great public health interventions of the 20th century. Since 1945, when the addition of fluoride to drinking water began, there has been a dramatic decline in tooth decay among children and reduction in tooth loss among adults. At optimal levels, water fluoridation improves the oral health of all residents, regardless of dental insurance coverage, access to health care, age, gender, income, race or ethnicity. 

What is drinking water fluoridation? 

Drinking water fluoridation is the adjustment of fluoride to an optimal level in accordance with scientific and dental guidelines. The US Public Health Service (PHS) has determined a fluoride concentration of 0.7 mg/L as the optimal concentration of fluoride in drinking water that maximizes fluoride’s oral health benefits while minimizing potential harms, such as dental fluorosis. Fluoride is a naturally occurring mineral present in varying amounts in almost all soil, water, plants and animals and a normal constituent of many diets. Naturally occurring levels of fluoride in drinking water sources are often too low for the benefit of cavity prevention and so water systems have the choice to add fluoride to the recommended optimal level. Water fluoridation is practical, cost-effective, and equitable for all members of the community. For every $1 invested by water systems in water fluoridation, Coloradans save an estimated $61 per person per year in dental care costs. Fluoride improves oral health by helping to prevent tooth decay through strengthening the tooth enamel and helping to remineralize tooth enamel lost to the acids in food and beverages. Fluoride also makes it harder for harmful bacteria to adhere to the teeth. Good oral health is an important part of good overall health and an essential part of our everyday lives. Diet, sleep, psychological status, social interaction, school and work are all affected by impaired oral health.

What is CDPHE’s role in water fluoridation?

The Colorado Department of Public Health and the Environment’s (CDPHE) Water Quality Control Division (WQCD) provides technical support to systems that add fluoride as part of their treatment process. WQCD also performs inspections of the fluoride treatment system as part of the sanitary survey process for regulated public water systems. WQCD performs these inspections under a “Memorandum of Understanding” with CDPHE’s Oral Health Unit (OHU) in the Prevention Services Division (PSD). Much like the monthly operating reports (MOR) surface water systems submit to show compliance with the Surface Water Treatment Rule, participating water fluoridating systems submit a monthly fluoride report to OHU for tracking optimal fluoride levels. CDPHE follows the PHS recommendation of 0.7 mg/L for the optimal fluoride level in drinking water. While water fluoridation in the state of Colorado is voluntary, the decision to add fluoride is held to the same drinking water standards; additives must meet NSF/ANSI standards, fluoride levels are monitored daily and reported monthly to OHU. 

The Environmental Protection Agency (EPA), through the Safe Drinking Water Act, has established national drinking water standards for public water systems. The EPA requires public water systems to comply with the maximum contaminant level (MCL) of 4.0 mg/L for fluoride in drinking water, with a secondary MCL of 2.0 mg/L. Public water systems that exceed the secondary MCL but are below the MCL are required to distribute public notice regarding the health effects of the elevated levels of fluoride. Recommended fluoride levels for the efficacy of cavity prevention are well below the EPA’s secondary MCL. A recent District Court case out of Northern California ordered the EPA to evaluate the public health risk of fluoride in drinking water under the amended Toxic Substances Control Act. Following the announcement of the Court’s opinion, the American Water Works Association, the American Dental Association, the American Academy of Pediatrics and the American Fluoridation Society have each reaffirmed support for optimal water fluoridation as safe, effective, and essential to the protection of the public’s health. CDPHE issued its own statement on October 14, 2024 in support of water fluoridation and will continue to review new and emerging research on water fluoridation.

For additional information about water fluoridation or further inquiries on the Court ruling, please reach out to the CDPHE OHU community water fluoridation program at cdphe.psfluoridationsmf@state.co.us.

➽ Aspen Coombs, P.E. WQCD Fluoride Liaison

Colorado Water Loss Initiative: Training and Technical Assistance for Water Loss Control

Water loss is water that is lost in a municipal distribution system between treatment and consumption. There are two types of water loss that lead to lost revenue and resources for systems and customers, real loss (leaky pipes) and apparent loss (metering inaccuracies, data handling errors). Real water loss typically occurs before any water meters, which are often located as the water enters buildings. This means that a utility is paying for all the cost of transporting the water from source to treatment plus treatment and distribution costs, but getting no revenue in return. 

Globally, water losses from drinking water supply networks account for 9 billion gallons a day of water use. Cost effective water loss management reduces cost and increases revenue, which improves a systems bottom line and better serves its customers. The Colorado Water Loss Initiative (CWLI) is a program developed by the Colorado Water Conservation Board (CWCB) that provides training and technical assistance to water providers. In November 2023, the Colorado Water Conservation Board instituted an annual water loss reporting requirement for systems supplying at least 2,000 acre feet of water per year to their customers. The CWLI was established to provide a comprehensive training program for systems as part of the Colorado Water Plan strategic objective to support water management activities for all water providers and drive water loss implementation to address future water needs.  The benefit to you, a training course on how to identify water loss, collect water loss data, audit and validate data, along with technical assistance to develop solutions to decrease water loss in your system. 

CWLI Training Program

The CWLI offers a training program to assist systems in learning the AWWA Free Audit Software and implementing the American Water Works Association (AWWA) M36 methodology to quantify water loss. Once systems have completed the data collection, auditing, and validation phase of training, they are then provided technical assistance opportunities to implement controls and tools to minimize water loss. Technical assistance can include activities such as meter testing and design analysis or billing data analysis and prorating. Grant assistance is available to program participants to remedy prioritized water loss interventions that were identified through the program.  

Who can benefit from the training?

All drinking water systems. Do you have a small system and aren’t required to report annual losses but still interested in water loss? No problem, small systems can benefit from the water loss program and are encouraged to register. Water loss best management practices can help all systems save water, money, prepare for water supply shortages, and prepare for future climate impacts. All systems will learn to take the appropriate steps toward effective water loss control management. 

How much is it? And where do I register for the program?

The program and materials are offered at no cost and are available to all eligible drinking water staff. See the below resources to learn more about the program

• Video interviewing participants about their experience
• CWCB Water Talk Podcast - CWLI staff discusses the program
• Register here for the program

Interested in helping to improve water loss control and management? Join the CWLI Committee!

The Colorado Water Loss Control & Management Committee was formally established in December 2023 by the Colorado Water Conservation Board. The committee's objective is to improve water loss control and management by planning water loss strategies, trade technical information, inform water loss policy discussions, train and educate water utilities on water loss, and support water loss goals of the Colorado Water Conservation Board. You can find more information at the Colorado Water Loss Control & Management Committee  website.  

➽ Angela Green Garcia, Drinking Water Training Specialist

➽ Kevin Reidy, DNR, Senior Water Efficiency Specialist 

Aqua Answers: PFAS and Biosolids

Dear Aqua Answers,

Please help! I have multiple questions about PFAS and biosolids. 

Thanks,

Newt R. Sludge

__________________________________________________________________________

Dear Newt,

I have listed your questions and the answers below:

Question 1:

Can you remind me, what are biosolids? 

Biosolids are a product of domestic wastewater treatment processes. They are rich in nutrients and organic matter; farmers can use them as fertilizer to improve soil quality. The Colorado Department of Public Health’s Water Quality Control Division and the U.S. Environmental Protection Agency require biosolids to meet regulatory requirements for pathogens, pollutants, and land application to protect human health and the environment. Biosolids produced in Colorado are either land applied to agricultural fields as a soil amendment/fertilizer (70+%), composted (20+%), or disposed of in landfills.

Question 2:

How do PFAS get into biosolids?

Industrial, commercial, and residential use and disposal of PFAS products can allow these chemicals to enter wastewater treatment facilities. As a result, researchers have found PFAS in treated wastewater and biosolids. PFAS can move in the environment and potentially impact the soil, water, and crops.

Question 3:

What is the department’s approach to reducing PFAS levels in biosolids? 

The department has taken a proactive approach that aligns with EPA’s newly released Draft Sewage Sludge Risk Assessment recommendations and focuses on measuring and understanding levels of PFAS in biosolids and identifying and reducing significant sources of PFAS migrating to wastewater treatment facilities. The department began implementing its Biosolids-PFAS Interim Strategy on January 1, 2023. It establishes monitoring requirements for biosolids preparers and a threshold level for requiring biosolids preparers to develop and implement a source control program to evaluate potential industrial or commercial sources of PFAS. More information about our interim strategy and biosolids test results the department has received are available on our PFAS and biosolids web page.

Question 4:

What can people living in our beautiful state do to reduce the amount of PFAS entering the environment? 

Over the past several years, Colorado has committed to identifying where PFAS are entering the environment, stopping new releases, and protecting Coloradans. In many ways, Colorado has led the way in its efforts to track and reduce exposure to PFAS. The department is now focusing on carrying out actions in the 2024 PFAS Action Plan to continue our work as a leader among states addressing widespread PFAS pollution. To learn more, please visit the 2024 PFAS Action Plan webpage.

To protect the environment and reduce the amount of PFAS entering our wastewater treatment plants, we need to phase out the production and use of products containing these chemicals and find safer alternatives. Recent legislation in Colorado has banned the sale of certain products containing PFAS. We encourage people to get the facts and take steps to limit their exposure from other sources and avoid PFAS when purchasing consumer goods and new household products. This will protect your health and further prevent the chemicals from entering our environment. We have resources at our PFAS public health website.  

Sincerely,

Aqua Answers

Early 2025 CoWARN updates

The WQCD is sending the below updates in partnership with the CoWARN steering committee. We encourage all water and wastewater providers in Colorado to join the mutual aid network to enhance your preparedness for emergency incident preparation, response, and recovery. Please reach out to CoWARN administrator Kyra Gregory with any questions or if you have interest in joining the CoWARN steering committee made up of volunteers from water/wastewater providers in CO: kyra.gregory@state.co.us 303-908-7519. 

New CoWARN website launched, take action today!

Colorado's Water/Wastewater Agency Response Network launched a new and much-improved website in fall 2023! However, the new website could not retain all the information from the old website. So, all CoWARN members need to please update their membership profiles on the new website. So far, only 63 out of 246 CoWARN members have updated their membership information. Because of this there have been multiple CoWARN activations that many CoWARN members did not receive: Two Buttes 8/27/24, Gardner 8/29/24, Genoa 11/19/24. If you did not receive text or email notification of these activations, please take action today to update your contact information and system membership through the new CoWARN website.

How does the new website work?

As a CoWARN member your water or wastewater facility will have a profile on the website. Each member profile will assign primary users who can activate CoWARN to send out email/text messages to the CoWARN network. As a user under your facility’s membership, you will need to: 

1. Reset your personal password
2. Navigate to your dashboard by clicking on the red icon in the top right hand corner of the screen. 
3. Update your personal information - be sure to add a cell phone number as you will need to receive a text message to log into the site. 
4. Create your facility’s membership profile - Under “my systems” click “Add”. You are now the primary user for the membership profile. 
5. Assign other primary users by clicking “Add” under “System Contacts” 

For more information and videos explaining the process, please follow these instructions and reach out to Kyra Gregory with any questions or issues you encounter. 

New Mutual Aid Agreement 

The CoWARN steering committee has revised the CoWARN Mutual Aid and Assistance Agreement. Please sign and return a copy of the updated agreement to CoWARN administrator Kyra Gregory (kyra.gregory@state.co.us). See new MAA here. Please note this is the new agreement that went into effect on January 8th, 2025 regardless of received signatures. 

A short description of the updates is below. 

• Correct Colorado Revised Statutes references 
• Revise definitions of operational structure to better reflect current operations and create flexibility for any future structural changes
• Remove specific language regarding agreement expiration
• Clarify CoWARN’s role in activations and that CoWARN is not a guarantor in any transactions nor an administrator of transactions.