Public Notice Requirements from Sanitary Surveys
Sanitary surveys are vital to protecting public health. During sanitary survey site visits, we identify and discuss violations of regulations 11 and 100, which we also report in the sanitary survey letters delivered to each public water system’s administrative contact. Any violation cited during a sanitary survey requires public notification to all of the system’s consumers.All public notifications must include the Ten Required Elements of a Public Notice. Distribution requirements vary based on the tier of the violation and the type of system where the violation occurred (e.g., city or town versus a campground).
To help water systems meet their public notice requirements, we’ve created an online tool to help generate public notifications that are tailored to specific situations. The tool uses a google form to create a notification template, but you do not need a gmail account to use the tool. The tool helps you get started, but you still need to take the steps indicated below to complete the process.
Completing the process
If your system has received a violation during a sanitary survey:
- Use our online tool public notice template generator. This will ensure that you have all of the 10 required elements in your public notice.
- When completing the form, make sure that you select "sanitary survey identified violations - tier 2" or "sanitary survey identified violations - tier 3" as the violation type.
- After completing the form, you will receive an email with a link to a template for the public notification. The template will be available in Google Docs format so you can easily edit the template.
- You will need to add descriptions for each violation, the date the violations need to be corrected, and the steps you will take (or have taken) to correct them.
- After you distribute the public notice(s), please submit a final copy, along with a certificate of delivery, through the department’s Drinking Water Portal.
Frequently Asked Questions
What is the difference between tier 2 and tier 3 public notification requirements?
Tier 2 notifications must be distributed within 30 days and repeated every 3 months until the violation is resolved. Tier 3 notifications must be delivered within 365 days and repeated every year until the violation is resolved. Most community water systems meet this requirement by including tier 3 violations in their annual Consumer Confidence Reports (CCRs).
What are the requirements for distributing a public notification?
The requirements are slightly different for community and non-community systems:
- For a community system (e.g., city or town), the notification must be:
- Distributed by mail or another direct delivery method to each customer and to other service connections; AND
- Any other method designed to reach all other consumers regularly supplied by the system.
- For a non-community system (e.g., business, school, or campground), the notification must be
- Distributed by posting the notice in conspicuous locations throughout the distribution system frequented by consumers OR by mail or direct delivery to each customer and service connection; AND
- Any other method designed to reach all other consumers regularly supplied by the system.
I need to include specific health effects language for a tier 2 violation. Where can I find that required language?
Many treatment technique violations do require specific statements warning consumers of the potential related health effects. Table 11.33-VI in Regulation 11, includes all of the standard health effects language. This language is also included in the template for any tier 2 violation as long as you select “sanitary survey identified violations - tier 2” as the violation type in the process to create a public notification described above.
If I distribute a notification for multiple violations and resolve one or more of the violations — but not all of them — can I modify and redistribute the notification?
Yes. This is an excellent way to inform your consumers not only of the violations but of the progress you are making to resolve each of the violations.
Can I use my annual water quality consumer confidence report to deliver a public notification?
Yes, as long as you meet the following direct delivery requirements:
- The public notice must be directly delivered to all consumers and sent by at least one additional method designed to reach those that might not receive it directly.
- You must meet the due date for the violation. This may entail delivering the report before the report due date.
- You cannot utilize the direct delivery waiver that is available.
Still have questions?
If you have any questions about sanitary survey-related public notice requirements, please contact the Drinking Water Compliance Assurance Section at 303-692-3556.
➽ Tim Jones, drinking water compliance assurance