This article provides a review of the updated facility classifications that will begin for existing facilities in March 2021. The department published an article in February 2020 reviewing these changes. Since the deadlines are fast approaching, it is appropriate to revisit these changes and confirm that you do not need to be considering higher level operator licenses for your water or wastewater treatment or distribution/collections system.
In November 2018, the Water and Wastewater Facility Operators Certification Board (board) updated the facility classification criteria in Regulation 100 after an extensive, state-wide stakeholder process. These revisions are important because classifying treatment facilities and distribution/collection systems establishes the minimum certification level for operators who act as the certified operator(s) in responsible charge (ORC). The 2018 updates focused on the complexity of facility operations and alignment with operator certification testing.
All facilities are subject to classification according to the 2018 board’s adopted criteria. In many instances, facility classifications will remain unchanged. For facilities where the classification will change, the effective date for the change will begin March 1, 2021. If the classification for your facility will be changing and you do not have the proper level of certification, you will need to upgrade to the new level to remain as the ORC.
Impacts of the 2018 Facility Classification Changes
- About 20% of facilities are expected to get a different classification.
- About 4% of ORCs are expected to need a higher certification to remain ORC.
Two-step Classification for Distribution and Collection
In the previous version of Regulation 100, the board considered population to be a good surrogate for system complexity. For example, a system with more people could be expected to have more flow, bigger and longer pipes, etc. The board did include some criteria for increasing classification of low population systems based on complexity, but the criteria were subjective and not applied consistently, if at all.
In 2018, the board adopted stakeholders’ ideas regarding objective criteria of complexities. Distribution and collection classification is now a two-step process. Step 1 considers the system’s population like before the update. The new Step 2 is a review of possible complexities. If a low-population system has one or more of the listed complexities, the classification may increase:
- Distribution system complexities include pressure zones, entry points, chloramines, etc. A pressure zone must serve at least 15 service connections to be counted as a zone for classification purposes.
- Collection system complexities include elements like larger lift stations.
When do new classifications apply?
- Beginning on March 1, 2019, new or substantially modified facilities were to be classified using the updated criteria during design review. During design review, the engineering section will evaluate any water or wastewater treatment facility that has submitted changes to the division for classification changes that would apply upon completion of construction.
- For existing facilities, the new criteria will apply beginning on March 1, 2021. Distribution and collection systems will not change until March 1, 2021 unless system population has increased to the next classification level.
- Delaying implementation for existing facilities until March 1, 2021 gives time to understand the impacts and plan appropriately.
How can I know the future facility classification?
Please review facility classification sections in Regulation 100. Sections 100.4 to 100.9 are the primary facility classification sections. Exemptions are included in section 100.1.5.
To assist owners/operators, Tables of all current and probable 2021 classifications are available on the internet. Some notes to consider: Tables may take several minutes to load, and the search functions at the top of tables are also very slow. An alternative, once the original table is loaded, is to just scroll down or use the page advance at the bottom of the tables. “O” means treatment ORC is not required. “0” means distribution or collection ORC is not required.
- If you disagree with the probable classification in the table based on your own review of the updated Regulation 100 criteria, you can use an online form to provide feedback.
- We will review responses to the Google form and contact facilities that responded along with any others where additional information suggests a discrepancy between the estimate and the classification.
The board has improved the operator testing program to provide more testing opportunities each year and in more locations. Certification testing is provided through the board’s contractor, Colorado Certified Water Professionals (CCWP). Examination information and CCWP operator portal tutorials are available on the CCWP program webpage.
What should we do if an ORC needs a higher certification?
We estimate that about 4% of current ORCs will need a higher certification. Operators are encouraged to study and test for the higher certification before March 2021. If a facility's classification is increasing and the ORC needs to get a higher certification to remain ORC, there are a few situations where an existing ORC can remain as ORC for a while before testing for the new certification level. These situations are described in section 100.10.8 (a)-(c). The site-specific ORC must be requested by December 31, 2020. Request consideration of site-specific ORC status by completing the application.
Online Resources:
- Regulation 100 Facility Classification - Tables of all current and probable 2021 classifications
- Water and Wastewater Facility Operators Certification Board - Regulation 100 is available on the board's webpage. We encourage you to review the updated Regulation 100.
Questions?
Drinking water, distribution
Tyson Ingels | tyson.ingels@state.co.us
Lead Drinking Water Engineer
Domestic wastewater, collection, reclaimed water, industrial wastewater
David Kurz | david.kurz@state.co.us
Lead Wastewater Engineer
