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Wednesday, May 19, 2021

Do I need to respond to significant deficiencies/violations from my sanitary survey? - Yes!

Don’t wait to address a significant deficiency or violation until it becomes a risk to public health. Reach out for help to achieve compliance and ensure safe drinking water! 



Do I need to respond to significant deficiencies/violations from my sanitary survey? 
YES, absolutely! 

Unresolved significant deficiencies and field based violations of Regulation 11 may pose a serious risk to public health, require additional (and potentially ongoing) public notice to customers and can result in enforcement and significant penalties. Please avoid this situation by proactively working with the Division to address unresolved significant deficiencies and violations.

Sanitary surveys are conducted at least every 3 years for community water systems and every 5 years for non-community water systems. During the sanitary survey, significant deficiencies and violations of Regulation 11 may be identified during the review of the 8 elements of the sanitary survey (see Regulation 11 Section 38). Significant deficiencies are any situation, practice, or condition in a public water system with respect to design, operation, maintenance, or administration, that the state determines may result in or have the potential to result in production of finished drinking water that poses an unacceptable risk to health and welfare of the public. The inspector may also identify violations of Regulation 11 in the field that require Tier 2 or Tier 3 public notice. Your inspector will review any significant deficiencies or violations identified with you during a close out meeting. The inspector will also send a sanitary survey letter that includes all findings of the inspection and the required responses. If significant deficiencies or violations are cited in the letter, the supplier must provide a written response within 45 days, documenting resolution of all significant deficiencies and violations, and/or propose a corrective action plan with a corrective action plan (CAP) schedule. All significant deficiencies must be resolved within 120 days of the date of the letter or by a Division approved corrective action plan schedule.  

Not sure if you have open significant deficiencies or violations? First, review your system’s latest sanitary survey letter. Sanitary survey letters can be found by searching for the Public Water System Identification (PWSID) number on the Division’s online record management system located here. Your Monitoring Schedule is also a great resource to review your Compliance and Public Notice Schedules. These schedules clearly list deadlines for resolving any open significant deficiencies or field based violations. 

Have open significant deficiencies and field violations and don’t know where to start? Contact your Field Services local field staff by county listed here or email us at cdphe_wqcd_fss_questions@state.co.us. Field service inspectors are available to review your sanitary survey with you and discuss options to gain compliance. 

Can’t get the issue fixed within 120 days? Field services works with suppliers to establish corrective action plans (CAP) for significant deficiencies or violations that require additional time for resolution. Please submit any information regarding your sanitary survey follow up to the DW portal here. Your Field Services follow up staff member will be alerted to your submission and will contact you.

Are you under enforcement for open significant deficiencies or violations from a sanitary survey and have questions? Please reach out to the compliance specialist listed in the enforcement order cover letter. 

For more information about sanitary surveys in Colorado, please visit our website.

 Heather Young, PE, CWP Field Services Section Manager and Nicole Graziano, PE, CAS Section Manager