A sanitary survey is an inspection of a public water system (PWS) to assess their capability to supply safe drinking water. As the state primacy agency implementing the federal Safe Drinking Water Act, the Colorado Department of Public Health and Environment is required to have a program to conduct sanitary surveys of the PWSs in the state. The safe drinking water program’s field services section conducts these inspections. This article will explore the basics of a sanitary survey, some of the most common issues identified, and give you resources to help prepare your PWS for your next sanitary survey.
Goals of the inspection
The primary goal of the sanitary survey is to protect public health. This is accomplished by identifying what is functioning well and what needs work in your facility to provide and distribute safe drinking water to the public. Another goal of the division is to use the survey as a way to build trust and establish good relationships with systems. The field services section aims to build those relationships by providing assistance and resources to help systems comply with regulations and protect public health.
The criteria that the survey is based on are:
Who, what, when and where?
All public water systems are required to have a sanitary survey. At a minimum, the surveys take place once every 3 years for community systems and once every 5 years for non-community systems. Field services can conduct surveys more frequently based on water quality concerns or to follow up on previous sanitary surveys. While typically the field services section schedules sanitary surveys in advance, in rare cases sanitary surveys are performed without advance notice. Not sure of your system type? Visit the division’s monitoring schedule website and search for your system name or PWSID.
Generally, your inspector will get in touch with you a few weeks before the survey to schedule your survey via email or phone (usually the ORC or AC is contacted). And the survey can take anywhere from several hours to multiple days depending on the size of your system and any issues that may arise during the survey. Your system’s Operator in Responsible Charge (ORC), Owner, Administrative Contact, and any key management and operators should attend. Basically you want to have all personnel in place to answer questions about general operations, management, security, and technical questions about your system.
The sanitary survey will be a three part process. The first step is to ensure that your system has accurate and up-to-date records, developed written plans for regulatory compliance, and maintains adequate operator certification. The second step is to do a field review in which the inspector will be looking at the entire water supply system. They will evaluate the entirety of the system including the water source, treatment facilities, storage tanks, and distribution system. Also, the on-site review covers monitoring, reporting, and data verification (i.e. are you sampling at the correct locations). The last step of the process is the post-survey follow up. Your inspector will send you a letter and you then need to follow up with a response form and address any issues that come up.
Common issues identified
Any issues identified in the survey will be documented in your post survey letter as the following:
Significant Deficiencies and Violations: The inspector who performed the sanitary survey will follow up on these items. The sanitary survey letter will specify when a written response is due from your water system and what needs to be addressed.
Observations/Recommendations: We won\'t directly follow up on these items, but we strongly recommend the water system address them.
The field services section has identified the most common violations and significant deficiencies at systems in recent years as:
Backflow & Cross Connection Control Incorrectly implemented
Lack of written program
Lack of annual reports
Inadequate tracking mechanism
Chlorine sampling
Inadequate records
Expired reagents
Failing to calibrate monitoring equipment per manufacturer requirements
Storage Tanks: Unprotected vents and overflows
Vents do not terminate in a downward direction
Improper hatches
Lack of normal maintenance and inspection schedule
Tank Rule and Tank Deficiencies
Design Review
Construction of new waterworks
Change in treatment process without approval
TC sampling not representative of distribution
Lack of up-to-date monitoring plan
How to prepare for your next survey
The division has prepared several resources to help you prepare for your next sanitary survey:
Monthly sanitary survey preparation training. Click here to see a schedule of upcoming training and to register.
If you still have questions after attending one of the monthly sanitary survey preparation trainings, consider one-on-one assistance provided by the Local Assistance Unit, a team of coaches specializing in drinking water regulatory compliance. Click here to request a coaching visit (virtual or in-person options available).
We also have these helpful documents on our website to help you:
