When is my Sanitary Survey?
Regulation 11.38(2) outlines the Sanitary Survey frequency requirements as once every three (3) years for Community Water Systems and once every five (5) years for Non-Community water systems. Please remember that these are minimum frequencies, and that the division has the authority to conduct sanitary survey inspections at any time.
You may ask, “we are overdue for a sanitary survey, what do we do?” First of all, do not panic, the WQCD has a backlog of suppliers due for sanitary surveys due to historic resource constraints and the COVID-19 pandemic. Please reach out to the Field Services Section email at cdphe_wqcd_fss_questions@state.co.us if you need to talk to someone about your sanitary survey schedule. A member of the Field Services Section will respond to let you know if you are scheduled for a sanitary survey this year or if it is delayed.
I am scheduled to have a Sanitary Survey, how do I get ready?
The WQCD has many documents to help prepare for the sanitary survey on our website. A great resource to take advantage of is the free Sanitary Survey Preparation training from the Local Assistance Unit. It’s a 3.0 hour course, you get 0.3 TUs and can register by selecting your date.
Do you need additional help beyond the basic sanitary survey preparatory class? Are there special treatment issues you could use help on? Please reach out for one-on-one customized coaching and assistance. A coach will come to your facility to take a look and discuss your specific needs. Training units are available, depending on time spent with the coach. Please use the Online training request to register. For more information please see the Local Assistance Unit website.
What changes do I need to be aware of?
EPA Region 8 performed a review of the CDPHE WQCD drinking water program to determine if CDPHE is in compliance with the National Primary Drinking Water Regulations (NPDWR). This review included sanitary survey letters and entry of sanitary survey findings into SDWIS. The EPA evaluation found that the historic practice of downgrading Significant Deficiencies to Observations if resolved prior to the letter issuance is not acceptable and must be discontinued. Therefore, in IY22 starting October 1, 2021, if a significant deficiency is identified during the Sanitary Survey Site Visit, CDPHE must cite it as a Significant Deficiency even if it was resolved the day of the sanitary survey. If the supplier is proactive and resolves it during the sanitary survey or before the sanitary survey letter is issued, we still have to cite the significant deficiency but will make sure to memorialize the resolution in the sanitary survey letter. The supplier will also need to include it in their Consumer Confidence Report (CCR). With this in mind, it will be critical that water system operators do a walkthrough of the facilities before the Sanitary Survey site visit date to identify any significant deficiencies and resolve them. A future Aqua Talk article will be coming that identifies the most frequently cited significant deficiencies and violations. We understand that this is a big change, but a necessary change to maintain compliance with our primacy agreement with EPA. If you have any questions or concerns, please reach out to me at heather.young@state.co.us.
Thank you for all your efforts to protect public health and we look forward to seeing you at your next sanitary survey.
➽ Heather Young, PE, CWP, Field Services Section Manager
