When we discuss creating a culture of public health among drinking water professionals, a key aspect of this culture is clear communication. This article discusses two tools used to communicate:
- Monitoring Schedule. The Drinking Water Compliance Assurance section uses this document to communicate your systems specific monitoring requirements based on Regulation 11.
- Chain of Custody. Drinking water systems use this to communicate which chemical or bacteriological analysis they would like performed on their samples, the turnaround time for the results, the location at which the samples were taken, and the order and manner in which the samples have been handled.
These two tools are crucial to ensuring that you are sampling at the correct time, for the correct analyte, and at the correct location, while correctly reporting the information to the division.
Why is it important to sample?
As drinking water professionals our main goal is to protect human health by providing safe drinking water to the public. We do this through establishing, maintaining, and monitoring the barriers to waterborne disease outbreaks, lowering levels of lead exposure and mitigating chronic health impacts from chemical and radionuclide contaminants:
- Source water protection
- Treatment
- Monitoring potential contaminants
- Storage
- Distribution
- Public Notification
Compliance sampling generates the data that confirms that the hard work to maintain the multi-barrier approach is working. We all use compliance data to drive our actions.
Monitoring Schedules
Last year our coaches described the monitoring schedule in detail. To summarize, your monitoring schedule can be used to:
- Identify where to sample, when to sample, and for what analyte,
- Plan your system’s sampling schedule for the calendar year,
- Verify that your sample results are being received by the division,
- Identify which analytes are required sampling for your system, and
- Help you fill out your chain of custody (COC) for your lab.
The monitoring schedule can also be used to help you budget for your system’s annual monitoring cost. The most up-to-date monitoring schedules can be found by visiting the division’s monitoring schedule website and searching for your system’s PWSID (COXXXXXXX) or name. If you cannot access the internet to find your monitoring schedule please contact the Compliance Assurance Unit’s public assistance line at 303-692-3556.
Your monitoring schedule will be updated on the division’s website every Thursday to reflect up-to-date schedule and sample results received information. It may take a few weeks for submitted samples to be reflected in the schedule due to lab turnaround and reporting time.
If you notice something in your schedule that is incorrect such as outdated contact information, incorrect facilities, and sample sites, please submit sections of your monitoring plan that need to be updated.
Resources:
- Division’s monitoring schedule website
- Example monitoring schedule
- Further sampling specifics information
Chain of Custody
The above snap shot is from the most up-to-date CDPHE drinking water COC.
The best way to ensure that your samples are processed appropriately is to follow these rules:
- Contact your lab prior to sampling. We suggest you send them a copy of your monitoring schedule so they can help you fill out your chain of custody accordingly.
- Follow hold times and temperature: every analyte has its own specific hold time and temperature. If the samples deviate from the appropriate ranges the lab can no longer use them for compliance analysis as they are no longer valid. Discussing these hold temperatures and times prior to sampling will help you set up your process to return the samples to the lab.
- Sample early in the monitoring period. Remember it can take days to weeks for the lab to analyze the samples. Sampling early will ensure you do not miss your compliance sampling and reporting deadlines.
- Order extra sampling kits/bottles. This way if you have any issues during the sampling event, you don’t have to wait for new bottles to sample.
- Label your sample bottles and fill out your COC prior to sampling.
- Ensure sample results are submitted in a timely manner – even if they are not due yet!
In some cases, reporting sample results long after they’ve been analyzed can result in violations. For example, if a sample result is high enough to trigger increased monitoring, the supplier will be accountable for all monitoring periods in which they should have been on increased monitoring. Monitoring violations would be issued for all missed monitoring periods and compliance with the maximum contaminant level would be evaluated with the data received over the applicable monitoring periods – even if those quarters did not have data!
Routinely check your monitoring schedule. You will know that the division has received the sample results because they will be crossed out on your schedule.
Most labs report data directly to the division through the drinking water portal. Please check with your lab to make sure they will do this for you. This will help ensure that your data is processed in a timely manner and avoid duplication in the data processing. You must provide the following required information to the lab on the chain of custody if they are reporting the data on your behalf:
- PWS ID - if you do not know you PWSID it is listed on your monitoring schedule
- Facility ID - exactly as listed on your monitoring schedule
- Sample Point ID - exactly as listed on your monitoring schedule
- Collection Date.
- For total coliform bacteria samples:
- Free Chlorine in mg/L.
- Total Chlorine in mg/L (only needed for systems with chloramines).
How to correct errors made in data submission?
Sample reporting errors with facility ID, sample point ID, chlorine residual type, or incorrect measurements can be corrected by resubmitting a revised CSV, creating and submitting a Sample Correction Form, or submitting a copy of sample results with corrected information clearly indicated, via the Drinking Water Portal, fax, or mail or by having your lab resubmit corrected results. Any corrections must be received by the applicable reporting deadline. The collection date, lab name or ID, lab sample ID, analyte, facility ID, sample point ID, and residual must be submitted correctly or the requested correction will not be processed, resulting in a monitoring and reporting violation. Updated CSVs with the same Lab ID, Lab Sample ID, and Analyte are considered revisions, and the most recent submission is used.
If a deletion is needed, please send a PDF through the drinking water portal, using the “Requests and Other Certifications” category or a fax, or mail. The request must include the unique lab sample ID, collection date, analyzing lab, analyte, and the reason for the requested sample to be deleted.
➽ Kyra Gregory Drinking Water Training Specialist
