Is your water system ready to notify the public?
You do an excellent job running your water system and it never has any violations. You do not need to be prepared to rapidly notify your customers of an acute health risk or other health-based violations. Right? Wrong! We believe that all systems need to be prepared for the possibility of issuing a system-wide public notice for a variety of situations.
Through no fault of your own, due to flooding and the associated damage or if routine and repeat samples in the distribution system come back positive for E. coli, your system may face a situation that represents an acute public health risk. According to the Colorado Primary Drinking Water Regulations, you would need to issue a Tier 1 public notice as soon as practical, but no later than 24 hours after becoming aware of the situation. Remember, that by the time the results come back positive on the repeat samples, a couple of days have gone by since the initial samples were collected. Will your customers be satisfied with waiting another 24 hours before being told not to drink their water without boiling it?
Are you ready to do this? On a weekend? On a major holiday? How will you do this, Reverse 911 or other methods? This kind of public notice has a huge impact in the community. Operations at restaurants, businesses, grocery stores, hotels, schools, daycares and more are all significantly impacted. Are you ready to be in touch with all of these entities? There could be media interest. They will ask what did you know? When did you know it? When is the situation going to be fixed? There could be an explosion of social media interest via Facebook and X. Are you ready to engage in these communication methods? What if the event overwhelms your available resources? Are you a member of CoWARN? If so, you may be able to get help from other water systems.
If there is uncertainty about how you will accomplish a rapid notice or about the answers to any of these questions, then we suggest that planning for this kind of event would be a very beneficial activity. While we do not offer specific training at this point in time about Tier 1 public notice, we would be happy to assist your water system with planning for such an event. Please contact Kyra Gregory at kyra.gregory@state.co.us.
Now, let’s switch gears to a lesser crisis. Suppose that due to an equipment malfunction followed by an alarm breakdown that does not alert you, your filtration system does not meet turbidity limits for a short time period. The drinking water acute team will evaluate the situation, and if there is not an acute risk, then tier 1 public notice would not be needed. However, this situation likely still represents a health-based violation of the Colorado Primary Drinking Water Regulations and triggers a tier 2 public notice. Tier 2 public notice must be issued as soon as practical, but no later than 30 days after the event. Again, will your customer be satisfied with finding out about a violation a month later? Will this generate media interest along the lines of “Why did you wait so long to tell people?” Again, planning for these situations in advance can help you meet not only regulatory requirements but also customer expectations.
Thank you.
➽ Ron Falco, P.E. Safe Drinking Water Program Manager
