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COMPLIANCE!

by John Hraska, Circuit Rider I

Be assured that compliance with the New York State Department of Health (NYSDOH) and the United States Environment Protection Agency (USEPA) is no joke. As a matter of fact, it is quite a serious matter. Many of us, including me, have a habit of procrastinating on our paperwork. This is the biggest cause of non-compliance! We may think that being a day late can't make a difference, but it does! Knowing the Local Public Health Engineer (LPHE) isn't an excuse. He or she is there to enforce the regulations and the law. Please remember that they are enforcing the laws that USEPA promulgate, friendship does not play a part. Our main job is to provide safe, sanitary potable water to our consumers and that is what they are concerned with. Most of us have many things to attend to in addition to our water treatment plant duties and think that regulatory agencies understand this. For the most part, they understand but cannot ignore the law. We are expected to perform our duties in compliance with all state and federal laws regulating potable water. You would not believe the amount of non-compliance violations I have seen on the federal level of water systems in New York State for monitoring and reporting. Unfortunately, monitoring took place, but reporting, was a day, or several days late. Another problem is forgetting or losing the test schedule the NYSDOH sends us each year, or the possibility that we did not receive the schedule. We should call the Department of Health during the month of January if we do not receive the schedule, to confirm what we are to test for during the year. The problem is that no person looking at the federal records understands that an oversight was the only problem. The average person will think that the monitoring was mistakenly omitted or late. They will think negligence. People in this day and age are concerned with proper compliance with the law. In other words, if you did it, why didn't you report it? This can be a tremendous headache to explain or justify. To most, this is unreasonable because we are doing our job and expect all of our consumers to understand. We cannot think this way. We are paid and expected to do the best we can to protect public health and welfare, this is our prime directive as water plant operators. Some say that many board of directors don't understand the importance of the water system because the water system has been taken for granted for years. We are in charge of it! It is up to us to make it clear to our board members what the ramifications would be if we ignore the importance of compliance. Many times, it is nothing more than spending several minutes to complete and send in our monthly report on time or checking the required testing schedule from the Health Department and following their direction. Picking up of leaves, garbage, sweeping the streets, etc. can wait for a quarter to a half hour, so that we can complete and send in our monthly report. We are not casting blame on the governing board, the NYSDOH, or the USEPA, but encourage you to talk with these people and come up with a mutual agreement to stay in compliance. Believe me, I have seen non-compliance records dating back to 1980. It is really shocking how many systems are out of compliance for simple omissions or mistakes. This does not mean that you have not been in compliance since then, but it does mean that once it goes on your record it does not come off for quite some time. People are very cautious about the water they drink and you are the one providing it to them. Don't give them a chance to question the quality of it, give them the opportunity to know how good the quality of the water you provide is. This is a simple promotion of the water treatment personnel and their capabilities. You are the people who make sure that your consumers stay healthy and happy with the water you supply to their homes. If you have any problems with compliance or justifying what you do to anyone, please give us a call and we will be happy to assist you. Don't go out on a limb, call us first. Sometimes the problems we see are real bummers, but if we are talking with someone else it can alleviate your frustration and possibly solve your problems.

Always remember that we are not looking at problems and heartaches, we are looking at challenges and opportunities for solutions. This is what makes us water plant operators!

 
     
New York Rural Water Association