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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!
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