Part 14 Cross Connection Rules Isolation of a high hazard use Obstacles to approaching this type of facility Types of equipment in these types of facilities Containment orders Explore ways to approach this use Stakeholders involved in the process Breaking the building down into manageable

components Plumbing Codes MIOSHA Part 474 Sanitation Governmental Immunity

Are we just there to protect the distribution system?

Are we concerned about the occupants inside the building?

Is the building just to big to manage? What about liability? What do the Part 14 Rules tell you to do? What are your obligations to public safety?

Should the Primary Protection focus be the distribution system only?

Or, is it reasonable to say that Secondary Protection is to the building occupants ?• Is it possible to trace all

plumbing lines to their end uses in these types of buildings?

• Is it possible to enter every room in a million square feet of building area.

• We do the best we can.• Testers are our eyes and

ears

R 325.11402 Compliance with regulations and local codes

Rule 1402. A connection with a public water supply system shall comply with existing laws, ordinances, codes and rules including:

(a) All Sections of the Michigan Plumbing Code pertaining to backflow and cross connection control.(2015 MPC Chapter 1, 2, 3, 4, 6, 15 and Appendix A all address backflow issues.)

The codes allow for existing plumbing systems to stay as currently installed, providing they were installed properly according to the code in effect at the time of installation and they do not currently present a safety hazard.

Rule 1404Rule 1404 (1): A type 1 public water supply shall develop a comprehensive control program for the elimination and prevention of all cross connections. The plan for the program shall be submitted to the department (MDEQ) for review and approval.

Suppliers may use the best practices manual for cross connection control prepared by the department of drinking water and municipal assistance, listed in R 325.10113 when developing a cross connection control program.

When the plan is approved, the water supply shallimplement the program for removal of all existing cross connections and prevention of all future cross connections.

Contents of Best Practices Manual (formally Cross Connection Rules Manual)

Chapter 1: Introduction Chapter 11: Acceptable Means of Protection

Chapter 2: Cross Connection Rules Chapter 12: Customers to inspectChapter 3: Cross Connection Terminology Chapter 13: Re-inspection

Chapter 4: Backflow Prevention Devices Appendix A: Suggested Model OrdinanceChapter 5: Hazards Appendix B: CCCP Guidance OutlineChapter 6: Common Hazards Appendix C: Model CCCPChapter 7: Common Facilities to Inspect Appendix D: Sample Record Keeping Forms

Chapter 8: Responsibilities Appendix E: Backflow Assembly Test Procedures

Chapter 9: Local Cross Connection Control Program

Appendix F: Sample Letters

Chapter 10: Containment, Isolation and Piping Identification

Appendix G: Approved Backflow Preventers

The Best Practice Manual is referenced in the Administrative Rules Promulgated under the Safe Drinking Water Act R 325.10113 Compliance with Rules; guidance Information Rule 113(d)

Section 7.3 Hospitals and other Medical Care Facilities:

These facilities are considered high hazard accounts due to the many possible cross connections typically found within them, including autopsy and mortuary equipment, bedpan washers, heat exchangers, cooling towers, auxiliary water supplies, kitchen and food processing equipment and fire suppression systems just to name a few.

In many cases, service line containment with an RPZ along with yearly testing of the assembly will be needed. If desired, the local inspection agency may also inspect the interior piping system. If an RPZ is installed on the service line, it does not eliminate the need for high degree of protection throughout the internal piping system.

This public health protection is of particular importance considering the function of hospitals.

Sections 108.7 Unsafe Plumbing, 106.1, 106.2 PermitsAny plumbing regulated by the code that constitutes a health hazard, insanitary condition or otherwise dangerous to human life

Is declared unsafe

Any use of plumbing regulated by the code constituting a hazard to safety, health or public welfare due to inadequate maintenance, dilapidation, obsolescence , damage or abandonment

Is declared unsafe

Any such unsafe equipment is declared to be a public nuisance and shall be abated by repair, rehabilitation, demolition or removal. Section 106.1 Permits Permits are required when you install,

enlarge, alter, repair, remove, convert or replace any plumbing system.Section 106.2 lists the exemptions from the permit requirement

Section 201 Cross ConnectionAny physical connection or arrangement between two separate piping systemsOne that contains potable water and the other of unknown or questionable safety orSteam, gas or chemicalWhereby there exists the possibility for flow from one system to the otherWith the direction of flow depending on the pressure differential between the two systems

Section 312.10 Inspection and testing of backflow prevention assembliesSection 312.10.1 Inspections

* Note that it does not include devices

Annual inspections shall be made of all backflow prevention assemblies and air gaps to determine whether they are operable

Section 312.10.2 Testing This section indicates that all testable assemblies must be tested at time of installation, immediately after repairs or relocation and at least annually.The testing procedure shall be performed in accordance with one of the following: ASSE 5013, ASSE 5015, ASSE 5020, ASSE 5047, ASSE 5048, ASSE 5052, ASSE 5056, CSA B64.10 or CSA B64.10.1

Section 303.2 Installation of Materials

* Part 14 Rule 1402 states existing systems must be installed properly and according to code on existing systems

All materials used shall be installed in strict accordance with the referencedstandards under which the materials are accepted and approved.

Section 422.3 ProtectionAddresses all devices, appurtenances, appliances, and apparatus intended to serve some special function.

INCLUDES: Must be protected from:

Sterilizationbackflow, flooding, fouling, contamination of the water supply system and stoppage of the drain

DistillationProcessingCoolingor Storage of ice or foodsConnections to either water supply or drain system

This chapter address specific requirements not addressed in Section 608 Protection of Potable Water SupplySection 406.1: automatic clotheswashers water connections

Must comply with air gap or backflow preventer per 608

Section 409.2: dishwashing machine water connections

Must comply with air gap or backflow preventer per 608

Section 414.1: garbage can washer water connections

Must comply with air gap or backflow preventer per 608

Section 423.1: baptisteries, ornamental pools, aquariums, fountain basins, pools and similar constructions

Must be protected against backflow per 608

Section 424.2: Hand Showers Must meet ASME A112.18.1/CSA B125.1 or ASME A112.18.3 standard for backflow

Lead ContentSection 605.2: lead content of water supply pipe, fittings and valves

Must meet 8% lead content

Section 605.2.1: leadcontent of drinking water pipe, fittings and valves

When used for drinking or cooking purposes,must meet NSF 372 and have a weighted average lead content of 0.25 percent or less

Section 608.1 GeneralThe potable water supply shall be designed, installed and maintained in such a mannerto prevent contamination from non-potable liquids, solids or gasesfrom being introduced into the drinking water supply

through cross connections or any other piping connections to the systemBackflow preventer applications shall conform to Table 608.1, except as specifically stated in Sections 608.2 through 608.16.10 (this means isolation)

***The code includes general provisions, specific requirements, allowable exceptions to those requirements and must meet the referenced standards listed in the code and Chapter 15

Section 609.1 Scope:This section governs those aspects of healthcare plumbing systems that differ from plumbing systems in other buildings.Section 609.4 Vacuum Breaker Installation:Vacuum breakers shall be installed 6-inches above the flood level rim of the fixture or device. The flood level rim for hose connections shall be the maximum height at which any hose is used.Section 609.7 Condensate Drain Trap Seal:A water supply shall be provided for cleaning, flushing and re-sealing the condensate trap, and the trap shall discharge through an air gap.

Is the plumbing code based on isolation or containment? Isolation

Do the Part 14 Rules require compliance with all components of plumbing code pertaining to backflow? Yes

Do the Part 14 Rules require you to eliminate all existing cross connections in accordance with current codes? Yes

Do the Part 14 Rules require the local authority to submit their program to the State for approval? Yes

Do you accept any liability if you don’t? The courts will decide this if something happens

The MDEQ has indicated that it is up to each local authority to determine how they protect the drinking water supply.

There is also no appeals process mechanism in place like the construction codes.

Enforcement is up to local interpretation. The Construction Code Laws Prohibit the local

authority from imposing more stringent requirements than the code.

The Safe Drinking Water Act allows the local water authority to impose more stringent requirements than minimum requirements as long as its in their program.

Shutting the water off to one of these facilities is most likely not going to happen. They are essential facilities.

There are many layers in hospital decision making process to make things happen. You need to be patient.

You need to know what your looking for or area’s you want to see.

There are procedures to be followed to enter certain areas. You should be working with your plumbing inspector through

this process as plumbing permits may be required. These buildings may include multiple buildings, and they are

large, complex and contain many different types of equipment.

It takes time to get things done. The interior culture for maintaining the facility, It may need to

be changed.

Fire systems (glycol loops unheated areas including walk-in freezers, exterior canopies and unheated mechanical rooms), multiple systems

Boilers – Heat Exchangers

Glycol loops (MRI or other medical equipment) Wells for secondary water supplies

Surgical instrument decontamination equipment (secured areas)

Janitorial chemical feeds

Kidney dialysis equipment Secondary domestic water treatment systems (Dihydro – pipe saving)

Portable kidney dialysis equipment KitchensClinical sinks Ice machines (kitchen/bed floors)Bedpan washers Beverage machines (kitchen/bed floors/break

rooms/waiting areas)

Can washers Surgical training lab (decontamination equipment)

Wheelchair washers LaboratoriesCooling towers MorguesPumps Specialty Equipment

Redundant water service lines (these buildings should be contained)

Lawn irrigation (some may be on wells or ponds, others may be on City water)Laundry equipmentDishwashing equipmentPower washers

Mobile Kidney Dialysis Machine

Wells, other source water supplies

HOW DO WE APPROACH THIS TYPE OF FACILITY

Make an appointment to sit down with the facilities maintenance director

Explain the changes to the cross connection rules program

Invite as many stakeholders as you canExplain that your trying to protect

the occupants of the building

Explain that they are an extremely high hazard use that treats and houses sick people with deficiencies in their immune systems

Explain your new policy and that you want to work with them

Bring your Part 14 RulesBring your plumbing codeBring the MIOSHA Requirements so they’re informed

SHOW THEM WHERE THIS IS COMING FROM AND WHAT YOU’RE TRYING TO ACCOMPLISH

• Explain to them that you understand that this is going to take time and that you are willing to work with them within reason, while considering the importance of protecting the drinking water supply.

• Explain that this will most likely take many meetings and site visits to accomplish.

• Explain that it is vital to evaluate their plumbing systems to first determine what you’re dealing with.

• Find out what types of equipment they may have. Prepare a list before the meeting. You need to tell them what you need to see and things will progress from there.

• Break the building down into components or it will be overwhelming. (kitchen, boiler room, decontamination rooms, cooling tower, kidney dialysis, fire systems, glycol systems, janitor closets, clinical sinks, chemical additive areas, all beverage areas including bed floors, etc.)

Is their testing done in house Are they ASSE 5110 certified Who does their repairs Do they pull permits How many testable assemblies do they have Can they provide you with a complete current list

of test reports Do they follow ASSE listing requirements

Explain how your process works beginning with test report reviews, inspections, notification letters, whether compliance or non-compliance, test report non-acceptance letters, containment orders, etc.

Include the facility director, nothing gets done without his approval and he has to answer to his superiors.

Include the chief building engineer. Include their master plumber if they have one. Include the plumbing inspector. Permitting issues will

need to be worked out. Don’t discard the responsibly of the permitting department.

Include your work leader so someone besides yourself knows what your doing. There is a lot to look at.

You need to know whether things have been installed correctly, protections are missing, wrong application, etc.

Part 14 tells you to use the plumbing code.◦ You should become familiar with Chapter 1 Scope,

Application and Unsafe Plumbing Systems◦ Chapter 2 Definitions◦ Chapter 3 General Regulations (pertaining to cross

connection control)◦ Chapter 4 Fixtures, Faucets and Fixture Fittings

(pertaining to cross connection control◦ Chapter 6 Water Supply and Distribution (pertaining

to cross connection control)◦ Chapter 15 Referenced Standards◦ Appendix A Non-potable Water Systems

Is there a cross connection first and foremost. Is it installed per manufacture installation

instructions and ASSE Listing requirements (high enough, missing valves, horizontal, vertical up/vertical down approvals, correct valves, etc.)?

Is it the proper application (low hazard –vs- high hazard)?

Is it an unprotected cross connection? Does it need to meet lead free requirements? Are valves placed where valves are prohibited? Prioritize corrective requirements based upon

degree of hazard.

If you have a meeting, put together an agenda and stay on track.

Your agenda should include the topics, length of meeting, who is present, decisions made, agreements made, things to research, time tables for corrections.

If there is a violation, put it in writing. If you reject test reports, put it in writing. This could potentially be a long process, your

record keeping will keep you on track to what is done and what is still outstanding. You will continuously have to refer back to these notes.

If the building chief plumber does not regularly refer to manufacture specs or ASSE listings, this will be a big change.

If this individual is not used to pulling permits this will be a big change.

While adapting to these changes they may find they just do not have the in house staff to do this and have to farm it out. This involves Purchase Orders and approvals, another big change.

If they’re not accustomed to an isolation type inspection, this will be a big change.

You will continue to find things as you continue moving through other areas of the building. This will be a process over time.

If corrective measures are extensive in cost, the approval for funds will most likely go all the way up the food chain and this will take time.◦ The director may have the authority to approve a limited amount and

anything above that needs to be approved by upper management or through an upper management layers.

*Be aware that it exists and use it to your advantage. They need to know this.

• Most recent MDEQ review was in 2010 which concentrated on the installation of an anti-siphon valve to prevent overdosing

• The MDEQ does not regulate this system or require permits, Yet

• Its up to each local municipality to determine how they address this issue

Considering the code paths, are we more liable if we look at these types of facilities from a containment perspective only, given the complexity of these facilities?

Or

Are we less liable if we do the best we can from a combination containment / isolation standpoint?

“Gross negligence” means conduct so reckless as to demonstrate a substantial lack of concern for whether an injury results.

691.1407 ‐ Immunity from tort liability; Intentional torts Section 7(2): Each officer and employee of a government agency is immune from 

tort liability for any injury to a person or damage to property caused by the officer, employee or member while in the course of employment or service or caused by the volunteer while acting on behalf of a government agency if all of the following are met:a) The officer, employee, member or volunteer is acting or reasonably believes he or she 

is acting within the scope of his or her authority. How does your continuing education factor into this?

b) The governmental agency is engaged in the exercise of discharge of a government function.

c) The officer’s, employee’s, member’s, or volunteer’s conduct does not amount to gross negligence that is the approximate cause of the injury or damage. How does just looking at containment factor into this?

Have you met your obligation to the health, safety and welfare of the public in your community? There is a lot to consider in these types of buildings.

Or, do you fall into the neglect of duties category based upon the above code path which is something we all need to think about?