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Maintaining Consistency & Credibility
In the Main - A technical assistance newsletter for Public Water Suppliers
August 2009
By Yvette DePeiza
The Drinking Water Program (DWP) is administered through four regional offices, one satellite office and the main office in Boston. Even though we are operating from several locations it is a priority for the program to respond to similar circumstances in a consistent manner. In order that the DWP maintains its credibility and the respect of the regulated community and consultants with whom we do business, a high degree of importance is placed on this. In this regard, the DWP uses a variety of tools to assure consistency of operation. However, in no way are these tools meant to stand in the way of independent judgement in response to special circumstances.
As described below, the DWP uses seven main tools to ensure consistency of regulations and program implementation: guidelines, policies, standard operating procedures, section chiefs' meetings, technical subcommittees and workgroups, monthly reports, and correspondence review.
The guidelines have been developed to provide a reference to MassDEP staff, public water systems employees, consulting engineers, and hydrogeologists. They are structured to address facets of water source development, construction, treatment, distribution, emergency response, capacity, and water management.
The policies have been drafted to clarify interpretation of the Massachusetts Drinking Water Regulations, and to establish a protocol for addressing site specific problems which have potential to recur in the administration of the regulations. Policies can be initiated at any level and are reviewed for comments by staff. Section chiefs and program managers make the final recommendation to adopt a policy to the program director. Policies become finalized upon signature of the bureau's assistant commissioner. Adopted policies may be subsequently considered for incorporation into a future revision of the guidelines and/or regulations.
Standard operating procedures (SOP) have been developed for certain activities, especially within the Water Quality Assurance (WQA) Program. These SOPs were previously categorized and catalogued in program guides ("Red Books") for reference. Program guides are also used to initiate new staff to WQA programs. The DWP is working to move all Red Book SOPs into electronic format. All DWP offices will have electronic access to all program guides or SOPs.
Monthly drinking water section chiefs' meetings provide a forum for discussion of general as well as regionally specific water supply issues. Certain issues may lead to the development of new policies or SOPs, which require approval of the section chiefs before being presented to the assistant commissioner for ultimate approval.
Technical subcommittees and workgroups are formed in response to a need to resolve complicated and potentially complicated issues which relate to a particular program or program component as well as developing the components of new rules. Each group is chaired by a program coordinator from the Boston office and comprised of a representative from each regional office. The members of a particular group will research and discuss matters of sufficient complexity and/or controversy that they might require a SOP or policy. The chairperson compiles the minutes of each meeting and prepares proposed resolutions for consideration by water supply staff by way of the section chiefs. The subcommittees/workgroups include: sanitary survey, Total Coliform Rule, enforcement, cross connection, source approval, data management, filtration (treatment), water management, Lead and Copper Rule, Long Term 2 Enhanced Surface Water Treatment Rule, Stage 2 Disinfection By-Products Rule, Consumer Confidence Report, Ground Water Rule, emergency response, underground injection control, arsenic and others.
Monthly reports, compiled by DWP programs in Boston such as water quality assurance (WQA), regularly provide a record of regional activity with respect to enforcement and sanitary surveys. The reports provide the reviewer with a sense of regional priorities. These reports are discussed at the section chiefs' meetings or as needed.
DWP's Boston office is the office of record for all correspondence generated by the program. As such, the Boston office receives copies of all regional water supply correspondence, in electronic or hard copy in specific cases. This provides Boston with the opportunity to review all regional letters for consistency with program regulation, policies and SOPs. If an inconsistency is observed, it is generally brought to the attention of the regional section chief by way of phone call, e-mail, or an item of discussion at the monthly section chiefs' meeting.
In addition to the seven main tools used by the program to ensure consistency the DWP continues to provide annual training on various topics to ensure that all staff is aware of the components and procedures of the program.
In The Main index
Maintaining Consistency & Credibility
Is SRF Financing for You?
In Brief: Drinking Water Operator Licenses Expire; Preparation Materials for Exams; Massachusetts Receives State Fluoridation Quality Award; Staff Spotlight: Melissa Privetera
Self Assess Your Emergency Response
Ground Water Rule Questions & Answers
Financial Assistance for Local Water Conservation
MWWA Meeting & Education Seminars
Consultant's Chemical Checklist
Patrick Administration Honors 25 Public Water Systems
Changes to the Total Coliform Rule
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