Certified Operator Staffing Requirements

Staffing Requirements at Public Water Systems

Massachusetts Drinking Water Regulations, 310 CMR 22.11B, require that every public water system (PWS) be operated with a primary operator and secondary operator for treatment and distribution. The primary operator must work one daily work shift per week and be certified at a grade level at least equal to the classification of the facility. The secondary operator must be certified at a grade level not less than one grade level lower than the classification of the facility and must be present "on all shifts when the primary operator is not present, unless otherwise authorized in writing by the Department and/or as exempted by 310 CMR 22.11B(5)." For most PWSs, this means that the primary operator works the weekday shift. For facilities that are operated more than one working shift per week, a secondary operator must be present on all shifts when the primary operator is not present. Properly certified operators must be present at all times in order to insure that the public health is adequately protected.

Treatment Facilities

Treatment facilities must be staffed at all times by a properly certified operator, unless the Department has granted the facility an exemption. Exemptions are typically only granted for automated operations, which must conform to MassDEP requirements detailed in 310 CMR 22.11B(5)(d) and approved in writing. A treatment facility typically has one primary operator and multiple secondary operators in order to provide coverage on all shifts. The primary and secondary operators are in direct responsible charge of the operation of the facility. Primary operators must hold Full licenses, but secondary operators may hold OIT (operator-in-training) licenses. Individuals working under the direct supervision of a properly certified primary or secondary operators, who is present and in charge, are not required by MassDEP to be certified. However, individuals who are not certified cannot provide sole coverage on any working shift, including weekends and holidays, in order to insure that proper process control and operational integrity are maintained. MassDEP strongly encourages the certification of all operators, but recognizes the need for PWSs to employ unlicensed individuals to assist primary and secondary operators so that they can be trained and become certified.

Distribution Systems

Distribution systems are required to be operated by a primary operator at least one daily working shift per week. The primary operator must also be available to respond to emergencies within one hour at all other times. Additionally, a secondary operator must operate the distribution system in the absence of the primary operator.  Primary operators must hold Full licenses, but secondary operators may hold OIT (operator-in-training) licenses.  There is no requirement that a distribution system have more than one shift. However, there must be a secondary operator present if the distribution system has more than one shift and the primary operator is not working. An unlicensed operator may respond to emergency calls when certified operators are not working, but any work must be performed under the direct supervision of a licensed operator (either primary or secondary) who is present and in charge.

Very Small Systems

Very small systems (VSS) serve a population of 500 or less. All non-community systems, including both transient (TNC) and non-transient (NTNC), are classified as VSS regardless of the population served. VSS do not require a secondary operator. However, during times when the primary operator is temporarily absent (for periods not exceeding 30 days), an operator with certification equal to or greater than the system must be retained to respond to an emergency. Emergency response time cannot exceed one hour. If a VSS has treatment, the operator is required to have a full treatment license equal to the classification of the facility.

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