CCR forms and guidance
MassDEP provides a template and guidance for use by water suppliers in preparing their CCRs, as well as a certification form to verify to MassDEP that they have distributed the completed CCR.
For details on electronic delivery of CCRs, see the next section.
Optional electronic delivery
Electronic delivery of Consumer Confidence Reports (CCRs) is an allowed option for distribution. Community public water systems (PWSs) must continue to meet all the same requirements of CCRs.
On January 3, 2013, EPA interpreted the existing federal regulations pertaining to direct delivery of Consumer Confidence Reports (CCRs) as allowing several options for electronic delivery (e‐delivery). No changes were made to the CCR regulation. Community public water systems (PWSs) must continue to meet all the same requirements (e.g., content, Good Faith Efforts to reach non‐bill paying consumers, foreign language, certification, etc.). Please note that e‐delivery is optional. Systems may choose to continue past delivery methods including regular mail, door‐to‐door delivery or posting in an appropriate location (when approved).
For PWSs that intend to use e‐delivery, the following information is applicable:
MassDEP began accepting e‐delivery of CCRs starting with the report due July 1, 2013.
Community PWSs must prominently display a message informing their customers of the option of obtaining a hardcopy CCR and how they can do so
MassDEP will allow e‐delivery via a mailed post card, bill stuffer, or other notice that includes a direct URL (i.e., web address), an email that contains a direct URL, or an email that contains the full CCR as part of the message (either as an attachment or as an embedded image). Any other e‐delivery method must be approved by MassDEP prior to its use. Direct URLs must open to the CCR without the need to browse to other web pages.
MassDEP will require that all CCRs be delivered to customers by July 1 of each year. If an email method is used and it is undeliverable for any reason, a paper CCR must be mailed to that customer by July 1.
MassDEP will require that the CCR URL be live until the next year’s CCR is issued.
MassDEP updated our CCR certification form to include e‐delivery options. All community PWSs must use this form.
The signed certification can be delivered to MassDEP (email@example.com) and Mass DPH (firstname.lastname@example.org) via email. Contact your local board of health to see if they will accept their copy via email. Certification must include both a complete copy (either a hardcopy or PDF) of the CCR and the URL. Only sending the URL is not acceptable.
Social media (e.g., Twitter, Facebook) and automated phone calls do not meet the direct delivery requirement but can be used to meet Good Faith Effort requirements.
The EPA memorandum can be found on the EPA website at https://www.epa.gov/sites/production/files/2015-12/documents/ccrdeliveryoptionsmemo.pdf. Systems without Internet access or that are unable to download this memorandum can obtain a hard copy by contacting the MassDEP Drinking Water Program. MassDEP strongly recommends that all systems read the EPA memorandum as it covers issues for consideration, provides helpful examples and expands on the helpful information below.
Good faith efforts and postal patron mailings
Community PWSs must mail or otherwise directly deliver a CCR to all “customers,” defined as bill‐paying consumers. Community PWSs must also make three Good Faith Efforts to reach the non‐billed consumers. Mailing out CCRs to the postal patrons in a PWS service area will reach more people than mailing to bill‐paying customers, but it has its limitations. Postal patrons may not include people who work in the service area but live in a different one. If a system decides to use a postal patron mailing, they are still required to do three additional Good Faith Efforts.
Combinations of delivery methods
In order to reach all customers, community PWSs will likely have to use a combination of e‐delivery and mailed paper copies. Some customers prefer a hard-copy version and some will not have internet access. Both the hard-copy and the e‐copy must have all the required information in them. The e‐copy allows the PWS to include additional information and can include links to this extra information. If the e‐copy CCR is different from the hard-copy CCR both must be sent to MassDEP for review along with your delivery certification.
Community PWSs that post their CCR to a web page must have the site live as soon as the URL is delivered to its customers. MassDEP will require that this site remain active until the next year’s CCR is delivered. PWSs must keep copies of the most recent three years of CCRs; make sure when you upload a new CCR that the previous CCRs are archived properly, either online or as hard copies in your files. Try to make the URL as clear and distinct as possible; avoid characters that could easily be confused, such as the number zero and the letter O or the capital letter L, the lower-case letter l, and the number 1. There are many URL‐shortening services out on the Internet. PWSs may use these services but do so at their own risk, as these links can be broken or spam filters may prevent their delivery. A PWS will be noncompliant with the CCR regulation if their URL is disabled. If a system uses a website to comply with the direct delivery requirement, that effort cannot also be counted as a Good Faith Effort.
Public notice and e-delivery
A CCR that includes a Tier 3 Public Notice may use e-delivery. All other Public Notices must follow existing delivery requirements and e-delivery is not permitted.
MassDEP may alter these policies over time to better meet the intent of e-delivery. If so, we will send out another letter explaining any changes.
Fluoride reporting in CCRs
When a PWS adds fluoride to their water and has a concentration to report in their CCR tables, the source of that fluoride must be clearly stated as “water additive which promotes strong teeth” or a similar phrase. Below is an example of contaminant table information.
|Contaminant||Date(s) Collected||Highest Result or Highest Running Average Detected||Range Detected||MCL||MCLG||Violation (Y/N)||Possible Sources of Contamination|
|Fluoride||__/__/20__||1.1||0.9 - 1.1||4||4||No||Water additive which promotes strong teeth|
Necessary information for treatment-description section:
In the treatment summary area of the CCR the PWS must explain why the treatment was added. Here are some examples of what could be written:
- Fluoride was added to prevent tooth decay/cavities.
- Fluoride has been added since (insert year) to prevent tooth decay/cavities.
- Fluoride addition was passed by referendum vote in (insert year) and added to the water supply in (insert year) to prevent tooth decay and improve dental health.
- Fluoride is a naturally occurring element in many water supplies in trace amounts. In our system the fluoride level is adjusted to an optimal level averaging one part per million (ppm or mg/l) to improve oral health in children. At this level, it is safe, odorless, colorless, and tasteless. Our water system has been providing this treatment since (insert year). There are over 3.9 million people in 140 Massachusetts water systems and 184 million people in the United States who receive the health and economic benefits of fluoridation.
Manganese Reporting in CCRs
If your community system detects manganese concentrations greater than 50 ug/L in any finished water sample, you must report these concentrations in your CCR.
Report the concentration(s) in the unregulated/secondary contaminant table of your report as follows. Please use the parts per billion (ppb) unit of measure when referencing manganese in your CCR (50 ug/L = 50 ppb).
|Unregulated or Secondary Contaminant||Date Collected||Result or Range Detected||Average Detected||SMCL||ORSG or Health Advisory||Possible Sources|
|Manganese (PPB)||__/__/20__||50||300 *||Erosion of natural deposits|
* US EPA and MassDEP have established public-health advisory levels for manganese to protect against concerns of potential neurological effects.
If your manganese detection is 300 ppb or over, in addition to the above CCR table, you must also include the following educational statement on manganese in the CCR report. You should also include a statement of what your system is doing to reduce manganese levels below 300 ppb.
You may use the educational statement below or get MassDEP’s written approval for alternative CCR language. The educational statement for manganese should explain the significance of the manganese detects and if customers need to be concerned by its presence. The bolded required language in the statement below must be included exactly as written in the CCR.
Manganese: Manganese is a naturally occurring mineral found in rocks, soil and groundwater, and surface water. Manganese is necessary for proper nutrition and is part of a healthy diet, but can have undesirable effects on certain sensitive populations at elevated concentrations. The United States Environmental Protection Agency (EPA) and MassDEP have set an aesthetics‐based Secondary Maximum Contaminant Level (SMCL) for manganese of 50 ug/L (micrograms per liter), or 50 parts per billion. In addition, MassDEP’s Office of Research and Standards (ORS) has set a drinking water guideline for manganese (ORSG), which closely follows the EPA public health advisory for manganese. Drinking water may naturally have manganese and, when concentrations are greater than 50 ug/L, the water may be discolored and taste bad. Over a lifetime, the EPA recommends that people drink water with manganese levels less than 300 ug/L and over the short term, EPA recommends that people limit their consumption of water with levels over 1000 ug/L, primarily due to concerns about possible neurological effects. Children younger than one year old should not be given water with manganese concentrations over 300 ug/L, nor should formula for infants be made with that water for longer than 10 days throughout the year. The ORSG differs from the EPA’s health advisory because it expands the age group to which a lower manganese concentration applies from children less than 6 months of age to children up to 1 year of age to address concerns about children’s susceptibility to manganese toxicity. See: EPA Drinking Water Health Advisory for Manganese, https://www.epa.gov/sites/production/files/2014-09/documents/support_cc1_magnese_dwreport_0.pdf, and MassDEP Office of Research and Standards Guideline (ORSG) for Manganese.
Unregulated Contaminants Monitoring Rule and public notification in CCRs
Consumer Confidence Reporting of UCMR
The Massachusetts Drinking Water regulations at 310 CMR 22.16A(4)(f)2 require reporting in the CCR of unregulated contaminants for which monitoring is required; and the UCMR is required testing by US EPA. All community systems are required to distribute CCRs annually to their consumers. (This requirement does not apply to non-community systems.) When unregulated contaminants are required testing, any detect above the minimum reporting level (MRL) is to be reported in the CCR. When reporting, include the average of the year’s monitoring results, the range (lowest and highest detect), and briefly explain in the CCR why the PWS is monitoring for unregulated contaminants.
Unregulated contaminants are those that don’t yet have a drinking water standard set by the US Environmental Protection Agency. The purpose of monitoring for these contaminants is to help US EPA decide whether the contaminants should have a standard.
Those community PWSs that wish to provide additional information to their customers may refer to the UCMR Data Summary at https://www.epa.gov/dwucmr/fifth-unregulated-contaminant-monitoring-rule.
Additional Information for Medium and Small Community Water Systems
All medium PWSs serving between 3,300-10,000 people and 800 representative small PWSs serving fewer than 3,300 people are required to monitor UCMR 5. Although medium systems will be selected for participation right away, their participation by the remainder are dependent on EPA obtaining the necessary funding. EPA is responsible for the analysis of UCMR samples from small PWSs and for the development, review, and distribution of monitoring results. Based on the lag time between sample collection and laboratory reporting of analytical results, the time required for EPA’s quality control review of the results, and the time required to develop and distribute UCMR reports to small systems, many small PWSs may not have results in time for their yearly CCR.
EPA’s view is that the CCR for a given year (due by July 1 of that year) is to report UCMR detections based on results received by the PWS during the previous calendar year. For example, a PWS’s 2020 CCR would include UCMR results received during calendar year 2019. If a small PWS does not receive its UCMR monitoring report from EPA until 2020, EPA’s view is that those results do not need to be included in the CCR until 2021 (even if the sample was collected during 2019).
Public Notification (PN) for UCMR
The PN rule requires PWSs to provide special notices for certain situations, including the availability of UCMR data. Special public notices of UCMR data are different from other public notices because they do not have to contain all the elements required of other types of public notices. Instead, systems need only report that the results are available, and provide a phone number or contact where the results can be obtained.
The Massachusetts Drinking Water Regulations at 310 CMR 22.16(7) state that Public Notice (PN) must be given for UCMR results within 12 months of the result date. This is regardless of whether you had detects or not. Your PN can be included in the body of your CCR if the CCR is delivered within 12 months of the date of the results of the UCMR.
Delivery of UCMR PN is the same as for regular PN notices and for CCRs. Deliver your UCMR PN/CCR to customers using one of the options below:
- Directly mail the PN/CCR to billed customers or postal patrons
- Upload the PN/CCR to a website and mail a postcard with the URL on it to all billed customers or add the URL to water bills
- Post the PN/CCR in local newspapers, public places, apartment-complex lobbies, and community organizations.
You must also send a copy of your UCMR PN and completed PN Certification Form to MassDEP, MassDPH, and your local board of health.
If you have any questions please contact Marie Tennant at 617-292-5885.
For UCMR help please contact Program.Director@mass.gov or at 617-292-5770.
Frequently asked questions about CCRs
What is a consumer confidence report (CCR)?
A CCR is an annual report on drinking water quality that community public water suppliers must deliver to their customers. Reports are due every July 1 for the previous calendar year. These reports are mandated by the federal Safe Drinking Water Act. The Massachusetts Department of Environmental Protection (MassDEP) is the state agency authorized to implement and enforce drinking water mandates such as the CCR rule.
Who has to file a CCR?
All community public water systems (PWS) are required to prepare and provide to their customers an annual consumer confidence report on the quality of their drinking water. A community public water system is defined as a public water system that serves at least 15 connections used by year-round residents or regularly serves at least 25 year-round residents. These reports will allow consumers to make personal health-based decisions regarding their water consumption. In Massachusetts there are approximately 533 community PWSs.
How is the average citizen supposed to interpret or use the data in the CCR or water quality report?
The report should say whether the water meets federal and state standards for safe drinking water. The presence of a particular ingredient does not mean that the water is unsafe to drink. However, if something is detected above the maximum level, the PWS must discuss the potential health effects, and actions taken to correct the problem.
People who have special health problems, immune deficiencies, or pregnant women should check with their health care provider if contaminants are detected in concentrations that are above the standard or maximum contaminant level (MCL).
Who is responsible for ensuring that the local water supplier is reporting the truth?
If a contaminant exceeds the standard or MCL, the PWS must notify their consumers about the potential health effects and what they must do until the problem is solved. MassDEP must be notified. MassDEP reviews all violations and reports to ensure accurate and truthful reporting.
How can consumers get additional information on their public drinking water?
Consumers should contact their PWS directly if they want more information on their local system. Fact sheets on drinking water, contaminants, health effects, and public education materials are available on the MassDEP and US EPA websites. Citizens may also call the US EPA Safe Drinking Water Hotline at 800-426-4791.
If a substance is detected and reported in the CCR, does that mean the water is unsafe to drink?
No, detecting a substance does not necessarily mean the water is unsafe to drink. When concentrations of substances in the water exceed certain health-based standards, MassDEP determines the potential for health impacts and orders the system to notify its consumers and take corrective actions. Corrective actions can include the use of an alternative source, treatment, or boiling.
Are the reports available in different languages?
Systems that have 25% or more of a particular population who speak a language other than English must translate the CCR into that language. Chelsea, Fall River, Holyoke, Lawrence, and New Bedford must do a complete CCR translation. Systems that have 10% or more of a particular population who speak a language other than English must include an "Important - Please have this CCR translated" statement in language used in their community. There are fifty-one of these municipalities.
Why do consumers need to have this information? What does MassDEP hope the outcome will be?
Most environmental laws have a consumer right-to-know component. The Safe Drinking Water Act Amendments of 1996 included several consumer right-to-know provisions. The CCR rule is the one with the most impact on community public water systems. These reports discuss the local drinking water quality and their PWS's compliance with the federal standards for safe drinking water.
MassDEP hopes that people will realize that public drinking water must meet stringent standards. MassDEP also hopes that these reports will lead to better communication between the system and the consumer, and the consumer will know whom to contact if they have problems.