9.5 Customer Service, Safety Programs, Operator Training & Regulatory Administration

9.5 Customer Service, Safety Programs, Operator Training & Regulatory Administration

Exam Focus: This section covers the remaining Security, Safety, and Administrative Procedures tasks: investigate various customer issues, monitor status of customer work orders, maintain records and file reports, conduct safety inspections, develop safety procedures, analyze system logs/records, maintain knowledge of current regulatory requirements, and train new operators.

---

Responding to Customer Complaints

The Backup Call

A sewage backup in a home is an emergency for the customer and a potential liability for the utility, and the field determination is time-critical.

Check the downstream manhole first. This single step establishes responsibility:

• If the main is surcharged — flowing high, at or above the pipe crown, or backing up in the manhole — the blockage is in the public main and it is the utility's responsibility. Relieve it immediately: jet or rod the line, and if flow is restored the backup drains.
• If the main is flowing normally and freely, the public main is clear and the problem lies in the private service lateral, which in most jurisdictions is the property owner's responsibility from the main or the property line.

Whichever the finding:

• Respond quickly. Every minute of continued backup adds damage.
• Document exhaustively. Photograph the manhole condition, the flow level, the time, the water marks in the structure. This record is what defends the utility, or fairly supports the customer's claim, months later.
• Be straight with the customer about what was found and what happens next, and hand off the claims process to the correct department rather than speculating about liability at the door.
• Investigate the cause — grease, roots, a structural defect, a protruding tap — and generate the follow-up work order. A repeat backup at a location the utility already knew about is far worse than the first one.

Odor Complaints

Odor complaints are dismissed too easily and are usually real. Systematic response:

1. Record the location, time of day, and weather — odor is worst in warm, still, low-pressure conditions and is frequently intermittent.
2. Identify candidate sources: a nearby manhole, a force main discharge point (the most common source, where turbulence strips H₂S out of solution), a lift station, a dry P-trap in the customer's own plumbing, or a vent.
3. Monitor and log H₂S with a datalogging instrument over several days rather than relying on a spot reading.
4. Apply the fix that matches the source: chemical dosing upstream, ventilation and carbon or biological odor control at the release point, sealing manhole covers, or advising the customer to refill a dry trap.

Work Orders and Customer Service Metrics

The criteria call for monitoring work order status. The lifecycle is intake, prioritization, assignment, execution, close-out with documented findings, and analysis. Utilities track response time to emergencies, backlog age, percentage of preventive work completed on schedule, and repeat calls to the same address. Repeat locations are the most valuable output — three calls to one block is a defect the maintenance schedule is failing to address, and it should convert into a CCTV inspection and then a rehabilitation project.

Records, Reports, and Log Analysis

Records a collection system maintains: daily operating logs, cleaning and CCTV records with PACP coding, lift station runtime and alarm history, SSO reports, flow monitoring data, confined space entry permits (retained at least one year), training records, calibration records, and maintenance histories.

Reports filed externally: SSO notifications within the permit deadline, discharge monitoring reports, CMOM program reporting, and annual reports required by permit or consent decree.

Analyzing logs is where the value is. Trend lift station runtime against rainfall to find the basin admitting the most I/I; trend pump amps to catch a wearing impeller; trend cleaning findings to move a line onto a shorter cycle or promote it to rehabilitation. Write reports factually and promptly — describe what was observed, when, by whom, and what was done, without speculation. Regulatory reports and incident reports are legal documents.

Safety Program Administration

The written programs a collection utility must maintain include permit-required confined space, lockout/tagout, hazard communication, respiratory protection, bloodborne pathogens exposure control, excavation, hearing conservation where noise warrants, and personal protective equipment hazard assessment.

Administration means more than having the binder:

• Job hazard analysis for each recurring task, identifying steps, hazards, and controls.
• Tailgate or toolbox talks before work, covering that day's specific hazards.
• Safety inspections and audits on a schedule, with findings tracked to closure.
• Incident investigation aimed at root cause, not blame. Near misses must be investigated with the same seriousness — they are free information about the next injury.
• Annual program reviews, which the confined space standard requires using canceled entry permits from the past year.
• OSHA recordkeeping on Forms 300 (log), 301 (incident report), and 300A (annual summary). The 300A must be posted from February 1 through April 30 of the following year.

Training New Operators

Train new operators is its own criteria task, and an experienced Class I operator will be asked to do it.

• Structured on-the-job training against a documented task list, rather than incidental shadowing.
• Required certifications before independent work: confined space entry roles, traffic control, first aid and CPR, equipment operation, and the state operator certification itself.
• Understand the role designations. A competent person is one who can identify existing and predictable hazards and has authorization to take prompt corrective action — the excavation standard requires one on site. A qualified person has a recognized degree, certificate, or demonstrated knowledge and skill to resolve problems relating to specified work. Authorized entrant, attendant, and entry supervisor are the defined confined space roles from Section 5.1.
• Cross-train so that no single person is the only one who can operate a critical asset.
• Document all training with date, content, trainer, and trainee acknowledgment. Undocumented training does not exist during an inspection or an investigation.

The Regulatory Framework

• The Clean Water Act prohibits the discharge of pollutants to waters of the United States except in compliance with a permit.
• NPDES permits implement that prohibition. A collection system's obligations flow through the treatment works' permit or through a separate collection system permit, and they include SSO reporting, monitoring, and often CMOM requirements.
• CMOM — Capacity, Management, Operation, and Maintenance — is EPA's framework for demonstrating that the system is being managed to minimize overflows (Section 6.5).
• General Pretreatment Regulations (40 CFR 403) govern what industrial users may discharge (Section 9.2).
• State operator certification determines who may operate the system and at what class, with continuing education for renewal.
• OSHA standards govern the work itself.

Maintaining current knowledge is an explicit criteria task. Regulations, permit conditions, and standards change; continuing education units, industry association membership, and reading the permit when it is reissued are how an operator stays current.