6.2 Public Notification, Consumer Confidence Reports & Customer Complaints

Public Notification, Consumer Confidence Reports & Customer Complaints

The ABC Water Treatment outline lists "notify the public according to regulatory requirements" and "respond to consumer complaints" as separate job tasks in the Security, Safety, and Administrative Procedures area, and the wastewater outline lists "respond to customer service requests and complaints." Both are application-level content.

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1. The Public Notification Rule

Every public water system must notify its customers of certain violations and situations. The rule assigns each event to one of three tiers based on the seriousness of the potential health effect.

What is a Tier 1 event

• Confirmed E. coli MCL violation or failure to test after an E. coli positive
• Nitrate, nitrite, or total nitrate/nitrite MCL exceedance - a single confirmed sample
• Exceeding the chlorine dioxide MRDL at the entry point when the distribution follow-up samples also exceed
• Waterborne disease outbreak or other waterborne emergency
• Detection of turbidity above 5 NTU where the state determines a Tier 1 notice is needed
• Failure to maintain a treatment technique where the state determines acute risk
• Occurrence of a significant deficiency or contamination where the state determines Tier 1 is warranted

The system must also contact the state within 24 hours of learning of the Tier 1 violation and consult on the notice language and additional actions.

The ten required elements of every notice

1. A description of the violation or situation, including the contaminant;
2. When it occurred;
3. Potential health effects, using the mandatory standard language from the rule's appendix - this language may not be paraphrased;
4. The population at risk and whether alternate water should be used;
5. What the system is doing to correct it;
6. When the system expects to return to compliance;
7. Contact name, business address, and phone number;
8. The standard language encouraging distribution to other persons served (multi-unit buildings, businesses, schools);
9. Multilingual requirements where a large proportion of the population is non-English speaking;
10. No language that minimizes or contradicts the required health effects language.

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2. Boil Water Advisories

A boil water advisory is issued when water may be microbiologically unsafe - after a loss of pressure event, a positive E. coli result, a treatment failure, a main break with confirmed contamination, or as a precaution during a distribution emergency.

The advisory instruction is to bring water to a rolling boil for one minute (three minutes at elevations above about 6,500 feet) before drinking, brushing teeth, making ice, washing produce, or preparing food.

Rescinding an advisory

Rescission is not an operator's judgment call; it follows a defined sequence with state concurrence:

1. The cause has been identified and corrected.
2. Adequate positive pressure has been restored and maintained throughout the affected area.
3. The system has been flushed and an adequate disinfectant residual has been re-established throughout.
4. Bacteriological samples collected from representative points in the affected area are absent for total coliform and E. coli - typically two consecutive sets 24 hours apart.
5. The state concurs with rescission.
6. The rescission notice is delivered by the same means as the advisory, which is the step most often done poorly - customers who never hear the rescission keep boiling for months and lose confidence in the utility.

Have the templates written before you need them. A Tier 1 notice must go out within 24 hours; that is not the moment to draft language, look up the mandatory health-effects text, and locate the media contact list.

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3. The Consumer Confidence Report

Every community water system must deliver an annual water quality report - the Consumer Confidence Report (CCR) - to each customer.

Required content

• The source(s) of water and, where available, a summary of the source water assessment;
• Definitions of MCL, MCLG, treatment technique, action level, and any units used;
• A table of all detected regulated contaminants with the MCL, MCLG, the level detected (highest and range), the likely source, and whether the MCL was exceeded;
• Lead-specific language - an explanation of lead in drinking water and steps consumers can take;
• Information on Cryptosporidium, radon, and other contaminants where detected or monitored;
• Any violations during the year, with an explanation and corrective action, including monitoring violations;
• Required health-effects language for any MCL violation;
• Vulnerable population language about immunocompromised persons;
• Contact information and how to participate in decisions affecting water quality;
• Multilingual requirements where applicable.

The CCR is often the only document a utility sends its customers all year that is not a bill. Operators are usually the source of the data in it, and an error in the table is a CCR violation.

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4. Handling Customer Complaints

The ABC criteria treat complaint response as a job task because complaints are distributed water quality data collected for free. They arrive faster than sampling results and they are geographically specific.

The intake record

Every complaint should capture, at minimum:

• Exact address and, if possible, which tap;
• Date and time the problem was noticed and whether it is continuous or intermittent;
• Hot water, cold water, or both - a hot-water-only problem is almost always the water heater;
• First draw or after running - a first-draw-only problem is premise plumbing;
• One fixture, whole house, or neighbors too - this single question separates a premise problem from a distribution problem;
• Description in the customer's words, and whether any health complaint is involved.

Diagnostic table

The rules that make complaint handling useful

1. Log every complaint, including the ones that resolve themselves. The pattern is worth more than any single call.
2. Map them. Three red-water calls on the same street in a week is a main condition, not three coincidences.
3. Respond and close the loop. Tell the customer what you found. A complaint answered builds more confidence than a complaint that never happened.
4. Escalate anything suggesting contamination - petroleum or solvent odor, any illness cluster, any report of a cross-connection - immediately, and never explain it away over the phone.
5. Feed the data back into the flushing program, the valve exercising program, the unidirectional flushing sequence design, and the capital plan.