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Recommendations Resulting From A Meeting Held On November 17 And 18, 1998National Airport Hilton Arlington, VirginiaThe National Drinking Water Advisory Council (NDWAC) held its Fall 1998 meeting at the National Airport Hilton on November 17 and 18, 1998. At this meeting, the Council was provided with recommendations from the Right to Know, Benefits, and Operator Certification Working Groups. The following are the recommendations the Council determined should be forwarded to the Administrator of the Environmental Protection Agency (EPA) and several recommendations that should go directly to the Office of Ground Water and Drinking Water. RIGHT TO KNOW Concurrence: The NDWAC concurred with the following mission statement for the Right to Know Working Group: To advise the National Drinking Water Advisory Council on tools which would encourage and enable citizens to fully use the public information and public involvement provisions in the Safe Drinking Water Act. This working group will recommend products to NDWAC through which EPA and its public and private partners can help stakeholders and the public learn about their drinking water, take steps to protect it, and make informed decisions for themselves and their communities. RECOMMENDATIONS FOR THE OFFICE OF GROUND WATER AND DRINKING WATER Recommendations #1: Guiding Principles for Outreach Products and Activities NDWAC recommends that the following principles should guide development of all Drinking Water Public Outreach Products and Activities 1. Messages and materials should be targeted to specific audiences, including the types of audiences listed below. This list is meant to be suggestive, not exclusive:
2. Tools used to deliver message should: Use different language
Be effective for the target audience Reflect appropriate literacy level(s)
3. Outreach products and materials should be multimedia: Use many pathways
4. Materials and activities should be placed within appropriate contexts, including: Wider health and resource
issues Risk communication and management Support for program, e.g. infrastructure
5. Curriculum and other materials should educate effectively: Audiences such as those
listed in #1 (above)
6. Because involvement is just as important as information dissemination, materials should: Foster public involvement
Enable informed action
7. Work in partnerships to develop outreach materials and activities in order to: Share successes Share
lessons from others (watershed, community right-to-know) Take better advantage
of funding opportunities Leverage interest and resources to take action
8. Evaluate effectiveness of products Recommendation #2: Guiding Principles for Consumer Confidence Reports (CCRs) NDWAC recommends that the following principles should apply to information prepared to support Consumer Confidence Reports. Information prepared to support Consumer Confidence Reports should: Prepare various audiences (general public water suppliers, state and local governments, health care providers, educators) to receive and to act upon CCRs Help audiences to read and to understand CCRs Empower, through education, audiences to act on information provided to them through CCRs Provide the next layer of information beyond CCRs and clearly point out how to continue delving further layers down Educate many audiences about drinking water, -- to make good decisions Be honest about where there are uncertainties in conclusions, or where there isn't sufficient information Recommendation # 3: Priority of Outreach Products NDWAC recommends that the following priority outreach products be created(ranked in priority order): A. Information announcing that CCRs are coming, including: Training to prepare groups
which will be expected to answer questions about CCRs Public Service Announcements
(print, radio, tv)
B. Health Effects Information, including:
C. Reference materials: how to get more information about CCRs, with links to more information:
D. Overview of public involvement opportunities in drinking water, with attachments. The attachments would be issue-specific fact sheets, for each significant SDWA provision which offers the public an opportunity to be involved. Each fact sheet would provide detailed information on that topic, and would explain how to use that information to get involved at the local, State, Tribal, Regional, or national level. (See Attachment B for list of fact sheets) E. Information on bottled water requirements, and point of use/point of entry devices. F. Education materials, curriculum, or science fair projects; including materials linked specifically to CCRs. G. Computer-based learning tools. H. Collection and sharing of existing CCRs and templates. I. Speaker's Bureau (perhaps based through EPA regions) to provide information, training, and to answer questions. Recommendation #4: Internet Links NDWAC recommends that all CCRs include EPA's web page address, and that water suppliers who post their CCRs on the Internet link their reports to the EPA web page. Recommendation #5: Liaisons NDWAC recommends that the Right to Know Working Group should work closely with the NDWAC's Health Care Provider Outreach and Education Working Group, as appropriate. The two DFOs and NDWAC members on the working groups should work closely together, and should provide opportunities to review each other's materials, schedule meetings together, or recommend that members serve as ex-officio representatives to the other group, as appropriate. RECOMMENDATION TO THE EPA ADMINISTRATOR Recommendation #6: Liaison with the Food and Drug Administration NDWAC recommends that the Administrator of EPA work closely with the Food and Drug Administration (FDA) to ensure that equivalent public right-to-know information is made as readily available to consumers for bottled water as it is for tap water, at a point where consumers can effectively use the information to make informed decisions and report to NDWAC on results of this coordination. NOTE: The Council chose to send back to the Public Right to Know Working Group a recommendation that suggests an inventory and/or collection of existing good, high-quality public materials on drinking water be assembled. It was felt the Working Group should spend some additional time developing this concept before bringing it back to NDWAC in May 1999. OPERATOR CERTIFICATION The NDWAC recommendations that follow are the result of a thorough discussion on the operator certification guidelines. These guidelines set the minimum baseline standards for an operator certification program to meet the provisions of the 1996 Amendments to the Safe Drinking Water Act. The intent of these guidelines is to enable States to have flexibility in the interpretation, implementation and enforcement of program details necessary to administer a successful operator certification program while ensuring the protection of public health. The Council recommends the following changes be made to the draft guidelines: Baseline Standards Baseline Standard #1: Authorization Recommended Revised Language for Baseline Standard #1: As evidenced by an Attorney General's certification, or certification from delegated counsel, the State must have the legal authority to implement the program requiring the certification of operators of all community and nontransient noncommunity water systems and to require that the systems comply with the appropriate requirements of the program. Baseline Standard #2: Classification of Systems, Facilities, and Operators Recommended Revised Language for Baseline Standard #2: To avoid DWSRF withholding, a State's program must meet the following requirements:
Baseline Standard #3: Operator Qualifications Recommended Revised Language for Baseline Standard #3: To avoid DWSRF withholding, States must require operator applicants to:
Have the defined minimum amount of on-the-job experience for each appropriate level of certification. The amount of experience required increases with each classification level. Experience that is used to meet the experience requirement for any class of certification may not be substituted for education. Education that is used to meet the education requirement for any class of certification may not be substituted for experience. States may allow experience and/or relevant training to be substituted for a high school diploma or GED. Post high school education may be substituted for experience. Credit may be given for experience in a related field (e.g., wastewater). Experience and education may not be used more than once as a substitution. Recommended Definition Validated Exam--An independent review by subject matter experts to ensure exams are based on a job analysis and related to the classification of the system or facility. Grandparenting (under baseline Standard #3) Recommended Revised Language for Grandparenting EPA recognizes that there are many competent small system
operators that may not meet the initial requirements to become certified.
EPA believes that If States choose to include a grandparenting provision in their programs, it must include the following requirements:
Baseline Standard #4: Enforcement Recommended Revised Language for Baseline Standard #4: To avoid DWSRF withholding, the State agency with primary
enforcement responsibility for the Public Water System Supervision
(PWSS) Program must have regulations requiring community water systems
and nontransient noncommunity water systems to comply with State operator
certification requirements. In nonprimacy States, the Governor shall
determine which State Agency shall have this responsibility. States
must have appropriate enforcement capabilities for example States must have the ability to revoke operator certifications. States must also have the ability to suspend operator certifications
or take other appropriate enforcement action for operator misconduct.
Examples include Baseline Standard #5: Certification Renewal Recommended Revised Language for Baseline Standard #5: To avoid DWSRF withholding, the State must establish training requirements for renewal based on the level of certification held by the operator. States must require operators to acquire necessary amounts and types of approved training. States may determine other requirements as deemed necessary. States must have a fixed cycle of renewal not to exceed three years. The State must require an Baseline Standard #6: Resources Needed To Implement the Program Recommended Revised Language for Baseline Standard #6: To avoid DWSRF withholding, the States must provide sufficient resources
to adequately fund and sustain the operator certification program
(components include Baseline Standard #7: Recertification Recommended Revised Language to Baseline Standard #7: To avoid DWSRF withholding, the States must have a process for recertification
of individuals whose certification has expired for a period exceeding
two years Baseline Standard #8: Stakeholder Involvement Recommended Revised Language for Baseline Standard #8: Stakeholder involvement is important to the public health objectives of the program. It helps to ensure the relevancy and validity of the program, and the confidence of all interested parties. To avoid DWSRF withholding, States must include ongoing stakeholder
involvement in the revision and operations of State operator certification
programs. Public comment on rule revisions is not adequate stakeholder
involvement. A stakeholder board or advisory committee is strongly
recommended. Examples of stakeholders may include Baseline Standard #9: Program Review Recommended Revised Language for Baseline Standard #9: To avoid DWSRF withholding, States must perform reviews of
their operator certification programs. EPA recommends that States
perform periodic internal reviews and occasional external/peer reviews.
Examples of items to review Program Submittal Process Requirements 1. Submittal Schedule Recommended Revised Language: Not later than two years after the guidelines are published,
to avoid DWSRF withholding, States must have adopted and Future annual submittals of State operator certification programs to EPA must be submitted either before or with the annual capitalization grant application. 2. Submittal Contents Recommended Revised Language: (a) Initial Submittal The submittal of operator certification programs to EPA by States must include the following:
(b) Subsequent Years
Withholding of Funds Recommended Revisions to Language The Administrator shall withhold 20% of a State's funds that it is entitled to receive under the DWSRF program (section 1452) unless the State has adopted and is implementing a program for the certification of operators of community and nontransient noncommunity public water systems that meets the requirements of these guidelines. This withholding provision will begin two years after the effective date of these guidelines. Definitions Recommended Revised Language for Definitions: Distribution System Complexity--Examples include Distribution System Size--Examples include Source Water--Examples include type (surface water, groundwater, groundwater under the influence of surface water, purchased water), quality (variability), and/or protection (e.g., wellhead protection) Treatment Facility Size (capacity)--Examples include Treatment Facility Complexity--Examples include Validated Exam--An independent review by subject matter experts to ensure exams are based on a job analysis and related to the classification of the system or facility. Expense Reimbursement The Council further recommends:
BENEFITS WORKING GROUP REPORT The specific charge of the Benefits Working Group was to "consider the range of quantifiable and non-quantifiable benefits that could be considered when developing drinking water regulations and provide recommendations to the Agency on which benefits should be routinely considered in developing its regulations." Following are the recommendations NDWAC is passing on to the Agency, after considering the report of the Working Group: Recommendation #1: Categories of Benefits The National Drinking Water Advisory Council recommends that EPA should focus its benefits analysis efforts primarily on assessing effects on human health, defining these effects as clearly as possible and using the best available data to value them. It is also recommended that EPA should consider the following benefits where appropriate: (1) health risk reductions; (2) taste and odor improvements; (3) reduction of damage to water system materials; (4) commercial water treatment cost reductions; (5) benefits due to source water protection (e.g. ecological benefits and non-use benefits); and (6) benefits derived from the provision of information on drinking water quality (e.g., a household's improved ability to make informed decisions concerning the need to test or filter tap water. Recommendation #2: Assessing Health Risks and Valuing Benefits NDWAC recommends that EPA should devote substantial efforts to better understanding the health effects of drinking water contaminants, including the types of effects, their severity, and affected sensitive subpopulations. Better information is also needed on exposures and the effects of different exposure levels, particularly for contaminants with threshold effects. These efforts should pay particular attention to obtaining improved information concerning impacts on children and other sensitive populations. Recommendation #3: Addressing Uncertainty NDWAC recommends that EPA should clearly identify and describe the uncertainties in the benefits and costs analysis, including descriptions of factors that may lead the analysis to significantly understate or overstate total benefits and costs. Factors that may have significant but indeterminate effects on the benefits and costs estimates should also be described. Recommendation #4: Addressing Non-Quantified Benefits NDWAC recommends that EPA consider both quantified and non-quantified benefits in regulatory decision-making. The information about quantified and non-quantified (qualitative) benefits should be presented together in a format, such as a table, to ensure that decision-makers consider both kinds of information. Recommendation #5: The Presentation of Information on Benefits and Costs NDWAC recommends that EPA should consider incremental benefits and costs, total benefits and costs, the distribution of benefits and costs, and cost-effectiveness in regulatory decision-making. This information should be presented together in a format, such as a table, to ensure its consideration by decision-makers. Recommendation #6: Source Water Protection Options NDWAC recommends that whenever EPA considers regulation of a drinking water contaminant, it should evaluate and consider, along with water treatment requirements to remove a contaminant, source water protection options to prevent such a contaminant from occurring. The full range of benefits of those options should be considered. SMALL SYSTEMS IMPLEMENTATION Concurrence: The NDWAC concurred with the following mission statement for the Small Systems Implementation Working Group: To advise the NDWAC on the specific challenges currently facing various types of small Public Water Systems (those serving <10,000 persons but with special emphasis on economically and socially disadvantaged systems serving <500 persons); the challenges likely to face these systems over the next 5-10 years; and strategic options that USEPA and the states should consider to assist small systems in meeting the pubic health protection objectives of the Safe Drinking Water Act. EPA Document/Website that answers general questions related to drinking water for various audiences. EPA will provide general answers to the following questions (e.g. drinking water sources include surface water, ground water, etc.), will clearly point them to the next layer of detail that can be provided by EPA, and will direct users to their local water supplier for specific local information. 1. What is the source of my drinking water? How can I prevent it from becoming impaired? How can I remediate existing pollution?
What are the health effects? Where do the contaminants come from? How did they get there? What is the standard setting process? How does it protect vulnerable populations, including children, the elderly, and immuno-compromised persons? 4. When and how do violations of drinking water standards occur? 5. How can I become involved in directing funding to prevent or remediate impairment of my drinking water? 6. How can I become involved in other parts of the drinking water program - variances, operator certification, etc. Recommended Product: Overview of SDWA Public Involvement Opportunities, including Issue-Specific Fact Sheets on Public Involvement Each fact sheet would include: Basic information How to use that information to get involved (at local, State, Tribal, Regional, National level)
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