EPA Regional Operator Certification
Coordinator's Handbook
Information for EPA Regional Evaluation of State Public Water
System Operator Certification Programs
Authorization
Classification
Operator
Qualifications
Enforcement
Certification
Renewal
w
Resources
M
Recertification
Stakeholder
Involvement
Program
Review
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Office of Water (4606M)
EPA 810-B-20-002
January 2020
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Table of Contents
Top Seven Regional Operator Certification Coordinator Tasks i
Purpose of the Handbook 1
1. Why is Operator Certification Important? 1
2. Operator Certification Reporting 5
2.1 Annual State Report 5
3. Improving Operator Certification Programs 6
3.1 Program Reviews 6
3.2 Workforce Development 7
3.3 Encouraging State Program Collaboration 10
4. Key Resources 11
4.1 List of Links to Historic Program Documents and Tools 11
4.2 Using the SharePoint Site 12
Appendix A: Desk Guide for Reviewing State Operator Certification Program Annual Reports 13
Appendix B: History of the Operator Certification Program 27
B.l The Safe Drinking Water Act 27
Appendix C: Operator Certification Program Overview 32
C.l Statutory Requirements 32
C.2 The EPA National Tribal Operator Certification Program 34
Glossary of Terms 35
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Top Seven Regional Operator Certification Coordinator Tasks
1. Review states' annual reports (Section 2.1 and Appendix B. 1.1).
Maintaining effective oversight of state programs is a key goal of the EPA Regional Operator Certification
coordinator in the Operator Certification program. Regional coordinators receive annual reports from
states and complete Annual Regional Operator Certification Program Evaluation Forms by September 30th.
2. Collect information on the Operator Certification program in the state (Section 2.1.1).
Regional coordinators work closely with the state Operator Certification coordinators to gather
information on each state program to have a complete understanding of the program's shortcomings and
strengths. This can be in the form of the state operator certification annual report, meetings, phone
discussions, and other correspondence.
3. Encourage states to conduct program reviews (Section 3.1).
Regional coordinators support state Operator Certification programs in their efforts to improve their
programs. The Regional coordinators encourage states to conduct internal and external reviews to
evaluate their program and identify areas for improvement.
4. Encourage states to focus on workforce development (Section 3.2).
Regional coordinators encourage states to work with utilities, educational institutions, and other
organizations to build workforce development programs to strengthen their operator workforce, keep
well-qualified operators and train Board members.
5. Coordinate with the Regional Capacity Development and Drinking Water State Revolving Fund (DWSRF)
teams (Section 3.3).
The Regional coordinator works with the Capacity Development and DWSRF coordinators to foster
program collaboration and to provide documentation to assess the state Operator Certification program
and determine whether a 20 percent withholding is needed.
6. Be a resource to state coordinators (Section 4).
Regional coordinators provide support to the state programs within their EPA Region, which includes
providing EPA resources, tools and trainings and providing opportunities for states to collaborate and
share best practices, questions, and lessons learned.
7. Evaluate state Operator Certification programs to ensure they meet the nine baseline standards
(Appendix A and C.1.2).
Regional coordinators assess each state Operator Certification program to
ensure it is complying with the nine baseline standards outlined in the
Federal Register (64 FR 5916-5921, February 5,1999, Vol. 64, No. 24). Click
on "Appendix A: Desk Guide" to review the Desk Guide for Reviewing State
Operator Certification Program Annual Reports.
Appendix A: Desk
Guide
Keep an eye out for this icon throughout the document. Whenever this appears it indicates that section is in
support of one of the Top Seven Regional Operator Certification Coordinator Tasks.
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1
Purpose of the Handbook
The EPA Regional Operator Certification Handbook is intended to provide comprehensive guidance for
those filling the role of EPA Regional Operator Certification coordinator. As the EPA Regional Operator
Certification coordinator, it is important to understand the state's Operator Certification requirements
to best aid the state Operator Certification programs. The handbook will provide resources,
explanations, and history of basic tasks to help new EPA Regional Operator Certification coordinators
understand their role and responsibilities including:
• overseeing state Operator Certification programs,
• ensuring that state Operator Certification programs meet the federally defined nine baseline
standards, and
• reviewing Operator Certification program reports annually to ensure they meet the Safe
Drinking Water Act (SDWA) initiatives.
The handbook will also include resources to help Regional coordinators provide support to state
Operator Certification programs, to help them improve their programs, develop a robust water
operator workforce, and support small systems.
1. Why is Operator Certification Important?
Operator certification is important because it protects public health. It involves the establishment of
minimum professional standards for the maintenance of safe, optimal, and reliable operations of water
treatment and distribution facilities. While the specific requirements vary from state to state, the goal of
all Operator Certification programs is to ensure that skilled professionals are overseeing the treatment
and distribution of safe drinking water. Operator certification is an important step in promoting
compliance with the SDWA.
Click on "Safe Drinking Water Act" to review that section of the document
and learn more about the operator certification provisions and history of
SDWA.
Safe Drinking
Water Act
At the state level, Operator Certification programs help states to improve drinking water quality by
ensuring that systems have certified, qualified, and capable operators. The state programs establish
classification for water systems and water operators, administer examinations to certify operators,
provide training to operators, and track system compliance.
At the system level, Operator Certification programs allow systems to have confidence in the
ability of their operators. Operator Certification programs require that systems have access to a certified
operator of the correct level for that system.
For operators, Operator Certification programs provide continuing education opportunities to
increase their knowledge and stay up to date with the latest rules, regulations, and techniques. They
also enable them to increase their qualifications through offering examinations to reach higher
certification levels and emphasize the importance of their role in protecting public health.
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Program Collaboration
Water
Systems
State Agencies
Public Health
Organizations
Local
Governments
Technical
Assistance
Organizations
Federal
Agencies
Operator
Certification
Collaboration
Click on the boxes in the Operator Certification Collaboration diagram to see examples of these
programs.
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Operator Certification programs seek input from a variety of stakeholders and programs. Key roles and
responsibilities of some federal and state agency staff are reviewed in further detail below.
Key Roles & Responsibilities
Regional DWSRF
Coordinator
State DWSRF
Coordinator
Regional Operator
Certification
Coordinator
State Operator
Certification
Coordinator
Water Systems
Regional CapDev
Coordinators
State
Administrator
¦
/
State CapDev
Coordinator
Please note that while a useful visualthis graphic does riot represent all drinking water program roles
that make for successful program collaboration. For more information about roles and how to interact
see the Tabletop Exercise.
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Annual Cycle of Tasks and Actions for Regional Coordinators
EPA Regional Operator Certification coordinators have certain tasks and actions they must complete
each year. The template timeline below can be used by Regional coordinators to set due dates to
complete each task. The only universal date is September 30th, the date by which Regional
coordinators need to document the withholding decision.
The Regional coordinator
reviews the states' annual
reports according to the nine
baseline standards.
I
The Regional coordinator works with the
CapDev and DWSRF Coordinators to assess
their state's program for purposes of the
DWSRF 20 percent withholding. The Regional
Coordinator submits written documentation to
the DWSRF Coordinator.
I
States submit annual
reports to the Regional
coordinator.
The Regional coordinator
provides feedback to the
states on their program and
may make suggestions for
improvement.
The Regional
coordinator needs
to document the
withholding decision
by September 30th
of each year.
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2. Operator Certification Reporting
Top
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Top
7
To maintain effective oversight of state Operator Certification programs, which is a major goal of
the EPA's National Operator Certification program, the Regional coordinators assess state Operator
Certification programs. Each year, state Operator Certification coordinators must provide reports to
their EPA Regional Operator Certification coordinators. These reporting requirements help the EPA
Region to ensure that the state is taking steps to demonstrate that all systems are maintaining
compliance with Operator Certification requirements.
Click "Key Roles & Responsibilities" to review that section of the document
and learn more about specific roles.
Key Roles &
Responsibilities
2.1 Annual State Report
States must send an annual implementation report to the EPA that documents that their Operator
Certification programs meet the nine baseline standards. The EPA Regional Operator Certification
coordinators review the annual reports and complete Annual Regional Operator Certification Program
Evaluation Forms that include state-by-state information.
Click "Nine Baseline Standards" to review that section of the document and
learn specifics about the federally defined standards that all state Operator
Certification programs must meet.
Click "Appendix A: Desk Guide" to review that section of the document and
learn more about reviewing annual reports.
Nine Baseline
Standards
Appendix A: Desk
Guide
2.1.1 Objectives
The EPA Regional Operator Certification coordinator must review and approve each state Operator
Certification program to ensure it is meeting the nine baseline standards. This process provides an
opportunity for the EPA Regions to work with the states on identifying ways to continue to support and
enhance the state programs, as well as an opportunity for the states to highlight program successes and
the importance of Operator Certification programs in each state.
2.1.2 Timeframe
Each state should submit annual reports with enough time for the EPA Region to review prior to the
September 30th deadline. The process of development and review of the annual report and any
subsequent discussions related to the report or additional information needed for the annual review are
critical to the oversight and implementation of Operator Certification programs. Therefore, time should
be allotted to engage in this process prior to September 30th each year.
2.1.3 Process and Checklist
Once the EPA receives the report, it is reviewed using the methodology laid out in the EPA's July 31,
2018 memo and Desk Guide for Reviewing State Operator Certification Annual Reports. Reviewers
evaluate the report using a checklist as a guide to ensure protection of public health, antibacksliding,
and that the nine baseline standards are addressed appropriately. Comments are shared with Regional
management and a preliminary determination is made deeming the report as acceptable, acceptable
with deficiencies, or not acceptable.
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3. Improving Operator Certification Programs
A continuous process in the Operator Certification program is to observe the effectiveness of program
efforts and make improvements. EPA Regional Operator Certification coordinators can encourage states
to be in a continuous cycle of development, implementation, observation, and revision of their program.
A critical aspect of this continual improvement process is coordination with the state Drinking Water
program, including the Capacity Development, enforcement, and DWSRF programs.
top 3.1 Program Reviews
States will periodically conduct a review of their own certification programs through both internal and
external reviews. The results of these reviews will be included in their Annual Operator Certification
Program Implementation Reports. EPA Regional Operator Certification coordinators should be familiar
with the requirements and goals of internal and external reviews in order to provide valuable feedback.
If states are not conducting internal or external reviews, EPA Regional Operator Certification
coordinators can recommend this as a way to improve their Operator Certification program.
3.1.1 Internal Review
Internal reviews are program reviews performed within the implementing agency. EPA Regional
Operator Certification coordinators may want to recommend that internal reviews be performed more
frequently than external reviews. The EPA recommends they occur every three years. Internal reviews
expend less resources for a state as they can be formal or informal but provide valuable information for
evaluating their program. Internal reviews consider a number of different elements including, but not
limited to:
• Staffing
• Budget
• Exam Reviews
• Compliance Rate Determination
• Regulation Review
• Enforcement
• Status of Certified Operators/Trends
• Training/Testing
• Renewals
• Database Management
• Outreach
• Stakeholder Involvement
Reviewing these factors provides important information for state Operator Certification programs to
identify areas that need improvement.
3.1.2 External Review
External reviews are program reviews performed by an entity outside the state Operator Certification
program primacy agency. The EPA recommends that these reviews happen every five years. External
reviews provide the state with a report describing the results and listing recommendations for
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improving their program. These reviews require more resources from the state but are essential to
improving Operator Certification programs. Funding for an external review can come from several
sources, including but not limited to: fees generated from certification and examination, state
legislature appropriations, Public Water Supply Supervision (PWSS) support, and DWSRF Programmatic
set-asides. States will need to plan ahead for the funding to conduct external reviews using existing
funding sources. It is recommended that the EPA Regional Operator Certification coordinators impress
upon states the importance of external program reviews. External reviews evaluate similar factors to
internal reviews with some additional considerations:
• Staffing
• Budget
• Exam Reviews
• Compliance Rate Determination
• Regulation Review
• Enforcement
• Status of Certified Operators/Trends
• Training/Testing
• Renewals
• Database Management
• Outreach
• Stakeholder Involvement
• State Regulation Changes
• Strategic Planning
• Primacy Agency Delegation/Changes
External reviews examine more factors than internal reviews, providing valuable insight from an outside
source that can identify further opportunities for improvement.
top 3.2 Workforce Development
3.2.1 Future of Water Workforce and Need for Newly Certified Operators
As in many sectors, the water industry is predicting large scale retirements in the near future. This will
create challenges for the utility workforce requiring increased recruitment and succession
planning. Water treatment plant operators are vital to protecting public health, so it is crucial to prevent
a potential shortage of certified operators. The EPA, other federal agencies, states, and industry
organizations are working to promote professional development in the water sector. If states are
concerned about future availability of operators, EPA Regional Operator Certification coordinators
should be aware of these efforts to provide assistance to their states.
State Framework for Workforce Development
Every state has their own unique situation when it comes to the future of their workforce. Regional
coordinators can suggest that states take an active role in mapping out a framework to address their
specific workforce needs. This will empower states to be proactive, instead of reactive, in dealing with
workforce issues.
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3.2.2 Recruitment and Training
Water Workforce Training Programs
There are several innovative recruitment and training programs that expose people to careers in the
water sector and promote the water industry. It is recommended that the EPA Regional Operator
Certification coordinators encourage states to work with utilities, educational institutions, and other
organizations to build these types of programs to strengthen their operator workforce.
Internships
EPA Regional Operator Certification coordinators may advise their states to promote internship
programs if they express that young people in their state do not seem to be entering the operator
workforce. Internship programs offer a glimpse into what a career as a water operator would look like.
Internship opportunities can be made available to students as early as high school. Focusing recruitment
efforts on students who attend technical or vocational schools can also identify interested candidates.
Through internship programs, young adults become aware of a previously unknown opportunity and
utilities create a pool of eligible candidates to hire when positions become available.
Apprenticeships
Apprenticeships also serve as beneficial training programs for participants, utilities, and states. If a state
reports having difficulty finding certified operators, EPA Regional Operator Certification coordinators
may suggest the state implements apprenticeship programs. Apprenticeships are longer-term programs
than internships, ranging from one year to a few years in length. They offer on-the-job training and
classroom instruction. Participating in apprenticeship programs gives operators the experience and
education they need to become certified and attain higher levels of certification. Apprenticeship
programs can be set up at the utility level or the state level. Utility level apprenticeship programs serve
a utility's specific needs while statewide programs standardize training across the industry.
Mentoring
As an industry that predicts large scale retirements, there is a risk that institutional knowledge may be
lost as experienced, certified operators leave the profession. EPA Regional Operator Certification
coordinators may recommend mentoring programs to facilitate the transfer of knowledge. Mentoring
programs match more experienced operators with new operators based on their skills, areas of
expertise, and preferences. Mentors pass on knowledge, proven best practices, and lessons learned
from their years of experience and provide support to mentees. Mentoring programs develop a network
of colleagues with established, supportive relationships, build common values, and promote lifelong
learning. They also develop leadership potential among newer operators, so they can transition into
management and supervisory roles. This strengthens the Operator Certification program overall.
Degree or Certificate Programs
Degree and Certificate programs offer another pathway for people interested in becoming a certified
operator. Technical high schools, community colleges, colleges, universities, and other organizations
offer certificates and degrees such as water treatment, water technology, and water treatment
operations, which prepare students to become certified operators. These programs make the pathway
to becoming a certified water operator more accessible and increase visibility for the profession. EPA
Regional Operator Certification coordinators may advocate for these programs in their EPA Region to
increase the pool of qualified and certified operators.
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Veterans as Water System Operators
Veterans represent a major recruiting opportunity for water utilities. Prior military experience gives
veterans an understanding of teamwork, discipline, and personal accountability that can make them
excellent employees for this field. In addition, while serving in the Armed Forces, veterans may have
held Military Occupation Specialties (MOS) that directly or indirectly translate into the type of positions
needed in the water sector. In 2012, the EPA and the Department of Veterans Affairs (VA) partnered to
connect veterans with careers in the water sector. When states express uncertainty about operator
workforce, EPA Regional Operator Certification coordinators can recommend making use of this
partnership by encouraging states and utilities to find veterans that may have compatible skills. State
Operator Certification coordinators can consult From M.O.S. to J-O-B: A Guide for Applying Military
Occupational Specialties (M.O.S.) to Civilian Drinking Water and Wastewater Operations to learn more
about how veterans can be well equipped to serve in the water industry and how their prior experience
can translate in their home state. In addition, the VA offers a number of programs to support both
veterans and employers to facilitate veterans' entry into the water sector. EPA Regional Operator
Certification coordinators can refer states to resources available through the VA.
Engaging Decision Makers
Board Member Training
EPA Regional Operator Certification coordinators can promote workforce planning by encouraging
states to engage decision makers. It is crucial for board members to have a deep understanding of the
water systems that they serve so they can
make informed decisions. EPA Regional
Operator Certification coordinators can
advocate for board member trainings. Board
member trainings should include sessions on
workforce planning, as well as a variety of
other issues related to operator certification.
If decision makers understand the necessity
of workforce development, more utilities
may establish internships, apprenticeships,
mentoring programs, or other training
programs.
3.2.3 Retaining Certified Operators
Retaining certified operators is as crucial to
the success of a water system as recruiting
new operators. If systems can increase
financial capacity through Capacity
Development programs, systems may be more able to offer a competitive salary and benefits package.
Certified operators are also more likely to remain in their role if they feel recognized, respected, and
in control. Creating a culture where operators feel valued can be achieved through regional operator
collaboratives, mentorship programs, or through promoting the importance of the profession to the
public. State Operator Certification coordinators can work with their state's Capacity Development
coordinator to promote these types of activities at water systems. Establishing a feeling of ownership
Regional Workforce Efforts
BAYWORK is a California-based regional consortium
with a common goal of operational reliability of Bay
Area water and wastewater utilities supported by a
high-performance workforce. Founded in 2009,
BAYWORK is open to all Bay Area water and
wastewater utilities and currently has 34 members.
Members collectively agree to develop qualified
candidates for mission critical jobs, provide staff with
the information they need to do quality work, modify
work process to optimize use of available staff and
maximize cost-effectiveness of workforce reliability
investments through collaboration. Learn more and
review their charter at ittp://baywork.org/.
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over the system for operators and engaging them in decision making can also empower and motivate
operators, encouraging operators to remain in their position.
3.3 Encouraging State Program
Collaboration
State Drinking Water programs manage and oversee a
variety of programs and activities that support PWSs,
including: Operator Certification, Capacity
Development, enforcement, and the DWSRF.
Collaboration among these programs will help to
ensure the greatest public health protection for the
American public.
State Capacity Development and Operator
Certification programs both aim to ensure the
provision of safe drinking water. Drinking water
system performance depends on many factors,
including adequate infrastructure to effectively and
efficiently manage and maintain operations.
Communication and cooperation between the
Capacity Development and Operator Certification
programs can help determine gaps in operator skills and knowledge, promote appropriate training,
assist PWSs with obtaining a qualified, certified operator, and improve system performance to protect
public health. The EPA's Capacity Development and Operator Certification Collaboration Factsheet
outlines examples of how the programs operate together.
Collaboration between programs allows team members to share their department's expertise and
perspectives to develop new potential solutions for small system concerns. Furthermore, discussions
among the different individuals and departments responsible for assisting struggling or non-compliant
PWSs can help everyone develop a more comprehensive understanding of these PWSs' unique
situations.
The EPA'S Table Top Exercise
The EPA Table Top Exercise: Collaborating across
State Drinking Water Programs to Support
Sustainable Systems (all materials for the exercise
are included in the .zip file) is an exercise to
enhance understanding of state Drinking Water
program roles and to emphasize the importance
of collaboration between programs. In this
exercise, participants (state staff who oversee or
assist PWSs, either directly or indirectly) are asked
to take on one of the roles in a state program, and
then to collaborate as a group to evaluate the
needs of example water systems and to prioritize
state assistance. Further details on background
and instructions are provided in the "Facilitator
Packet" document.
Colorado: Targeting Operator Training to Boost PWS Performance
In the past, many of Colorado's small drinking water systems did not have properly trained or certified
operators. The state determined that there had been a lack of coordinated, targeted, high quality
training for operators and other personnel. Colorado employed a systematic planning process for
evaluating and responding to training needs for PWS personnel. The process included evaluating
system failures and root causes, preparing a Baseline Assessment Report, conducting a 1-day PWS
training roundtable and developing a 5-year strategic plan. Colorado also provides technical assistance
to PWSs through a highly-trained "Coaching" unit. Furthermore, the Capacity Development and
Operator Certification programs meet monthly as part of the "Drinking Water Advisory Team." From
2005 to 2012, CWSs and NTNCWSs with certified operators in charge increased from 89 percent to 98
percent. There has been a measurable improvement in compliance in the areas of disinfection
operations and management, and in the overall development of water quality monitoring plans.
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4. Key Resources
EPA Regional Operator Certification coordinators can provide the following resources from the EPA and
other organizations to state coordinators. These resources can be used by state or water system
personnel to increase understanding about Operator Certification, to build an Operator Certification
program, and to help improve communication and collaboration.
4.1 List of Links to Historic Program Documents and Tools
Statutes Operator Certification
1996 SDWA Amendments
Final Guidelines for the Certification and Recertification of the Operators of Community and Non-
transient Non-community Public Water Systems; Notice
Final Additions to the Final Guidelines for the Certification and Recertification of the Operators of
Community and Non-transient Non-community Public Water systems; Final Allocation Methodology
for Funding to States for the Operator Certification Expense Reimbursement Grants Program
Websites Operator Certification
The EPA's website on Operator Certification
Capacity Development and Operator Certification Collaboration Factsheet
Tabletop Exercise
The EPA's website on Information for States about Building the Capacity of Drinking Water Systems
Workforce Development
The EPA's website on Workforce Development
Resources for Small Systems Operators
Water Workforce Veteran Promotion
From M.O.S. to J-O-B: A Guide for Applying Military Occupational Specialties (M.O.S.) to Civilian
Drinking Water and Wastewater Operations
Water Workforce Training Programs
Supporting Water Operator Apprenticeship Programs
"Water You Waiting For?" Videos
A Selection of Training Programs for Water and Wastewater Operators
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Tribal Operator Certification Programs
The EPA's website on Tribal Drinking Water Operator Certification Program
Federal Register Notice: Tribal Drinking Water Operator Certification Program 2010
Tribal Drinking Water Operator Certification Program Final Guidelines
Tribal Drinking Water Operator Certification Program document
Drinking Water Infrastructure Grants Tribal Set-Aside Program Revised Guidelines
Find an EPA Regional Tribal Drinking Water Coordinator Contact
Drinking Water State Revolving Fund
DWSRF Eligibility Handbook
Drinking Water State Revolving Fund: Program Operations Manual - Provisional Edition
Analysis of the Use of Drinking Water State Revolving Fund Set-asides: Building the Capacity of
Drinking Water Systems
Analysis of the Use of Drinking Water State Revolving Fund Set-Asides: Promoting System
Sustainability
Analysis on the Use of Drinking Water State Revolving Fund Set-Asides: Promoting Capacity
Development
Additional Resources
Find an EPA Drinking Water Operator Certification Contact
Operator Certification 101 Training Modules
4.2 Using the SharePoint Site
The EPA maintains a SharePoint site where Operator
Certification coordinators can contribute and download
materials to support Operator Certification programs.
To download pertinent files: navigate to the site, select the file you are interested in, and "Download a
Copy." If the EPA Regional Operator Certification coordinators are adding content to the site, ensure
that they have permissions to add to the site. With the appropriate permissions, the EPA Regional
Operator Certification coordinators should be able to drag and drop files directly from their local drive.
The EPA SharePoint Site Link
h ttps://usepa. sh arepoin t. com/sites/O W/D
WPB/SST/capacitydevelopment/SitePages/
Home.aspx
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Appendix A: Desk Guide for Reviewing State Operator
Certification Program Annual Reports
The EPA's Memorandum: Review of State Drinking Water Operator Certification Program Annual
Submittals
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Desk Guide for Reviewing State Operator Certification Program Annual Reports
BACKGROUND
The 1996 amendments to the Safe Drinking Water Act (SDWA) required the establishment of the
Operator Certification (OpCert) Final Guidelines to establish minimum requirements for state OpCert
programs to avoid mandatory withholding of 20 percent of the Drinking Water State Revolving Funds
(DWSRF) capitalization grant.
On February 5, 1999, the Final Guidelines for the Certification and Recertification of the Operators of
Community and Nontransient Noncommunity Public Water Systems ("Final Guidelines") were
published in the Federal Register (64FR_5916).
The resulting Nine Baseline Standards established the minimum required elements that state OpCert
programs must adhere to, in order to avoid the 20 percent mandatory DWSRF withholding. As
referenced in the Final Guidelines, state OpCert programs are approved by EPA for the initial submittal
of the program, as well as being approved for each of the subsequent years submittals (i.e., "annual
reports"). The Final Guidelines also established the reporting requirements for both the initial submittal
and subsequent years submittals for approval or a withholding determination.
As stated in the Final Guidelines, states must submit annual reports that include documentation and
evaluation detailing the ongoing implementation of their programs. States must also submit a new State
Attorney General's certification from the Attorney General or delegated counsel, if there were any
changes to the statutes or regulations during the year. The state must also submit a copy of any revised
regulations or statutes.
Each state annual report must include sufficient information to determine whether the state OpCert
program meets the requirements in the Final Guidelines and thus whether or not the agency must
withhold 20 percent of the capitalization grant, as required in SDWA 1419(b). Documentation and
evaluation of the program must include evaluation of each of the Nine Baseline Standards, as well as
each of the elements included in all baseline standards, the anti-backsliding provision in the Final
Guidelines, as well as the public health objectives of the program.
PURPOSE
The purpose of this document and its accompanying attachments is to provide Regional OpCert program
personnel with the tools to consistently review state OpCert annual reports, as well as provide accurate
recommendations for DWSRF withholding decisions.
Objectives:
The objectives of this desk guide are to:
1) Provide a tool for consistent Regional review of state OpCert programs;
2) Describe a process for communicating any identified issues with management and the state; and
3) Provide a timeline for review and program DWSRF withholding determination completion.
Timeframe and overall determinations of annual report review:
There is an expectation that EPA receives the annual report with sufficient time for review prior the
deadline of September 30th. States should submit annual reports in the timeframe set by the Region. At
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Desk Guide for Reviewing State Operator Certification Program Annual Reports
the completion of the annual report review process, the mandatory DWSRF withholding decision will be
determined with one of the following classifications: acceptable, acceptable with deficiencies or not
acceptable.
Acceptable
The annual report documents and evaluates ongoing
implementation of the state's OpCert program. Mandatory
DWSRF withholding is recommended to be waived.
Acceptable with deficiencies
The annual report documents and evaluates ongoing
implementation of the state's OpCert program but has
deficiencies that must be corrected. Grant condition is
recommended.
Not acceptable
The annual report does not document and evaluate ongoing
implementation of the state's OpCert program. A DWSRF
grant withholding is recommended.
Operator Certification Program Annual Reports Review Process:
~ State submits annual OpCert report (Regional review process starts)
I I Regional OpCert Coordinator shares annual report with additional Regional personnel as
appropriate, per Regional review process (e.g. state program managers, capacity development
coordinators, etc.) See Attachment 2 for sample distribution email.
~ OpCert and other appropriate Regional personnel review and share comments about report,
ensuring all elements discussed in the checklist (Attachment 1) are addressed. The Regional
OpCert Coordinator compiles and shares the combined comments with the other reviewers. See
Attachment 3 for sample email on combined comments.
~ OpCert and other appropriate Regional personnel make a preliminary determination, according
to Regional processes. Comments and preliminary determination are shared with management
and finalized by Regional OpCert Coordinator. The finalized document is then shared with the
state OpCert representative as appropriate per Regional process. See Attachment 4 and
Attachment 5 for example emails based on the preliminary determination.
~ Regional and state representatives correspond as necessary (e.g., conference call, email, etc.) to
discuss comments and to share grant recommendation determination.
I I Regional OpCert Coordinator develops a recommended determination decision memo and shares
it with other appropriate Regional personnel for review. See Attachment 6 for a sample memo.
~ Determination Decision Memo is signed by Regional Administrator (or delegated Division
Director), finalized, and distributed as per the Regional process. Copies are shared with state
OpCert representative and other appropriate Regional personnel (e.g., DWSRF).
15
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Attachment 1
Annual Report Review Checklist
16
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Attachment 1
Operator Certification Guidelines (Public Health
Objective + Antibacksliding + 9 Baseline
Standards)
EPA national criteria to evaluate annual reports
with rcsocct to reauirement to show documentation
and evaluation of onsoins oroeram implementation
Notes
The public health objectives of the guidelines are
to ensure that:
Customers of any public water system be provided
with an adequate supply of safe, potable drinking
water.
• The state provides an affirmative statement that
the state ensures the public health objectives are
met by the OpCert program.
Consumers are confident that their water is safe to
drink.
Public water system operators are trained and
certified and that they have knowledge and
understanding of the public health reasons for
drinking water standards
Antibacksliding
• A statement to show that a state's OpCert
program remains the same and that no
backsliding has occurred since the last year, OR
• A discussion of any policy changes AND a
discussion to show policy, regulatory, or
statutory changes do not alter the state OpCert
program which a state had in place 12 months
prior to the effective date of Final Guidelines
unless the reduction can be justified by the state
and is approved by EPA.
9 Baseline Standards
1. Authorization
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.
In annual reports, a state must submit the following
if changes were made to regulation or statute:
• Attorney General's Certification OR
Certification from delegated counsel (must
include a copy of the delegation), AND
• Amend the initial or latest amended full program
description and additional explanation (include
discussion of meeting the antibacksliding
provision see above), AND
• Copv of new regulations or statutes
2. Classification of Svstems, Facilities, and
Oncrators
a) It must classify all community and nontransient
noncommunity water systems based on
indicators of potential health risk, which for
example may include: (a) complexity, size,
source water for treatment facilities, and (b)
complexity, size for distribution systems. It
must develop specific operator certification and
renewal requirements for each level of
classification.
• A statement describing how the state classifies its
systems and operators.
• Matrix showing total number of CWS and
NTNCWS in each classification or multiple
classifications (TNCWS would be included if the
state required TNClVSs to have a certified
operator 12 months before the effective date of
the guidelines. Also, TNClVSs treating surface
water and/or using chlorine dioxide should be
included).
• Matrix showing total number of certified
operators in each classification or multiple
classifications (Recommended: discuss
activities related to workforce / recruiting,
such as number of trainee (OIT) designations
for operators working under an operator in
responsible charge (OIRC))
• Names of systems where classifications were
changed (and reasons) within reporting period
(Recommended, but not required).
17
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Attachment 1
Operator Certification Guidelines (Public Health
Objective + Antibacksliding + 9 Baseline
Standards)
EPA national criteria to evaluate annual reports
with rcsocct to reauirement to show documentation
and evaluation of onsoins oroeram implementation
Notes
b) It must require owners of all community and
nontransient noncommunity water systems to
place the direct supervision of their water
system, including each treatment facility and/or
distribution system, under the responsible
charge of an operator(s) holding a valid
certification equal to or greater than the
classification of the treatment facility and/or
distribution system.
c) It must require, at a minimum, that the
operator(s) in responsible charge or equivalent
must hold a valid certification equal to or
greater than the classification of their water
system including each treatment facility and
distribution system, as determined by the state.
• An affirmative statement that it meets the
requirements of both "b" and "c" in Baseline
Standard 2 (see left).
• Number of systems without a certified operator
with date of the data compilation.
• As applicable, implementation of a temporary
operator certification or licensing program (i.e.,
operator in responsible charge temporarily does
not meet minimum education, experience, and/or
examination requirements).
o Number of systems with temporary
operators,
o Number of systems succeeding to
permanent, fully-qualified operators in
responsible charge.
• Description of the process used to track operators
(treatment facility and/or distribution system)
with respect to the name, identification, and
classification of the PWS and name and
classifications) of the operator in responsible
charge.
d) It must require that all operating personnel
making process control/system integrity
decisions about water quality or quantity that
affect public health be certified.
A statement reaffirming that regulations and
policies are in place to ensure persons making
process control/system integrity decision are
certified. [Recommended: briefly describe these
policies]
e) It must require that a designated certified
operator be available for each operating shift.
A statement reaffirming that regulations and
policies are in place to ensure designated certified
operator is available for each operating shift.
[Recommended: briefly describe these policies,
such as monitoring of the system when a
properly certified operator is not physically on-
site (e.g., SOPs, SCAD A, other), and any limits
or guidance regarding contract operators (e.g.,
travel distance, number of systems per
operator).]
3. Onerator Qualifications
States must require the following for an operator to
become certified:
a) Take and pass an exam that demonstrates that
the operator lias the necessary skills,
knowledge, ability and judgement as
appropriate for the classification. All exam
questions must be validated.
• An affirmative statement that state meets this
requirement (see "a" to left).
• Brief description of the examination events
provided during the year.
• Number of exams and type of exams (e.g.,
treatment and/or distribution classification).
• Percent passing in each exam classification.
• Exam question validation activities for the year
(Short summary of issues reviewed, pass/fail
rate, new questions, subject matter experts,
psychometrician). [Recommended: Brief
discussion of the state's reciprocity approval
process, if applicable, and the number of new
operators based on reciprocity.!
18
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Attachment 1
Operator Certification Guidelines (Public Health
Objective + Antibacksliding + 9 Baseline
Standards)
EPA national criteria to evaluate annual reports
with rcsocct to requirement to show documentation
and evaluation of onsoins oroeram implementation
Notes
b) Have a high school diploma or a general
equivalency diploma (GED). States may allow
experience and/or relevant training to be
substituted for a high school diploma or GED.
Education, training, or experience that is used
to meet this requirement for any class of
certification may not be used to meet the
experience requirement.
• Reaffirm all operators have high school diploma
or GED or equivalent experience.
c) 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. Post high school education may be
substituted for experience. Credit may be given
for experience in a related field (e.g.,
wastewater). Experience that is used to meet
the experience requirement for any class of
certification may not be used to meet the
education requirement.
• Reaffirm that the program has a defined
minimum amount of on-the-job experience for
each appropriate level of certification.
d) Grandparenting
EPA recognizes that there are many competent
small system operators that may not meet the initial
requirements to become certified. EPA believes that
states may need a transition period to allow these
operators to continue to operate the system through
"grandparenting". It is recommended that
grandparenting determinations be based on factors
such as system compliance history, operator
experience and knowledge, system complexity, and
lack of treatment. If states choose to include a
grandparenting provision in their programs, they
must include specific requirements.
• Provide an affirmation of previously approved
grandparenting practice and current numbers.
Grandparenting is no
longer allowed.
However, some states
may still have
grandparented operators.
The number of
grandparented operators
is expected to continue
to decrease to zero.
Tracking existing
grandparented operators
is part of meeting the
Baseline Standards.
4. Enforcement
The state agency with primary enforcement
responsibility for the Public Water System
Supervision (PWSS) Program must have
regulations that meet the requirements of these
guidelines and require community water systems
and nontransient noncommunity water systems to
comply with state operator certification
requirements. In nonprimacy states, the Governor
must determine which state Agency will have this
responsibility. States must have appropriate
enforcement capabilities. 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.
• Description of how state OpCert program is
following up with systems lacking a properly
certified operator (e.g., notices of violation,
compliance assistance, how state is tracking/
finding out about lack of operator and how long
the system is without operator), including (as
applicable):
o Number of systems which had some type
enforcement action taken to bring system into
compliance with state OpCert regulations,
o Number of contacts/notices to system owners
who have not designated an operator in
responsible charge,
o Number of letters sent to systems/operators
which do not have an operator in responsible
charge holding a valid certification at their
system.
• Number of licenses revoked in the state in
current year.
• Total number of licenses in the process of
revocation at the end of the reporting period.
19
-------
Attachment 1
Operator Certification Guidelines (Public Health
Objective + Antibacksliding + 9 Baseline
Standards)
EPA national criteria to evaluate annual reports
with rcsocct to reauirement to show documentation
and evaluation of onsoins oroeram implementation
Notes
• Number of licenses suspended in the state in
current year.
• Total number of licenses in the process of
suspension at the end of the reporting period.
5. Certification Renewal
a) The state must establish training requirements
for renewal based on the level of certification
held by the operator.
• Number of operators renewing in each
classification.
• Affirmation that operators get the necessary
training to cover all the knowledge, skills, and
abilities required for the license classification for
which an operator is certified.
b) States must require all operators including
grandparented operators to acquire necessary
amounts and types of state approved training.
States may determine other requirements as
deemed necessary.
• Number of training courses approved.
• Number of operators required to take additional
training as deemed necessary by the state.
c) States must have a fixed cycle of renewal not to
exceed three years.
• Simple statement of renewal cycle, unless it
changes, which should include a more
descriptive narrative (under Antibacksliding and
Baseline Standard 1, above).
d) The state must require an individual to recertify
if the individual fails to renew or qualify for
renewal within two years of the date that the
certificate expired.
• Number of operators renewing after failing to
renew or qualify for renewal within the state-
specified time period, but no more than two
years.
e) States must pay special attention to identify
specific renewal requirements for
grandparented operators to ensure that they
possess the knowledge, skills, ability and
judgement to properly operate the system. This
must be done by one or more of the following
approaches or by an alternative approach
approved by EPA.
• Number of grandparented operators where
renewal training was specified.
f) States may specify renewal requirements for
grandparented operators on a case-by-case
basis, taking into consideration factors such as
a system's compliance history and operator
experience and knowledge. For systems that
have a history of being out of compliance, any
certification renewal decision should consider
whether noncompliance is the result of actions
or inactions by the system's owner or the
system's operator.
• Number of grandparented operators where
renewal cycle training was specified for the
operator and reason.
g) States may require specific training
requirements for certification renewal at the
first renewal cycle for grandparented operators.
This training should include all of the
information covered by the initial certification
exam for the system classification level for
which the operator was grandparented even
• N/A First renewal cycle past.
20
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Attachment 1
Operator Certification Guidelines (Public Health
Objective + Antibacksliding + 9 Baseline
Standards)
EPA national criteria to evaluate annual reports
with rcsocct to reauirement to show documentation
and evaluation of onsoins oroeram implementation
Notes
though an initial certification exam may not be
required for certification renewal.
h) States may require operators with
grandparented certificates to meet all of the
initial certification requirements for the
classification level for which the operator was
grandparented, and thereby obtain certification
within a reasonable time period specified by
the state.
• Number of grandparented operators with active
licenses.
6. Resources Needed to Imnlcmcnt the Program
States must provide sufficient resources to
adequately fund and sustain the operator
certification program (components include, but are
not limited to: staff, data management, testing,
enforcement, administration, and training approval).
EPA recommends that states establish a dedicated
fund that is self-sufficient.
• An affirmative statement that state meets Baseline
Standard 6.
• While the Initial Submittal may show the funding
resource, additional information needs to be
included if a primacy fee has been added or if
Public Water System Supervision or DWSRF set-
asides have been added, increased, or decreased.
• A discussion of the staff describing increases or
decreases in FTEs. Provide comparison to staff
resources reported in the Initial Submittal (or the
previous year).
• A brief discussion on how resources are dedicated
toward the data management, testing,
enforcement, administration and training
approval.
• Other. If there is an additional type of resource not
listed, describe and relate to the program.
7. Recertification
The states must have a process for recertification of
individuals whose certification has expired for a
period exceeding two years. This process must
include: review of the individual's experience and
training, and reexamination. An individual is not
certified with an expired certificate. The state may
develop more stringent requirements for
recertification for individuals whose certificates
have expired, been revoked, or been suspended.
• A simple summary of the recertification process
in the state
8. Stakeholder Involvement
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. 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.
• An affirmative statement that state meets
Baseline Standard 8.
• Documentation of meetings with stakeholders,
e.g., date, purpose, stakeholders involved,
summary of revisions and operations of the state
OpCert programs discussed, and feedback
provided
9. Program Review
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
include: regulations, exam items for relevancy and
• Documentation of internal and external meetings
which focus on program implementation which
could change as a result of the meeting- e.g.,
include date of the meeting, an identifier as
internal or external, programs or stakeholders
involved, purpose of the meeting, results of the
21
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Attachment 1
Operator Certification Guidelines (Public Health
Objective + Antibacksliding + 9 Baseline
Standards)
EPA national criteria to evaluate annual reports
with rcsocct to reauirement to show documentation
and evaluation of onsoins oroeram implementation
Notes
validity, compliance, enforcement, budget and
staffing, training relevancy, training needs through
examination performance, and data management
system.
meeting(s) or a copy of the program review
report.
22
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Attachment 2. Example of email to appropriate Regional personnel with instructions,
after receiving a state OpCert annual report.
(State PWSS Coordinate) ):
Attached is the annual operator certification program submittal from the ( tate agenc ).
I would appreciate your review and comments provided to me by (two weeks from the date of this email).
Please contact me if you have any questions.
Thank you,
(Op Cert Coordinator)
Attachment 3. Example of email to appropriate Regional personnel with instructions, after
combining comments on the state OpCert annual report.
(State PWSS Coordinato ):
Thank you for providing your comments on the ( tat() Operator Certification program annual submittal from
the (State agenq).
I have incorporated the comments you provided with the ones I developed. Please review this information and
be ready to discuss the combined comments during our internal discussion on ( ne week from the date of this
emai).
Please contact me if you have any questions.
Thank you,
(Op Cert Coordinator)
23
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Attachment 4. Example of email to the state OpCert Representatives with comments for
discussion on the OpCert annual report ( i major concerns).
(State Op Cert Coordinate ):
We have reviewed the (State agenc ) Drinking Water Operator Certification program annual submittal provided
to us on ( Date of annual program submitta ). The ( tate agenc ) Operator Certification program annual
submittal shows documentation and evaluation of ongoing program implementation with respect to the Federal
Guidelines.
We do have additional questions and comments for discussion related to the documentation and evaluation of
ongoing program implementation. We are not expecting any changes to the current annual submittal, but may
have suggestions for improvements for future annual submittals. I will work on a time to schedule a conference
call in a week to discuss these questions and comments with you and others as necessary.
Our comments, suggestions and questions are as follows:
(Comments, Suggestions and Questions)
Thank you for your work to ensure that:
• Customers of any public water system be provided with an adequate supply of safe, potable drinking
water;
• Consumers are confident that their water is safe to drink, and;
• Public water system operators are trained and certified and that they have knowledge and
understanding of the public health reasons for drinking water standards.
We look forward to the discussion.
Please contact me if you have any questions.
Thank you,
(Op Cert Coordinator)
Send to state OpCert Coordinator and other appropriate Regional personnel.
Work with the state to have a conference call and send out invitations to everyone.
24
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Attachment 5. Example of email to state OpCert Representative with comments for discussion on
the state OpCert annual report ( or concern ).
(State Op Cert Coordinator and state PWSS Program Manager):
We have reviewed the (State agenc ) Drinking Water Operator Certification program annual submittal provided
to us on ( Date of annual program submitta ). The ( tate agenc ) Operator Certification program annual
submittal has major issues and does not show documentation and evaluation of ongoing program
implementation with respect to the Federal Guidelines.
Our concerns with the annual submittal are such that we need additional information in the report before
September 30, ( 'ear). We will need to alert our Regional Division Director and the Director or the Office of
Ground Water and Drinking Water at EPA Headquarters to inform them of the situation, and that we are
working with the (itate agency) to address the issue(s).
The following are our concerns which will need to be addressed in a revised annual submittal.
(List of Concerns/Issues)
According to the April 18, 2001, Final Additions to the Final Guidelines, we need to review and determine if the
revised annual submittal shows documentation and evaluation of ongoing program implementation to meet the
Federal Guidelines by September 30. Should this requirement not be met, the Drinking Water State Revolving
Loan program for ( :ate) will have 20% of its FY( bs ) capitalization grant allotment withheld.
Please contact me as soon as possible to discuss these concerns and provide a time frame to provide a revised
report to us in time to review and determine if the revised annual submittal shows documentation and
evaluation of ongoing program implementation to meet the Federal Guidelines.
If you have questions, you can contact me at (Op Cert coordinator's phone numbe ).
Thank you,
(Op Cert Coordinator)
Send to state Op Cert Coordinator, and other appropriate Regional personnel as necessary.
Work with the state to have a conference call and send out invitations to everyone.
25
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Attachment 6. Sample of Annual state OpCert Program determination memo.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION XX
12345 Any Boulevard
Big City, State 12121
MEMORANDUM
SUBJECT: [ sa ] [Stat ] Drinking Water Operator Certification Annual Evaluation for [ ez ] SRF Grant
FROM:
[Responsible Person in EPA Region]
[Appropriate Water Management Branch]
TO:
[EPA Regional SRF Coordinator]
[Appropriate Branch]
We have reviewed the [State Agenc ] [ :ai ] Drinking Water Operator Certification Program Annual Report
submitted [Dat ]. Based on our review of the report, discussions at meetings and conference calls, the [ itate
Agenc\ ] has provided documentation and evaluation of ongoing program implementation of the [State drinking
water operator certification program for the reporting period of [ ime fram ] in accordance with section 1419
of the Safe Drinking Water Act. We recommend full allotment for the [ tate Agenc ] Drinking Water State
Revolving Fund capitalization grant for [ ederal Fiscal Year] as defined in section 1452 of the Safe Drinking Water
Act.
[Summary of highlights or suggestions from the report submittal]
We would like to thank [ : applicable, State of XX Operator Certification Program Manager Name ] and his/her
staff for their protection of public health through the drinking water operator certification program.
Questions regarding this matter can be directed to me.
Printed on Recycled Paper
26
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27
Appendix B: History of the Operator Certification Program
B.l The Safe Drinking Water Act
The SDWA was passed in 1974 to address public health
concerns by regulating drinking water, The SDWA
authorizes the EPA to set national health-based standards
to protect consumers from both naturally-occurring and
man-made contaminants that may be present in drinking
water, as well as work with states and PWSs to ensure that
those standards are met.
Originally, the SDWA focused on treatment as the primary
means of providing safe drinking water. The 1996 SDWA
Amendments established stronger prevention programs
(e.g., source water protection), increased state flexibility,
provided more in-depth information to consumers, and
strengthened the EPA's regulatory development process.
The 1996 Amendments also included initiatives to improve
communication with the public, employ better science for
risk assessment, and provide funding to states and PWSs to
achieve the public health protection objectives of the
SDWA through the DWSRF program.
The next page depicts the timeline of how the U.S. protects
public health and drinking water.
Table of
Contents
Key Resources
Glossary
Desk Guide for Reviewing State
Operator Certification Annual Reports
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28
Timeline
State public health
programs are created
to protect public
water supplies.
The EPA was established to
consolidate federal research,
monitoring, standard-setting, and
enforcement activities to ensure
environmental protection.
Congress passed the national
interim primary drinking water
regulations and amendments,
further protecting drinking water
from contamination.
Major SDWA amendments created
the DWSRF, Capacity Development,
and Operator Certification programs.
1965
© ®
1974
1986
Early
1900s
1970
Water Quality Act requires
states to review, establish,
and revise water quality
standards.
4 ©
America's Water
Infrastructure Act(AWIA)
amended SDWAto improve
drinking water and enhance
infrastructure investments.
2016
1977 & 1979
©
1996
© ©
Major SDWA Amendments strengthened
the pace of regulatory development and
regulation of microbial contaminants.
2018
Congress Passed SDWA, authorizing
EPA to set national health-based
standards for drinking water
contaminants and to work with
states to ensure standards are met.
The Water Infrastructure
Improvements for the
Nation (WlIN) Act revised
SDWAto improve drinking
water infrastructure.
Table of
Contents
Key Resources
Glossary
Desk Guide for Reviewing State
Operator Certification Annual Reports
-------
29
B.l.l The 1996 SDWA Amendments
"op
7 The 1996 Amendments provided the framework for the Operator Certification program, DWSRF,
primary enforcement authority, and Capacity Development program. Operator Certification was
introduced as part of the 1996 Amendments as a stronger approach to preventing drinking water
contamination. Capacity Development, as discussed in the 1996 Amendments, created a national
program through which states demonstrate their water systems' technical, managerial, and financial
(TMF) capacity to deliver safe and reliable drinking water.
Operator Certification
Ensuring safe drinking water requires knowledgeable and skilled public water system operators. To
ensure that operators are well-trained, Section 1419 of the 1996 SDWA required all states to establish
an Operator Certification program that meets guidelines developed jointly by the EPA and the states.
Before the SDWA and the Operator Certification Guidelines, the Surface Water Treatment Rule,
promulgated in 1989, required that surface water systems were operated by qualified operators. In
1998, the regulatory requirement for operators to be qualified was added for systems that disinfect. The
Operator Certification Guidelines published in 1999 specified the minimum standards for certification
and recertification of operators of community water systems (CWSs) and non-transient, non-community
water systems (NTNCWSs). Water system operators can be qualified based on their work experience
and education, but they are certified according to each state's application and examination process.
States may use a DWSRF set-aside to implement an Operator Certification program. Congress
appropriates funding for the DWSRF. The EPA then awards capitalization grants to each state based on
the results of the most recent Drinking Water Infrastructure Needs Survey and Assessment. The state
provides a 20 percent match. The SDWA requires the EPA to withhold 20 percent of a state's DWSRF
funds if the state fails to implement a program that meets the published Operator Certification
Guidelines. The withholding requirement ensures that states have both a public health and a financial
motivation to implement an Operator Certification program.
The objective of the Operator Certification program is not to require that every water system operator
be certified. Instead, the program is to ensure that water systems have (directly, under contract, or in
conjunction with other systems) an operator who is trained and certified to the level that each state
determines appropriate for the functions, facilities, and operations of that system to perform certain
key compliance functions. Operator Certification programs may vary between states but must meet the
nine operator certification baseline standards outlined in the Final Guidelines for Operator Certification.
The EPA Regions oversee state Operator Certification programs by conducting annual reviews of state
Operator Certification annual reports. These annual report reviews evaluate if a state Operator
Certification program meets the baseline standards set forth in the final guidelines. If the program
meets the requirements, the EPA Region determines that the DWSRF grant should not be withheld.
Other SDWA Provisions Related to Operator Certification
Capacity Development
Capacity development is the process through which water systems acquire and maintain the TMF
capabilities necessary for them to continuously provide safe, reliable drinking water. The SDWA's
capacity development provisions (outlined in Section 1420) provide a framework for states and water
systems to work together to build capacity and meet the SDWA public health protection objectives. The
Table of
Contents
Key Resources
Glossary
Desk Guide for Reviewing State ^
Operator Certification Annual Reports^
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30
focus on capacity development is through two major provisions; both of which are associated with the
DWSRF (the DWSRF provisions are outlined in Section 1452 of the SDWA).
• First, for states wishing to receive the full amount of DWSRF capitalization to which they are
entitled, states must develop and implement programs for new and existing systems.
Through these programs, new water systems must demonstrate capacity, while existing
water systems must build and maintain capacity. States failing to develop and continue
implementing such programs face having 20 percent of their annual DWSRF capitalization
grant withheld.
• Second, the SDWA ties a water system's eligibility to receive assistance under the DWSRF to
the system's TMF capacity. In short, providing DWSRF assistance to a system which, in the
judgement of the state, lacks the TMF capacity to ensure ongoing compliance with SDWA
requirements is prohibited.
Drinking Water State Revolving Fund
All 50 states and Puerto Rico are authorized to receive grants from the EPA to help capitalize their
DWSRF. The District of Columbia and U.S. territories receive a share of DWSRF appropriations as grants
to their governments and/or water utilities. States enjoy flexibility in establishing and managing their
DWSRF in a manner most suitable to their circumstances.
Each year, as part of the application to receive its capitalization grant, each state develops an Intended
Use Plan (IUP). The IUP describes how the state intends to utilize its DWSRF resources for the year. The
IUP contains a Project Priority List (PPL). Priority for receiving DWSRF assistance must be given to those
projects that:
• Address the most serious risks to human health.
• Are necessary to ensure compliance with the SDWA.
• Assist systems most in need according to state affordability criteria.
The state must fund projects in the order they appear on the PPL; however, projects which are not ready
to proceed to construction may be skipped to reach the next most highly-ranked ready to proceed
project. States may include provisions for funding emergency projects in the IUP. For more information,
the )WSRF Eligibility Handboo is a one-stop-shop manual for DWSRF eligibility questions for states and
interested stakeholders.
Set-Asides
The 1996 Amendments established a process through which up to approximately 31 percent of a state's
capitalization grant can be used in "set-aside" programs.1 Set-asides are a unique and important feature
of the DWSRF program and states have the option to take some, none, or all the authorized set-aside
amounts. The set-asides give states the flexibility through a wide range of activities to help PWSs
address compliance challenges, including those which do not require capital investment to resolve. The
EPA's State-bv-State Analysis explores different ways in which the 50 state Drinking Water programs and
Puerto Rico use DWSRF set-asides to support PWSs.
1 The Water Infrastructure Improvements for the Nation Act amended the set-asides. See text box below.
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Administration
and TA
TA to Small
Systems
State Program
Management
This set-aside may be used to cover the costs of administering the
DWSRF program and to provide technical assistance (TA) to water
systems. (See text box below for additional explanation.)
This set-aside may be used to provide technical assistance
exclusively to systems serving 10,000 or fewer persons.
This set-aside may be used to develop and implement an Operator
Certification program, develop and implement a Capacity
Development program, administer or provide technical assistance
through source water protection programs, and administer the
state Public Water Supply Supervision (PWSS) program.
LOCal Assistance This set-aside may be used to develop local drinking water
initiatives in the areas of capacity development, source water
and Other State . .. , ... , . .. M .. in . ,
protection, and wellhead protection. No more than 10 percent of
PrOgra mS the state's capitalization grant may be used for the any one activity.
In Focus: 2016 WIIN Act & 2018 AWIA
The Water Infrastructure Improvements for the Nation (WIIN) Act of 2016 amended the SDWA. It
changed the DWSRF's "4-Percent Set-Aside" calculation to be the greatest of $400,000, one-fifth
percent of the current valuation of the fund, or an amount equal to 4 percent of all grant awards to
the fund for the fiscal year.
America's Water Infrastructure Act of 2018 amended SDWA to expand source water protection-
related eligibilities under the 15 percent Local Assistance set-aside. Updates to source water
assessments are now eligible for funding, and expenditures under section 1452(k)(l)(D) now go
beyond wellhead protection programs to include the implementation of source water protection
activities.
Click on "Statutory Requirements" to go to the Statutory Requirements
section of this document
Statutory
Requirements
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Appendix C: Operator Certification Program Overview
Each state has an Operator Certification program whose mission is to assist PWSs in obtaining and
retaining qualified and capable water system operators. In response to the 1996 Amendments, the EPA
and states developed the nine baseline standards that all Operator Certification programs must meet.
These guidelines provide states with the minimum standards for the development, implementation, and
enforcement of Operator Certification programs for CWSs and NTNCWSs. The establishment of the nine
baseline standards offered guidance while also allowing flexibility to develop state-specific programs to
achieve compliance with Operator Certification Guidelines.
C.l Statutory Requirements
Congress established the goals of the Operator Certification program in 1996 with the following
statutory requirements:
The EPA shall establish guidelines "specifying minimum standards for certification (and
recertification) of the operators of community and nontransient noncommunity public water systems.
Such guidelines shall take into account existing State programs, the complexity of the system, and
other factors aimed at providing an effective program at reasonable cost to States and public water
systems, taking into account the size of the system."
[§1419(a)]
"[T]he Administrator shall withhold 20 percent of the funds a State is otherwise entitled to receive
under 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 the guidelines published pursuant to subsection (a) [Guidelines] or that has been
submitted in compliance with subsection (c) [Existing Programs] and has not been disapproved."
[§1419(b)]
"The Administrator shall withhold 20 percent of each capitalization grant made pursuant to this
section unless the State has met the requirements of 1419 (relating to operator certification)."
[§1452(a)(l)(G)(ii)]
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C.l.l Financial Implications for Operator Certification and Capacity
Development/DWSRF Programs
To avoid DWSRF withholding, a state must demonstrate that it is implementing an Operator Certification
program that meets the requirements in the guidelines established pursuant to §1419(a) or the
equivalent published state requirements.
Click "1996 SDWA Amendments" to review that section of this document to
learn more about the 1996 Amendments.
1996 SDWA
Amendments
C.l.2 Nine Baseline Standards
The nine baseline standards were published in 1999 as a requirement in §1419(a). These standards
establish the minimum required elements for a state drinking water Operator Certification program.
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Authorization
The state must have the authority to implement the Operator Certification program and require systems
to comply with the program requirements, or they are subject to a 20 percent withholding of the state's
DWSRF allocation.
Classification of Systems, Facilities and Operators
A state's program must:
• Classify all CWSs and NTNCWSs based on indicators of potential health risk.
• Develop specific requirements for each level of classification.
• Require owners to place the direct supervision of their water system under the responsible
charge of an operator(s) holding a valid certification equal to or greater than the classification of
their water system.
• Require that all operating personnel making decisions about water quality or quantity that affect
public health be certified.
• Require that a designated certified operator be available for each operating shift.
Operator Qualifications
The state must require an exam, a high school diploma, or general equivalency diploma (GED) and
appropriate job experience for an operator to become certified.
Enforcement
The state must enforce the PWSS program and water systems must meet the required regulations to
comply with state Operator Certification requirements. States must have appropriate enforcement
capabilities and they must have the ability to revoke or suspend operator certifications.
Certification Renewal
A state's program must:
• Establish training requirements for renewal.
• Require all operators to acquire necessary amounts and types of state approved training.
• Have a fixed cycle of renewal not to exceed three years.
• Require an individual to recertify if the individual fails to renew or qualify for renewal within two
years of the date that the certificate expired.
• Identify specific renewal requirements for grandparented operators to ensure that they possess
the knowledge, skills, ability, and judgement to properly operate the system.
Resources Needed to Implement the Program
States must provide sufficient resources to adequately fund and sustain the Operator Certification
program.
Recertification
The states must have a process for recertification of individuals whose certification has expired for a
period exceeding two years. This process must include a review of the individual's experience, training,
and reexamination.
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Stakeholder Involvement
States must include ongoing stakeholder involvement in the revision and operations of the state
Operator Certification program.
Program Review
States must perform reviews of their Operator Certification program.
C.2 The EPA National Tribal Operator Certification Program
C.2.1 Program Overview
The EPA has primacy in some tribal lands. Regional office Direct Implementation programs implement
the Tribal PWSS program, have enforcement authority over tribal drinking water systems, and
implement the Tribal Operator Certification program. The EPA Regional Operator Certification
coordinator is responsible for coordinating with the Direct Implementation program's Tribal Operator
Certification program in their EPA Region, and may have responsibilities in both programs. The purpose
of the EPA National Tribal Drinking Water Operator Certification program is to increase public health
protection by increasing the training and certification opportunities for personnel operating CWSs and
NCWSs in Indian country.
The National Tribal Drinking Water Operator Certification Program Final Guidelines establish the
program requirements for drinking water system operators in Indian country to provide meaningful
public health protection. This program provides water system operators in Indian country with further
training and certification opportunities in addition to existing training or certification programs offered
by states, various federal agencies, or private organizations. All CWSs, NTNCWSs, and any system
receiving Drinking Water Infrastructure Grant Tribal Set-Aside (DWIG-TSA) funds must be operated by
certified operators. Water system operators in Indian country can receive certification from the National
Tribal program, state, and/or other certification provider programs that have received EPA approval.
C.2.2 Role of the Regional Coordinator
Tribes Under EPA Direct Implementation
The Regional Direct Implementation program oversees the National Tribal Drinking Water Operator
Certification program where they have primacy for tribes in their EPA Region. The Regional Direct
Implementation program facilitates training and tracks certification of tribal water system operators as
state Operator Certification coordinators do with water system operators.
Tribal PWSs understate Primacy and Tribes with Primacy
For tribal PWSs under state primacy, the state primacy agency implements its Operator Certification
program. The role of the EPA Regional Operator Certification coordinator for tribal PWSs under state
primacy is the same as for non-tribal PWSs. Similarly, for tribes with primacy that have an Operator
Certification program, the tribe implements its Operator Certification program and the EPA Regional
Operator Certification coordinator provides oversite as it would a state primacy agency.
Tribal PWSs under tribal or state primacy are subject to the same certification requirements to receive
Drinking Water Infrastructure Grants - Tribal Set-Aside funding as Tribal PWSs under the Regional Direct
Implementation programs.
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Glossary of Terms
Term
Definition
Community water
system (CWS)
According to the Safe Drinking Water Act, a drinking water conveyance system
serving at least 15 service connections used by year-round residents of the
area served by the system or regularly serving at least 25 year-round residents.
Drinking Water State
Revolving Fund
(DWSRF)
State fund that provides financial assistance for public water systems and state
drinking water programs, established under the Safe Drinking Water Act.
Congress appropriates funding for the DWSRF. The EPA then awards
capitalization grants to each state based on the results of the most recent
Drinking Water Infrastructure Needs Survey and Assessment. The state
provides a 20 percent match.
Financial Capacity
The ability of a water system to acquire and manage sufficient financial
resources to allow the system to achieve and maintain compliance with Safe
Drinking Water Act requirements. Part of a state's Capacity Development
program.
Managerial Capacity
The ability of a water system to conduct its affairs in a manner enabling the
system to achieve and maintain compliance with Safe Drinking Water Act
requirements, including institutional and administrative capabilities. Part of a
state's Capacity Development program.
Non-community
water system (NCWS)
A public water system that is not a community water system. A non-
community water system is either a transient, non-community water system
or a non-transient, non-community water system.
Non-transient, non-
community water
system (NTNCWS)
A public water system, such as a school or hospital, that is not a community
water system and that regularly serves at least 25 of the same persons over 6
months per year.
Operator Certification
The establishment of minimum professional standards for the maintenance of
safe, optimal, and reliable operations of water treatment and distribution
facilities. While the specific requirements vary from state to state, the goal of
all Operator Certification programs is to ensure that skilled professionals are
overseeing the treatment and distribution of safe drinking water.
Primacy
The responsibility for ensuring that a law is implemented, and the authority to
enforce a law and related regulations. A primacy agency has primary
responsibility for administrating and enforcing regulations.
Public water system
(PWS)
A system for the provision to the public of piped water for human
consumption, if such system has at least 15 service connections that regularly
serve at least 60 days out of the year.
Safe Drinking Water
Act (SDWA)
Federal drinking water quality legislation administered by the U.S.
Environmental Protection Agency (EPA) through state primacy agencies;
amended in 1986 and 1996.
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Term
Definition
Technical Capacity
The physical and operational ability of a water system to meet SDWA
requirements, including the adequacy of physical infrastructure and the
technical knowledge and capability of personnel. Part of a state's Capacity
Development program.
Transient, non-
community water
system (TNCWS)
A non-community water system, such as a summer camp, that does not
regularly serve at least 25 of the same persons over 6 months per year.
Water System
A series of interconnected conveyance facilities owned and operated by a
drinking water supplier.
Withholding
An irreversible and permanent decrease in DWSRF allocation that will occur by
failing to implement a variety of programs. The SDWA requires the EPA to
withhold 20 percent of a state's DWSRF funds if the state fails to implement a
program that meets the published Operator Certification Guidelines.
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