Consumer Confidence Reports Frequently Asked Questions

Regulation

How early can I deliver my report to my customers?

You must deliver your Consumer Confidence Report (CCR) to your customers and the state before July 1 of each year. You may deliver it any time after you complete last year's monitoring requirements and receive your lab results. As long as the report contains the most recent information through December of last year, it can be delivered any time between January 1 and July 1 of the new year.

I may not be able to meet the July 1 due date for this year's report. May I have an extension?

The CCR summarizes the results of water quality monitoring through December of last year. You have six months (January through the end of June) to produce and distribute the report. We will not grant extensions beyond July 1 because six months is enough time for you to produce and distribute the report.

Can my CCR be delivered late—after July 1?

Your CCR an important key in communicating with your customers. The report has meaningful information about the source of your community's drinking water, its water quality, and the potential health effects of any contaminants that may be in it. By communicating with your customers through the CCR, you are empowering them to make important personal health decisions. You are also strengthening your relationship with your best allies. After all, your customers support your business. And you provide a vital resource to everyone.

It is important to understand that purveyors who do not submit a CCR to their customers and the state before the annual due date of July 1 are in violation of a state regulation. Despite a status of non-compliance, it is important to the State Department of Health that you produce and distribute the CCR, even if it is late. We urge you to produce and distribute your CCR to your customers and your Drinking Water Regional Office as soon as possible.

Are state CCR requirements different from old federal CCR requirements?

No. The state adopted the federal Consumer Confidence Report regulation "as is." State CCR requirements are the same as federal CCR requirements. State regulations read differently than the old federal regulations because we rewrote it clarity and simplicity. The requirements have not changed.

We support your efforts to communicate with your customers frequently and consistently. Although you do not need to include any additional information beyond state required minimums. The CCR as an invaluable opportunity for you to inform and educate your customers about the many daily activities at your water system. Ideas for and information about activities you may wish to highlight in your report can be found under the topic Report Writing Assistance on this homepage.

Do systems have to make the report available in languages other than English?

This depends on your community and the languages spoken. The CCR intent is to inform the public about the quality of their drinking water. If a large proportion of residents living in a community speak language(s) other than English, it is your responsibility to let them know this water quality information is available in their language.

To determine whether your community has a large proportion of non-English speaking members, look at census information for your county. Go to the U.S. Census Bureau's website. Once you are there, click on State & County Quick Facts, select Washington State and the county you are interested in; go into the Demographics section and select Race information. You also may consider conducting a very short informal survey of your customers—as a postcard mailing or over the phone—asking what language is typically spoken in their household.

The state regulation does not require you to produce the whole report in languages other than English or to provide a translator. The report needs to contain at a minimum only a sentence or two, in appropriate non-English language(s), that says the report contains information about drinking water quality and for the reader to seek help in having it translated.

The utility guidance document offered by EPA (see the topic Preparing Your Drinking Water Consumer Confidence Report under this homepage) has boilerplate sentences in common non-English languages that are available for copying into reports.

If your customers ask for translation help, ask if they have any multi-lingual family members or friends who could read it to them. Multi-lingual members of your community may be willing to help your non-English speaking customers. You may also suggest that the consumer look into hiring a translator themselves. For the names of translators, look in the Yellow Pages under Translators & Interpreters.

What is meant by the "source water assessment" information that is required in my report? [This question refers to WAC Chapter 246-290-72003(2) and (3).]

DOH is required by EPA to conduct a source water assessment of all drinking water sources of Group A public water systems. DOH uses information provided by purveyors through their wellhead protection program, watershed control program, and submitted susceptibility assessment data as the basis for these assessments.

Until DOH contacts a water system and provides the purveyor with the results of the DOH source water assessment, the purveyor is not required to include information about source water assessments in their CCR. While waiting for the results of the state assessment, however, EPA and DOH strongly encourage purveyors to include in their CCR other readily available information about potential sources of contamination to the system's drinking water sources. Such information could include the results of sanitary surveys, wellhead protection studies, watershed control studies, susceptibility studies and the like.

Your CCR is your opportunity to inform and educate your customers about the impacts that they and others may have on the quality of their source water or to explain how your community's drinking water supply is being protected. You also may want to provide pollution prevention tips or information about local cleanup activities.

Click here for more information about Source Water Protection and the Source Water Assessment Program (SWAP). If you have questions about SWAP, email Nikki Guillot or call 360-236-3114.

Report Distribution

When it comes time for me to send a copy of my report to the state, where do I send it?

Southwest Regional Officeccr.swro@doh.wa.gov

  • For systems located in Clallam, Clark, Cowlitz, Grays Harbor, Jefferson, Kitsap, Lewis, Mason, Pacific, Skamania, Thurston, and Wahkiakum counties.

Northwest Regional Officeccr.nwro@doh.wa.gov

  • For systems located in Island, King, Pierce, San Juan, Skagit, Snohomish, and Whatcom counties.

Eastern Regional Officeccr.ero@doh.wa.gov

  • For systems located in Adam, Asotin, Benton, Chelan, Columbia, Douglas, Ferry, Franklin, Garfield, Grant, Kittitas, Klickitat, Lincoln, Okanogan, Pend Oreille, Spokane, Stevens, Walla Walla, Whitman, and Yakima coutnies.

What methods can I use to transmit my CCR and certification form to the Office of Drinking Water Regional Office?

You can do any of the following.

  • Hand deliver a hard copy to the appropriate regional office.
  • Email with a word processing file or PDF attached.
  • Request the appropriate regional office download your report from an Internet website if you provide a specific URL link.
  • Request a Box.com folder through our administrative staff. Box.com allows you to easily transfer very large files.
     

Where do I get the CCR Certification Form to attach to my report when I send it to the state?

Click the form Consumer Confidence Report Certification Form 331-203-F (PDF)It includes instructions for mailing it to the state. Print, complete, sign and date, and attach it to the copy of your report you send to us. Keep a copy for your files.

How do I distribute my CCR to people who live in apartment complexes, nursing and retirement homes, work at office buildings or spend time at schools?

Federal regulation requires you to make a good faith effort to ensure the report is available to consumers who do not have a direct service connection with the water system. Tailor an adequate good faith effort to best inform members of your community about the availability of the report. Use at least two methods to satisfy this good faith distribution requirement.

Suggested methods include posting the report your website; mailing it to postal patrons in metropolitan areas; advertising the availability of the report in the news media; publishing it in local newspapers; posting it in public places such as cafeterias or lunch rooms of public buildings; delivering multiple copies for distribution by single-billed customers such as apartment buildings or large private employers; delivering to community organizations. If you think of other distribution methods that best suit your community's situation, they could count towards satisfying this required good faith effort.

Do small water systems (that serve less than 10,000 people) have a waiver that excludes them from having to deliver the report to each of their customers?

No. The federal CCR regulation gave states the option of offering to small water systems a waiver for the direct delivery requirement when the state made the regulation a state requirement. After discussion, we decided not to offer the waiver for at least the first several years that the CCR requirement is a state regulation. As a public health agency, we believe the information is important for the public to receive. We may be evaluating in the coming years whether it is appropriate to offer the waiver, but for the present, the waiver is not available.

Please note that the direct delivery waiver, even if it becomes available to small water systems at a future date, would not alleviate the purveyor from being responsible for producing the report. If the waiver is offered in the future, alternative requirements would apply depending on system size. Systems that serve between 500 and 10,000 persons would have to publish the report in local newspaper(s), prominently post it in conspicuous locations, and make it available upon request to anyone who asks for it.

For systems that serve less than 500 persons, the purveyor would have to make the report available upon request and provide notice of its availability to each customer at least once a year. Regardless of whether the waiver is granted, purveyors would still have to send a copy of the report to the state before the July 1 annual due date.

Chemical Reporting

Do I have to use the word contaminant in my CCR?

Even though state regulations and EPA's utility guidance document make consistent references to contaminants, you are not required to use this word in your CCR. You must use the word contaminant for mandatory language required by the regulation. Other words you may want to use include analyte, chemical, compound, substance, or element. You may use terms for your customers' understanding, especially where you add any substance to the water for health purposes (e.g., fluoride).

Do I need to list all my water quality monitoring data in my CCR? How do I tell whether I have a detected or non-detected value in my lab report?

No, the CCR regulation does not require you to list all the chemicals that you test and have results for. You need to include only detected chemicals - that is, those that are reported as positive values by your laboratory. To understand "detected," here's a quick lesson in analytical chemistry jargon:

"Zero" is the absence of a chemical. Laboratory equipment is not typically designed to look for zero chemical in a water sample. Equipment has a limit to how low a concentration it can detect when it looks for a specific chemical.

The detection limit (DL) or method detection limit (MDL) is the lowest concentration that a piece of laboratory equipment can detect when it looks for a specific chemical. Chemicals that are not detected are typically shown with a "ND" (for not detected), a "U" (for undetected) or will be shown as a value preceded by a "

Chemicals that are detected are typically shown as positive numbers without any letters or signs associated with them.

The state reporting level (SRL) is the concentration that the state requires laboratory equipment to be able to go down to when looking for a specific chemical. The SRL may be the same as or higher than the detection limit or the method detection limit.

Lastly, there are the Maximum Contaminant Level (MCL), the Action Level (AL) and the Treatment Technique (TT) standards which are state or federal standards that determine compliance with drinking water regulations.

What is required in your CCR are any chemical concentrations that your laboratory reports as higher than the state reporting level (SRL). You need to include those concentrations that are higher than the MCL or AL or TT, as well as what might appear to be trace amounts or very low concentrations that are well below the standard.

The CCR regulation requires that you NOT include non-detects in your data summary table. You can talk about them if you wish, but do not include them in the data summary table. The report is intended to provide the reader with a short "snapshot" of what was in the water in recent years. Your customers shouldn't have to wade through a long list of non-detects to find those few substances that were detected. You may summarize your non-detections by saying something to the effect that "ABC Water System tests for 16 IOCs (inorganic contaminants), 32 SOCs (synthetic organic contaminants), and 19 VOCs (volatile organic contaminants). Only 4 of these substances were detected in your drinking water last year." This would let your customers know that you are looking for many possible contaminants, but that only a few were actually found.

Do I need to report on chemicals with secondary MCLs, such as iron and manganese?

With the exception of fluoride and copper, the Consumer Confidence Report regulation does not require you to report chemicals with secondary MCLs. Secondary MCLs are not based on health effects as primary MCLs are, but are based on aesthetic and cosmetic effects. Therefore, you do not need to include detections of iron, manganese, chloride, sulfate, zinc, or silver. Although fluoride and copper do have secondary MCLs, they are special cases and the CCR regulation specifically requires that detection of these compounds be included in your report. See the FAQ in this section on fluoride and on calculating the 90th percentile copper value.

If you do have detected concentrations of substances with secondary MCLs, however, your report is a great opportunity to educate your customers about their levels and effects in drinking water. For example, you may explain that high levels of iron and manganese typically stain clothes and may result in "smelly" water at certain times of the year.

How do I address waivers for monitoring requirements in my report?

In a nutshell, you do not have to mention that you have a waiver. Waivers are typically granted because a source was determined by the state to have a low susceptibility to contamination and, for example, certain chemicals were not detected in the water. Since non-detected chemicals are not required to be included in your report, you do not have to mention them. You may, however, want to say that you have a waiver and are not required to monitor for a certain chemical or class of chemicals, and give the reason why if you know it.

Do I have to include monitoring data from emergency sources of water?

If you used an emergency source of water that contained contaminants at levels above the Maximum Contaminant Level (MCL), then you must include this data in your report's data summary table. Your report must then also include mandatory statements about the contaminant source and possible health effects. (These statements are provided in WAC Chapter 246-290-72012 of the state regulation.) You may want to go on to explain how often and when this emergency water is typically used and why. Such additional information might help alleviate possible questions or concerns from your customers about your use of emergency sources that contain elevated levels of contaminants.

If your emergency source water monitoring results indicate MCLs were not exceeded, but you feel your use of emergency water was such that your customers could benefit from knowing about the quality of water from this source, then you might consider including the data and explaining why you used this source, when and how often. This is a case where you, the water purveyor, must use your best judgment, remembering that the intent of the CCR regulation is for you to inform your customers about the quality of water you've been serving them throughout the previous year.

If you do report your emergency source water data and the water from the emergency source was blended with water that is more regularly used, combine the emergency source water data with the "regular" water data to create your report's data summary table. If the emergency source water was not blended, present these data separately from those of your "regular" water. You could separate these different sources of water quality data by using different columns in the data summary table or presenting the results separately in a different table.

I monitor for volatile organic chemicals (VOCs) only once every three years and I didn't have to collect a VOC sample during the last (most recent) calendar year. Do I need to include my VOC results in this year's report that summarizes last year's data? (The answer below also applies to synthetic organic chemicals (SOCs).)

Yes. Although each year's report focuses on summarizing information about the quality of water you served during the previous calendar year, you also need to include the most recent result of monitoring that was conducted for other chemicals that aren't tested for every year. You need go back, however, only as far as five years to report the most recent result. Along with reporting the concentration of a detected VOC or SOC, you would include the date of that last sample result in the data summary table. This information is required to be repeated in each year's report until you have new results to report from a more recent round of monitoring. Any other chemicals that you monitor for less frequently than every year are to be handled this same way.

When reporting lead or copper detections, do I include my distribution results or my IOC results?

It is possible that you may need to report both. If you have detections from your Inorganic Chemical (IOC) monitoring results, you need to include this information in your data summary table. If you have detections as a result of your distribution monitoring, you need to report the 90th percentile of your last sampling round. (See the next FAQ in this section on how to calculate the 90th percentile value.) If you have detections in only one type of monitoring, just report those results. No detections? No reporting of lead or copper.

How do I calculate the 90th percentile value to report the results of my lead and copper distribution samples?

The following instructions (taken from Chapter 246-290-025 WAC, 40 CFR Section 141.80) are written using lead as the example, but they apply in the same way to copper results.

Put all of your lead results in increasing order, starting with the smallest value and ending with the largest value, including non-detects. You'll probably have several non-detects listed first, followed by a few detections. Make sure your detections are in increasing order.

Multiply the number of samples you took by 0.9. Round this result up to the next highest whole number.

Go to your ordered list of lead sample results and identify the sample that corresponds to the whole number from step 2 above.

The concentration of that sample is the 90th percentile.

Here is an example:

32 samples were collected.
32 x 0.9 = 28.8. Round to 29.
Identify the 29th sample in your list of ordered samples (ordered from lowest to highest).
The concentration of lead for the 29th sample is the 90th percentile.

What do I put in my CCR if I have one unsatisfactory (positive) total coliform result, but all of the required follow-up samples were satisfactory?

The CCR regulation requires that any and all unsatisfactory samples be reported even if all required follow-up samples are satisfactory. The unsatisfactory result needs to be included in your data summary table along with its MCL, MCLG and typical source language (provided in WAC Chapter 246-290-72012). Having only one unsatisfactory sample is not a violation if the four immediate repeat samples plus the following month's five samples all are satisfactory. In this case, you may want to explain in the text of your report that all follow-up samples were satisfactory and that one unsatisfactory sample does not necessarily represent a public health threat. (Note: If you collect fewer than 40 total coliform samples per month, the MCL is "1" for total coliform. The MCLG is "0".)

How do I report fluoride in my consumer confidence report?

Simply put, if fluoride has been detected in the water you serve, you are required to include this result in your report. If your lab reports a "non-detect" for fluoride, do not include fluoride in your report.

Overall, whether fluoride is naturally present, your system fluoridates, or you purchase fluoridated water, it is important for you to communicate to your customers that fluoride levels in drinking water vary. Levels may not always be within the desirable therapeutic range of 0.6 to 2.0 mg/L (or parts per million, ppm) at their tap. (Note that this therapeutic range includes the levels of 0.8 to 1.3 mg/L that are required by WAC 246-290-460 to be maintained in the distribution system of water systems that fluoridate.) Fluoride levels reported in your CCR should not be used by medical or dental professionals as a basis for prescribing fluoride supplements. You should encourage your customers to contact you for system-specific information on your fluoridation practices.

Now for a bit more detail:

Fluoride is an element with a Maximum Contaminant Level (MCL) of 4 mg/L. If you have fluoride levels above the state reporting level (SRL) of 0.2 mg/L, you are required to include these results in your report's data summary table. You also must include the MCL, MCL Goal and typical source language that are provided in WAC Chapter 246-290-72012.

If your system purchases water from another system, and the water that you purchase has fluoride above 0.2 mg/L, you are required to report this to your customers. This information should be in the water quality report that the system supplying your water is required to provide to you by April of this year.

Fluoride is a beneficial chemical at levels of 0.6 mg/L to 2.0 mg/L whether it occurs naturally or is added during water treatment.

To avoid confusion among your customers when reporting levels of fluoride above 0.2 mg/L and below 2.0 mg/L, we recommend you refer to fluoride using terms such as substance, compound, chemical, element or analyte. Fluoride does not need to be listed as a "contaminant."

If you need to report fluoride levels at or above 2.0 mg/L and below 4.0 mg/L, we suggest you mention that fluoride at levels above 2.0 mg/L may result in mottled teeth.

If you need to report a fluoride level that is above its MCL of 4.0 mg/L, you also need to include the required possible health effects language provided in WAC Chapter 246-290-72012 of the regulation.

If you add fluoride to the water, you may want to include a brief explanation in the text of your report that explains why you add fluoride to the distribution system. Perhaps, for example, your community voted for fluoridation because of its recognized positive effects on dental health.

Do I have a monitoring waiver for asbestos? Do I need to report a monitoring violation for asbestos if I didn't monitor for it?

Asbestos monitoring is required under federal regulations and Chapter 246-290-300(4) of the state WAC. It is a primary inorganic chemical subject to a Maximum Contaminant Level (MCL) and may need to be addressed in your consumer confidence report depending on whether your system qualifies for a waiver.

DOH offers a monitoring waiver for asbestos to systems that have less than 10 percent asbestos cement (AC) pipe and that use only springs, groundwater, purchased water, or inter-tie sources. If your system fits this description, you must have completed an Asbestos Monitoring Waiver Form in order for the waiver to be in effect. If you did not file this form with DOH, you did not receive the waiver. If you have any questions about the asbestos waiver, please contact your Drinking Water regional office.

Systems that have10 percent or more AC pipe and systems that use surface water or a combination of surface water and other sources are not eligible for a monitoring waiver for asbestos.

So, as far as your CCR goes, if you did not monitor for asbestos, but your system qualifies for an asbestos monitoring waiver and you filed the form with DOH, you do not need to report a monitoring violation in your consumer confidence report.

If you did not monitor for asbestos and your system does not qualify for an asbestos monitoring waiver, you must call out an asbestos monitoring violation in your consumer confidence report. Do not include this monitoring violation in your detected data summary table. In a separate part of your report, list asbestos, its MCL, MCL Goal (MCLG) and typical source language (provided in WAC Chapter 246-290-72012). Explain the violation in the text of your report by (1) saying how long you've been out of compliance, (2) including the health effects language (provided in WAC Chapter 246-290-72012), and (3) describing any actions your system has taken or will take to correct the violation.

If you don't have an asbestos monitoring waiver and your laboratory result indicates asbestos was detected, you need to report an asbestos detection in your consumer confidence report. Please see (or click on) Writing Assistance for help with writing your consumer confidence report.

Do I have to talk about radionuclides in my report? If so, how do I do that?

Community water systems are required to monitor for radionuclides under EPA regulations and Chapter 246-290-300 (9) of the WAC. Most community systems are required to monitor for radionuclides every four years, although systems downstream from a nuclear facility may need to monitor as frequently as every three months. The CCR regulation requires you to go back as far as five calendar years for data to include in your report.

If you monitored for radionuclides during the last five calendar years and your lab report indicates radionuclides were detected, summarize the most recent of your results in your CCR data summary table. If your lab report indicates radionuclides were not detected, you do not need to include radionuclides in your report.

If you have not monitored for radionuclides during the last five years (and were required to do so), the CCR regulation requires you to report this as a radionuclide monitoring violation. Do not include this monitoring violation in your data summary table of detections. In a separate part of your report, list the type of radionuclides you should have monitored for, their MCLs, MCLGs, and typical sources (provided in WAC Chapter 246-290-72012). Explain the violation by (1) saying how long you've been out of compliance (state if and when you last monitored for radionuclides), (2) including the potential health effects language of WAC Chapter 26-290-72012, and (3) describing any actions your system has taken or will take to correct the violation (that is, for example, when you will next monitor for radionuclides).

The Department of Health determined that radionuclide monitoring is a low health priority in Washington State based on historical water quality data. You may want to explain to your customers that, although you have been required to monitor for radionuclides, we have not been actively enforcing this requirement. Although we anticipate that radionuclides will remain a low health priority, it is the responsibility of a water purveyor to comply with all state and federal drinking water regulations. Please see Writing Assistance for help writing your CCR.

Training and Assistance Opportunities

Does the state have a guidance document? Will the state send me a form that doesn't need a computer to be filled out? Will workshops be offered?

The state developed a guidance document titled Tips for Preparing User-Friendly Consumer Confidence Reports 331-296. This booklet provides a comprehensive tool for preparing CCRs.

DOH is currently looking into shifting some of our resources to support CCR training and education. Please check our training calendar for up-to-date information about CCR training opportunities offered by professional organizations. And last, but not least, click here for assistance with writing this year's report.