Your Trusted Partner in Environmental Solutions

The Safe Drinking Water Act (SDWA) was passed by Congress in 1974 to protect public health by regulating the nation’s public drinking water supply. The SDWA was amended in 1986 and 1996 and requires many actions to protect drinking water and its sources. The SDWA authorizes the United States Environmental Protection Agency (US EPA) to set national health-based standards for drinking water to protect against both naturally occurring and man-made contaminants that may be found in drinking water. US EPA, states, and water system operators have responsibilities to make sure that these standards are met. In Louisiana, the Louisiana Department of Health (LDH) administers drinking water rules as codified in Louisiana Administrative Code (LAC) 51, Part XII - Water Supplies. 

Water Systems

LAC 51, Part XII defines a public water system as: a system for the provision to the public of water for potable water purposes through pipes or other constructed conveyances, if such system has at least 15 service connections or regularly serves an average of at least 25 individuals daily at least 60 days out of the year. LDH considers systems which do not meet these requirements as private water systems. LAC 51 Part XII also applies to private water systems. 

LAC 51 Part XII §309 requires that all public water systems be under the supervision and control of a duly certified operator. Certified operators must earn 8 hours of continuing education credits every two years. 

Public water systems may not construct, operate or modify the capacity, hydraulic conditions, treatment processes or the quality of finished water without a permit from the state health officer. Detailed plans and specifications for the installation for which a permit is requested shall be submitted by the Engineer of Record or the person responsible for the charge of a municipally owned public water supply or by the owner of a privately owned public water supply.

Cross-connection Control

In 2016, LDH adopted the International Plumbing Code (IPC) as amended in LAC 17, Part I, §111. LAC 17, Part I, §111 amends a requirement to color code potable and non-potable water pipes when non-potable water is present for certain industrial facilities listed in R.S. 40:4.12. The exemption requires certain industrial facilities to have a cross-connection control survey performed by a certified person meeting the requirements of American Society of Inspectors of Plumbing and Sanitary Engineers (ASSE) 5120 every five years. The exemption also requires the development of a potable water distribution identification plan (PWDIP) satisfying the statute requirements. The exemption to the color-coding requirement is only applicable to facilities with the following 1997 National America Industrial Classification System (NAICS) Standard Industrial Classification (SIC) codes:

• 22111 electric power generation.
• 3221 pulp, paper, and paperboard mills.
• 324 petroleum and coal products manufacturing.
• 325 chemical manufacturing.
• 326 plastics and rubber products manufacturing.
• 331 primary metal manufacturing.
• 211 oil and gas extraction.
• 486 pipeline transportation.
• 213111 drilling oil and gas wells.
• 213112 support activities for oil and gas operations.
  

How CK Associates Can Help 

CK Associates (CK) can provide support in evaluating, maintaining, and documenting compliance with drinking water systems. This support includes:

• Conducting cross-connection control surveys and backflow preventer inspections
• Developing/updating potable water distribution identification plans
• Evaluating drinking water quality for compliance with disinfectants/disinfection byproduct, lead and copper, and total coliform requirements
• Sampling water supply sources for per- and polyfluoroalkyl substances (PFAS) 

Charles Roccaforte joins CK Associates’ Woodlands office as a Senior Scientist on the Air Team. Charles brings 30 years of experience supporting complex industrial operations, achieving and maintaining compliance excellence. Charles has extensive knowledge and experience in regulatory compliance, including developing compliance programs, federal and state air permitting, and auditing, and has strong relationships with federal and state regulatory agencies. His career includes nearly two decades at the ExxonMobil Beaumont Complex, where he supported one of the largest refineries in North America.

Throughout his career, Charles has built a strong reputation for his collaborative leadership style, his ability to translate complex rules into clear, actionable guidance, and his skill in fostering positive relationships with regulatory agencies and internal stakeholders. He has developed compliance assurance systems, led major permitting initiatives and conducted audits to ensure continuous improvement.

The United States Postal Service (USPS) has implemented updates to its postmark date system that may affect how regulatory agencies determine the official receipt date of mailed documents. While the intent of this change is to modernize mail processing, it does introduce important timing considerations for regulatory filings and compliance submittals.

At CK, we’re staying ahead of this shift so our clients can stay focused on their operations with peace of mind that their compliance needs remain in good hands.

What’s Changing

Under the updated USPS system, postmark dates may no longer consistently reflect the exact day a document is physically mailed. In some cases, postmarks may be applied later in the mail-processing cycle, which could impact deadlines where agencies rely strictly on postmark date rather than delivery confirmation.

For time-sensitive regulatory submittals, this change increases the risk that mailed documents could appear late even when they were sent on time.

How This May Affect Clients

Certain environmental and regulatory programs require documentation to be postmarked by a specific deadline. With this USPS change:

• Relying solely on traditional mail postmarks may carry added risk
• Agencies may question compliance timing if postmarks are delayed
• Proof of timely submission becomes more important than ever

How CK Is Navigating the Change

CK is proactively adjusting our internal processes to protect our clients and maintain compliance certainty. Our approach includes:

• Earlier submission planning to build in additional buffer time
• Expanded use of electronic submittals where allowed or encouraged by agencies
• Alternative delivery methods (such as tracked or certified services) when mailing is required
• Clear documentation and records to support proof of timely submission
• Client communication and coordination for deadlines that may be affected

We are also closely monitoring regulatory agency guidance as they adapt to the USPS changes and will adjust our practices as expectations evolve.

What Clients Can Expect from CK

As always, CK’s priority is compliance confidence. You can expect:

• Thoughtful planning around deadlines
• Transparent communication when mailing timelines matter
• Practical, forward-thinking solutions that reduce risk
• A steady partner who keeps up with changes so you don’t have to

If you have questions about how this change may affect a specific submittal or program, your CK project team is ready to help. We’ll walk alongside you and make sure deadlines are met no surprises, no scrambling.

Additional details regarding this change can be found in the Federal Register notice USPS Postmark Date System Updates (FR Doc. 2025-20740)