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DEP Delivers Final Rule to IRRC—Addresses Supplemental Disinfection to Health Care Facilities’ Water Supplies

June 22, 2018

A health care facility’s potable water supply is provided by a public water utility. Many health care facilities consider providing supplemental disinfection to the health care facilities’ water supply to provide additional protections for their patients and employees.

Unfortunately, current Department of Environmental Protection (DEP) regulations place a regulatory burden on hospitals as they do not take into account the unique circumstances that occur in the health care facility setting. HAP and the Pennsylvania Society of Health Facility Engineers (PSHFE) met with DEP officials to address the regulatory burdens. In response, DEP developed regulations to provide for the implementation of a general permit process allowing hospitals to register for approval to provide supplemental disinfection to their water supply.

The Environmental Quality Board published a proposed rule, which included a provision that would establish the regulatory basis for issuing general permits for high-volume, low-risk modifications or activities to the water supply.

HAP and PSHFE submitted a joint comment letter urging the DEP to consider hospital water systems that purchase water from a public water system as a “single system.” This would exempt them from unnecessary and undue regulatory burdens.

DEP recently submitted the Safe Drinking Water General Update and Fees final rulemaking to the Independent Regulatory Review Commission (IRRC) for review and consideration. This final rulemaking is tentatively scheduled to be considered by IRRC at its public meeting on Thursday, June 28, 2018.

HAP’s comments and DEP’s response are contained in the Comment and Response document. HAP is encouraged by DEP’s response and welcomes the opportunity to collaborate with DEP to design a general permit process that will specifically address the hospital community’s needs for the implementation of supplemental disinfection systems.

Questions may be addressed to Mary Marshall, HAP’s director, workforce and professional development.

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