Academy/Maintenance Fundamentals
Private water systems
Who is responsible for testing and maintaining water that doesn't come from a city pipe.
If your association owns a well or a shared water system that isn't municipal, testing and upkeep are the association's job, not a regulator's. Private water systems are exempt from federal drinking water rules, so responsibility for testing falls on the owner until the system's connection count crosses a state-set threshold that turns it into a regulated public water system.
What makes a water system "private"
A private water system is any source that isn't a municipal or investor-owned utility, most commonly a well the association drilled to serve a clubhouse, a cluster of buildings, or the whole community. Because it isn't hooked to a city system, nobody is automatically inspecting it on the association's behalf.
Testing is on you, not a regulator
The U.S. Environmental Protection Agency is direct about this: private wells are exempt from the Safe Drinking Water Act, which is the law that forces municipal utilities to test and report on water quality. That exemption doesn't mean the water is safe by default, it means nobody else is checking.
"Test your private well annually for total coliform bacteria, nitrates, total dissolved solids, and pH levels."
Source: Protect Your Home's Water, U.S. Environmental Protection Agency
EPA also recommends testing more often, or for more contaminants, if the well serves residents who are pregnant, very young, elderly, or immunocompromised, or if the water's taste, odor, or appearance changes.
When a private system becomes a regulated public water system
A private well can cross a line and become a legally regulated "public water system" once it serves enough connections or people, even though it's still privately owned. EPA sets a baseline definition, but states run their own drinking water programs and can set the actual threshold that applies in your area. Whether your system counts as regulated, and what testing that triggers, depends on your state's drinking water program. Ask your state's drinking water program directly rather than guessing from the number of homes it serves.
Building a maintenance program without one national code
Unlike a fire alarm or an elevator, private water systems generally, other than wells specifically, aren't governed by a single nationwide standard the board can point to. That doesn't mean there's nothing to do. Build the program from what does exist: the equipment manufacturer's service specifications, a licensed water or well contractor's recommended schedule, and your own governing documents' assignment of who pays for what. Write the schedule down and log every test, the same way you would for any other reserve component.
Check yourself
Answer before you read the explanation, recalling it is what makes it stick.
Your association owns a well that supplies four buildings. An owner asks who is legally required to test it for safety. What's true?
Two associations privately own their water systems, one has 30 connections and one has 300. Which is more likely to cross the line into a regulated public water system?
The board can't find a single national code covering its private water system. What should it do to build a maintenance program?
Sources
- Protect Your Home's Water, U.S. Environmental Protection Agency
- Information about Public Water Systems, U.S. Environmental Protection Agency
Related elsewhere in the Academy
Maintenance Fundamentals
Next, learn what an inspection program looks like once you know what needs checking. See Inspection programs.
Whether your system counts as a regulated public water system, what that triggers, and how often testing is required all depend on your state's drinking water program and your system's connection count.