# Cross Connection Control Plan: California Checklist > A section-by-section checklist of what a California cross connection control plan must contain under the CCCPH, for community and noncommunity systems. Source: https://www.exoduswater.com/post/cross-connection-control-plan-checklist-california Cross-connection & backflow October 30, 2026Exodus Water Services # Cross-Connection Control Plan Checklist for California Water Systems A section-by-section checklist of what a California cross connection control plan must contain under the CCCPH, for community and noncommunity systems. **Short answer:** A California Cross-Connection Control Plan is the written description of how a public water system runs its cross-connection control program, and it must cover 13 required elements listed in Section 3.1.4 of the State Water Board’s Cross-Connection Control Policy Handbook (CCCPH). Existing water systems had to submit their plan no later than 12 months after the CCCPH took effect on July 1, 2024, which was July 1, 2025, and every plan must stay current with how the program actually runs (Sections 3.1.4(a) and (d)). This checklist maps each required element to its CCCPH section, then adds the plan content required by other sections that are easy to miss. _Last reviewed October 30, 2026, against the April 21, 2026 revision of the CCCPH. Sources are listed at the end._ ## What is the difference between a cross-connection control program and a plan? The two terms are used together but mean different things in the CCCPH: | Cross-connection control **program** | Cross-Connection Control **Plan** | | | ------------------------------------ | -------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------ | | What it is | The ongoing work: rules, assessments, protection, testing, records, response, outreach | The written document describing that work | | CCCPH section | 3.1.3 | 3.1.4 | | Who sees it | Customers, testers, staff | Submitted to the State Water Board (your DDW District Office or Local Primacy Agency) for review | The program has ten required elements under Section 3.1.3(a): operating rules or ordinances, a program coordinator, hazard assessments, backflow prevention, certified testers and specialists, assembly testing, recordkeeping, backflow incident response, public outreach and education, and local entity coordination. The plan shows how each one is done. ## When is the plan due, and who reviews it? | Situation | Deadline or rule | Section | | -------------------------------------------------- | --------------------------------------------------------------------------------------- | ----------- | | Existing PWS (permitted on or before July 1, 2024) | No later than 12 months after the effective date, which was July 1, 2025 | 3.1.4(a)(1) | | New PWS | Submitted for review and approval before the domestic water supply permit is issued | 3.1.4(a)(2) | | Extension | Written request with the reason; approval is at the State Water Board’s sole discretion | 3.1.4(a)(3) | | Substantive revision | Submit the revised plan for review | 3.1.4(d) | | On request | Make the plan available to the State Water Board | 3.1.4(d) | The State Water Board’s FAQ says plans and extension requests go to the local DDW District Office or Local Primacy Agency. It also says the CCCPH sets content requirements only, with no required format, and that a plan may be a collection of existing and new documents if it is presented in a clear, organized way. The State Water Board has posted a fill-in plan template for small community systems with 201 to 999 connections; it states that using it does not guarantee approval. ## Who has to help write the plan? | System size | Requirement | Section | | --------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------- | | Any size | Designate at least one Cross-Connection Control Program Coordinator | 3.1.3(a)(2) | | 1,000 or more service connections | Develop the program in consultation with a certified cross-connection control specialist | 3.1.3(b) | | 3,000 or more service connections | Coordinator must be a certified specialist, and at least one specialist must be a permanent or contracted employee reachable (directly or through a designee) within one hour | 3.1.3(a)(2), 3.1.3(c) | The State Water Board can also require specialist involvement for smaller systems (Sections 3.1.3(b)(2) and (c)(2)). ## Checklist: the 13 required plan elements Use this as a working checklist. Section 3.1.4(b) applies to community water systems; Section 3.1.4(c) applies to noncommunity systems, with the differences noted. | # | Plan element | CCCPH section | Check | | -- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | --------------------- | ----- | | 1 | How the system will achieve and maintain compliance with **each** requirement in Chapter 3 (noncommunity: each applicable requirement) | 3.1.4(b)(1), (c)(1) | ☐ | | 2 | Process, personnel, and timeframes for initial **and** ongoing hazard assessments under Section 3.2.1 | 3.1.4(b)(2), (c)(2) | ☐ | | 3 | Legal authority under Section 3.1.3 for corrective action when a water user fails to comply | 3.1.4(b)(3), (c)(3) | ☐ | | 4 | Process and timeframes for inspecting and field testing each assembly, and inspecting each air gap, at least as often as required | 3.1.4(b)(4), (c)(4) | ☐ | | 5 | Process and timeframe for installing and maintaining non-testable backflow preventers under the system’s ownership or administration per the California Plumbing Code (noncommunity: those used for internal protection) | 3.1.4(b)(5), (c)(5) | ☐ | | 6 | Process for confirming tester qualifications: (A) tester certification, (B) test kit or gauge accuracy verification, (C) field test reports | 3.1.4(b)(6), (c)(6) | ☐ | | 7 | Procedures and timeframes for responding to backflow incidents, including customer notification and reporting under Section 3.5.2 | 3.1.4(b)(7), (c)(7) | ☐ | | 8 | Contact information for cross-connection personnel, including the coordinator and specialist (noncommunity: the coordinator) | 3.1.4(b)(8), (c)(8) | ☐ | | 9 | Tracking system with: (A) Section 3.5.1 records, (B) location and type of each assembly, (C) the highest threat potential hazard each assembly protects against (noncommunity also: location and type of each non-testable preventer used for internal protection) | 3.1.4(b)(9), (c)(9) | ☐ | | 10 | User supervisor information under Section 3.2.2(f), if user supervisors are used | 3.1.4(b)(10), (c)(10) | ☐ | | 11 | Corrective actions and timeframes when (A) the assembly does not match the hazard or none is installed, or (B) an assembly needs replacement or maintenance (noncommunity: includes non-testable preventers) | 3.1.4(b)(11), (c)(11) | ☐ | | 12 | Public outreach and education program under Section 3.1.3(a)(9) | 3.1.4(b)(12), (c)(12) | ☐ | | 13 | Procedures for coordinating with local entities (noncommunity examples: local health departments with internal programs, building and plumbing officials) | 3.1.4(b)(13), (c)(13) | ☐ | ## Checklist: plan content required by other sections These items are not in the Section 3.1.4 list, but other sections of the CCCPH say they belong in the plan. They are where we most often see gaps. | Item | What the plan must say | CCCPH section | Check | | --------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------- | ---------------------- | ----- | | Older hazard assessments | If assessments done before the CCCPH count as initial assessments, describe how you reviewed them | 3.2.1(d) | ☐ | | Periodic reassessment | The interval for periodic hazard reassessment (the CCCPH sets none, so the plan must) | 3.2.1(e)(5) | ☐ | | Initial assessment deadline (community) | A proposed and justified timeframe; the FAQ says there is no statewide date for community systems | 3.1.4(b)(2); FAQ | ☐ | | Swivel-ell | The use and operation of any swivel-ell at a recycled water use area | 3.2.2(d)(2) | ☐ | | Fire protection systems | Any proposed alternative date or method for existing fire systems that cannot get DC protection within ten years of July 1, 2024 | 3.2.2(e)(2) | ☐ | | User supervisor training | Training and qualification requirements, who provides the training, and recurring frequency | 3.2.2(f)(2) | ☐ | | Repair extensions | Any extension to the 30-day repair or replacement deadline for failed assemblies; extensions are allowed only if the plan includes them | 3.3.3(e) | ☐ | | Incident investigation | How complaints are considered as possible backflow, sampling and pressure recording, and documentation | 3.5.2(a)–(c) | ☐ | | Existing DCs at auxiliary supply sites | The testing and repair timeframe that an existing pre-July 1, 2024 DC must meet to stay in service | Appendix D, (+-+) note | ☐ | ## What records must the plan’s tracking system hold? Element 9 points to Section 3.5.1\. The tracking system has to hold: - the two most recent hazard assessments for each premises; - for each assembly: hazard or application, location, owner, type, manufacturer and model, size, installation date, and serial number; - for each air gap: hazard or application, location, owner, and as-built plans; - all assembly test, air gap inspection, and swivel-ell results for the previous three calendar years, with the tester’s name, test date, repair date, and certification number; - repairs, replacements, and relocations for the previous three calendar years; - the most current cross-connection tests, such as shutdown or dye tests; - user supervisor contacts and training, if used; - descriptions and follow-up of all backflow incidents; - a copy of any current contract for program work; - the current plan; and - outreach materials for the previous three calendar years. All of it must be available to the State Water Board on request (Section 3.5.1(b)). Spreadsheets struggle with this quickly. [Exodus Water Compliance](https://www.exoduswater.com/exodus-water-compliance) keeps assemblies, assessments, test reports, and notices in one record built around these fields. ## Which deadlines should the plan account for? | Date | What happens | Source | | ------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | --------------------------------- | | July 1, 2024 | CCCPH effective | CCCPH Section 1.3.1 | | July 1, 2025 | Plans due for existing systems | 3.1.4(a)(1) | | July 1, 2026 | Tester and specialist certification articles take effect | 3.4.1(g), 3.4.2(g) | | July 1, 2027 | Noncommunity initial or follow-up hazard assessments due; only testers and specialists certified by an ANAB-accredited body (or one in a mutual recognition arrangement with ANAB) qualify | 3.2.1(f), 3.4.1(d), 3.4.2(d); FAQ | | July 1, 2034 | Fire protection systems need at least DC protection (ten years after the effective date) | 3.2.2(e) | ## Common gaps we find in submitted plans - **Legal authority described but not adopted.** The FAQ allowed a draft at submittal, but the plan must explain the process and timeframe to finalize it. - **No periodic reassessment interval.** Section 3.2.1(e)(5) assumes the plan sets one. - **No residential method.** The FAQ allows GIS, building records, and customer surveys instead of a site visit at every home, but the plan should say how that works and when a physical visit follows. - **Specialist sign-off missing.** Every initial and follow-up assessment needs a specialist’s written finding (Section 3.2.1(h)). - **Repair extensions used without being in the plan.** Section 3.3.3(e) ties extensions to the plan. - **Plan out of date.** Section 3.1.4(d) requires the plan to represent current operations “at all times.” For the rest of the handbook, see our [CCCPH guide](https://www.exoduswater.com/post/cccph-explained) and [hazard assessment guide](https://www.exoduswater.com/post/cccph-hazard-assessments-what-water-systems-must-do) . ## How Exodus helps Exodus Water Services has prepared and revised Cross-Connection Control Plans for California water systems, including plans for San Bernardino County’s program, the City of Fillmore, the City of Eureka, the City of Gridley, and the California Institution for Women, and plans with supporting ordinances for both City of Port Hueneme systems ([proven work](https://www.exoduswater.com/services#proven-work) ). Our certified Cross-Connection Control Specialists work from Thousand Oaks and support systems [across California](https://www.exoduswater.com/california-coverage) . See [cross-connection control services](https://www.exoduswater.com/cross-connection-control) . ## Frequently asked questions **What is a cross-connection control plan?**It is the written document a California public water system submits to the State Water Board describing how its cross-connection control program complies with the CCCPH. Section 3.1.4 lists the 13 required elements. **When were cross-connection control plans due in California?**Existing public water systems had to submit plans no later than 12 months after the July 1, 2024 effective date, which was July 1, 2025\. New systems must have an approved plan before their permit is issued. Extensions were available on written request. **Is there a template for a cross-connection control plan?**The State Water Board posts a template for small community water systems with 201 to 999 connections. The FAQ says the CCCPH sets content requirements only, not a format, and DDW has not developed a template for all community systems. **Does a small water system need a cross-connection control specialist to write its plan?**Consultation with a specialist is required for systems with 1,000 or more connections, or when the State Water Board requires it. Every system still needs a specialist to review or conduct each initial and follow-up hazard assessment (Section 3.2.1(h)). **Do I have to resubmit my plan after changes?**Yes, if the revision is substantive. Section 3.1.4(d) requires the plan to represent current operations at all times and requires submittal of substantive revisions. **Does the April 2026 CCCPH revision require a new plan?**The revision did not add a plan element. It changed certification accreditation wording and Appendix D items 8 and 9\. Plans that cite Appendix D item 8 or 9, or that set rules for auxiliary water supply sites, should be checked against the new wording. **What is the difference between a cross-connection control program and a plan?**The program is the ongoing work required by Section 3.1.3\. The plan is the written description of that work required by Section 3.1.4. Last reviewed: October 30, 2026. ## Sources - State Water Board, [Cross-Connection Control Policy Handbook page](https://www.waterboards.ca.gov/drinking%5Fwater/certlic/drinkingwater/cccph.html) - State Water Board, [Cross-Connection Control Policy Handbook, April 2026 revision (PDF)](https://www.waterboards.ca.gov/drinking%5Fwater/certlic/drinkingwater/docs/2026/cross-connection-control-policy-handbook-apr-2026.pdf) : Sections 3.1.3, 3.1.4, 3.2.1, 3.2.2, 3.3.3, 3.4.1, 3.4.2, 3.5.1, 3.5.2, and Appendix D - State Water Board, [Water System FAQ for the CCCPH, updated June 27, 2025 (PDF)](https://www.waterboards.ca.gov/drinking%5Fwater/certlic/drinkingwater/docs/faq-cccph.pdf) - State Water Board, [Small Community Water System CCC Plan template, v3, February 2025 (PDF)](https://www.waterboards.ca.gov/drinking%5Fwater/certlic/drinkingwater/docs/2025/cccp-template-med-v3.pdf) - State Water Board, [Changes to the CCCPH, April 2026 change log (PDF)](https://www.waterboards.ca.gov/drinking%5Fwater/certlic/drinkingwater/docs/2026/april-2026-change-log.pdf) Want your plan checked against every element above before your next review? [Request a plan review](https://www.exoduswater.com/contact-us?service=ccc) or call (805) 991-7333. ## How Exodus can help - Related service [Cross-connection control services ](https://www.exoduswater.com/cross-connection-control) - Free tool [CCCP Readiness Assessment ](https://www.exoduswater.com/tools#cccp-assessment) [Request a Compliance Review](https://www.exoduswater.com/contact-us?service=ccc) [(805) 991-7333](tel:+18059917333) [Browse all articles](https://www.exoduswater.com/blog) Related service [Cross-connection control services](https://www.exoduswater.com/cross-connection-control)