Operator of Record Requirements for Small California Water Systems

For a small water system, the certified operator is often one person. When that person retires, takes another job, or lets a certificate lapse, the system can fall out of compliance on the same day. Board members and managers of small systems are often the last to learn the rules, because the rules were always handled by the operator.

This guide covers what California requires: who needs a certificate, how the required grade is set, how certificates stay valid, and the options when your system needs a qualified operator.

The term “operator of record”

California’s regulations do not use the phrase “operator of record.” The Drinking Water Operator Certification Program regulations (California Code of Regulations, Title 22, Division 4, Chapter 13, starting at Section 63750.10) use two defined roles:

• Chief operator: the person with overall responsibility for the day-to-day, hands-on operation of a water treatment plant or water distribution system.
• Shift operator: the person in direct charge of operating a treatment plant or distribution system for a specified period of the day.

When the industry says “operator of record,” it usually means the certified chief operator a system relies on to meet these requirements, whether that person is on staff or under contract.

Who needs a certificate

According to the State Water Board’s Office of Operator Certification (OOC) guidance, anyone who operates a water distribution system must hold a valid, unexpired water distribution operator certificate. Anyone who operates a water treatment plant must hold a valid, unexpired water treatment operator certificate.

“Operating” is defined broadly. For a distribution system it includes decisions that control the quality or quantity of drinking water, including supervising others. Title 22 Section 63770 lists activities that may only be decided by certified distribution operators, including:

• installing, tapping, disinfecting, testing, and connecting water mains;
• shutting down, repairing, disinfecting, and testing broken mains;
• overseeing flushing and cleaning of mains;
• pulling, resetting, rehabilitating, disinfecting, and testing domestic wells;
• stand-by emergency response for after-hours distribution emergencies; and
• draining, cleaning, disinfecting, and maintaining distribution reservoirs.

The same section allows certified distribution operators or trained certified treatment operators to make decisions on pump and pressure operations, chemical dosing for wellhead disinfection and residual maintenance, and investigating distribution water quality problems.

How the required grade is set

The grade your chief operator needs depends on how your system is classified.

Distribution systems are classified D1 through D5. Under Title 22 Section 64413.3, the distribution system of each community and nontransient-noncommunity water system is classified by population served, with a point system that can move a system up one class for factors such as multiple pressure zones, disinfectant application in the distribution system, pump size, number of storage reservoirs, uncovered reservoirs, and customers also served by a non-potable system. Your system’s classification appears on your permit or classification letter from the Division of Drinking Water (DDW).

Treatment plants are classified T1 through T5 under separate rules (Title 22 Section 64413.1).

Once you know your class, the minimums are set out in Title 22 Section 63770 (distribution) and 63765 (treatment). The OOC guidance summarizes them:

• The chief operator must hold a certificate equal to or greater than the system’s classification.
• Shift operators at a D4 system or lower may hold a certificate no more than one grade lower than the classification. At a D5 system, shift operators may be up to two grades lower.
• Everyone else who conducts operations at the system must also hold a valid certificate.

For a small D1 or D2 distribution system, that means the chief operator needs at least a D1 or D2 certificate respectively. Systems with treatment need to meet the treatment plant requirements as well.

Keeping certificates valid

The OOC guidance is direct on renewal:

• Certificates are valid for three years.
• Renewal is the operator’s responsibility, whether or not they receive a notice. OOC generally sends a courtesy reminder about six months before expiration.
• To renew, the operator submits the renewal application, the fee, and proof of continuing education completed during the certificate period.
• Required contact hours are 12 hours for Grade 1, 16 for Grade 2, 24 for Grade 3, and 36 for Grades 4 and 5, with no more than 25 percent safety-related.
• Operators cannot legally operate with an expired certificate. A certificate not renewed within one year of expiration can no longer be renewed, and the person must pass the examination again.

Renewal forms and fees are due 120 days before the certificate expires (State Water Board Operator Certification FAQ). Send contact hours with the renewal; if they arrive less than 45 days before expiration, the state may not have time to process the renewal before the certificate lapses.

A simple safeguard for any small system: keep a list of every certified person, their grade, and their expiration date, and review it at each board meeting.

Why this matters to the system, not just the operator

The OOC guidance notes that operating without an appropriate, valid certificate is a misdemeanor and may carry civil liability. It also states that owners or permittees, and supervising operators including chief operators, who permit an uncertified person to operate a distribution system or treatment plant may also be liable.

In other words, a lapsed certificate is the system’s problem. It is not something a board can leave to the operator alone.

Getting new operators started

For small systems trying to grow their own operators, the education rules have a useful path. For water distribution and water treatment operator Grades 1 and 2, the high school diploma requirement can also be met by passing the State Water Board’s Basic Small Water Systems Operations Examination, or by one year of qualifying experience. Higher grades require specialized coursework and experience at the right grade and system classification.

When your chief operator leaves

If your system loses its chief operator, or the certificate lapses, work through these steps quickly:

1. Confirm your classification. Pull your permit or classification letter so you know exactly which grade you need.
2. Check who else is certified. A shift operator or another staff member may already hold the required grade.
3. Arrange qualified coverage. Many small systems contract a certified operator to serve as chief operator, either for a transition period or long term. Check whether your permit carries any staffing or notification conditions when the chief operator changes.
4. Talk to your DDW district office. Your district engineer can tell you what your permit requires and what documentation they expect.
5. Fix the records. Make sure monitoring, sampling, and reporting tasks the departing operator handled are assigned and on a calendar.

Plan around the deadlines

The free Compliance Deadline Checker on the Exodus tools page covers operator certification alongside your other California deadlines, so a renewal does not get lost among sampling and reporting dates.

Exodus provides a qualified, appropriately graded operator of record to satisfy DDW staffing requirements, along with supplemental certified operator support during startup, transitions, or peak demand. See Operator of Record services for details, or contact us if your system needs coverage now.