If you manage a small public water system in Mississippi, you already know that “compliance” is a word that carries a lot of weight. Whether you are overseeing a rural water association, a mobile home park, a church well for a daycare, or a small municipal system, you are bound by the Revised Total Coliform Rule (RTCR).
The RTCR is not a suggestion; it is a federal requirement. Failing to meet its standards leads to more than just paperwork. It can result in monitoring violations, mandatory public notices, and “acute” violations that require you to notify every customer within 24 hours.
At Bonner Analytical Testing Company, we’ve seen how stressful these regulations can be for operators who are already spread thin. This guide breaks down the rules’ requirements and explains what South Mississippi operators need to do to stay compliant, especially as regional lab options continue to change.
What Exactly Is the Revised Total Coliform Rule (RTCR)?
The Total Coliform Rule (TCR) was first published by the EPA in 1989 and became enforceable in 1990. It set health goals and legal limits for coliform bacteria in drinking water and required every public water system to monitor total coliforms in its distribution system on a schedule scaled to the population it serves.
The Revised Total Coliform Rule (RTCR) replaced the original TCR effective April 1, 2016. The revision was published in the Federal Register on February 13, 2013, with minor corrections in 2014. Every public water system except those covered by the Aircraft Drinking Water Rule must now comply with the RTCR.
The rule is a National Primary Drinking Water Regulation, which means it’s enforceable under the Safe Drinking Water Act. In Mississippi, the Mississippi State Department of Health (MSDH) is the primary agency, meaning MSDH implements and enforces the RTCR on behalf of the EPA within the state.
Does This Rule Apply to You?
Many facility owners are surprised to learn they qualify as a “Public Water System” (PWS). You fall under these regulations if your system:
15+
service connections
25 people
served regularly for 60+ days/year
This includes more than just city utilities — schools with private wells, RV campgrounds, bed-and-breakfasts, and even some restaurants. If you meet those numbers, the RTCR applies to you.
The 8 Core Requirements for Compliance
1
Maintain a Sample Siting Plan
Bonner provides sterile, parameter-appropriate sample containers. You cannot use a random bottle — bacteriological sampling requires a sterile, properly preserved container to produce valid results.
2
Routine Sampling on Schedule
The number of samples you need depends on the population you serve. For very small systems, this might be monthly or quarterly. The key is consistency. Samples must be collected by trained personnel and sent to a certified lab like ours in Hattiesburg.
3
Simultaneous Testing (Total Coliform and E. coli)
One of the more efficient parts of the RTCR is that a single 100ml sample is tested for both Total Coliform and E. coli at once. The lab incubates the sample for 18 to 24 hours. If it glows under UV light, it’s positive for E. coli. You don’t need to send a second sample for the E. coli check; we handle that entire workflow on the original bottle you provide.
4
The 24-Hour Repeat Sample Rule
If a routine sample comes back positive for total coliform, the clock starts. You have exactly 24 hours to collect at least three repeat samples. Usually, you’ll take one at the original site, one upstream, and one downstream.
5
Follow-Up Sampling
If you are on a quarterly or annual schedule and get a positive result, you typically have to collect additional routine samples the following month. This ensures the fix you implemented actually worked.
6
Level 1 and Level 2 Assessments
Under the old rules, a positive coliform test was an automatic violation. Now, it triggers a “Find and Fix” protocol:
- Level 1 Assessment: A self-examination of the system to find the source of the problem.
- Level 2 Assessment: A more intensive investigation, usually conducted by the state, triggered by more serious issues like an E. coli positive.
7
Public Notification
If you hit an E. coli limit, you have 24 hours to tell the public (Tier 1). For less urgent monitoring issues, you have up to 30 days (Tier 2) or a mention in your annual report (Tier 3).
8
Seasonal Start-Up Procedures
If you run a seasonal campground or youth camp that shuts down for the winter, you must follow a state-approved start-up procedure and certify it with the MSDH before turning the taps on for the season.
What Triggers an Acute Violation?
The most serious situation is an Acute MCL Violation for E. coli. This happens if:
- A routine sample is total coliform-positive AND a repeat sample is E. coli-positive
- A routine sample is E. coli-positive AND any repeat sample is total coliform-positive
- The system fails to take all required repeat samples after an E. coli-positive routine sample
- The system fails to test for E. coli when required after a total coliform-positive repeat sample
Acute MCL violations require Tier 1 public notification within 24 hours. They are the most serious violations under the rule.
What Operators Get Wrong
A few patterns show up repeatedly in small system compliance issues:
- Sampling from undocumented locations — using a tap that isn't listed in the siting plan
- Missing the 24-hour repeat sample window — samples collected late or sent to a lab too far away to meet holding times
- Poor sample collection technique — contaminating the sample and producing a false positive
- Missing the seasonal start-up procedure for systems that go offline part of the year
- Not having a backup plan when the primary lab is unavailable — leaving a positive sample sitting too long
That last one has gotten more pressing in South Mississippi recently. With certified lab capacity in the region shifting, operators who don’t already have a contingency plan in place are most at risk of missing repeat-sample windows and triggering avoidable violations.
Where to Send Your RTCR Samples
To stay compliant, your lab must be MSDH-certified. Bonner Analytical Testing Company (BATCO) has been a fixture in South Mississippi since 1981. We understand the local geography and the specific pressures Mississippi operators face.
Our Credentials:
MSDH Certified
Microbiology
EPA ID
MS00013
USEPA CLP
Certified
We work with municipal systems and private well owners across the Jackson metro, the Pine Belt, and the Gulf Coast.
Don’t wait for a positive result to find a lab. Having a relationship with a certified lab ahead of time ensures you have the right bottles on hand and a direct line to a technician when time is of the essence.
Bonner Analytical Testing Company 2703 Oak Grove Road Hattiesburg, MS 39402
The RTCR is a complex regulation, but you don’t have to navigate it alone. Reliable testing is the foundation of a safe water system, and we are here to provide that foundation for South Mississippi.