Texas Commission on Environmental Quality (TCEQ) requires commercial properties with backflow prevention assemblies installed on public water systems to have those assemblies tested annually by a licensed Backflow Prevention Assembly Tester. The requirement is not optional. The deadline is not flexible. The documentation must be filed with the local water purveyor on a schedule the property operator controls.
For Dallas-Fort Worth commercial property operators, this guide covers what TCEQ requires, who performs the testing, what the documentation cycle looks like, and how facility management coordinates the program across multi-property portfolios. Proportional FM does not perform backflow testing; the licensed Backflow Prevention Assembly Tester does. This piece is about the coordination layer that keeps the testing on schedule and the documentation filed.
What TCEQ requires
Under Chapter 290 of the Texas Administrative Code (the Rules and Regulations for Public Water Systems), backflow prevention assemblies installed on a public water system in Texas must be tested at the time of installation, after any repair or relocation, and annually thereafter. The testing must be performed by a TCEQ-licensed Backflow Prevention Assembly Tester (BPAT).
The result of each test is filed with the local water purveyor. For most DFW commercial properties, the purveyor is the municipal water utility: Dallas Water Utilities, Fort Worth Water, Plano Public Works, Frisco Water, and so on. Each water utility maintains its own filing schedule, its own forms, and its own filing window after the test date.
If a property has multiple backflow prevention assemblies (irrigation system, fire suppression riser, food service equipment, medical or lab equipment), each device requires its own annual test and its own filing. The annual cycle compounds quickly across multi-property portfolios.
Failure to test or file by the required deadline can trigger disconnection of water service to the property, fines, and downstream operational impact for any tenant or operation depending on continuous water supply.
Who performs the testing
BPAT testing is performed by a Backflow Prevention Assembly Tester licensed by TCEQ. The license is held by an individual, not a company. A property cannot have its facility manager, property manager, or general handyman perform the annual test, regardless of how qualified those roles may be in other facility scopes. The TCEQ license is the gatekeeper.
Most BPATs operate either as employees of plumbing companies that hold themselves out for the work, or as independent licensed testers. Both are acceptable. Pricing varies by region, by the type of device, and by whether testing is scheduled in advance or scheduled as a rush. Annual cadence scheduling is materially less expensive than rush scheduling.
The licensed tester completes the test, generates the standardized BPAT report, and provides the report to the property operator. The operator (or the operator's facility manager) is responsible for filing the report with the appropriate water utility. The licensed tester does not always file on the property's behalf; that step is the property operator's obligation.
The documentation cycle
The annual cycle has three checkpoints that facility management coordinates.
Scheduling. The next-year test should be scheduled at the time the current-year report is filed. The annual anniversary of the prior test is the safest target date. Sliding the schedule earlier in the year, rather than later, builds a margin for any retesting that becomes necessary after a failed test.
Performance. The licensed BPAT arrives, performs the test, generates the report, and confirms the assembly is functioning. If the device fails, repair or replacement is required before retesting and filing.
Filing. The report is filed with the water utility within the utility's required window, typically 30 to 60 days from the test date. Each utility has its own form, its own filing portal, and its own deadline. Multi-property operators with assemblies in different DFW jurisdictions deal with multiple filing portals and schedules running on different annual clocks.
How facility management coordinates the program
Proportional FM coordinates the backflow testing program without performing the licensed test work itself. The coordination scope covers:
- Inventory tracking of every backflow prevention assembly on the property or across the portfolio, including device type, install date, and last-test date
- Scheduling the licensed BPAT visit at the right point in the annual cycle
- Receiving the BPAT report from the licensed tester
- Filing the report with the relevant water utility within the utility's required window
- Maintaining the documented record for the operator's compliance file
- Surfacing retest requirements if a device fails the annual test
The licensed test work itself is performed by a BPAT held by an individual licensed by TCEQ. Proportional FM does not perform the test, the repair, or the replacement of any backflow prevention assembly.
For multi-property operators with assemblies in different DFW jurisdictions (Dallas, Fort Worth, Plano, Frisco, Irving, Arlington, and the surrounding metroplex), the coordination layer is what keeps the testing on schedule across jurisdictions running different filing systems and different deadlines. A single point of accountability replaces a scattered set of annual reminders the operator otherwise tracks personally.
Where compliance and facility management intersect
Backflow preventer testing sits at the intersection of compliance and facility management. The compliance obligation is the operator's. The facility management role is to ensure the obligation is met on schedule, by the right party, and with the documentation filed correctly. The two roles are complementary; neither one substitutes for the other.
For a single-property operator, the testing cycle is manageable internally if the operator builds and maintains the cadence. For a multi-property operator, the coordination overhead compounds with portfolio size: ten assemblies across five properties in three DFW jurisdictions is ten separate annual cycles, ten test schedules, and three filing systems. The structured cadence, integrated into the broader Facility Condition Assessment cycle, is what keeps the program from drifting.
