xvEPA
Draft Technical Guidance
Manual for the Proposed
Aircraft Drinking Water Rule
(ADWR)
July 2008
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Office of Water (4606M)
EPA 816-D-08-003
June 2008
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Purpose of this Document
This document provides guidance and contains EPA's current policy
recommendations for complying with the Aircraft Drinking Water Rule, to the extent
that it is finalized as proposed.
The statutory provisions and the final regulations described in this document contain
legally binding requirements. This document is not a regulation itself, nor does it
change or substitute for those provisions and regulations. Thus, it does not impose
legally binding requirements on EPA or public water systems. This guidance does not
confer legal rights or impose legal obligations upon any member of the public.
While EPA has made every effort to ensure the accuracy of the discussion in this
guidance, the obligations of the regulated community are determined by statutes,
regulations, or other legally binding requirements. In the event of a conflict between
the discussion in this document and any stature or regulation, this document would not
be controlling.
The general description provided here may not apply to a particular situation based
upon the circumstances. Interested parties are free to raise questions and objections
about the substance of this guidance and the appropriateness of the application of this
guidance to a particular situation. EPA and other decision makers retain the discretion
to adopt approaches on a case-by-case basis that differ from those described in this
guidance, where appropriate.
Mention of trade names or commercial products does not constitute endorsement or
recommendation for their use.
This is a living document and may be revised periodically without public notice. EPA
welcomes public input on this document at any time. Guidance provided in this
document reflects provisions of the proposed rule published April 9, 2008 at 73 FR
19320 and will be revised to reflect the provisions in the final rule after it is issued.
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Table of Contents
CHAPTER 1 INTRODUCTION 1
1.1 Purpose, Applicability, and General Requirements of the Proposed Aircraft
Drinking Water Rule 1
1.2 Intended Use of this Document 3
1.3 Intended Audience for this Document 3
1.4 Outline of this Document 4
CHAPTER2 OVERVIEW OF THE RULE 6
2.1 What is an Aircraft Public Water System? 6
2.7.7 Types of Public Water Systems 6
2.7.2 Components of Aircraft Public Water Systems 6
2.2 Public Health Protection and the Aircraft Drinking Water Rule 8
2.2.7 Public Health Threats Addressed by the Rule 8
2.2.2 ADWR Public Health Protection Measures 10
2.3 Compliance Dates and Requirements 10
CHAPTERS AIRCRAFT INVENTORY 14
3.1 Identifying Aircraft Public Water Systems 14
3.2 Reporting Existing Inventory Information 15
3.2.7 Inventory Details 15
3.2.2 Inventory Reporting Format and Procedure 16
3.3 Reporting Inventory Updates 16
CHAPTER 4 COLIFORM MONITORING 17
4.1 Overview of Coliform Sampling 17
¥.7.7 Types of Coliform Samples 17
¥.7.2 Sequence of Coliform Sampling 18
4.2 Coliform Sampling Plans 20
4.3 Sampling Frequencies 22
4.4 Suggested Sampling Protocol 22
4.4.1 Materials and Preparation for Sampling 22
4.4.2 Sample Collection 23
4.5 Certified Laboratories and Analytical Methods 24
¥.5.7 Analytical Methods 24
¥.5.2 Sample Invalidation 24
4.6 Reporting Sampling Results 25
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CHAPTERS OPERATIONS AND MAINTENANCE PLANS 27
5.1 Overview of Requirements and Timeframes 27
5.2 Routine and Corrective Disinfection and Flushing 29
5.3 Training of Personnel 31
5.4 Procedures for Conducting Self-Inspections 32
5.5 Practices and Procedures for Boarding Water 33
5.5.7 Routine Practices 33
5.5.2 Procedures for When Water of Unknown Quality or Contaminated Water
Must be Boarded 35
CHAPTER 6 PUBLIC NOTIFICATION 36
6.1 Purpose of Public Notification 36
6.2 Notification of Passengers and Crew 36
6.2.1 Public Notice Methods and Timing 37
6.2.2 Public Notice Format and Content 38
6.3 Required Language for Public Notification 39
6.3.1 Detection of total coliforms only (not fecal coliforms or E. coli) 39
6.3.2 Routine or Repeat Sample Positive for E. coli or Fecal Coliform 40
6.3.3 Failure to Monitor, Improper Testing Procedures, or Failure to Disinfect
and Flush 40
6.4 Public Address Announcement for Positive E. coli Samples 40
CHAPTER 7 RECORDKEEPING AND REPORTING 42
7.1 Air Carrier Recordkeeping 42
7.2 Reporting Requirements 43
7.2.7 Coliform Sampling and O&MPlans 43
7.2.2 Aircraft Inventory 44
7.2.3 Coliform Sampling Re suits and Violations 44
7.2.4 Self-Inspection and Compliance Audit Results 44
CHAPTER 8 VIOLATIONS OF THE RULE 46
CHAPTER 9 SUGGESTED ENGINEERING AND MANAGEMENT PRACTICES. 49
9.1 Maintaining Water Quality 49
9.2 Considerations for Supplemental Treatment 50
9.3 Considerations for Supplemental Operator Training and Maintenance 51
9.4 Considerations for Supplemental Recordkeeping 51
REFERENCES 53
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List of Tables
Table 2.1 Rule Components and Compliance Dates 10
Table 4.1. Coliform Sampling Frequencies Based on Disinfection and Flushing
Frequencies 22
Table 5.1 Typical Disinfectants Used for Aircraft Water Systems 29
List of Exhibits
Exhibit 2.1 Aircraft Onboard Water System 7
Exhibit 2.2 Potential Contamination Pathways within the Aircraft Water System
Supply and Transfer Chain 9
Exhibit 4.1 Overview of Coliform Monitoring Requirements 19
Exhibit 7.1 Example Format for Disinfection and Flushing Records 43
Exhibit 8.1 Violations of the ADWR 47
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Acronyms and Abbreviations
ADWR
ANSI
AOC
ATA
BMP
CDC
CFR
CRMP
CWS
DBF
EPA
E. coli
FAA
FDA
FR
GWS
GWUDI
HACCP
ICC
ICR
IESWTR
LIMS
Aircraft Drinking Water Rule
American National Standards Institute
Administrative Order on Consent
Air Transport Association
Best Management Practice
Centers for Disease Control and Prevention
Code of Federal Regulations
Comprehensive Representative Monitoring Plan
Community Water System
Disinfection Byproducts
United States Environmental Protection Agency
Escherichia coli
United States Federal Aviation Administration
United States Food and Drug Administration
Federal Register
Ground Water System
Ground Water Under the Direct Influence of Surface Water
Hazard Analysis Critical Control Point
Interstate Carrier Conveyance
Information Collection Request
Interim Enhanced Surface Water Treatment Rule
Laboratory Information Management System
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mL Milliliters
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
MRDL Maximum Residual Disinfectant Level
mg/L Milligrams per Liter
NAICS National American Industry Classification System
NATA National Air Transportation Association
NASA National Aeronautics and Space Administration
NCWS Non-Community Water System
NOW AC National Drinking Water Advisory Council
NO V Noti ce of Vi ol ati on
NPDWR National Primary Drinking Water Regulation
NSF NSF International
NTNCWS Non-Transient Non-Community Water System
NTTAA National Technology Transfer and Advancement Act
O&M Operations and Maintenance
OMB Office of Management and Budget
PN Public Notification
ppm Parts per Million
PWS Public Water System
QAPP Quality Assurance Proj ect Plan
RFA Regulatory Flexibility Act
SBA Small Business Administration
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SDWA
SDWIS
SWTR
TC
TCR
TNCWS
TT
UMRA
WHO
WSG
WSP
Safe Drinking Water Act
Safe Drinking Water Information System
Surface Water Treatment Rule
Total Coliform
Total Coliform Rule
Transient Non-Community Water System
Treatment Technique
Unfunded Mandates Reform Act
World Health Organization
Water Supply Guidance
Water Safety Plan
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Chapter 1 Introduction
1.1 Purpose, Applicability, and General Requirements of the
Proposed Aircraft Drinking Water Rule
The primary purpose of the proposed Aircraft Drinking Water Rule (ADWR) is to ensure
that safe and reliable drinking water is provided to aircraft passengers and crew. This
entails providing air carriers with a feasible way to comply with National Primary
Drinking Water Regulations (NPDWRs) under the Safe Drinking Water Act (SOWA).
Water provided onboard aircraft through lavatory and galley faucets must meet standards
for human consumption, which includes uses such as washing face or hands; brushing
teeth; consuming coffee, tea, or other beverages made with onboard water; and drinking
the water from galley or lavatory water taps. Thus, even if passengers and crew are
provided bottled water for drinking, water from aircraft lavatory taps must still meet
drinking water standards.
Safe drinking water regulations that pertain to traditional stationary public water systems
have proven difficult for owners and operators of aircraft to implement due to the unique
characteristics of their water systems. For example, aircraft fly to multiple destinations
over the course of one day and may board drinking water at many of these destinations.
Because aircraft board water from airport watering points via temporary connections,
aircraft drinking water quality depends on a number of factors, including the quality of
the water boarded from each source, the care used to board the water, and the operation
and maintenance (O&M) of the onboard water system and the water transfer equipment
(such as water cabinets, trucks, carts, and hoses). To address these challenges, EPA is
amending the NPDWRs through the ADWR and has prepared this guidance document.
The proposed ADWR applies to all aircraft water systems that board only finished water,
provide piped water for human consumption, and meet all of the following criteria:
• Aircraft that regularly serve an average of at least 25 or more individuals daily at least
60 days out of the year.
By definition, a public water system regularly serves an average of at least 25 or
more individuals daily at least 60 days out of the year [40 CFR 141.2]. If the
aircraft does not operate at least 60 days each year, or if it does not regularly serve
an average of at least 25 people daily at least 60 days in a year, the aircraft would
not be a PWS. The 25-person minimum includes the total number of passengers
and crew for all of the flights in a day.
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• Aircraft with a galley or a qualifying lavatory.
A qualifying lavatory is defined as a private room with a flushing toilet and sink.
Curtained-off toilet seats without lavatory sinks (as seen in some small, short-
range aircraft) are not considered a qualifying lavatory. An aircraft need only
have a galley or a qualifying lavatory to meet this criterion.
• Aircraft that fly domestic routes between two or more U. S. locations.
• Aircraft used for passenger conveyance in interstate commerce.
The SDWA and NPDWRs exclude from regulation public water systems that:
consist only of distribution and storage facilities and do not have any collection
and treatment facilities; obtain all water from, but are not owned or operated by, a
public water system; do not sell water to any person; and are not a carrier which
conveys passengers in interstate commerce [40 CFR 141.3]. If the other
exclusion criteria described above are met, the proposed ADWR and other
NPDWRs do not apply to aircraft used solely for cargo purposes because they do
not convey passengers in interstate commerce.
The proposed requirements of the ADWR are detailed later in this guidance manual. In
general terms, the proposed ADWR seeks to protect the quality of drinking water
onboard aircraft public water systems by requiring:
• Routine disinfection and flushing of the aircraft water system at a minimum
frequency as specified by manufacturers' guidelines. Where manufacturers do not
specify a frequency, the proposed rule will require quarterly disinfection and flushing.
• Routine monitoring for total coliform bacteria at aircraft water system taps, at
frequencies ranging from monthly to annually, depending on the routine disinfection
and flushing frequency.
• Updated aircraft water system operations and maintenance (O&M) plans, which must
be incorporated into the air carriers' FAA-approved or accepted O&M program for
aircraft. The O&M plans must include a plan for sampling coliform bacteria and
performing routine disinfection and flushing, among other requirements.
• Analysis of total coliform-positive samples for the presence of fecal coliform or
Escherichia coli (E. coli).
• Options to conduct either disinfection and flushing of the aircraft water system or
repeat monitoring for total coliform bacteria (in some cases) when routine samples
contain total coliform.
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• Corrective disinfection and flushing of the aircraft water system under some
circumstances.
• Follow-up sampling and analysis for total coliform to confirm the effectiveness of
corrective disinfection and flushing.
• Public notification for violations including failure to disinfect and flush, a fecal
coliform/E1. co//'-positive sample, or failure to monitor for total coliform.
• Comprehensive self-inspection of each aircraft's water system components no less
than every 5 years.
• Compliance audits at an interval determined by the United States Environmental
Protection Agency (EPA).
• Reporting and recordkeeping associated with the activities described above.
1.2 Intended Use of this Document
This guidance is intended to help facilitate compliance with and implementation of the
requirements of the ADWR when final. It explains the applicability of the rule to aircraft
water systems and describes the rule requirements. It also recommends sampling
procedures that ensure accurate sampling results and maintenance procedures that help
preserve good water quality onboard the aircraft. This manual also provides templates for
the various public notices required by the proposed rule. While the rule will not be in
effect until it is final, this guidance is intended to explain the provisions in the proposed
rule and how it will likely be implemented if finalized as proposed. EPA will update and
revise this guidance document, prior to issuance, to reflect the text of the final rule.
While EPA has made every effort to ensure the accuracy of the discussion in this
document, the obligations of the regulated community are determined by statutes,
regulations, or other legally binding requirements. In the event of a conflict between the
discussion in this document and any statute or regulation, this document would not be
controlling.
1.3 Intended Audience for this Document
This manual is intended for aircraft industry professionals and air carrier employees who
need to be familiar with the proposed rule requirements. This may include air carrier and
airport owners and managers, pilots, flight attendants, fixed based operators, and
maintenance staff.
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1.4 Outline of this Document
The guidance manual is organized as follows:
Chapter 1. Introduction - Explains the purpose of this manual.
Chapter 2. Overview of the Aircraft Drinking Water Rule - Describes rule requirements
and compliance dates, as well as key background information.
Chapter 3. Aircraft Inventory - Explains recordkeeping requirements related to aircraft
inventory.
Chapter 4. Coliform Monitoring - Describes coliform monitoring requirements including
monitoring plan content, sampling locations, sampling frequency, sampling protocol,
analytical methods, and reporting requirements. The chapter also discusses repeat
sampling activities.
Chapter 5. Operations and Maintenance Plans - Discusses the requirements for an
operations and maintenance (O&M) plan, conducting routine disinfection and flushing,
performing water system inspections, and training personnel on the public health
implications of their activities regarding the water system and how to perform aircraft
water system O&M.
Chapter 6. Public Notification - Describes public notice requirements including methods,
timing, format, and required language.
Chapter 7. Recordkeeping and Reporting - Describes the requirements for reporting
information to the EPA, including inventory information and compliance data, and
internal recordkeeping requirements for the air carriers.
Chapter 8. Violations of the Rule - Summarizes rule violations and corrective actions for
returning to compliance.
Chapter 9. Suggested Engineering and Management Practices - Describes proactive
measures that are above and beyond regulatory requirements and that may contribute
additional protection to obtaining and maintaining drinking water quality. Topics include
recordkeeping for boarding water, disinfectant residual monitoring, booster disinfection,
biofilm management, and supplemental treatment options.
References. Provides a bibliographic list of references cited in this manual.
Appendix A. Proposed Rule Language - The proposed rule as published in the Federal
Register. [NOT INCLUDED IN THIS VERSION OF THE DOCUMENT]
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Appendix B. Public Notification Templates - Provides example language for various
public notices required as a result of a rule violation. [NOT INCLUDED IN THIS
VERSION OF THE DOCUMENT]
Appendix C. Quick Reference Guide - A stand-alone fact sheet that summarizes rule
requirements and key background information. [NOT INCLUDED IN THIS VERSION
OF THE DOCUMENT]
Appendix D. Aircraft Self-Inspection Guide - Provides a discussion of the essential
elements of an aircraft self-inspection and includes an example checklist for a self-
inspection procedure. [NOT INCLUDED IN THIS VERSION OF THE DOCUMENT]
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Chapter 2 Overview of the Rule
2.1 What is an Aircraft Public Water System?
2.1.1 Types of Public Water Systems
The National Primary Drinking Water Regulations (NPDWRs) define a public water
system (PWS) as a system for providing piped water for human consumption to the
public that regularly serves an average of at least 25 individuals daily, at least 60 days per
year [40 CFR 141.2]. All public water systems are subject to the NPDWRs unless they
are exempted by the Safe Drinking Water Act (SOWA) Section 1411. Section 1411
excludes from regulation any PWS that receives all its water from another regulated
PWS, does not sell or treat the water, and is not a "carrier which conveys passengers in
interstate commerce." Thus, because aircraft involved in interstate commerce are not
exempt from the SOW A, they are regulated public water systems. This applicability
requirement is also found in 40 CFR 141.3. The classes of ICCs include aircraft, trains,
buses, and water vessels.
PWSs are subject to different subsets of the NPDWRs based on the type of population
they serve. The two main subsets are community water systems and non-community
water systems. Community water systems primarily serve residential populations; non-
community systems primarily serve nonresidential users. Non-community water systems
are further divided based on whether they regularly serve the same people for more than
6 months per year, such as schools or workers at a business or industry. If the same
people are served, the system is classified as a non-transient non-community water
system (NTNCWS). If different people are served, as occurs at restaurants or highway
rest stops, the system is classified as a transient non-community water system (TNCWS).
Aircraft public water systems are regulated as TNCWSs because they are non-community
water systems that do not regularly serve at least 25 of the same people over six months
per year. Because TNCWSs serve a transient population, they are subject only to
regulations that address acute health effects resulting from short term exposure. Acute
health effects are impacts on health which occur over a short period of time after
exposure to the contaminant. The ADWR is designed to address such health risks.
2.1.2 Components of Aircraft Public Water Systems
The ADWR applies to the onboard water system only. The components of an aircraft
water system include the water service panel, the filler neck of the aircraft finished water
storage tank, the onboard water storage tank(s), piping, treatment equipment, galley and
lavatory faucets, galley coffee makers, and any other plumbing fixtures that supply water
to passengers or crew. A schematic of an aircraft water system is shown in Exhibit 2.1.
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TO WATER USING
FACILITIES
WATER QUANTITY
TRANSMITTER
LEGEND
POTABLE WATER
AIR PRESSURE
Exhibit 2.1 Aircraft Onboard Water System
Water is supplied to the aircraft through a fill port. Water is drained from the water
system through a drain port on the underbelly of the aircraft. The water system may be
pressurized using bleed air from the operation of the aircraft engines or an on-demand
electric pump.
Aircraft water systems vary depending on the type of aircraft. Onboard storage tank
capacity varies from 5 gallons in a regional jet to 360 gallons in a Boeing 777. Various
piping configurations in the galley may include separate lines for the sink and a hot water
tap located on the coffee maker. Some aircraft have carbon filters on the supply line to
the coffee makers, which should be replaced according to the manufacturer's
recommendations.
The aircraft water system may also include some protective devices to meet sanitation
requirements, such as air filters in bleed-air lines and at compressor inlets for protection
from contaminants; self-venting valves in galley and lavatory supply lines to help drain
the system; and air gaps between the water supply and the drain system.
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Many aircraft have two separate water systems - one in the forward section of the aircraft
for a galley and a lavatory, and one system in the rear of the aircraft for a galley and/or
lavatory. The ADWR requirements apply to each aircraft, regardless of the number of
separate water systems on board. Chapter 4 describes suggested coliform sampling plans
for aircraft with more than one onboard water system.
2.2 Public Health Protection and the Aircraft Drinking Water
Rule
2.2.1 Public Health Threats Addressed by the Rule
Aircraft water systems that are subject to this rule board finished water (water that
requires no further treatment) from a public water system owned either by the airport or
the city that serves the airport. Finished water from a regulated PWS is delivered to the
airport terminals and is accessible to aircraft and water service providers at watering
points approved by the Food and Drug Administration (FDA) [21 CFR 1240.80]. Water
is transferred to the aircraft storage tank either by a direct hose connection from a water
cabinet mounted on the terminal building or a mobile truck or cart, depending on the
aircraft's relative location to the watering point. Small aircraft such as regional jets may
not have a service port for filling the onboard storage tank. Instead, these aircraft water
systems are equipped with a removable tank (usually 5 gallons) that is refilled at the
airport's catering facility.
The ADWR seeks to protect against disease-causing microbiological contaminants or
pathogens in the drinking water of the onboard water system. Microbiological
contamination is a concern because it can occur during the water boarding process if
there are problems with the watering point hoses, water transfer equipment, or the
sanitary practices employed. Contamination can also occur if an aircraft boards water in a
country that has less stringent drinking water standards, or if an aircraft boards water
from an airport whose drinking water source is a domestic PWS that is in violation of the
drinking water standards. Water quality can also deteriorate if water is held in the
airport's distribution system or in the aircraft's water system for too long. As the water
ages, coliform bacteria and other bacteria, although generally harmless, can accumulate
on pipe and storage tank interior surfaces forming biofilm, a layer of microorganisms that
can provide shelter for pathogens if they enter the system.
Because aircraft are transient non-community public water systems, only contaminants
that cause acute health effects are of concern. An acute health effect is a brief and severe
onset of illness after short-term exposure. Chemicals contaminants that can cause acute
health effects include nitrate, nitrite, and high levels of chlorine dioxide. The ADWR
assumes chemical contaminants are addressed by the PWS from which finished water is
boarded and does not require aircraft to monitor for them. Since finished water is water
that is ready for human consumption without further treatment, it must meet all
regulatory requirements pertaining to contaminants. An aircraft must, however, provide
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public notification and corrective action if water is boarded that is in violation of a
drinking water standard. This situation may occur if the aircraft must board water and the
only available water is known to violate a NPDWR.
EPA defers to the FDA with respect to regulating watering points such as water cabinets,
carts, trucks, and hoses from which aircraft board water. The FDA also approves the
design of aircraft water systems and requires that interstate carrier conveyances provide
potable water for drinking and culinary purposes [21 CFR 1240.80]. Therefore,
additional treatment of the water should not be needed prior to boarding the water.
However, the opportunity exists for microbiological organisms to be introduced during
the process of boarding water, or for biofilm to develop within the water system itself,
which may cause the system to need to be disinfected and flushed. Exhibit 2.2 illustrates
potential mechanisms and pathways through which water may be contaminated prior to
being boarded, or may become contaminated or deteriorate in quality while onboard the
aircraft. The ADWR is intended to minimize such occurrences and prescribe appropriate
response actions if they occur.
Exhibit 2.2 Potential Contamination Pathways within the Aircraft Water
System Supply and Transfer Chain
Public Water System
C-fdss connection with baekflow
FlighttoNext
Airport
«
«
(e.g..
Aircraft Water System
. ^ » Boarded water k con ~ ..... " ^ ii-"i
f
«** » ...... ~ ••••• ii ••• '
A * Water .......... -•* .....
f
*Iiiipropei*ly designed ^y^tem allows
Lavatory Sink
vj.'-j.- ly
."•.d'.l".i:«.i'.r j
-.![. I J -JltS,
Water
Cabinet
Galley
Sink/
Coffee
to
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2.2.2 ADWR Public Health Protection Measures
With aircraft, it is impractical to test the water for microbiological contaminants every
time water is boarded from a different source - several samples may be required in one
day for some aircraft, and coliform bacteria analytical results would not be available for
at least 24 hours after sample collection. The ADWR therefore requires air carriers to
develop a comprehensive operations and maintenance (O&M) plan for each aircraft water
system to minimize opportunities for contamination. The plan addresses procedures for
routine disinfection and flushing, to be performed at frequencies recommended by the
aircraft water system manufacturer. The plan requires occasional testing for total coliform
bacteria to confirm the effectiveness of O&M procedures. It also identifies minimum
training content and requires training of personnel involved in boarding water and water
system maintenance. In the event that an air carrier becomes aware of contamination on
an aircraft, the ADWR requires public notification of passengers and crew.
In addition to the O&M plan, the ADWR requires self-inspections by air carriers of each
aircraft water system, and allows for EPA compliance audits. Lastly, the rule requires
reporting and recordkeeping to facilitate compliance tracking and rule implementation.
2.3 Compliance Dates and Requirements
Several rule components will require implementation six months after rule promulgation;
the remainder must be implemented within one year after promulgation. These
compliance dates allow the air carriers to be taken off the administrative orders on
consent (AOC) under which they operate until the final ADWR is in effect. The rule
requirements and compliance dates are summarized in Table 2.1, below, and are
described briefly following the table.
Table 2.1 Rule Components and Compliance Dates
6 Months After Rule Promulgation
Submit aircraft water system inventory
Develop coliform sampling plan and report coliform sampling frequency
Update O&M plan to reflect ADWR and report plan is complete
1 Year After Rule Promulgation
Update aircraft inventory and coliform sampling plans as needed for new aircraft
Begin coliform sampling
Begin routine disinfection and flushing
Begin reporting and recordkeeping
Conduct corrective disinfection and flushing as needed
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Conduct public notification as needed
Conduct self-inspections (every 5 years) and correct deficiencies
Aircraft Inventory. Air carriers are required to report their fleet inventory for all
aircraft water systems to EPA within six months of promulgation of the ADWR. They are
required to submit changes in inventory within 10 days after the end of the month in
which the changes occurred. Since each aircraft is a PWS, the inventory will include a
unique identifier number for each aircraft. Inventory information will be submitted to
EPA electronically, in a database format designed by EPA to facilitate subsequent
reporting, recordkeeping, and compliance monitoring. Air carriers that have submitted
inventories for compliance with AOCs prior to promulgation of the final rule need only
update the inventory. See Chapter 3 for more information.
Coliform Sampling Plans. Air carriers must develop coliform sampling plans for
existing aircraft within six months after rule promulgation. The sampling plan will
include sampling procedures, along with aircraft sampling frequencies and disinfection
and flushing frequencies. Air carriers are not required to submit the coliform sampling
plan to EPA, but must inform EPA that the plan is complete and submit their planned
sampling frequencies. However, EPA may choose to review the plans during a
compliance audit, and can request that the plan be submitted at any time. Although the
rule requires a sampling plan for each aircraft, individual plan documents are not required
for each aircraft - EPA anticipates a plan may be developed that covers several aircraft
and specifies the aircraft identifier numbers within the document. For new aircraft, air
carriers must develop sampling plans and report coliform sampling frequency within the
first three months of operation of the new aircraft. See Chapter 4 for more information.
Operation and Maintenance Plans. Within six months after rule promulgation, air
carriers must update their existing Federal Aviation Administration-approved or accepted
operations and maintenance programs with aircraft water system operations and
maintenance plans. Air carriers need not submit the O&M plans to EPA, but must inform
EPA that the plans are complete. EPA can request a copy of the plan at any time and may
view the plan during compliance audits. For new aircraft, air carriers must revise the
O&M plan and inform EPA that the plan is complete within the first three months of
operation. See Chapter 5 for more information.
Self-Inspections. Beginning one year after rule promulgation, air carriers must begin
conducting self-inspections of aircraft water systems. Each aircraft water system must be
inspected every five years - a frequency consistent with sanitary surveys of stationary
TNCWSs and intended to be compatible with other significant aircraft maintenance
events. Air carriers must address deficiencies they discover during the inspections within
90 days, and inform EPA of any that are not addressed within this timeframe. See
Chapter 5 and Appendix D [APPENDIX D TO BE DEVELOPED] for more information.
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Notification to Passengers and Crew. Beginning one year after rule promulgation, air
carriers will be required to notify passengers and crew that are on board the aircraft in all
of the following situations:
• Public access to the aircraft water system is required to be restricted because any
routine or repeat sample is fecal coliform-positive or E. co//'-positive [40 CFR
141.803(c)(3)], or if more than one routine sample or any repeat sample is total
coliform positive even if they are fecal coliform-negative (or E. co//'-negative) [40
CFR141.803(c)(4)].
• There has been a failure to collect routine, repeat, or follow-up coliform samples [40
CFR 141.803(e) or (f)].
• Water has been boarded from a watering point that has not been approved by the
FDA or otherwise determined to be safe [40 CFR 141.804(b)(6)].
• The EPA, the air carrier, or the crew otherwise determine that notification is
necessary to protect public health [40 CFR 141.805(a)(4)].
However, if access to the water system by passengers is physically prevented through
disconnecting or shutting off the water, or if water is supplied only to lavatory toilets and
not to any lavatory taps, then only the notice to the crew is required. This exception only
applies when there is no possibility of the passengers accessing the water system for
consumptive use.
Notification is required within 24 hours of being informed of sample results or other
events which trigger notification, or within 24 hours of being informed by EPA to
perform notification, whichever occurs first. The ADWR does not require notification of
passengers that were onboard the aircraft at the time the coliform-positive samples were
collected. However, such passengers may be notified if it is directed as part of an illness
or event investigation. Notification of passengers and crew must continue until all follow-
up samples required by the situation that triggered the notice are coliform-negative. See
Chapter 6 for more information.
Recordkeeping and Reporting. Air carriers must keep their coliform sampling plans
and O&M plans on hand and make them available for EPA review during compliance
audits and upon request. Records of coliform monitoring and disinfection and flushing
must be kept for at least five years, and records of self-inspections must be kept for at
least 10 years. The rule also specifies a minimum public notice records retention
requirement of three years.
In addition to the reporting described previously for aircraft inventory, sampling plans,
and O&M plans, the rule requires air carriers to report sample results, self-inspection
results, failure to comply with monitoring or disinfection and flushing requirements, and
the occurrence of events requiring corrective disinfection and notification of passengers
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and crew. This reporting begins starting one year after promulgation; actual reporting
deadlines vary. See Chapter 7 for more information on recordkeeping and reporting.
Implementation Oversight and Enforcement. The rule authorizes EPA to conduct
onsite compliance audits of aircraft and aircraft records. EPA may review records, take
coliform samples, and observe procedures at any time.
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Chapter 3 Aircraft Inventory
Under the ADWR, air carriers will be required to submit to EPA an inventory of all
aircraft public water systems (PWSs) in their fleet and to update the inventory as fleet
changes occur [40 CFR 141.806(b)]. This chapter describes how to identify aircraft that
are PWSs, the information to be reported, and how to submit the inventory data.
3.1 Identifying Aircraft Public Water Systems
The criteria that must be met for an aircraft with an onboard water system to be regulated
under the ADWR are as follows:
• The water system must provide piped water to the public for human consumption.
"Water for human consumption" means water used for purposes identified under
the NPDWRs and accompanying preamble and court decisions, which includes,
but is not limited to: drinking, beverage preparation, bathing, showering, hand
washing, cooking, dishwashing, and maintaining oral hygiene. Human
consumption does not mean water used for toilet uses. If piped water is available
to the public onboard an aircraft, then there is human consumption.
• The water system must regularly serve an average of at least 25 individuals daily at
least 60 days out of the year.
The aircraft must have at least 60 days of flight in a year and the total number of
persons served each day, including passengers and crew, must average at least 25
individuals. The number of persons served includes all flights in a day. A smaller
aircraft can still be considered a PWS if it flies at least 60 days a year and serves a
total of at least 25 people over the course of a day. That is, if two flights have 20
individuals each, the total number for the day is 40 persons served.
• The aircraft must convey passengers in interstate commerce.
Cargo planes or other aircraft that have a water system on board but are not
involved in any passenger conveyance for interstate commerce are not subject to
the ADWR.
The ADWR requirements still apply if an aircraft provides bottled drinking water for
drinking purposes if there is an onboard water system available for human consumption.
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3.2 Reporting Existing Inventory Information
3.2.1 Inventory Details
Within the first six months after rule promulgation, air carriers must provide EPA a
complete inventory of aircraft PWSs. EPA may request additional information; however,
inventory data must include all of the following:
• The unique aircraft identifier number
o This may be the nose or tail number that is unique to the aircraft and is used for
other aircraft tracking requirements.
• The status of the aircraft as active or inactive
o An active aircraft is one that is actively used for passenger service at least 60 days
a year and could therefore reasonably be expected to meet the monitoring,
disinfection and flushing, and other requirements of the ADWR.
o An inactive aircraft is one that is not in service often enough to qualify as a public
water system, i.e., it does not operate at least 60 days a year serving 25 or more
people.
• The type and location of any treatment equipment installed on the aircraft water
system.
o Treatment equipment includes supplemental disinfection systems, carbon or
particle filters on water lines, or other apparatus that changes the chemical,
biological, or physical condition of the water. Although it is possible for increased
temperature to cause changes to the chemical, biological, and physical condition
of water, for the purposes of aircraft inventory hot water heating units on coffee
makers and/or hot water lines are not listed as water treatment equipment.
• Whether the aircraft water system can be shut off and the extent to which it can be
made inaccessible to the passengers and crew.
o The ability to shut-off the supply of water to all faucets and other plumbing
fixtures affects the requirements for public notification and the timeframe for
implementation of corrective disinfection and flushing following a single fecal
coliform or E. co//'-positive sample, or following more than one total coliform
positive sample in any monitoring period. If the water cannot be shut off,
corrective disinfection and flushing must occur within 72 hours. If the system can
be shut off, the aircraft must perform disinfection and flushing prior to resuming
unrestricted public access as defined in §141.803(c)(5). Public notification need
only be provided to the crew if the water system is shut off to prevent access by
the passengers.
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3.2.2 Inventory Reporting Format and Procedure
Electronic reporting of inventory data is required. To facilitate collection and analysis of
aircraft water system data, EPA is developing an internet-based electronic data collection
and management system. Inventory will be reported directly to this database using Web
forms and free software. The data system will perform logic checks on data entered and
will calculate final results for accountability and regulatory oversight. This is intended to
reduce reporting errors and limit the time involved in investigating, checking, and
correcting errors at all levels.
PLACEHOLDER FOR ADDITIONAL TEXT FOLLOWING DEVELOPMENT OF
THE DATABASE:
• Description of spreadsheet format and reporting method
• Accessing the downloadable spreadsheet
• What to do if inventory was submitted for an AOC
3.3 Reporting Inventory Updates
After the initial inventory submission, changes in aircraft inventory must be reported to
EPA no later than 10 days following the calendar month in which the change occurred.
This includes changes to an aircraft's identifier number, active status, treatment
equipment, or ability to shut off the water to passengers. This also includes adding a new
aircraft to the fleet. Prompt notification of inventory changes is necessary to ensure
violations are not incurred by aircraft that are out of service or otherwise inactive, and
that new aircraft are in compliance with the rule.
Note this reporting requirement for inventory updates is different than the requirement for
new aircraft coliform sampling plans and operations and maintenance plans, which must
be completed and reported within the first calendar quarter of operation of the aircraft.
PLACEHOLDER FOR ADDITIONAL TEXT FOLLOWING DEVELOPMENT OF
THE DATABASE:
• Reporting format
• Method for inventory changes
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Chapter 4 Col if orm Monitoring
4.1 Overview of Coliform Sampling
Coliforms are used as an indicator of possible contamination of the water system. They
are used to indicate a water system's vulnerability to pathogens, and are required to be
monitored by every public water system.
4.1.1 Types of Coliform Samples
Coliform samples required by the ADWR are of three types: routine samples, repeat
samples, and follow-up samples.
Routine samples are collected on a specified schedule, which is determined by the
frequency of routine disinfection and flushing of the water system. For routine sampling,
two samples of 100 milliliters (mL) each must be taken, one from a galley and one from a
lavatory tap. If the aircraft has only one tap, two 100-mL samples must be taken from that
tap. The ADWR does not specify whether samples should be collected from hot or cold
taps, but EPA strongly recommends collection of samples from cold water taps. Some
concern exists about sampling from hot taps since hot water could kill microorganisms,
masking whether there is a microbiological problem in the aircraft system. In addition,
water lines that are connected to hot water heaters may be warmer than cold water piping,
which often encourages microbial growth within those lines.
Repeat samples are an option to performing corrective disinfection and flushing of the
system when only one routine sample is total coliform-positive and it is also fecal
coliform/E1. co//'-negative. For repeat sampling, four repeat samples of 100 mL each must
be collected no later than 24 hours after the laboratory notifies the air carrier of the
routine sample results. If the option to collect repeat samples is selected, a set of four
repeat samples must be collected and analyzed from four taps within the aircraft as
follows: the tap that resulted in the total coliform-positive routine sample, one other
lavatory tap, one other galley tap, and one other tap. If less than four taps exist, then a
total of four 100 mL samples must be collected and analyzed from the available taps
within the aircraft water system.
Follow-up samples are a set of two coliform samples used to confirm the effectiveness of
corrective disinfection and flushing procedures. Follow-up samples (two samples of 100
mL each) must be taken at the same locations as routine sampling. Follow-up sampling is
required after corrective disinfection and flushing, or disinfection and flushing triggered
by failure to perform routine coliform monitoring. Although the ADWR does not specify
a timeframe by which follow-up samples must be collected, a complete set of two follow-
up samples must be coliform-negative before public access to the water is allowed.
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Aircraft may also voluntarily collect special purpose samples as needed to indicate the
quality of the onboard water. The routine and repeat coliform sampling requirements of
the ADWR are summarized below and are detailed in 40 CFR 141.803.
4.1.2 Sequence of Coliform Sampling
Each aircraft PWS must be routinely monitored for total coliform at the frequency
specified in the coliform sampling plan for that aircraft. During each monitoring period -
which may be monthly, once per quarter, or once per year - a set of two routine samples
must be collected. In order to provide meaningful results, routine coliform sampling
should be representative of the general conditions of the aircraft water system. That is,
they should represent water provided to passengers and crew on a typical flight. To
ensure that routine sample results are not inadvertently skewed by sampling too close to a
disinfection event, routine coliform samples must not be collected within 72 hours after
completing disinfection and flushing procedures.
If any sample is positive for total coliform, that sample must be analyzed for E. coli or
fecal coliform bacteria. E. coli and fecal coliform are considered indicators of fecal
contamination. If either of these is present in any sample, public access to the water
system must be restricted, public notice must be provided, and corrective disinfection and
flushing with follow-up coliform sampling must be performed. All follow-up samples
must be coliform-negative before unrestricted public access to the water system is
allowed.
If total coliform bacteria are not detected in any routine samples in a monitoring period,
the aircraft must continue collecting routine samples for total coliform analysis at the
frequency specified in the coliform sampling plan.
If one routine sample is positive for total coliform and it is also fecal coliform/E1. coli-
negative, the aircraft may either collect four repeat samples or choose to disinfect and
flush the water system and collect a set of two follow-up samples.
If both routine samples are positive for total coliform, the option for collection of repeat
samples is removed and the aircraft must restrict public access to the water system
including providing notice to the passengers and crew, disinfect and flush the water
system, and collect follow-up samples. These actions are also required if any repeat
samples are positive for total coliform but are fecal coliform/£'.co//-negative.
Exhibit 4.1 provides a diagram of the coliform monitoring requirements of the ADWR.
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Exhibit 4.1 Overview of Coliform Monitoring Requirements
No routine
samples are
coliform-
positive
Continue
schedule for
routine
coliform
monitoring
Are any
repeat
samples or
follow-up
samples
positive for
total
coliform
System collects two routine
samples per monitoring period
One routine
sample is total
coliform positive
Collect repeat
samples, or
disinfect and
flush the
system and
collect follow-
up samples.
Is the
sample
also fecal
coliform/E.
coli-
positive?
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Is the
sample
also fecal
coliform/E.
coli-
positive?
Disinfect and flush the
system, restrict public
access to the system,
collect follow-up
samples, and issue public
notice for fecal
coliform/E'. co/i-positive
results. All follow-up
samples must be
coliform negative before
returning to routine
monitoring
Two
routine
samples
are total
coliform-
positive
Is either
sample
also fecal
coliform/E.
coli-
positive?
Disinfect and flush the system,
restrict public access to the system,
collect follow-up samples, and issue
public notice for total coliform-
positive results. All follow-up
samples must be coliform negative
before returning to routine
monitoring
19
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4.2 Coliform Sampling Plans
Within six months after rule promulgation, each aircraft must be covered by a coliform
sampling plan. The sampling plan ensures representative and meaningful samples are
collected from each aircraft. A separate plan does not need to be developed for each
aircraft. EPA recommends a plan be developed for each type of aircraft and that the plan
include a table with the unique aircraft identifier numbers to which the plan applies.
Once completed, EPA must be notified that the coliform sampling plan has been prepared
and the plan must be included in the aircraft O&M program. If additional aircraft are
added to the fleet, EPA must be notified that a sampling plan has been completed for the
new aircraft by the end of the calendar quarter in which the aircraft begins operation.
New aircraft may be added to the list of aircraft covered by an existing plan, or a new
plan may be developed. EPA notification will utilize the electronic reporting and
compliance database described in Chapter 7.
At a minimum, all coliform sampling plans must include the following [40 CFR
141.802]:
• Coliform sample collection procedures
Standardized procedures ensure representative samples are collected and
meaningful samples results will be obtained. Suggested procedures are included
in section 4.4.
• Sample tap location(s) representative of the aircraft water system
Identification of sample taps from which specific samples are collected provides
useful information for follow-up investigations. For example, an air carrier
reported to EPA that being able to identify the specific sample location from
which coliform-positive samples were collected helped detect problematic
faucets. Once the specific faucets were identified and replaced, persistent
coliform-positive sample problems were eliminated for that aircraft.
Identifying sample taps as to whether they are fore or aft, lavatory or galley, and
other details helps identify the specific location from which a sample was
collected. When this location information is entered on the coliform sample form
submitted to the laboratory, the sample results will also be reported with the
location.
The ADWR specifies two routine samples must be taken during each routine
monitoring period for each aircraft that qualifies as a public water system. Some
aircraft may have more than one water tank and plumbing system, all of which
may not be interconnected. In such situations, EPA recommends all drinking
water tanks and plumbing on an aircraft be included in the coliform sampling
plan, and that the sample locations be alternated between the discreet systems
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each sampling period so as to collect representative samples to the extent
possible. For example, an aircraft on quarterly coliform monitoring might have a
lavatory sample collected from the forward system and a galley sample collected
from the rear system in one quarter, and collect second quarter samples from the
forward galley and rear lavatory. Systems with a single water system may also
move the sample locations each monitoring period if necessary to collect
representative samples. Identification of sample collection locations in the
coliform sampling plan is required by 40 CFR 141.802(a)(2).
• Frequency and number of routine coliform samples to be collected
Making note of the required frequency and number of samples to be collected
helps ensure personnel responsible for this task will collect the correct number of
samples during the appropriate monitoring period. The frequency of sample
collection means whether the samples are collected monthly, quarterly, or once
per year. All aircraft must collect two routine samples during each monitoring
period. These are collected from different locations on the aircraft if more than
one tap is available, but they are both collected during the same sampling event.
Aircraft have the option to collect more than two samples during each monitoring
period if desired.
• Frequency of routine disinfection and flushing as specified in the operation and
maintenance plan
The frequency of routine disinfection and flushing of the aircraft water system
determines the minimum frequency for routine coliform sample collection.
Including the disinfection and flushing frequency in the coliform sampling plan
helps ensure the proper frequencies are followed, and that both activities are
performed.
• Procedures for communicating sample results to ensure any required actions are
conducted in a timely manner
The first step in the communications process is the notice the laboratory
performing the coliform analyses provides to the air carrier regarding the sample
result. Notification of both positive and negative sample results in a timely
manner is critical to ensure the required action may be promptly implemented.
Required actions may include repeat or follow-up sampling, restricting public
access, corrective disinfection and flushing, notification of passengers and crew,
or returning to unrestricted access to the water. EPA suggests that
communications procedures include specific contact personnel names, phone
numbers, and back-up contact information.
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4.3 Sampling Frequencies
Routine coliform sampling frequencies depend on the frequency at which routine
disinfection and flushing is conducted. Routine disinfection and flushing must be
conducted at the frequency recommended by the manufacturer of the aircraft water
system. If the manufacturer does not recommend a frequency, routine disinfection and
flushing must be performed no less frequently than quarterly. Table 4.1 shows the
monitoring frequency that corresponds with a given disinfection frequency. Additional,
or special, coliform sampling is always encouraged and recommended by EPA.
Table 4.1. Coliform Sampling Frequencies Based on Disinfection and
Flushing Frequencies
Disinfection and Flushing Frequency
Quarterly
1-3 Times a Year
Less Than Once a Year
Routine Coliform Sampling
Frequency
Annually
Quarterly
Monthly
4.4 Suggested Sampling Protocol
The following is a suggested sampling protocol that could be used for collection of
routine, repeat, or follow-up samples.
4.4.1 Materials and Preparation for Sampling
Contact the laboratory that will perform sample analysis in advance of the planned
sampling date. Sufficient time should be allowed to obtain materials and to agree on a
sample submittal date.
The laboratory should be notified of the number of sample bottles needed, and it should
be determined whether the laboratory will provide a return-shipping cooler and ice packs
(although shipping the sample on ice to obtain a shipping temperature of 10 degrees C or
less without freezing the sample is recommended, it is not a requirement of the ADWR).
All materials should be on-hand and ready for use at least 48 hours prior to sampling.
Note that a separate cooler or holding container for each day/location of sample
collection will be needed if samples are not hand-delivered to the laboratory each day.
Below is a list of suggested materials needed for sampling.
1) Data sheet
2) Copy of this protocol
3) Laboratory chain of custody form
4) Indelible pen
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5) Sample bottles -100-mL sterile plastic with non-toxic cap
6) Cooler with ice (optional) (contained-ice packs are preferable to ice cubes)
7) Rubbing alcohol (isopropyl alcohol) and cotton swabs, or prepared alcohol wipes
8) Rubber / latex exam gloves
Pre-label all bottles with the following information:
• Sample ID correlating to the sample tap location and other information listed on the
laboratory chain of custody form and data sheet
• Date and time of collection
• Analyses requested (e.g., total coliform)
• Sampler's initials
On each aircraft, total coliform samples must be collected from a galley tap and a
lavatory tap unless there is only one tap. Galley samples should be collected from a cold
water tap if possible. If the only sampling point in the galley is the coffee maker and/or
hot water tap, collect the sample at that location and indicate the sampling location on the
data sheet. Ask ramp personnel to refrain from servicing the aircraft water system until
completion of sampling. This will help ensure the sample is representative of the water
available to passengers and crew during normal operating conditions; sampling the water
system immediately after filling the system would be not be representative of the water
that had been available to consumers.
During sampling, rubber gloves should be used when handling samples to minimize
sample contamination and exposure to sample preservatives. Bottles should be kept
closed until ready to be filled.
4.4.2 Sample Collection
The following steps are recommended for routine, repeat, and post-disinfection follow-up
sample collection.
1) Put on gloves.
2) Inspect galley faucet for aerator on outlet. If an aerator is present, remove if possible,
clean, and re-install.
3) Swab galley faucet and water outlet with alcohol.
4) Allow to air dry.
5) Open tap fully and allow water to run for 2 to 3 minutes.
6) Reduce water flow to allow sampling of water without splashing out of container.
Do not sample from leaking taps or taps which allow water to run down the outside
of the faucet.
7) Open sterile cap of total coliform sample bottle.
8) Do not touch interior of cap or top of bottle. Do not place cap on counter.
9) Place bottle under water stream. Allow approximately 1-inch air gap between top of
bottle and water faucet.
10) Do not rinse bottle. Do not fill bottle to top. Allow 1-inch air gap in top of bottle.
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11) Replace cap and tighten.
12) Ensure that sample ID matches that recorded on data sheet.
13) Place bottles into Ziploc® or similar bag. Place bag in cooler or other transport
container (packing the sample on ice is recommended, but optional)
14) Complete chain of custody sheet provided by laboratory. Ensure that sample ID
matches that on the label and data sheet. If chain of custody sheet is not provided in
duplicate, photocopy it for your records.
15) Sign and date the following statement on the data sheet. If there was any deviation
from protocol, note at the bottom of data sheet.
I certify that all samples were collected in accordance with the protocol entitled "Protocol
for Sampling Drinking Water on Commercial Aircraft".
Signature Date
4.5 Certified Laboratories and Analytical Methods
4.5.1 Analytical Methods
EPA interprets the proposed ADWR as including a requirement that a certified laboratory
be used for all coliform sample analyses, and a maximum holding time between sample
collection and analysis for coliform samples of 30 hours.
EPA-approved analytical methodologies must be used for the analysis of coliform
bacteria and E. coli. The current list of approved analytical methods is provided on EPA's
website at http://www.epa.gov/safewater. For compliance with the ADWR, methods
approved for compliance with the Total Coliform Rule are also appropriate. Each sample
need only be analyzed for the presence or absence of the organisms; enumeration of the
bacterial colonies present is not necessary.
EPA strongly recommends using methods that provide the most rapid test results and
include simultaneous total coliform and fecal coliform/E1. coli test results. Discuss with
the laboratory the test methods they are certified to perform and the anticipated
timeframe for reporting results, as well as their procedure for reporting results. Because
of the availability of overnight shipping, the preferred laboratory may not be the one
closest to the sampling location.
4.5.2 Sample Invalidation
The invalidation of a total coliform sample result can only be made by EPA in
accordance with 40 CFR 141.21(c)(l)(i), (ii), or (iii) or by the State- or EPA-certified
laboratory in accordance with 40 CFR 141.21 (c)(2). If an air carrier believes that a result
is incorrect, they may submit the result as a contested result and petition EPA to
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invalidate the sample. If an air carrier contests a sample result, they must submit a
rationale to EPA providing a justification, including a supporting statement from the
laboratory.
EPA may invalidate samples if any of the following applies:
• The laboratory establishes that improper sample analysis caused the total coliform-
positive result.
• EPA, on the basis of the results of repeat samples, determines that the total coliform-
positive sample resulted from a non-distribution system plumbing problem. EPA
cannot invalidate a sample on the basis of repeat sample results unless all repeat
sample(s) collected at the same tap as the original total coliform-positive sample are
also total coliform-positive, and all repeat samples collected at other taps are total
coliform-negative (e.g., EPA cannot invalidate a total coliform-positive sample on the
basis of repeat samples if all the repeat samples are total coliform-negative, or if the
aircraft water system has only one tap).
• EPA has substantial grounds to believe that a total coliform-positive result is due to a
circumstance or condition which does not reflect water quality in the aircraft water
system. The decision to invalidate, with the rationale for the decision, must be
documented in writing and approved and signed by the supervisor of the EPA official
who recommended the decision. EPA must make this document available to the
public. The written documentation must state the specific cause of the total coliform-
positive sample, and what action the system has taken, or will take, to correct this
problem. EPA may not invalidate a total coliform-positive sample solely on the
grounds that all repeat samples are total coliform-negative.
As provided in 40 CFR 141.21(c), a laboratory must invalidate a total coliform sample
(unless total coliforms are detected) if the sample produces a turbid culture in the absence
of gas production using an analytical method where gas formation is examined (e.g., the
Multiple-Tube Fermentation Technique), produces a turbid culture in the absence of an
acid reaction in the Presence-Absence (P-A) Coliform Test, or exhibits confluent growth
or produces colonies too numerous to count with an analytical method using a membrane
filter (e.g., Membrane Filter Technique). If a laboratory invalidates a sample because of
such interference, the system must collect another sample from the same location as the
original sample within 24 hours of being notified of the interference problem, and have it
analyzed for the presence of total coliforms. The system must continue to re-sample
within 24 hours and have the samples analyzed until it obtains a valid result. EPA may
waive the 24-hour time limit on a case-by-case basis.
4.6 Reporting Sampling Results
Reporting of sampling results begins one-year after the final rule is published. As the
primacy agency, EPA will oversee reporting by air carriers. To facilitate collection and
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analysis of aircraft water system data, EPA is developing an internet based electronic data
collection and management system. This approach is similar to that used under the EPA
SDWIS/STATE (Safe Drinking Water Information System/State version) reporting
program. Analytical results for microbiological testing will be reported directly to this
database using Web forms and software that can be downloaded free of charge. The data
system will perform logic checks on data entered and calculate final results for
accountability and regulatory oversight. This is intended to reduce the reporting errors
and limit the time involved in investigating, checking, and correcting errors at all levels.
Air carriers should instruct laboratories to either manually enter analytical results into an
EPA-managed Web-based data system, or to electronically upload data files from their
laboratory information management systems (LEVIS) to a Web-based data file submission
program. These data files must be in a format prescribed by EPA. If an air carrier
determines that its laboratory does not have the capability to report data electronically,
they can submit a request to EPA to use an alternate reporting format. If it is believed that
a result was entered into the data system erroneously, the air carrier may notify the
laboratory to rectify the entry.
All sample results must be reported to EPA no later than 10 calendar days following the
monitoring period in which the sampling occurred. Remember that the length of the
monitoring period depends on the coliform sampling frequency and may be monthly,
quarterly, or annual sampling.
All events requiring notification to passengers and crew and non-routine disinfection and
flushing must be reported within 10 days of the event triggering the notification or
disinfection and flushing requirement. For example, once an air carrier is notified by the
laboratory that a set of two routine coliform samples are positive for total coliform, the
air carrier has 10 days to notify EPA of the event including an indication of whether
required notification was provided to passengers and/or crew. The electronic database
reporting system will include the capability and instructions to facilitate compliance with
these reporting requirements.
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Chapter 5 Operations and Maintenance Plans
This chapter describes ADWR requirements related to operation and maintenance
(O&M) of the aircraft water system. The ADWR requires air carriers to update their
FAA-approved or -accepted O&M program for each aircraft with procedures specific to
the aircraft water system. This chapter includes example O&M practices used by some air
carriers. These practices may not be applicable to all types of aircraft or all configurations
of aircraft water systems.
5.1 Overview of Requirements and Timeframes
An O&M plan must be completed for each aircraft that is a public water system at the
time of rule promulgation. For new aircraft added to a fleet after the rule promulgation
date, the aircraft O&M plan must be completed by the end of the first calendar quarter
during which the aircraft is placed into operation. In order to ensure that the appropriate
multiple barriers are in place, each aircraft water system O&M plan must include the
following components:
• Watering Point Selection Requirement. The O&M plan must include a statement
that all water sources must from a FDA-approved watering point as required under 21
CFR 1240.80.
• Procedures for Disinfection and Flushing of Aircraft Water System. The O&M
plan must include a description of disinfection and flushing procedures for aircraft
water systems that are conducted in accordance with or are no less stringent than the
manufacturer recommendations. This allows for equipment-specific designs and for
flexible implementation of disinfection procedures with the evolution of technology.
The description of disinfection procedures must include the specific disinfection
frequency, disinfecting agent, disinfectant concentration, and disinfectant contact
time. The description of flushing procedures must include the flushing volume or
flushing time. EPA understands that some manufacturers do not provide equipment
disinfection and flushing recommendations. Where a recommended routine
disinfection and flushing frequency is not specified by the aircraft water system
manufacturer, the aircraft water system must perform disinfection and flushing no
less frequently than quarterly.
• Procedures for Follow-up Sampling. The O&M plan must include written
procedures for conducting follow-up sampling, defined as additional sampling for
coliform bacteria that is required by the ADWR following detection of total coliform,
E. coli., or fecal coliform bacteria in routine or repeat samples. Follow-up samples are
also required after corrective disinfection and flushing is performed when triggered
by a failure to collect routine coliform samples.
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• Training Requirements. The O&M plan must describe training requirements for all
staff involved with the O&M provisions of the ADWR including water quality
monitoring.
• Self-Inspection Procedures. Aircraft pre-flight inspections consider the safety of all
passengers, the pilots, and flight attendants. EPA expects the same level of attention
to be exhibited when air carriers conduct self-inspections of their aircraft public water
systems. The O&M plan must describe how self-inspections of the aircraft water
system will be conducted, including but not limited to: inspection of the storage tank,
piping, supplemental treatment, plumbing fixtures, valves, and backflow prevention
devices. Air carriers must report evidence of a self-inspection to EPA within 90 days
of completion of the self-inspection, including an indication that all deficiencies were
addressed. Copies must be made available to EPA during compliance audits. If any
deficiency has not been addressed within 90 days of identification of the deficiency,
the report must also include a description of the deficiency, an explanation as to why
it has not yet been addressed, and a schedule for addressing it as expeditiously as
possible.
• Procedures for Boarding Water. The O&M plan must include a description of how
the water will be transferred from the watering point to the aircraft in a manner that
ensures it will not become contaminated during the transfer. This description may be
provided in a step-by-step procedure format, or other means which are useful to
personnel responsible for the transfer process. This information will be helpful for
ground crews responsible for maintaining the equipment supplying the aircraft with
finished water. The plan must also describe emergency procedures to be used in the
event that water is boarded that does not meet drinking water standards but is needed
to operate essential systems, such as toilets. Those emergency procedures must
include notification of passengers and crew, as described in Chapter 6; disinfection
and flushing within 72 hours in accordance with the procedures in the O&M manual;
and collection of follow-up samples. The plan must include a description of how the
carrier will ensure that water boarded outside the United States is safe for human
consumption.
• Coliform Sampling Plan. The O&M plan must include the monitoring plan for
coliform bacteria. The coliform sampling plan is described in Chapter 4. Plan
elements include but are not limited to:
o Coliform sample collection procedures
o Sample tap locations representative of the aircraft water system
o Frequency of coliform sampling and number of samples to be collected during
each sampling event
o Frequency of routine disinfection and flushing
o Procedures for communicating sample results
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5.2 Routine and Corrective Disinfection and Flushing
As described in section 5.1, routine disinfection and flushing must be conducted at the
frequency recommended by the manufacturer of the aircraft water system. If the
manufacturer does not specify a frequency, the aircraft water system must be disinfected
and flushed at least quarterly. Corrective disinfection and flushing must be conducted if
E. coli or fecal coliform are detected in any sample, if two or more routine samples or
any repeat sample is total coliform-positive, or if any follow-up coliform sample is total
coliform-positive.
The following section summarizes example flushing and disinfection practices for aircraft
water systems. Typical disinfectants and dosage rates are summarized in Table 5.1.
Table 5.1 Typical Disinfectants Used for Aircraft Water Systems
Disinfectant
Trade Name
Purogene plus
citric acid
activator
Ozone
Elsil
Herlisil
Chi or ox, sodium
hypochlorite, or
calcium
hypochlorite
Chi or ox, sodium
hypochlorite, or
calcium
hypochlorite
Active Ingredient
2% chlorine dioxide
Ozone
3% hydrogen peroxide
50% hydrogen
peroxide
chlorine
chlorine
Dosage
Rate
100 parts per
million (ppm)
1.5 ppm
400 ppm
400 ppm
100 ppm
50 ppm
Contact
Time
1 hour
20 minutes to
1.5 hours
1 hour
1 hour
1 hour
4 hours
Recommended Disinfection Procedure
1) Open all taps and completely drain water system.
2) Remove filters and replace filter caps.
3) Make up disinfectant solution (disinfectant type and dose vary, see Table 5.1).
4) Fill water system tank with disinfectant solution until full (drains out of tank
overflow).
5) Flush galley and lavatory taps until proper disinfectant concentration is measured at
all taps.
6) Top off water system tank with disinfectant solution.
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7) Hold disinfectant solution in water system for predetermined contact time (varies
depending on disinfectant type and dose, see Table 5.1).
8) Record contact time and initial disinfectant concentration in maintenance records
(Aircraft Maintenance Report).
9) Open all taps and completely drain water system.
10) If measured disinfectant concentration was less than required, or actual contact time
was less than required, repeat disinfection procedure.
11) If disinfection procedure met requirements for disinfectant concentration and
contact time, refill the water system with potable water and allow water to flow
from each tap for 2 minutes.
12) Collect water samples for coliform bacteria if follow-up samples are required.
13) Repeat disinfection procedure if coliform samples are coliform-positive, or if water
quality is otherwise unsatisfactory.
14) Install new filters.
In step 5, after the aircraft water system tank has been filled with the disinfectant
solution, all lavatory and galley taps are opened in order to draw the disinfectant solution
completely through all pipes and fixtures. Various procedures have been suggested to
accomplish this step. For example:
• Flush galley and lavatory taps until disinfecting solution flows from the tap.
• Flush toilets 2 to 5 times with 15 second interval between flushes.
• Flush galley and lavatory taps for 3 minutes.
• Flush toilets 5 times.
• Flush toilets 15 times.
• Flush galley taps enough to run 5 liters of solution through the tap.
• Flush cold water tap in lavatory enough to fill sink, drain the sink, then flush hot
water tap enough to fill sink.
When the aircraft is temporarily taken out of service, the water system is typically
drained to prevent water quality degradation and to protect the system from frozen pipes
during cold weather. Before the water system can be returned to service, it should be
disinfected and flushed. One air carrier provided EPA with the following general
recommendations/guidelines for water system maintenance associated with aircraft
storage:
1) If the aircraft will be parked for more than three days, drain the water system. When it
is returned to service, perform disinfection procedure, and then fill the lines with
potable water.
2) If the aircraft will be stored (i.e., taken out of service), conduct the following prior to
storage: drain the water system, perform the disinfection procedure, and then drain
the water system again so that there is no water in the system while the aircraft is
stored. Before the aircraft is returned to service, conduct the following: perform the
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disinfection procedure, replace charcoal filters if installed, and fill with potable water
and flush the lines.
5.3 Training of Personnel
Training is required for air carrier staff and contractors responsible for operating and
maintaining the aircraft water system. This includes staff that board water; conduct
sampling, disinfection, and flushing; and perform self-inspections. The training will
emphasize the use of sanitary practices in operating and maintaining the water system in
order to maintain water quality and to protect public health.
The aircraft water system O&M plan must describe the air carrier's program for training
personnel responsible for O&M activities. The O&M manual can also serve as a training
reference for personnel through inclusion of recommended operating procedures and
guidance for making operational decisions. An up-to-date manual should always be
accessible to operations staff.
The O&M plan should describe the following elements of the training program:
• Training topics and typical training schedule, including the frequency training that
will be provided and duration of the training
• Training program for new staff
• Refresher classes for existing staff
Training topics for aircraft water system personnel should include:
• The public health and safety reasons for the ADWR requirements
• ADWR requirement details
• Acute contaminants, contaminant pathways, and control measures
• Procedures for boarding water
• Collecting water samples for coliform bacteria analysis and transport of samples to
the laboratory
• Routine disinfection and flushing practices
• Procedures for taking aircraft out-of-service and returning to service (e.g., draining,
disinfection, flushing)
• Performing self-inspections
• Draining and cleaning the storage tank
• Backflow prevention and cross connection control
• Water treatment equipment maintenance and replacement requirements
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5.4 Procedures for Conducting Self-Inspections
The O&M plan must explain how self-inspections of the aircraft water systems will be
conducted. The ADWR requires that a self-inspection be completed no less frequently
than once every five years. The purpose of the self-inspection is to make sure that the
aircraft water system is not compromised or subject to contamination.
It may be convenient to schedule the self-inspection when the aircraft is taken out of
service for other regularly scheduled maintenance, such as a D-Check. A D-Check is a
periodic maintenance check preformed on all aircraft after a certain amount of time or
usage. It is the most complete of the four types of maintenance checks and occurs
approximately every 4-5 years. During a D-Check, the entire aircraft is essentially taken
apart for inspection. Alternatively, the self-inspection could be scheduled after a certain
number of flight hours. However, the ADWR requires that it occur no less frequently
than once every five years.
Appendix D [TO BE DEVELOPED] provides a discussion of the essential elements of an
aircraft self-inspection and an example checklist of items to be included in a self-
inspection procedure. This checklist is provided as guidance for air carriers to assess their
aircraft water system for potential problem areas and to assist them in preparing for a
compliance audit by EPA.
Aircraft water systems are generally considered to include the following basic elements: a
water service panel, a storage tank, treatment equipment (if any are on the aircraft), the
distribution lines (piping and valves), and plumbing fixtures. A thorough inspection is
needed to determine:
• Whether the system can provide a safe and adequate supply of drinking water to the
passengers and crew
• The potential for degradation of the water quality or sanitary risks
• The system's reliability and vulnerability
The self-inspection example checklist is based on the eight essential elements of a public
water system sanitary survey, with modifications appropriate for an aircraft water system.
The eight elements of a typical sanitary survey include the following:
1. Source
2. Treatment
3. Distribution System
4. Finished Water Storage
5. Pumps, pump facilities, and controls
6. Monitoring, reporting, and data verification
7. System management and operation
8. Operator compliance with State Requirements
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Although some of these elements may not directly apply to an aircraft water system, the
self-inspection procedure is intended to provide the same degree of scrutiny for potential
public health risks and reliability issues.
Specific reporting and recordkeeping requirements also apply to aircraft self inspections.
Within 90 days of discovering a deficiency during a self-inspection, the deficiency must
be addressed. In addition, within 90 days of completion of the self-inspection, the air
carrier must report to EPA that it has completed the self-inspection and all deficiencies
have been addressed. Any deficiencies that have not been addressed within 90 days of
when they are identified must be included in the report to EPA, including a description of
the deficiency and a schedule for addressing it as soon as possible.
5.5 Practices and Procedures for Boarding Water
5.5.1 Routine Practices
Water is transferred to aircraft at the airport's watering points using either water cabinets
mounted on the airport terminal building or a mobile water cart or truck. The design,
operation, and maintenance of watering point facilities are regulated by the FDA [21 CFR
1240 and 21 CFR 1250].
At a minimum, compliance with FDA regulations is required. It is also advisable to
periodically check FDA's website (www.fda.gov) for updated information and
guidelines. For example, at a future date, FDA is planning to have a list of approved
watering points on their website.
An example of water boarding practices provided by the National Air Transportation
Association (NATA) and Airline Services Council & Associates includes the following:
1) Persons known to have or suspected of having one or more of the following
conditions are not allowed to conduct drinking water service for aircraft water
systems:
a) Carrier of a communicable disease.
b) Suffering from a gastrointestinal disease/illness.
c) An open lesion or evidence of infection on exposed surfaces of body.
d) Personnel engaged in removal or disposal of wastes from aircraft or other airport
facilities.
2) Personnel handling drinking water service equipment shall keep hands clean at all
times.
3) Water service tanks and connected plumbing, hoses, hose reels, racks, and cabinets
must be kept clean at all times.
4) All plumbing and hoses must be water-tight with no leaks.
5) All tank openings except the tank vent must be capped or plugged at all times except
when being repaired or serviced or when tank is being filled.
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6) The hose end that is connected to the aircraft water system must be carried to and
from its storage place and never allowed to touch the ground. When not in use, the
hose end must be plugged, capped, or attached to an approved storage fitting.
7) When not in use, hoses must be stored on a hose reel or suitable bracket to prevent
kinking, damage, and contamination from dirt, oil, etc.
8) Prior to connecting a service vehicle to the aircraft water system, flush the system by
running 5 to 10 gallons of water through it.
9) Thoroughly flush mobile water trucks and carts every 1 to 2 days.
Notes on typical system design:
1) Hoses for filling the aircraft drinking water tanks are 3/4 inch in diameter or less, and
are equipped with a cap and keeper chain. They must meet FDA specifications.
2) All hose connections for servicing the aircraft drinking water system are a different
size or type than those used for servicing lavatory facilities on the aircraft.
3) When hoses are transported on the drinking water servicing vehicle, storage facilities
shall be provided on the vehicle to protect hoses from contamination.
4) Aircraft galley potable water tanks may be filled independently or from the main
potable storage tanks aboard. If filling is to be from the main tanks, it shall be via a
continuous, closed piping system. Shut-off valves may be installed in these lines. If
filling is directly to the galley tanks, the water filling connection shall be quick-
coupling, of a size or type different from other service connections on the aircraft (no
greater than 3/4 inch). The connection shall be clearly labeled "Potable Water Filling"
and be provided with properly secured protective dust-tight cover. The fill line shall
be completely independent and not cross-connected with any line used for non-
potable liquids.
5) If insulation is used to protect hoses from freezing, it must be protected to prevent
water adsorption and contamination.
To prevent contamination of the drinking water during the water transfer and boarding
process, the following specific guidelines are suggested:
• Daily checks for leaks, seals on fill ports, storage of fill hoses, and draining of tank
dumps.
• Monthly checks of hose diameter (in relation to lavatory fill hose), tank vents,
flushing and sanitizing of tanks, and "drinking water only" markings on vehicles.
• Attach cap to hoses.
• Use clean hands at watering point.
• Inspect watering point on regular basis.
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5.5.2 Procedures for When Water of Unknown Quality or Contaminated
Water Must be Boarded
EPA understands and recognizes that aircraft traveling overseas may board water from
sources that are outside the jurisdiction of the United States. EPA is aware that a number
of air carriers have procedures in place to provide assurances on the quality of water
boarded from such sources. EPA is supporting an international effort led by the World
Health Organization (WHO) to address the boarding of water from foreign countries.
The Agency is also aware that in limited circumstances, water of unknown quality is
occasionally boarded to operate essential systems, such as toilets. When instances such as
these occur, passengers and crew must be notified, access to the water must be restricted,
disinfection and flushing of the aircraft water system must occur within 72 hours if the
water system cannot be shut off from public access, and follow-up samples must all be
coliform-negative before the water system can be accessible to the public. These are the
same steps as are required in the event a fecal coliform or E. co//-positive sample is
collected from the aircraft water system. EPA believes this will provide the best method
of protection to the public health by minimizing the risks of exposure to unknown
contaminants.
The ADWR requires that the O&M plan include emergency procedures to be used in the
event that water is boarded to operate essential systems, such as toilets, but is not boarded
from an FDA approved or otherwise safe watering point. In this situation, the public
notification and disinfection and flushing requirements are similar to those for water of
unknown quality, such as when routine samples are not collected.
It may be necessary for an air carrier to have different response plans for different types
of aircraft if some aircraft have a separate water system for toilets and/or a separate water
intake valve.
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Chapter 6 Public Notification
6.1 Purpose of Public Notification
Public notification requirements of the NPDWRs are intended to alert consumers to
potential health risks from violations of the drinking water standards or other situations
that may present a health risk. Violations of the public notice requirements for stationary
systems are divided into three tiers to take into account the seriousness of the violation or
situation and any potential adverse health effects that may be involved. Public notices
related to acute health risks are categorized as tier 1, and typically must be provided
within 24 hours of identification of the violation. Because most of the violations or
situations encountered by aircraft water systems pose potential acute health risks,
notification is also typically required within 24 hours. Due to the transient nature of the
public served by TNCWSs such as aircraft, public notice is often provided by posting the
notice at locations where passengers and crew may access drinking water from the water
system. Notification may also be given though written or verbal means.
Passengers and crew served by an aircraft water system have a right to be informed of
problems with the drinking water. With proper notification, they can make choices about
using the water based on their perception of risk. As mentioned in Chapter 3, water
provided on aircraft must meet standards for human consumption, including uses such as
hand washing and brushing teeth. Thus, even if bottled water is provided to passengers
and crew for drinking, water in aircraft lavatories must still meet drinking water
standards.
The right to know about drinking water problems extends not just to contamination but
also to failure to perform required monitoring or maintenance. For example, when an air
carrier fails to monitor, the quality of the water is unknown. If the carrier does not
conduct routine disinfection and flushing, it cannot be sure the water system is adequately
maintained.
6.2 Notification of Passengers and Crew
Air carriers must issue public notice to passengers and crew for all events described
below [40 CFR 141.805].
1) When public access to the water must be restricted due to the detection of fecal
coliform or E. coli in one or more water samples, or if more than one coliform
sample in a monitoring period is total coliform-positive. In each of these
situations, the ADWR specifies health effects language that must be included in the
notice to the crew that explains the significance of the indicator organisms found in
the water.
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2) Failure to conduct routine, repeat, and follow-up monitoring for coliforms
When routine monitoring is not completed, the water is considered to be of unknown
quality. In this case, the notification advises passengers and crew that sampling did
not take place and specifies the water may be used for handwashing, but not for
drinking, teeth brushing, or food and beverage preparation. In contrast, when repeat
or follow-up samples are not collected, the notification restricts all access to the water
including handwashing. The content of the notice will be determined by the events
that triggered the repeat and follow-up monitoring requirement.
3) Water has been boarded from a watering point that is not FDA-approved or has
not otherwise been determined to be safe. Boarding water from a watering point
that is not FDA-approved or has not otherwise been determined to be safe (as may
occur when water is boarded from foreign water sources) creates a potential public
health risk caused by water of unknown quality. The notification of passengers and
crew advises only using the water for handwashing, but no other consumptive uses.
4) The EPA, the air carrier, or the crew otherwise determine that public
notification is necessary to protect public health. Aircraft must also give notice for
other violations or situations that could cause serious health effects as a result of
short-term exposure. The EPA, the air carrier, or the crew may determine specific
conditions exist that create a public health risk for which public notice is warranted.
Public notice is required for other violations such as failure to perform disinfection
and flushing, failure to perform coliform monitoring, or failure to restrict public
access. An example of when notification might be necessary is if water must be
boarded onto the aircraft but it is known to be contaminated or in violation of
drinking water standards applicable to TNCWSs, such as when the public water
system serving the airport has violated a coliform standard, surface water treatment
technique, or nitrate/nitrite maximum contaminant level.
When public access to the water system is restricted, the ADWR requires the provision of
alternatives to meet basic hygienic needs of passengers and crew as well as alternative
sources of drinking water [40 CFR 141.803(c)(5)(iii)]. Bottled water must be provided
for drinking and coffee/tea preparation, and antiseptic alcohol-based hand gels or wipes
must be provided in the galley and lavatories. Other feasible measures that reduce or
eliminate the need to use the aircraft water system during the period in which public
access is restricted are also required. These additional measures are important for the
protection of public health in that they assure basic sanitation needs are met. They are
also important to ensure potable water is available to passengers and crew during flights
when they are unable to access alternatives on their own.
6.2.1 Public Notice Methods and Timing
Air carriers must provide notification to passengers and crew within 24 hours of being
informed of sample results that trigger notification, or within 24 hours of being directed
by EPA to provide notification, whichever occurs first. The notification to passengers
may be limited to the basic message, "the water is non-potable and should not be used for
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drinking, food or beverage preparation, handwashing, teeth brushing, or any other
consumptive use." A more detailed notification is required for the crew. Notification
must be reasonably calculated to reach all persons served by the aircraft water system and
must be provided with one or more of the following forms of delivery:
1) Broadcast over a public announcement (PA) system on aircraft;
2) Posting of the notice in conspicuous locations (such as all the galleys and lavatories in
the affected aircraft);
3) Hand delivery of the notice to passengers and crew; or
4) Another delivery method approved in writing by EPA.
All posted notices must continue and must remain visible until all follow-up coliform
samples are negative for total coliform. Likewise, all public address announcements must
be repeated on each flight until follow-up samples are negative for total coliform.
All events requiring notification to passengers and crew must also be reported to EPA
within 10 days of the event triggering the notification, such as the air carrier being
informed of sample results by the laboratory. This reporting must include an indication of
whether the required notification was provided to passengers and crew. This does not
require that a copy of a notification be provided to EPA. However, a copy must be
available for EPA review as part of an audit. Copies of notices must be kept for at least
three years after issuance. See Chapter 7 for more information on reporting requirements.
6.2.2 Public Notice Format and Content
Each notice to passengers:
1) Must be displayed in a conspicuous way when printed or posted;
2) Must not contain overly technical language or very small print;
3) Must not be formatted in a way that defeats the purpose of the notice;
4) Must not contain language that nullifies the purpose of the notice; and
5) Must contain information in the appropriate language(s) regarding the importance of
the notice reflecting a good faith effort to reach the non-English speaking population
served, including where applicable, an easily recognized symbol for non-potable
water.
Notice to passengers is not applicable if access to the water is physically prevented by
shutting-off of the water, or if water is supplied only to the lavatory toilets and not to any
lavatory taps.
EPA also recommends that if public access to the water is restricted or limited to
handwashing only, all paper cups or paper cones be removed from the lavatories and
faucet areas to reinforce the message that the water should not be consumed.
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In addition to placards or postings for aircraft passengers, each notice to the crew must
provide complete information about the event or situation that triggered the notice. The
ADWR requires additional information to be provided to the crew to ensure they are able
to answer passenger questions, thoroughly understand the situation to appropriately
implement restrictions and other activities, and make informed decisions regarding their
exposure to the water. The notice provided to the crew must include the following
elements:
1) A clear statement that the water is non-potable and should not be used for drinking,
food or beverage preparation, hand washing, teeth brushing, or any other consumptive
use;
2) A description of the violation or situation triggering the notice, including the
contaminant(s) of concern;
3) When and where the violation or situation occurred;
4) Any potential adverse health effects from the violation or situation, as appropriate;
5) The population at risk, including sensitive subpopulations particularly vulnerable if
exposed to the contaminant in the drinking water;
6) What the air carrier is doing to correct the violation or situation; and
7) When the air carrier expects to return to compliance or resolve the situation.
6.3 Required Language for Public Notification
The rule contains standard language that must be used for each situation where public
notice to the crew is required. Standardized language ensures that the crew (and,
indirectly, the passengers) receives a consistent message. This section provides the
language for each type of situation.
Some of the standard language paragraphs contain bracketed sections. The brackets
indicate where the necessary information specific to each event should be inserted, or
where an applicable phrase could be selected. If the bracketed phrases request
information, such as dates or number of samples, the required information should be
inserted and then the brackets deleted. Including the language in this section does not
completely fulfill the public notification requirements—all the elements described in
section 6.2 must also be addressed.
Appendix B [TO BE DEVELOPED] of this manual contains samples of notices designed
for posting. The text of an example public address announcement is included in section
6.4.
6.3.1 Detection of total conforms only (not fecal conforms or E. coli)
Use the following language when any routine or repeat sample is total coliform-positive,
but is negative for fecal coliforms and E. coli:
Coliform are bacteria that are naturally present in the environment and are used as
an indicator that other, potentially harmful, bacteria may be present. Coliforms were
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found in [INSERT NUMBER OF POSITIVE ROUTINE AND REPEAT SAMPLES]
samples collected and this is a warning of potential problems. If human pathogens
are present, they can cause short-term health effects, such as diarrhea, cramps,
nausea, headaches, or other symptoms. They may pose a special health risk for
infants, young children, some of the elderly, and people with severely compromised
immune systems.
6.3.2 Routine or Repeat Sample Positive for E. coli or Fecal Coliform
Use the following language for any routine or repeat sample that is positive for E. coli or
fecal coliform bacteria (note that in this situation, the notice for total coliform-positive
samples is not also issued, even though these samples would have been total coliform-
positive):
Fecal coliform andE. coli are bacteria whose presence indicates that the water may
be contaminated with human or animal wastes. Microbes in these wastes can cause
short-term health effects, such as diarrhea, cramps, nausea, headaches, or other
symptoms. They may pose a special health risk for infants, young children, some of
the elderly, and people with severely compromised immune systems.
6.3.3 Failure to Monitor, Improper Testing Procedures, or Failure to
Disinfect and Flush
Public notices for monitoring, disinfection and flushing, or testing procedure violations
must include the following text. Select the appropriate phrase from the options inside the
brackets and delete the inapplicable phrases:
Because [REQUIRED MONITORING AND ANALYSIS WAS NOT CONDUCTED],
[REQUIRED DISINFECTION AND FLUSHING WAS NOT CONDUCTED],
[WATER WAS BOARDED FROM A WATERING POINT NOT APPROVED BY FDA]
or [other appropriate explanation], we cannot be sure of the quality of the drinking
water at this time. However drinking water contaminated with human pathogens can
cause short-term health effects, such as diarrhea, cramps, nausea, headaches, or
other symptoms. They may pose a special health risk for infants, young children,
some of the elderly, and people with severely compromised immune systems. This
water may be used for hand washing, but not for drinking, food or beverage
preparation, or teeth brushing.
6.4 Public Address Announcement for Positive E. coli Samples
Sample language for a violation involving an E. co//-positive sample is provided below.
This is suggested language to be announced during each flight, but announcement of the
violation is not required if the message is also posted or if public access to the water
system is restricted.
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The water on this aircraft is non-potable and should not be used for drinking,
food or beverage preparation, handwashing, teeth brushing, or any other
consumptive use.
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Chapter 7 Recordkeeping and Reporting
This chapter discusses the recordkeeping and reporting requirements associated with the
ADWR. The rule language can be found in 40 CFR 141.806 and 40 CFR 141.807 (see
Appendix A).
7.1 Air Carrier Recordkeeping
Air carriers must keep records of information as specified below. The records retention
system should be designed and organized to enable retrieval of specific records for each
aircraft upon request by EPA. Records include hard copy or electronic files.
• Records of bacteriological analyses must be kept for at least 5 years. The following
information must be retained:
o The date, time and place of sampling, and the name of the person who collected
the sample;
o Identification of the sample as a routine, repeat, follow-up or other special
purpose sample;
o Date of the analysis;
o Laboratory and person responsible for performing the analysis;
o The analytical technique/method used; and
o The results of the analysis.
• Records of disinfection and flushing must be kept for at least 5 years (see Exhibit
7.1 for example format and content)
• Records of self-inspections must be kept for at least 10 years
• Copies of public notices provided to passengers and crew must be kept for at least 3
years after issuance.
• Copies of coliform sampling plans must be available for review by EPA during
compliance audits and upon request.
• Copies of aircraft water system O&M plans must be maintained in accordance with
FAA requirements and available for review by EPA during compliance audits and
upon request.
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Exhibit 7.1 Example Format for Disinfection and Flushing Records
Aircraft Identification Number:
Date and
Time
Routine
(R)or
Corrective
(C)
Disinfectant
Type and
Dose
Contact
Time
Completed
by (Initials)
Follow-up
Samples
Collected
(Date/Time)
Follow-up
Samples
Results
7.2 Reporting Requirements
All reporting to EPA must be submitted in an electronic format established or approved
by EPA. If an air carrier is unable to report electronically, an alternative approach may be
used if approved in advance by EPA.
[PLACEHOLDER FOR MORE INFORMATION ON THE DATABASE AND
REPORTING FORMATS - THAT INFORMATION MAY WARRANT RE-WRITING
OF THIS CHAPTER]
7.2.1 Coliform Sampling and O&M Plans
Although copies of coliform sampling plans and O&M plans must be retained, they are
not required to be submitted to EPA. However, EPA must be informed when the plans
are completed, or changed, and EPA may request a copy of the plan at any time.
In addition, for each aircraft water system, the proposed routine coliform sampling
frequency must be reported to EPA. The frequency of coliform monitoring and routine
disinfection and flushing will be tracked and compared to the minimum requirements of
the rule for use as the basis for determining compliance with the provisions of the
ADWR.
For existing aircraft, both sampling frequencies and coliform sampling plan completion
must be reported to EPA within 6 months after final rule publication. For new aircraft
placed into operation after promulgation of the ADWR, sampling frequencies and plan
completion must be reported within the first calendar quarter of initial operation of the
aircraft. See Chapters 4 and 5 for more information on coliform sampling and O&M plan
requirements.
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7.2.2 Aircraft Inventory
The air carrier must report its complete inventory of aircraft that are PWSs to EPA no
later than six months after publication of the final rule in the Federal Register. Inventory
information includes, but is not limited to the following:
• The unique aircraft identifier number;
• The status of the aircraft as active or inactive; and
• The type and location of any treatment equipment installed on the water system.
Any changes in aircraft inventory must be reported no later than 10 days following the
calendar month in which the change occurred. Required information includes, but is not
limited to the following:
• Status of aircraft water systems as active or inactive, and
• Type and location of any treatment equipment added to or removed from the water
system.
See Chapter 3 for more information on reporting requirements.
7.2.3 Coliform Sampling Results and Violations
In most cases, all coliform sampling results (routine, repeat, and follow-up) must be
reported no later than 10 calendar days after the end of the monitoring period in which
the samples were collected. The monitoring period is based on the monitoring frequency
identified in the coliform sampling plan and may vary for different aircraft in an air
carrier fleet. Thus, the monitoring period could be one month, one quarter (three months),
or 1 year.
If sample results trigger disinfection and flushing or public notification, the event must be
reported to EPA within 10 days of being informed of sample results by the laboratory.
Such events include any routine or repeat sample positive for E. coli or fecal coliform.
Failure to comply with the monitoring or disinfection and flushing requirements of this
regulation must also be reported to EPA within 10 calendar days. Failure to comply with
monitoring requirements includes, but is not limited to, failure to take routine samples
according to the schedule in the coliform sampling plan, failure to take repeat samples
and follow-up samples within the time required, and failure to use EPA-approved
analytical methods. Failure to comply with disinfection and flushing requirements
includes failure to perform routine disinfection and flushing according to the schedule in
the O&M plan, and failure to conduct corrective disinfection and flushing.
7.2.4 Self-Inspection and Compliance Audit Results
Air carriers must provide evidence of a self-inspection to EPA within 90 days of
completion of the self-inspection (self-inspections of aircraft water systems are required
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every 5 years). The report must include an indication that all deficiencies identified in
the inspection have been addressed.
If any deficiencies have not been addressed within 90 days of a compliance audit or self-
inspection, the air carrier must report a description of each unaddressed deficiency, an
explanation as to why it has not been addressed, and a schedule for addressing each
deficiency as quickly as possible.
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Chapter 8 Violations of the Rule
Implementation and enforcement of National Primary Drinking Water Regulations
applicable to interstate conveyance carriers is a responsibility of the EPA. In addition, the
ADWR allows for improved coordination of federal programs in the FAA and FDA to
regulate aircraft water systems. This chapter describes violations of the ADWR.
When a violation of ADWR requirements occurs, several actions may be required
including formal notification of the aircraft passengers and crew, corrective actions to
bring the aircraft water system into compliance with the rule, and notification to EPA of
actions taken. Exhibit 8.1 summarizes rule violations, public notification requirements
and recommended corrective actions. The exhibit also provides references for further
information.
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Exhibit 8.1 Violations of the ADWR
Violation
Failure to disinfect and flush. This includes
failure to conduct routine disinfection and
flushing as specified in the O&M plan and
failure to conduct corrective disinfection and
flushing.
Failure to monitor for coliforms. This
includes failure to monitor according to the
frequency in the coliform monitoring plan,
along with failure to analyze total coliform-
positive samples for fecal coliform or E. coli,
failure to conduct repeat sampling after routine
samples are found to be positive for total
coliform, and failure to conduct follow-up
monitoring after disinfection and flushing.
Failure to conduct a self-inspection or
address a deficiency in accordance with
your O&M plan. Self-inspections are
required every 5 years. Deficiencies noted
during self-inspections must be corrected
within 90 days.
Failure to develop a coliform sampling plan.
Coliform sampling plans must be developed
within 6 months of ADWR promulgation.
Failure to develop operation and
Public
Notice
Required?
Yes
Yes
No
No
No
Corrective Action
(1) Notify passengers and crew as
expeditiously as possible, but in no case later
than 24 hours after discovery of failure to
disinfect and flush or after being notified by
EPA of failure to disinfect and flush, (2)
conduct disinfection and flushing within 72
hours, (3) collect follow-up samples.
(1) Notify passengers and crew as
expeditiously as possible, but in no case later
than 24 hours after discovery of failure to
collect required samples or after being
notified by EPA of failure to collect required
samples, whichever comes first, (2) conduct
disinfection and flushing within 72 hours, (3)
collect follow-up samples.
Conduct a self-inspection and provide
evidence to EPA the self-inspection was
completed. Report to EPA a description of
any deficiencies not addressed, an
explanation as to why it has not yet been
addressed, and a schedule for addressing any
deficiencies as expeditiously as possible.
Develop a coliform sampling plan and notify
EPA the plan has been completed.
Develop an operation and maintenance plan
Chapter
Reference for
Further
Information
Chapter 4,
Chapter 5
Chapter 4
Chapter 5
Chapter 4
Chapter 5
ADWR
Reference
§141.810(a)(l)
§141.810(a)(2)
§141.810(b)(3)
§141.810(b)(4)
§141.810(b)(4)
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Violation
maintenance plan.
— For existing aircraft, O&M plans must be
developed within 6 months of ADWR
promulgation.
— For new aircraft, the air carrier must develop
the operations and maintenance plan required
by §141.804 within the first calendar quarter
of initial operation of the aircraft.
It fails to perform any of the requirements in
accordance with §141.803(c) - coliform
sample results
One or more fecal coliform-positive or E.
co/i-positive sample in any monitoring
period (routine and repeat samples are used
in this determination).
Failure to provide notification to passengers
and crew.
Failure to comply with the reporting and
recordkeeping requirements.
Public
Notice
Required?
Yes
Yes
No
No
Corrective Action
and notify EPA it has been completed.
Perform the requirements specified.
(1) Restrict public access to the aircraft water
system as expeditiously as possible, but in no
case later than 24 hours after being notified
of the positive result by the laboratory;
(2) Conduct disinfection and flushing prior to
resumption of unrestricted public access to
the aircraft water system, or no later than 72
hours if the aircraft water system cannot be
physically disconnected/shut off to the crew
and passengers; and
(3) Collect follow-up samples.
Implement the correction necessary to
remove the need for public notification.
Implement a reporting and recordkeeping
process and procedure.
Chapter
Reference for
Further
Information
Chapter 4
Chapter 4
Chapter 6
Chapter 7
ADWR
Reference
§141.810(a)(3)
§141.810(a)(4)
§141.810(b)(l)
§141.810(b)(2)
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Chapter 9 Suggested Engineering and Management
Practices
This chapter offers guidance on expanding engineering and management practices for
aircraft water systems above and beyond the regulatory requirements to improve
protection of public health. These suggested practices include water quality maintenance,
supplemental treatment, operations and maintenance, recordkeeping and public
notification. Although many of the recommendations may apply to a given aircraft water
system or specific condition, all recommendations will not be applicable to all systems.
Recommended practices may need to be modified to reflect the characteristics of an
individual system.
9.1 Maintaining Water Quality
Disinfection Residual
Maintaining a disinfectant residual in the water distribution system can have several
benefits including inactivation of microorganisms and controlling biofilm growth. It
provides health protection in the event that a contaminant such as a waterborne pathogen
enters the water system.
The operation of an aircraft water system can potentially decrease the disinfectant
residual in the boarded water. If the water is held in the system for an excessive period of
time, the disinfectant residual may decrease. Although the aircraft water system is
exposed to various levels of atmospheric pressure during flight, there is no documented
evidence that these pressure changes affect water quality or the disinfectant residual.
Onboard treatment devices may potentially affect the water's disinfectant residual.
Contact the treatment system manufacturer to determine if there is any effect on the
disinfectant residual.
Disinfectant residual monitoring is not required by the proposed ADWR because aircraft
may board water from multiple locations, some of which may use groundwater supplies
that are not required to maintain a disinfectant residual. However, some air carriers may
choose to monitor disinfectant residual in the aircraft water system to collect additional
information on water quality and potential public health risks. A low disinfectant residual
or no residual may prompt the air carrier to conduct voluntary flushing and refilling the
aircraft water system with water containing a disinfectant residual. This information may
also help the air carrier determine the appropriate frequency for periodic system flushing
and disinfection, to warn of potential contamination when disinfectant residual suddenly
decreases, and as a general measure of water quality. Disinfectant residual monitoring is
inexpensive and easy to perform in the field using industry standard methods.
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Recommendations for booster (supplemental) disinfection systems are discussed below
with other supplemental treatment topics.
Water Age Management
Under certain conditions, the design and/or operation of aircraft water systems can cause
water to be held for excessive periods of time. Increased water age is a major factor in
water quality degradation such as formation of disinfection byproducts (DBFs),
accumulation of sediments, microbial growth such as biofilms, nitrification, taste and
odor problems, and increased disinfectant decay.
Some air carriers allow "topping off' or adding water to the onboard storage tank without
draining it. This practice can cause stored water to have a longer water age. Many air
carriers have existing procedures for draining a water system if the aircraft is going to be
parked for an extended period of time or due to air temperatures. These practices protect
the aircraft water system piping from breakage due to freezing, and also help to minimize
water age. Draining of tanks every three days is a common practice for some air carriers.
Recommended practices to minimize water age include the following:
1. Drain and refill tank every day if air temperature is above freezing.
2. Due to the weight of water, air carriers typically limit the amount carried to what
is needed but this also is a good practice for minimizing water age.
3. Periodic flushing and disinfection per manufacturer's recommendations is
required, but may be appropriately practiced more often than recommended.
4. Increase the draining interval at airport locations with higher air temperatures
where aircraft are parked overnight or long-term.
Biofilm Management
".. .a water distribution system biofilm is a complex mixture of microbes, organic and
inorganic material accumulated amidst a microbially produced organic polymer matrix
attached to the inner surface of the distribution system... .Biofilm likely exist in all
distribution systems and are accepted as a normal part of the distribution system."
(USEPA OGWDW 2002). Biofilm can entrain substances in the water including
waterborne pathogens, and later release these substances into the water, causing water
quality problems such as tastes and odors, and increased disinfectant demand. Biofilm
can protect microbes from disinfection, can increase pipe corrosion and can affect pipe
hydraulics. Microbes can enter distribution systems through physical gaps in the
distribution system piping or tank, or due to contamination during the water transfer
process at the airport. Microbial growth and biofilm development are a concern when
aircraft water system experiences excessive water age, higher temperatures, and when
nutrients are present in the water.
9.2 Considerations for Supplemental Treatment
In cases where supplemental treatment is added to an aircraft, an additional barrier
against contamination will be provided and potential risks to public health may decrease.
Aside from charcoal/carbon, canister, and particle removal filters in some galleys and
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lavatories, the majority of aircraft do not provide additional treatment for boarded water.
Barriers to installing supplemental treatment include the cost of treatment units (e.g.,
ultraviolet light disinfection systems) and the logistical challenges to install them in
aircraft.
Some new aircraft are manufactured with water purification systems onboard. These
systems are operating under the assumption that they are treating potable water and are in
addition to any requirements to be included in the Aircraft Drinking Water Rule. In other
cases, an air carrier may decide to add supplemental treatment to an existing aircraft
water system to improve drinking water quality. In both new and existing aircraft, the
design and installation of water treatment components must be approved by FDA.
9.3 Considerations for Supplemental Operator Training and
Maintenance
Training operations and maintenance personnel on the details of supplemental treatment
equipment installed on aircraft water systems is an important part of ensuring the
equipment is properly installed, maintained, and inspected. Manufacturer's
recommendations for installation and maintenance, as well as any troubleshooting
concepts should be reviewed periodically and incorporated in to the training program as
well as the operations and maintenance plan for the aircraft.
The consequences of improperly installed treatment equipment can include contributing
to the degradation of the quality of the water, such as when biofilm growth is encouraged
or protected by the device.
9.4 Considerations for Supplemental Recordkeeping
Water Boarding Locations/Volume Records
An effective system of communication is critical amongst air carriers, the PWSs that
provide drinking water to the airports, and the airports. If an air carrier were to receive
advance notice that water did not meet drinking water standards, they may be able to plan
water boarding at alternate locations. Procedures for handling water contamination events
should be part of both airport and air carrier emergency response plans. Also, it is critical
that the airport emergency response coordinator ensures that the operator for the PWS
that serves the airport knows who to contact at the airport in the event of a water
emergency such as a treatment failure or a water main break. Likewise, air carriers must
ensure that airport authorities know who to notify at each air carrier in the event of a
water contamination event.
Air carriers are not currently required to record the volume of water boarded onto
aircraft, the date/time of boarding or the location of boarding. This information may be
valuable to the airline in the event that onboard water is later implicated in a public health
problem, or the onboard water is tested and found to contain coliform bacteria. If the
water can be traced back to a particular location, the water quality issue could be traced
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back to the source of the problem and resolved, thereby limiting the number of aircraft
water systems that board the problem water.
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References
USEPA Office of Groundwater and Drinking Water. 2002a. Health Risks From
Microbial Growth and Biofilms in Drinking Water Distribution Systems. Available at:
http://www.epa.gov/safewater/disinfecti on/tcr/pdfs/whitepaper_tcr_biofilms.pdf.
USEPA Office of Groundwater and Drinking Water. 2002b. Effects of Water Age on
Distribution System Water Quality. Available at:
http://www.epa.gov/safewater/disinfection/tcr/pdfs/whitepaper tcr waterdistribution.pdf
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