United States
Environmental Proteeiion
Agency
Fact Sheet: Aircraft Drinking Water
Rule
The Environmental Protection Agency (EPA) is proposing to amend the National Primary
Drinking Water Regulations (NPDWRs) for aircraft public water systems under the Safe
Drinking Water Act (SDWA). Aircraft public water systems are subject to the requirements
of SDWA and the NPDWRs.
Why is EPA proposing the ADWR?
The primary purpose of the 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 SDWA and NPDWRs. The existing NPDWRs were designed for
traditional, stationary public water systems (PWSs), not mobile aircraft water systems that are
operationally very different. Aircraft must maintain rigorous operating schedules. They fly to
multiple destinations throughout the course of any given day and may board drinking water
from sources at any of these destinations. Aircraft board water from airport watering points
via temporary connections. Aircraft drinking water safety depends on a number of factors
including the quality of the water that is boarded from these multiple sources, the care used to
board the water, and the operation and maintenance of the onboard water system and the
water transfer equipment (such as water cabinets, trucks, carts, and hoses). These unique
operational characteristics present different challenges that necessitate tailoring of the
NPDWRs for aircraft PWSs in the ADWR.
What concerns does this proposal address?
During a reevaluation of the drinking water requirements for interstate carrier conveyances,
EPA worked with air carriers and concluded that it is not feasible for air carriers to comply
with all of the monitoring that is required in the existing regulations. Subsequently, in 2004,
EPA tested 327 aircraft of which 15 percent tested positive for total coliform. EPA considers
this to be a high percentage of positive samples.
In response to these findings, EPA embarked on an accelerated process to tailor the existing
regulations for aircraft public water systems. In the interim, EPA placed 45 air carriers under
Administrative Orders on Consent (AOC) that will remain in effect until tailored aircraft drinking
water regulations are final.
Who will be affected by this rule?
Aircraft which convey passengers in interstate commerce and are public water systems that board
only finished water will be affected by this rule. Aircraft that do not provide water for human
consumption or those with water systems that do not regularly serve an average of at least twenty-
five individuals daily do not meet the definition of a PWS. The ADWR only addresses aircraft
within U.S. jurisdiction; however, EPA is supporting an international effort led by the World Health
Organization to develop international guidelines for aircraft drinking water. The ADWR applies to
the aircraft's onboard water system only. The components include: water service panel, storage
tanks, pipes, valves, treatment devices, and plumbing fixtures within the aircraft that supply water to
passengers or crew. The Food and Drug Administration (FDA) is responsible for regulating the
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watering points that include the water cabinets, carts, trucks, and hoses from which aircraft board
water. EPA and the states are responsible for regulating the public water systems that supply
drinking water to the airport watering points.
How much will the rule cost water suppliers and consumers?
EPA assumes that air carriers will pass on some or all of the costs of a new regulation to their
passengers in the form of ticket price increases. EPA estimates that 708.4 million passengers
travel each year on aircraft that are affected by the ADWR. EPA estimates air carriers' total
annualized cost of the ADWR to be about $8.0 million using a 7 percent discount rate. The
cost passed on to passengers can be roughly estimated by dividing the air carriers' annualized
costs incurred by the number of passengers traveling each year. Based on this approximation,
EPA estimates that passengers could face a relatively negligible increase of about one cent per
ticket.
What does the rule require?
The rule combines coliform sampling, best management practices, corrective action, public
notification, operator training, and reporting and recordkeeping to improve public health
protection. EPA believes that this rule provides the flexibility to meet the ever changing
needs of the air carrier industry while still providing adequate barriers of protection.
What is the frequency for coliform sampling?
The frequency of coliform monitoring is tied to the frequency of disinfection and flushing of
the aircraft water system as follows:
Frequency for Aircraft PWS Routine Coliform Sampling
and Routine Disinfection and Flushing
Disinfection and Flushing Frequency
At least quarterly
One to three times per year
Less than once per year
Coliform Sampling
Frequency
Annually
Quarterly
Monthly
Two coliform samples are taken per monitoring period: One sample must be taken from a
lavatory and one sample from a galley. Any total coliform-positive sample must be further
analyzed for the presence of fecal coliform or E. coli. The frequency of disinfection must be
no less than the minimum recommended by the manufacturer, though it may be more
frequent. This allows for equipment-specific designs and for flexible implementation with the
evolution of technology.
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What triggers corrective action and public notification?
Corrective Action and Public Notification Requirements for Aircraft
PWS
Monitoring Result
Corrective Action
Public Notification
If no more than one routine
sample is total coliform-
positive, and it is fecal
coliform/E1. co//'-negative
Perform disinfection and
flushing no later than 72 hours
after being notified by lab of
total coliform-positive result;
and
Collect follow-up samples.
or
Collect 4 repeat monitoring
samples no later than 24 hours
after being notified by lab of
total coliform-positive result
None Required.
If more than one routine
sample result or a
combination of routine and
repeat samples is total
coliform-positive (but all are
fecal coliform/E1. coli-
negative)
Restrict public access to
water system no later than 24
hours after being notified by
lab of positive result;
Perform disinfection and
flushing prior to resumption
of unrestricted access to water
system, or no later than 72
hours if water system cannot
be shut off to passengers and
crew; and
Collect follow-up samples.
Within 24 hours,
public notification
issued until all follow-up
samples are negative for
total coliform.
One or more routine or
repeat sample result is fecal
coliform/E1. co//'-positive
Restrict public access to
water system no later than 24
hours after being notified by
lab of positive result;
Perform disinfection and
flushing prior to resumption
of unrestricted access to water
system; or no later than 72
hours if water system cannot
be shut off to passengers and
crew; and
Collect follow-up samples.
Within 24 hours,
public notification
issued until all follow-up
samples are negative for
total coliform.
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Corrective Action and Public Notification Requirements for Aircraft
PWS
Monitoring Result
Corrective Action
Public Notification
Failure to collect required
routine samples
Perform disinfection and
flushing within 72 hours.; and
Collect follow-up samples.
Notify passengers and
crew no later than 24
hours after discovery of
failure to collect
required samples or after
being notified by EPA
of failure to collect
required samples,
continue public
notification until all
follow-up samples are
negative for total
coliform.
Failure to collect repeat or
follow-up samples
Restrict public access to the
water system no later than 24
hours after discovery of
failure to collect required
samples or after being notified
by EPA of failure to collect
required samples.
Perform disinfection and
flushing prior to resumption
of unrestricted access to water
system; or no later than 72
hours if water system cannot
be shut off to passengers and
crew; and
Collect follow-up samples.
Within 24 hours,
public notification
issued until all follow-up
samples are negative for
total coliform.
What coliform sampling plans and operations and maintenance plans need to be
developed?
Each air carrier, for each aircraft that it owns or operates, must have a coliform sampling plan
and an aircraft PWS operation and maintenance plan within six months after the final rule is
published for each existing aircraft public water system, and within the first calendar quarter
of initial operation for new aircraft PWS. These plans must be included in a Federal Aviation
Administration-approved or accepted aircraft operations and maintenance program. The
frequency for routine coliform sampling must also be reported to EPA.
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What types of inspections or audits are required by the rule?
Each air carrier must conduct a self-inspection of each aircraft water system no less frequently
than once every 5 calendar years. In addition, EPA may conduct compliance audits as deemed
necessary. The air carrier must address significant deficiencies found as a result of routine
compliance audits or self-inspections within 90 days of identification of the deficiency.
How will information (inventory data, sampling data, etc) be transmitted to EPA?
Reporting will begin 6 months following promulgation of the ADWR. As the primacy
agency, EPA has oversight responsibility for aircraft PWS reporting information. To
facilitate collection and analysis of aircraft PWS 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. This is intended to reduce the reporting errors and limit the time involved
in investigating, checking, and correcting errors at all levels. If an air carrier determines that
it or its laboratory does not have the capability to report data electronically, the air carrier can
submit a request to EPA to use an alternate reporting format. Regardless of the reporting
process used, air carriers are to report the required information based on the schedule as
stipulated in the ADWR.
How can I get more information?
The proposed rule and other supporting information are available on EPA's Web site at
http://www.epa.gov/safewater/airlinewater/index2.html. For additional information, contact
the Safe Drinking Water Hotline toll free Monday through Friday, 10:00 am to 4:00 pm
eastern time (except Federal holidays) at 1-800-426-4791.
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