oEPA
FACT SHEET:  FINAL AIRCRAFT
    SSSS5,«—   DRINKING WATER RULE
    Agency

The Environmental Protection Agency (EPA) is publishing the final 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 publishing 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 the NPDWRs
for aircraft PWSs in the final ADWR.

What concerns does the ADWR address?
In 2004, EPA found all aircraft PWSs to be out of compliance with the NPDWRs.  According
to the air carriers, it is not feasible for them to comply with all of the monitoring that is
required in the existing regulations.  Subsequently, 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 (AOCs). Until the final ADWR
compliance dates, air carriers remain subject to the existing national primary drinking water
regulations or their respective AOCs.

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 final ADWR. 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 final ADWR only addresses
aircraft within U.S. jurisdiction.

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 watering points that include the water cabinets, carts, trucks, and hoses
Office of Water (4606)              EPA 816-F-09-011                 October 2009

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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 ADWR cost air carriers 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 to implement the ADWR to be about $6.95 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 final 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 required for coliform sampling?
The frequency of coliform monitoring is tied to the frequency of disinfection and flushing of
the aircraft water system, as follows:
Routine Disinfection and Flushing and Routine Sample Frequencies
Minimum Routine Disinfection & Flushing
Per Aircraft
At least 4 times per year = At least once within
every three-month period (quarterly)
At least 3 times per year = At least once within
every four-month period
At least 2 times per year = At least once within
every six-month period (semi-annually)
At least 1 time per year or less = At least once
within every twelve-month period (annually)or
less
Minimum Frequency of Routine Samples Per
Aircraft
At least 1 time per year = At least once within
every twelve-month period (annually)
At least 2 times per year = At least once within
every six -month period (semi-annually)
At least 4 times per year = At least once within
every three-month period (quarterly)
At least 12 times per year = At least once every
month (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 E. coli. The air carrier must conduct disinfection and flushing of
the aircraft water system in accordance with, or consistent with, the water system
manufacturer's recommendations.  This allows for equipment-specific designs and for flexible
implementation with the evolution of technology. In cases where a recommended routine
disinfection and flushing frequency is not specified by the aircraft water system manufacturer,
the air carrier is given the flexibility to choose a disinfection and flushing frequency, and
corresponding monitoring frequency, specified in the above table.
Office of Water (4606)
EPA816-F-09-011
October 2009

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What triggers corrective action and public notification?
              Initial Corrective Action and Public Notification Requirements for Aircraft Water Systems
     * Additional corrective actions based on repeat sample results or follow-up sample results are not reflected in this table.	
          Monitoring Result or Failure
                     Corrective Action
                              Public Notification
     If any routine sample is total coliform-
     positive and E. 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
           — Restrict public access to the water
           system no later than 72 hours after being
           notified by lab of total coliform-positive
           result; all public access restrictions must
           remain in-place until the aircraft water
           system has been disinfected and flushed
           and a complete set of follow-up samples
           has been collected;
           or
           — Collect 3 repeat monitoring samples no
           later than 24 hours after being notified by
           lab of total coliform-positive result.	
                    If the air carrier chooses to restrict public
                    access to the water system, the air carrier
                    must initiate public notification at that
                    time (i.e., no later than 72 hours after
                    being notified by lab of total coliform-
                    positive result) and continue until the
                    aircraft water system is returned to
                    unrestricted public access.
Office of Water (4606)
EPA816-F-09-011
October 2009

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              Initial Corrective Action and Public Notification Requirements for Aircraft Water Systems
     * Additional corrective actions based on repeat sample results or follow-up sample results are not reflected in this table.	
          Monitoring Result or Failure
                      Corrective Action
                               Public Notification
     If any routine sample is E. co//'-positive
           — Restrict public access to the water
           system no later than 24 hours after being
           notified by lab of E. co//-positive result;
           all public access restrictions must remain
           in-place until the aircraft water system has
           been disinfected and flushed and a
           complete set of follow-up samples is total
           coliform-negative;
           and
           - If the aircraft water system cannot be
           physically disconnected or shut-off, or the
           flow of water otherwise prevented through
           the tap(s), the air carrier must disinfect
           and flush the system no later than 72
           hours after the lab notifies the air carrier
           of the E. co//-positive result;
           and
           - Collect follow-up samples.
                    Initiate public notification when
                    restriction of public access is initiated
                    (i.e., no later than 24 hours after being
                    notified by lab of E. co//'-positive result)
                    and continue until the aircraft water
                    system is returned to unrestricted public
                    access.
    Failure to perform routine disinfection and
    flushing or failure to collect and analyze
    the required routine coliform samples
           Restrict public access to the water system
           no later than 72 hours after discovery of
           the failure; all public access restrictions
           must remain in-place until the aircraft
           water system has been disinfected and
           flushed and a complete set of follow-up
           samples has been collected.
                    Initiate public notification when
                    restriction of public access is initiated
                    (i.e., no later than 72 hours after discovery
                    of the failure) and continue until the
                    aircraft water system is returned to
                    unrestricted public access.
Office of Water (4606)
EPA816-F-09-011
October 2009

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              Initial Corrective Action and Public Notification Requirements for Aircraft Water Systems
     * Additional corrective actions based on repeat sample results or follow-up sample results are not reflected in this table.	
          Monitoring Result or Failure
                      Corrective Action
                               Public Notification
    Failure to collect and analyze the required
    follow-up samples as a result of an E.
    co//'-positive result
           — Restrict public access to the water
           system no later than 24 hours after
           discovery of the failure; all public access
           restrictions must remain in-place until the
           aircraft water system has been disinfected
           and flushed and a complete set of follow-
           up samples is total coliform-negative;
           and
           — If the aircraft water system cannot be
           physically disconnected or shut-off, or the
           flow of water otherwise prevented through
           the tap(s), the air carrier must disinfect
           and flush the system no later than 72
           hours after the lab notifies the air carrier
           of the E. co//'-positive result;
           and
           — Collect follow-up samples.
                    Initiate public notification when
                    restriction of public access is initiated
                    (i.e., no later than 24 hours after discovery
                    of the failure) and continue until the
                    aircraft water system is returned to
                    unrestricted public access.
    Failure to collect and analyze the required
    repeat or follow-up samples as a result of
    a total coliform-positive and E. coli-
    negative result
           Restrict public access to the water system
           no later than 72 hours after discovery of
           the failure; all public access restrictions
           must remain in-place until the aircraft
           water system has been disinfected and
           flushed and a complete set of follow-up
           samples has been collected.
                    Initiate public notification when
                    restriction of public access is initiated
                    (i.e., no later than 72 hours after discovery
                    of the failure) and continue until the
                    aircraft water system is returned to
                    unrestricted public access.
Office of Water (4606)
EPA816-F-09-011
October 2009

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             Initial Corrective Action and Public Notification Requirements for Aircraft Water Systems
     * Additional corrective actions based on repeat sample results or follow-up sample results are not reflected in this table.	
          Monitoring Result or Failure
                     Corrective Action
                              Public Notification
    When the air carrier becomes aware of an
    E. co//'-positive event resulting from:
    (1) boarding water from a watering point
    not in accordance with FDA regulations
    (21 CFR part 1240 subpart E), or

    (2) boarding water that does not meet
    NPDWRs applicable to transient non-
    community water systems (§§141.62 and
    141.63, as applied to TNCWS), or

    (3) boarding water that is otherwise
    determined to be unsafe due to non-
    compliance with the procedures specified
    in§141.804(b)(6).
          — Restrict public access to the water
          system no later than 24 hours after
          discovery of the failure; all public access
          restrictions must remain in-place until the
          aircraft water system has been disinfected
          and flushed and a complete set of follow-
          up  samples is total coliform-negative;
          and
          — If the aircraft water system cannot be
          physically disconnected or shut-off, or the
          flow of water otherwise prevented through
          the tap(s), the air carrier must disinfect
          and flush the system no later than 72
          hours after the lab notifies the air carrier
          of the E. co//'-positive result;
          and
          — Collect follow-up samples.
                    Initiate public notification when
                    restriction of public access is initiated
                    (i.e., no later than 24 hours after discovery
                    of the failure) and continue until the
                    aircraft water system is returned to
                    unrestricted public access.
Office of Water (4606)
EPA816-F-09-011
October 2009

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             Initial Corrective Action and Public Notification Requirements for Aircraft Water Systems
     * Additional corrective actions based on repeat sample results or follow-up sample results are not reflected in this table.	
          Monitoring Result or Failure
                     Corrective Action
                              Public Notification
    When the air carrier becomes aware of a
    non-E. co//'-positive event resulting from:
    (1) boarding water from a watering point
    not in accordance with FDA regulations
    (21 CFR part 1240 subpart E), or

    (2) boarding water that does not meet
    NPDWRs applicable to transient non-
    community water systems (§§141.62 and
    141.63, as applied to TNCWS), or

    (3) boarding water that is otherwise
    determined to be unsafe due to non-
    compliance with the procedures specified
    in§141.804(b)(6).   	
          Restrict public access to the water system
          no later than 72 hours after discovery of
          the failure; all public access restrictions
          must remain in-place until the aircraft
          water system has been disinfected and
          flushed and a complete set of follow-up
          samples has been collected.
                    Initiate public notification when
                    restriction of public access is initiated
                    (i.e., no later than 72 hours after discovery
                    of the failure) and continue until the
                    aircraft water system is returned to
                    unrestricted public access.
Office of Water (4606)
EPA816-F-09-011
October 2009

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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 water system operation and maintenance plan within 18 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-accepted aircraft operations and maintenance program. The
frequency for routine coliform sampling must also be reported to EPA.

What types of inspections or audits are required by the ADWR?
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, or
where such deficiency is identified during extended or heavy maintenance, before the aircraft
is put back  into service.

How will information (inventory data, sampling data, etc) be transmitted to EPA?
Reporting will begin 18 months following publication 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.
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?
EPA's Aircraft Drinking Water Rule and other supporting information are available on EPA's
Web site at http://www.epa.gov/safewater/airlinewater/index2.html. For additional
information about the rule, 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.
Office of Water (4606)                EPA 816-F-09-011                October 2009

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