Guidance Manual for the
Aircraft Drinking Water Rule
v>EPA
(ADWR) - Interim Final
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Office of Water (4606M)
EPA 816-R-10-020
http://www.epa.gov/drink
October 2010
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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.
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 final rule published on October 19, 2009, at 74
Federal Register 53590.
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 statute 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 retains 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.
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Table of Contents
1. INTRODUCTION 1
1.1 PURPOSE OF THE AIRCRAFT DRINKING WATER RULE 1
1.2 APPLICABILITY OF THE AIRCRAFT DRINKING WATER RULE 2
1.3 GENERAL REQUIREMENTS OF THE AIRCRAFT DRINKING WATER RULE 6
1.4 INTENDED USE OF THIS DOCUMENT 7
1.5 OUTLINE OF THIS DOCUMENT 7
2. OVERVIEW OF THE AIRCRAFT DRINKING WATER RULE 9
2.1 COMPLIANCE DATES AND REQUIREMENTS 9
2.2 WHAT is AN AIRCRAFT PUBLIC WATER SYSTEM? 13
2.2.7 Types of Public Water Systems 13
2.2.2 Components of Aircraft Public Water Systems 14
2.3 QUALITY OF ONBOARD WATER 15
2.3.1 Public Health Threats Addressed by the Rule 15
2.3.2 Maintaining Water Quality Throughout the Supply and Transfer Chain 16
2.3.3 ADWR Public Health Protection Measures 19
3. AIRCRAFT INVENTORY 21
3.1 IDENTIFYING AIRCRAFT PUBLIC WATER SYSTEMS 21
3.2 AIRCRAFT STATUS AS "ACTIVE" OR "INACTIVE" 23
3.3 REPORTING INVENTORY INFORMATION 24
4. COLIFORM MONITORING 27
4.1 TYPES OF COLIFORM SAMPLES 27
4.2 COLIFORM SAMPLING PLANS 29
4.2.1 Coliform Sample Collection Procedures 30
4.2.2 Sample Tap Location(s) Representative of the Aircraft Water System 30
4.2.3 Frequency and Number of Routine Coliform Samples to Be Collected 32
4.2.4 Frequency of Routine Disinfection and Flushing As Specified In the Operation and
Maintenance Plan 33
4.2.5 Procedures for Communicating Sample Results to Ensure All Required Actions Are
Conducted in a Timely Manner 33
4.2.6 Scheduling Coliform Sampling to Minimize Service Disruption 34
4.3 RESPONDING TO COLIFORM TEST RESULTS 35
4.3.1 Total Coliform-Negative Routine Sample Result 38
4.3.2 Total Coliform-Positive and E. coli-Negative Routine Sample Result 38
4.3.3 E. coli-Positive Routine or Repeat Sample Result Options 47
4.4 SUGGESTED SAMPLING PROTOCOL 49
4.4.1 Materials and Preparation for Sampling 49
4.4.2 Sample Collection 50
4.5 CERTIFIED LABORATORIES AND ANALYTICAL METHODS 51
4.5.1 Certified Laboratories 51
4.5.2 Analytical Methods 51
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4.5.3 Sample Invalidation 57
4.6 REPORTING SAMPLE RESULTS 53
5. OPERATIONS AND MAINTENANCE PLANS 55
5.1 OVERVIEW OF REQUIREMENTS AND TIMEFRAMES 55
5.2 WATERING POINT SELECTION REQUIREMENT 55
5.3 ROUTINE AND CORRECTIVE DISINFECTION AND FLUSHING 56
5.4 FOLLOW-UP SAMPLING 58
5.5 TRAINING OF PERSONNEL 59
5.6 PROCEDURES FOR CONDUCTING SELF-INSPECTIONS 61
5.7 PROCEDURES FOR BOARDING WATER 62
5.7.7 Boarding Water within the United States 62
5.7.2 Transferring Water Safely for Human Consumption 62
5.7.3 Ensuring Water Boarded Outside of the USis Safe for Human Consumption 63
5.7.4 Emergency Procedures for Failure to Board Water from a Safe Watering Point... 63
5.8 COLIFORM SAMPLING PLAN 67
5.9 AIRCRAFT WATER SYSTEMS DISCONNECT/SHUT-OFF/FLOW PREVENTION STATEMENT
67
6. PUBLIC NOTIFICATION 69
6.1 PURPOSE OF PUBLIC NOTIFICATION 69
6.2 NOTIFICATION OF PASSENGERS AND CREW 70
6.2.1 Notice for Detection ofE. coli or Total Coliform Bacteria 77
6.2.2 Notice for Failure to Monitor, Failure to Conduct Disinfection and Flushing, and
Situations Where Water Does Not Meet Standards (Non-E. coil-Positive Event)... 74
6.2.3 Notice for Failure to Conduct Follow-Up Monitoring and Situations Where Water
Does Not Meet Standards (E. coil-Positive Event) 77
6.2.4 Notice Where Necessary to Protect Public Health 80
6.2.5 Crew-only Notice 82
7. RECORDKEEPING AND REPORTING 83
7.1 AIR CARRIER RECORDKEEPING 83
7.7.7 Record Maintenance 83
7.1.2 Information Included in Records 84
7.2 REPORTING REQUIREMENTS 85
7.27 Reporting Format 85
7.2.2 Aircraft Inventory 85
7.2.3 Coliform Plan and Sampling 87
7.2.4 O&M Plans and Activities 90
7.2.5 Public Notification 92
7.2.6 Self-Inspections 92
7.2.7 Compliance Audits 95
8. VIOLATIONS OF THE RULE 97
9. OTHER WATER SYSTEM CONSIDERATIONS 107
9.1 WATER AGE AND BIOFILM MANAGEMENT CONSIDERATIONS 107
9.2 CONSIDERATIONS FOR SUPPLEMENTAL TREATMENT 108
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9.2.7 Type of Treatment Provided 108
9.2.2 Supplemental Treatment Maintenance and Operator Training 109
9.3 COMMUNICATION STRATEGY 109
9.4 RECORDKEEPING PRACTICES FOR BOARDING OF WATER 109
REFERENCES Ill
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Appendices
Appendix A Federal Register Publication of the Final ADWR Requirements
Appendix B ADWR Quick Reference Guide
Appendix C Example Coliform Sampling Plan
Appendix D Public Notification Templates
Appendix E Example Water Safety Plan for an Air Carrier
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List of Exhibits
Exhibit 1.1 ADWR Applicability to Aircraft 5
Exhibit 2.1 ADWR Components and Compliance Dates 10
Exhibit 2.2 Example Components of One Type of an Aircraft Water System 14
Exhibit 2.3 Potential Contamination Pathways within the Aircraft Water System
Supply and Transfer Chain 17
Exhibit 4.1 Example Sample Locations 32
Exhibit 4.2 Coliform Sampling Frequencies Based on Disinfection and Flushing
Frequencies 33
Exhibit 4.3 Overview of Possible Coliform Sample Result Scenarios 36
Exhibit 4.4 Restricting Public Access 37
Exhibit 4.5 Overview of Options for Response to Total Coliform-Positive (E. coli-
Negative) Sample Results 39
Exhibit 4.6 Total Coliform-Positive andE. co//'-Negative Routine Samples: Option 1:
Disinfection and Flushing Details 41
Exhibit 4.7 Total Coliform-Positive and E. co//-Negative Routine Samples: Option 2:
Restricting Public Access 43
Exhibit 4.8 Total Coliform-Positive andE1. co//'-Negative Routine Samples: Option 3:
Repeat Sample Details 46
Exhibit 4.9 E. co//'-Positive Routine or Repeat Samples: Required Activities 48
Exhibit 5.1 Example Response Plan for Failure to Board Water from a Safe Watering
Point (E. co//-positive event) 65
Exhibit 5.2 Example Response Plan for Failure to Board Water from a Safe Watering
Point (non-E. co//'-positive event) 66
Exhibit 6.1 Public Notification Requirements in Response to a Total Coliform-
Positive or E. co//'-Positive Sample Result 72
Exhibit 6.2 Public Notification Requirements for Failure to Monitor, Disinfect and
Flush, or Board Water from a Safe Watering Point (Non-E. co//'-Positive)
75
Exhibit 6.3 Public Notification Requirements for Failure to Monitor, Disinfect and
Flush, or Board Water from a Safe Watering Point (E. co//-Positive) 78
Exhibit 6.4 Public Notification Requirements When Notification is Deemed
Necessary by EPA, the Air Carrier, or the Crew 81
Exhibit 7.1 Duration of Record Maintenance 83
Exhibit 7.2 Reporting Aircraft Inventory 85
Exhibit 7.3 Aircraft Inventory Reporting Requirements 86
Exhibit 7.4 Reporting for Coliform Plan and Sampling 88
Exhibit 7.5 Implications of Changes to Coliform Sampling Frequencies 89
Exhibit 7.6 Reporting O&M Plans and Activities 91
Exhibit 7.7 Public Notification Reporting Requirements 92
Exhibit 7.8 Self-Inspection Reporting 92
Exhibit 7.9 Self-Inspection Reporting Requirements 94
Exhibit 7.10 Compliance Audit Reporting 95
Exhibit 8.1 Violations of the ADWR 98
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Acronyms and Abbreviations
ADWR Aircraft Drinking Water Rule
ANSI American National Standards Institute
AOC Administrative Order on Consent
ARCS ADWR Reporting and Compliance System
ATA Air Transport Association
BMP Best Management Practice
CDC Centers for Disease Control and Prevention
CFR Code of Federal Regulations
CRMP Comprehensive Representative Monitoring Plan
CWS Community Water System
DBF Disinfection Byproducts
E. coli Escherichia coli
EPA United States Environmental Protection Agency
EO Executive Order
FAA United States Federal Aviation Administration
FDA United States Food and Drug Administration
FR Federal Register
GWS Ground Water System
GWUDI Ground Water Under the Direct Influence of Surface Water
HACCP Hazard Analysis and Critical Control Point
HHS Department of Health and Human Services
HPC Heterotrophic Plate Count
ICC Interstate Carrier Conveyance
IESWTR Interim Enhanced Surface Water Treatment Rule
LEVIS Laboratory Information Management System
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
mg/L Milligrams per Liter
mL Milliliters
MRDL Maximum Residual Disinfectant Level
NAICS National American Industry Classification System
NATA National Air Transportation Association
NASA National Aeronautics and Space Administration
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NCWS Non-Community Water System
NELAP National Environmental Laboratory Accreditation Program
NO V Noti ce of Vi ol ati on
NPDWR National Primary Drinking Water Regulation
NSF National Sanitation Foundation International
NTNCWS Non-Transient Non-Community Water System
OEI Official Establishment Inventory
O&M Operations and Maintenance
P-A Presence-Absence
PN Public Notification
ppm Parts per Million
PWS Public Water System
SDWA Safe Drinking Water Act
SDWIS Safe Drinking Water Information System
SWTR Surface Water Treatment Rule
TC Total Coliform
TCR Total Coliform Rule
TCRDSAC Total Coliform Rule/Distribution System Advisory Committee
TNCWS Transient Non-Community Water System
TT Treatment Technique
US United States
UV Ultraviolet
WHO World Health Organization
WSG Water Supply Guidance
WSP Water Safety Plan
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1. Introduction
1.1 Purpose of the Aircraft Drinking Water Rule
The primary purpose of the Aircraft Drinking Water Rule (ADWR) is to ensure that a safe and
reliable supply of drinking water is provided to aircraft passengers and crew. The rule applies to
aircraft that are public water systems (PWSs) and requires that the water provided through
lavatory and galley faucets and drinking fountains on the aircraft meet standards for human
consumption. The ADWR does not require that water be provided on an aircraft.
Human consumption refers to more than just drinking water or water-based beverages. It
includes water uses such as drinking or food preparation, as well as water for brushing teeth,
dishwashing, and hand washing [40 CFR 141.801]. Therefore, even if passengers and crew are
provided bottled water for drinking, water from all taps on the aircraft (including taps in the
lavatories and galleys) must meet drinking water standards. Examples of common uses of
drinking water by passengers and crew on an aircraft include:
Medical use, including ingestion of medications.
Hygienic purposes such as brushing teeth, washing hands
and/or face, and where provided, onboard showering.
Food and beverage preparation such as making coffee
and tea, mixing powered drinks, or re-hydrating
dehydrated foods.
Hand washing by crew prior to providing ice or pre-
packaged food to passengers.
Sanitation activities such as washing utensils or work
areas, or wetting towels for use in dish washing or for
wiping hands.
Direct ingestion from taps or fountains (even if drinking
cups are not provided by the air carrier).
o
o
o
o
o
o
Applicability of the
ADWR
All interstate carrier
conveyances that provide
piped water for human
consumption and that
regularly serve at least 25
individuals daily at least
60 days per year are public
water systems regardless
of whether they treat or
sell the water and
regardless of whether they
are publicly or privately
owned. Applicability is
discussed in more detail in
Section 1.2.
Aircraft classified as public water systems are subject to the
requirements of the Safe Drinking Water Act (SOW A). Under SOW A, the United States
Environmental Protection Agency (EPA) sets national health-based standards for drinking water
quality and oversees the implementation and enforcement of those standards. The health-based
standards are National Primary Drinking Water Regulations (NPDWRs). NPDWRs include
maximum allowable levels of contaminants, treatment requirements, monitoring, public
notification, reporting, and recordkeeping requirements.
Until the ADWR was developed, safe drinking water regulations have been written with
traditional stationary public water systems in mind. Examples of stationary public water systems
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include large municipal utilities, as well as schools and restaurants that are served by their own
wells. The regulations for stationary systems have proven difficult to implement for aircraft due
to the unique characteristics of aircraft water systems. For example, aircraft operate under
rigorous flight schedules, fly to multiple destinations over the course of one day, and may board
drinking water at many of these locations. The ADWR tailors drinking water regulations to
provide a more feasible way for air carriers to comply with NPDWRs. The ADWR adapts to
aircraft water systems the applicable requirements of the Total Coliform Rule, the suite of
Surface Water Treatment Rules, and the Public Notification Rule. The ADWR also builds upon
existing aircraft operations and maintenance programs, better coordinates federal programs that
regulate aircraft water systems, and enables aircraft to select compliance options that minimize
disruptions of aircraft flight schedules.
Because aircraft board water from airport watering points via temporary connections, aircraft
drinking water quality depends on a number of factors. These factors include the quality of the
water boarded from each source, the care used to board the water, the water transfer equipment
(such as water cabinets, trucks, carts, and hoses), and the operation and maintenance (O&M) of
the onboard water system. The ADWR, along with complementary US Food and Drug
Administration (FDA) regulations, addresses each of these factors in order to safeguard against
possible contamination and to ensure that the water is suitable for human consumption.
1.2 Applicability of the Aircraft Drinking Water Rule
The ADWR applies to each aircraft that meets the definition of a public water system, boards
only finished water, operates within US jurisdiction, and is not excluded from regulation under
40 CFR 141.3. The ADWR applies to the onboard water system only. EPA defers to the FDA
with respect to regulating watering points such as water cabinets, carts, trucks, and hoses from
which aircraft board water. FDA requirements for watering points do not entail the individual
certification of every potential source, method, facility, or system; however, interstate carrier
conveyance selected watering points must be in accordance with FDA requirements [21 CFR
part 1240, subpart E]. Furthermore, the applicability of the ADWR is not based on the ownership
of the aircraft. That is, an aircraft that is subject to the ADWR may be publicly or privately
owned, or government or foreign-owned.
The applicability criteria for the ADWR are described in more detail below and are presented in
Exhibit 1.1.
• Aircraft that meet the definition of a public water system have an onboard water system of
piped water for human consumption and regularly serve an average of at least 25 or more
individuals daily at least 60 days out of the year.
Piped water for human consumption means the onboard water system provides water
through taps (e.g., in a galley, a lavatory, or drinking fountain). The onboard water can be
supplied to the aircraft via a fill port and piping, or by a removable tank.
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A galley is the area of the aircraft where food is cooked and prepared. If the galley has a
water tap, even if there is only a hot water tap, the aircraft will be subject to the ADWR.
EPA also considers "human consumption" to occur in a lavatory if there is a tap.
Facilities with toilet seats without a lavatory tap (as seen in some small, short-range
aircraft) are not considered to be providing water for human consumption under SDWA
because tap water cannot be accessed by passengers or crew. A lavatory sink with a tap
provides water for human consumption even if the tap and basin are only intended for
hand washing and drinking cups are not provided. An aircraft need only have a galley tap
or a lavatory tap or a drinking fountain to be considered providing water for human
consumption.
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]. The 25-person average
minimum includes the total number of passengers and crew for all of the flights in a day;
the 60 days per year do not need to be consecutive days. 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 public water system. For
example, the ADWR and other NPDWRs do not apply to aircraft that are used solely for
cargo purposes if they do not regularly serve an average of at least 25 people daily, even
if they have an onboard water system.
• The ADWR is limited to aircraft that board only finished water.
The ADWR assumes that only finished water is boarded for human consumption on
aircraft because of the FDA requirement that only potable water may be provided for
drinking and culinary purposes on interstate carrier conveyances [21 CFR 1240.80].
Finished water is defined as water that is introduced into the distribution system of a
public water system and is intended for distribution and consumption without further
treatment, except as treatment necessary to maintain water quality in the distribution
system [40 CFR 141.801]. Disinfection, such as an ultraviolet light disinfection system, is
an example of treatment that may be used to maintain water quality after the water has
been boarded. Carbon filters and particle removal filters are installed on some aircraft
water systems for aesthetic purposes.
An aircraft public water system that boards water that is not of finished quality is not
eligible to comply with the ADWR but is subject to all of the other applicable National
Primary Drinking Water Regulations.
• Aircraft that fly international routes with two or more destinations within US jurisdiction.
Aircraft that fly international routes that make only one stop in the US solely for the
purpose of unloading passengers transported from outside the US and/or loading
passengers for transportation to a destination outside the US are excluded from ADWR
regulations. Thus, under the ADWR, if an aircraft serves two or more US destinations
before returning to an international location, the aircraft is subject to the ADWR while
within the US.
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Aircraft not excluded from regulation under 40 CFR 141.3.
The SDWA [Section 1411(4)] andNPDWRs [40 CFR 141.3] specifically exclude from
regulation public water systems that meet all of the following criteria: 1) consist only of
distribution and storage facilities and do not have any collection and treatment facilities;
2) obtain all water from, but are not owned or operated by, a public water system; 3) do
not sell water to any person; and 4) are not a carrier that conveys passengers in interstate
commerce.
Aircraft are carriers; therefore, if aircraft that are public water systems convey passengers
in interstate commerce they are specifically identified as being subject to the drinking
water regulations and cannot be excluded.
A government-owned aircraft used solely for government purposes that is not conveying
passengers in interstate commerce may be excluded from SDWA and ADWR regulations
if it meets the other three criteria. However, if a government-owned aircraft does not
obtain all water from a public water system (e.g., the aircraft boards water from a location
that is outside of US jurisdiction), the aircraft would not be excluded from regulation.
It is important to note that the term "interstate commerce" does not exclusively apply to
aircraft conveying passengers between two different states. Interstate commerce includes
activities that substantially affect interstate commerce even if they are not themselves
interstate. As a result, EPA interprets the statute to reach intrastate carriers that meet the
definition of a public water system; such aircraft are subject to the ADWR if all other
necessary criteria are met.
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Exhibit 1.1 ADWR Applicability to Aircraft
Does the aircraft serve an average
of 25 people or more at least 60
days/year? (See Note 1)
Mo
Yes
Does the aircraft have a galley,
lavatory, or drinking fountain?
(See Note 2)
Mo
Yes
Does the aircraft board only finished
water for human consumption?
(See Note 3)
Mo
Yes
If the aircraft flies international routes, does it
serve2 or more US destinations before
returning to an international location?
Mo
Yes
Is the aircraft excluded from
regulation under 40 CFR 141.3?
(See Note 4)
Yes
ADWR Not
Applicable
Mo
r
ADWR is
Applicable
Note 1: 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 average minimum
includes the total number of passengers and crew for all of the flights in a day.
Note 2: A lavatory has a flushing toilet and a tap. A galley is a food preparation and handling area where food is
cooked, prepared, or stored.
Note 3: EPA considers water for human consumption to include water for drinking, food preparation, brushing teeth,
and hand washing. An aircraft PWS that boards water that is not of finished quality is not eligible to comply with the
ADWR but is subject to all of the other applicable National Primary Drinking Water Regulations.
Note 4: Aircraft that meet all criteria in 40 CFR 141.3 are excluded from regulation under ADWR.
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1.3 General Requirements of the Aircraft Drinking Water Rule
In general terms, the ADWR seeks to protect the quality of drinking water onboard aircraft
public water systems by establishing the following requirements. Details of each requirement are
provided in later chapters in this guidance document. The rule language as published in the
Federal Register is provided in Appendix A and a Quick Reference Guide summarizing the rule
requirements is provided in Appendix B.
• Routine disinfection and flushing of the aircraft water system at a frequency consistent with
the water system manufacturers' recommendations. Where manufacturers do not specify a
frequency for routine disinfection and flushing of the system, the rule gives air carriers four
options from which to choose their preferred frequency (see Chapters 4 and 5).
• Routine monitoring for total coliform (TC) bacteria at aircraft water system taps, at
frequencies ranging from monthly to annually, depending on the routine disinfection and
flushing frequency (see Chapter 4).
• Aircraft water system operations and maintenance (O&M) plans, which must be incorporated
into the air carriers' FAA-accepted O&M program for aircraft. The O&M plans must include
a coliform sampling plan and procedures for performing routine disinfection and flushing, as
well as other requirements (see Chapter 5).
• Coliform sampling plans, which must be included in the aircraft water system O&M plan.
The coliform sampling plan must include the frequency and number of routine coliform
samples, location of sample taps, sampling collection procedures, as well as other
requirements (see Chapter 4).
• Analysis of total coliform-positive samples for the presence of Escherichia coli (E. coif) (see
Chapter 4).
• Corrective actions in response to a total coliform-positive or E. co//'-positive sample (see
Chapter 4).
• Corrective disinfection and flushing of the aircraft water system when specific circumstances
occur (see Chapter 5).
• Follow-up sampling and analysis for total coliform to confirm the effectiveness of corrective
disinfection and flushing (see Chapters 4 and 5).
• Comprehensive self-inspection of each aircraft's water system components no less than every
5 years (see Chapter 5).
• Compliance audits at an interval determined by EPA (see Chapter 5).
• Public notification when specific circumstances occur (see Chapter 6).
• Reporting and recordkeeping associated with the activities described above (see Chapter 7).
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1.4 Intended Use of this Document
This guidance is intended to help facilitate compliance with and implementation of the
requirements of the ADWR. 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 discusses other considerations to help preserve good water quality aboard
the aircraft. This manual also provides templates for the various public notices required by the
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. Furthermore, the recommendations
offered by EPA in this technical manual are provided solely to assist air carriers in rule
implementation. Air carriers may develop their own policies and procedures as they deem
appropriate based on the nature of their individual operations and are responsible for ensuring
those policies and procedures are consistent with, and support compliance with, the rule.
1.5 Outline of this Document
This guidance manual addresses the requirements of the ADWR and provides suggestions to air
carriers for ensuring that safe drinking water is provided by aircraft public water systems.
Although aircraft operators have the responsibility to protect their water systems from deliberate
acts that may threaten public health, this issue is not within the purview of this guidance or the
ADWR.
The guidance manual is organized as follows:
Chapter 1. Introduction - Explains the applicability of the ADWR and purpose of this manual.
Chapter 2. Overview of the Aircraft Drinking Water Rule - Describes, in general terms, the
ADWR requirements and compliance dates, aircraft public water systems, as well as key
background information.
Chapter 3. Aircraft Inventory- Explains the criteria for identifying if an aircraft is a public water
system, defines the status of aircraft, and describes other aircraft inventory requirements.
Chapter 4. Coliform Monitoring - Describes coliform monitoring requirements including
monitoring plan content, sampling locations, sampling frequency, sampling protocol, analytical
methods, and the reporting of sample results. Also discusses activities and options for responding
to the detection of coliform organisms in routine or repeat samples.
Chapter 5. Operations and Maintenance Plans - Discusses the required elements of an operations
and maintenance (O&M) plan and recommendations for conducting disinfection and flushing
procedures, performing water system inspections, and training personnel on the public health
implications of their activities on the quality of water onboard the aircraft water system.
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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. Other Water System Considerations - Describes considerations that are above and
beyond the ADWR regulatory requirements, which may contribute to obtaining and maintaining
drinking water quality. Topics include water age and biofilm management, considerations for
supplemental treatment, strategies for communications with water systems from which finished
water is obtained, and recordkeeping practices for boarded water.
References. - Provides a bibliographic list of references cited in this manual.
Appendix A. Rule Language - The rule as published in the Federal Register.
Appendix B. Quick Reference Guide - A stand-alone two-page summary of the rule
requirements and key background information.
Appendix C. Example Coliform Sampling Plan - Provides an example coliform sampling plan
illustrating all of the required elements of a coliform sampling plan.
Appendix D. Public Notification Templates - Provides examples for various public notices
required by the ADWR.
Appendix E. Example Water Safety Plan for an Air Carrier - Provides an outline of a water
safety plan based on World Health Organization (WHO) guidelines. EPA encourages the
development of comprehensive water safety plans by air carriers. Water safety plans are not
required by the ADWR.
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2. Overview of the Aircraft Drinking Water Rule
Aircraft public water systems are required to develop aircraft water system operation and
maintenance plans including coliform sampling plans, conduct operations and maintenance
activities, periodically sample the onboard drinking water, and report compliance with ADWR
requirements to an electronic database developed by EPA (ADWR Reporting and Compliance
System). Compliance oversight of ADWR requirements is provided by the EPA Regional Office
in which the air carrier's US headquarters is located. EPA Headquarters will administer the
ADWR Reporting and Compliance System and play a continuing role in ensuring consistent
implementation and enforcement of the ADWR.
This chapter provides an overview of the requirements of the ADWR including compliance
dates, a description of an aircraft water system, and background information related to the quality
of the onboard water.
2.1 Compliance Dates and Requirements
Several rule components must be implemented 18 months after rule promulgation, which is April
19, 2011 [40 CFR 141.806(a)(l)]; the remainder must be implemented within two years after
promulgation, which is October 19, 2011 [40 CFR 141.800].
The ADWR relies on a combination of routine aircraft water
system operations and maintenance (O&M) practices that
build on existing air carrier O&M programs, with periodic
monitoring. The ADWR rule components and their
compliance dates are summarized in Exhibit 2.1. Chapters 3
through 7 of this document provide details of the requirements
of the ADWR.
Air carriers that are operating under an Administrative Order
on Consent and Request for Information (AOC) to address
pre-ADWR non-compliance with the Safe Drinking Water
Act and National Primary Drinking Water Regulations must
continue to meet the requirements of their AOCs until the
ADWR compliance date of October 19, 2011 [40 CFR
141.800(b)].
If an air carrier is not subject to an AOC, then that air carrier
must comply with the applicable requirements of the existing
NPDWRs under 40 CFR 141 for each of its aircraft that is a
public water system [40 CFR 141.800(b)]. The applicable requirements include those for a
transient non-community water system (TNCWS) that uses finished surface water and serves
1,000 or fewer people per day.
Aircraft PWS
Requirements Prior to the
ADWR
Until the compliance date
of October 19, 2011, air
carriers remain subject to
the requirements of their
AOCs, if an AOC is in
effect.
If an AOC is not in effect
for an air carrier, then that
air carrier must comply
with the applicable
requirements of the existing
NPDWRs under 40 CFR
141 for each of its aircraft
that is a public water
system.
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Exhibit 2.1 ADWR Components and Compliance Dates
Component
Submit aircraft water system inventory.
Develop coliform sampling plan and report coliform sampling
frequency.
Develop aircraft water system O&M plan, and report disinfection and
flushing frequency and that the O&M plan is completed.
Aircraft water system O&M plan must be incorporated into an FAA-
accepted aircraft operations and maintenance program [40 CFR
141.804(a)].
Update aircraft inventory and coliform sampling plans as needed for
new aircraft.
(New aircraft placed into operation after April 19, 201 1, must
complete these requirements within the first calendar quarter of
initial operation [40 CFR 141.806(a)(2)].)
Conduct routine coliform sampling
Conduct routine disinfection and flushing.
Conduct all other reporting and recordkeeping requirements.
Conduct corrective disinfection and flushing as needed.
Conduct public notification as needed.
Complete initial self-inspection of each aircraft that is included in the
inventory as of October 19, 201 1, and address deficiencies or notify
EPA of schedule to address deficiencies.
Conduct subsequent self-inspections every 5 years thereafter.
Complete self-inspections of each aircraft that was added to the
inventory after October 19, 201 1.
Compliance
Date
April 19,2011
April 19,2011
April 19,2011
October 19, 2011
Beginning
October 19, 2011
Beginning
October 19, 2011
Beginning
October 19, 2011
Beginning
October 19, 2011
Beginning
October 19, 2011
Beginning
October 19, 2011
No Later Than
October 19, 2016
5 years after
previous self-
inspection
Within 5 years
after aircraft was
added to
inventory
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Aircraft Inventory
Air carriers are required to report their fleet inventory for all existing aircraft that are public
water systems to EPA by April 19, 2011. The inventory must specify the aircraft that are
currently active and those that are inactive [40 CFR 141.806(b)(l)]. Once the initial inventory
has been submitted to EPA, any change in inventory must be submitted to EPA within 10 days
after the end of the month in which the change occurred [40 CFR 141.806(b)(2)]. Since each
aircraft is a public water system, the inventory must include a unique identifier number for each
aircraft [40 CFR 141.806(b)(l)]. Inventory information must be submitted to EPA electronically,
in the ADWR Reporting and Compliance System to facilitate subsequent reporting and
recordkeeping. If an air carrier is unable to report electronically, the air carrier may use an
alternative approach that the Administrator approves [40 CFR 141.806(d)]. Chapter 3 includes
more information on inventory information, what is meant by active and inactive status of an
aircraft, and the reporting format and procedures.
Coliform Sampling Plans
Air carriers must develop coliform sampling plans for existing aircraft by April 19, 2011 [40
CFR 141.802(b)]. The sampling plans must include sampling procedures, aircraft sampling
frequencies, and routine disinfection and flushing frequencies [40 CFR 141.802(a)]. Air carriers
are not required to submit the coliform sampling plans to EPA but must inform EPA that the
plans are complete and submit their planned sampling frequencies by April 19, 2011 [40 CFR
141.806(a)(l)]. EPA may choose to review the plans during a compliance audit, and can request
that the plans be submitted at any time. Although the ADWR 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 place the aircraft under an existing sampling plan or
develop a new plan. Air carriers must report the coliform sampling frequency within the first
three months of operation of the new aircraft [40 CFR 141.806(a)(2)]. See Chapter 4 for more
information on coliform monitoring requirements including coliform sampling plans, sample
collection procedures, and follow-up actions and options when routine coliform samples indicate
coliforms are present.
Operation and Maintenance Plans
By April 19, 2011, air carriers must report to EPA that they have developed their aircraft water
system O&M plans. Air carriers need not submit the O&M plans to EPA but must inform EPA
that the plans are complete [40 CFR 141.806(a)(l)]. The O&M plans must be included in the
Federal Aviation Administration (FAA)-accepted O&M program by October 19, 2011 [40 CFR
141.804(a)]. EPA can request a copy of the plan at any time and may also view the plan during
compliance audits. Although the rule requires an O&M 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.
Beginning October 19, 2011, air carriers must revise an existing plan to add the new aircraft or
develop a new aircraft water system O&M plan within the first calendar quarter of operation of a
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new aircraft water system and inform EPA that the plan is complete [40 CFR 141.806(a)(2)]. See
Chapter 5 for more information on the required elements of the O&M plans.
Self-Inspections
Under the ADWR, air carriers or their representatives must perform a self-inspection of all water
system components for each aircraft water system no less frequently than once every 5 years [40
CFR 141.800(b) and 141.808(b)]. This frequency is consistent with sanitary surveys of stationary
transient non-community water systems and intended to be compatible with other significant
aircraft maintenance events. This schedule requires that each aircraft that is included in the
inventory as of October 19, 2011, be inspected any time before October 19, 2016. Any new
aircraft added to the inventory after October 19, 2011, must have a self-inspection completed
within 5 years after it is added to the inventory [40 CFR 141.808(b)]. The air carrier must
address any deficiency identified during compliance audits or routine self-inspections within 90
days of identification of the deficiency. Where a deficiency is identified during a period of time
when the aircraft water system is inactive (see Chapter 3 for a definition of an inactive aircraft
water system), such as during extended or heavy maintenance of the aircraft, the deficiency must
be corrected before the aircraft water system is returned to active status [40 CFR 141.808(c)]. If
a deficiency is addressed within 90 days of identification, the air carrier will not incur a
violation. In addition, if more than 90 days have elapsed but the aircraft water system is not
active, the air carrier will not incur a violation as long as the deficiency is addressed before the
aircraft water system is returned to active status. Procedures for conducting self-inspections must
be included in the aircraft water system O&M plan [40 CFR 141.804(b)]. See Chapter 5 for more
information on self-inspections.
Notification to Passengers and Crew
Beginning October 19, 2011, air carriers are required to notify passengers and crew that are on
board the aircraft of specific situations related to the quality of the water. If access to the water
system by passengers is physically prevented through disconnecting or shutting off the water, or
the flow of water to the taps is prevented (such as 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.
See Section 4.3 for more details on restricting public access.
Notification requirements and timeframes depend on the severity of the health risk created by the
situation. When public notice must be provided, the ADWR requires only onboard notification of
passengers and crew. Passengers on previous flights may be notified as part of an illness or event
investigation, but this is not a requirement of the ADWR. Notification of passengers and crew
aboard the aircraft must continue to be provided until situation-specific criteria are met [40 CFR
141.805]. See Chapter 6 for more information on public notification requirements.
Reporting and Recordkeeping
In addition to the reporting described previously for aircraft inventory, coliform sampling plans,
and O&M plans, the rule requires air carriers to report [40 CFR 141.806]:
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• Sample results;
• Routine disinfection and flushing;
• That self-inspections were completed and any unresolved deficiencies that were noted;
• Failure to comply with monitoring or disinfection and flushing requirements; and
• The occurrence of events requiring corrective disinfection and flushing of the water
system and notification of passengers and crew.
This reporting begins October 19, 2011; actual reporting deadlines vary. See Chapter 7 for more
information on recordkeeping and reporting.
Air carriers must maintain their coliform sampling plans and O&M plans. The records do not
need to be retained on the aircraft, and may be kept in electronic format. 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 public notice records must
be kept for a minimum of three years [40 CFR 141.807]. Records that are required to be
maintained by the ADWR must be made available to EPA upon request and during compliance
audits.
Implementation Oversight and Enforcement
The rule authorizes EPA to conduct onsite compliance audits of aircraft and aircraft records.
EPA may review records, collect coliform samples, and observe procedures at any time. The
ADWR does not affect or modify the responsibilities or requirements of the FDA or FAA.
2.2 What is an Aircraft Public Water System?
2.2.1 Types of Public Water Systems
The National Primary Drinking Water Regulations (NPDWRs) define a public water system
(PWS) as a system for providing water for human consumption to the public through pipes or
other constructed conveyances if such system either has at least 15 service connections or
regularly serves an average of at least 25 individuals daily, at least 60 days per year [40 CFR
141.2]. As described in Section 1.1, human consumption includes uses such as water for drinking
or food preparation, as well as water for brushing teeth and hand washing.
Public water systems are subject to different requirements of the NPDWRs based on the type of
population they serve. The type of population served is defined whether consumers are exposed
to the water for short time periods or extended time periods. The two main categories of public
water systems are community water systems (CWSs) and non-community water systems
(NCWSs). CWSs primarily serve residential populations; non-community systems primarily
serve nonresidential users. NCWSs are further divided based on whether they regularly serve at
least 25 of 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. If different people are served, as occurs at campgrounds,
restaurants, or highway rest stops, the system is classified as a transient non-community water
system.
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Aircraft public water systems are regulated as transient non-community water systems because
they are NCWSs that do not regularly serve at least 25 of the same people over six months per
year. They are also regulated as surface water systems because they are likely to board finished
water from public water systems that use surface water (since many stationary systems serving
airports rely, at least in part, on surface water as a source). Since aircraft public water systems
serve a transient population, they are subject only to regulations that address acute health effects
resulting from short-term exposure to drinking water contaminants. Acute health effects are
impacts on health that occur over a short period of time after exposure to the contaminant. The
ADWR is designed to address such health risks.
2.2.2 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, and
any other plumbing fixtures that supply water to passengers or crew. An example of one type of
an aircraft water system is shown in Exhibit 2.2.
Exhibit 2.2 Example Components of One Type of an Aircraft Water System
Pressurization
System
Galley
Overflow
Fitting
Fill
Fitting Vatve
Overflow Line
o o-J
Valve
*H2>-
Service
Panel
Fill Line
Potable Water Tank
Drain Line
Valve
Drain Line
Fitting
Drinking
Fountain
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Generally, water is supplied to the aircraft through a fill port or ports. A. „
TT7 . • i • i r- ,1 . . ,1 i i • . ,1 Aircraft with More
Water is drained from the water system through a dram port on the
Than One Water
Storage Tank and
Piping System
Each aircraft is
regulated as one
public water system
regardless of
whether the aircraft
has more than one
discrete storage and
piping system.
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 a single
removable/portable tank in a regional jet to multiple tanks exceeding
one hundred gallons in long-range aircraft. 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
activated carbon filters and/or particle removal filters on the supply
line to the coffee makers; others may have more elaborate onboard
supplemental treatment systems.
The aircraft water system may also include some protective devices to meet sanitation
requirements. Examples include 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.
Many large aircraft have more than one water service panel and associated storage and piping
system. For example, one may be in the forward section of the aircraft to serve a galley and a
lavatory, and one in the rear of the aircraft to serve a galley and/or lavatory. Interconnections
between such systems commonly exist so water service can be provided if one system is not
operational. Even if interconnections do not exist and the storage and piping systems are distinct,
each aircraft is regulated as a single aircraft public water system. That is, all compliance tracking
and activities are based on the aircraft, not the number of discrete storage and piping systems that
comprise the aircraft water system.
2.3 Quality of Onboard Water
2.3.1 Public Health Threats Addressed by the Rule
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. Acute health effects are often caused by microbiological organisms
and by some chemicals. Chemicals that can cause acute health effects include nitrate, nitrite, and
high levels of chlorine dioxide.
The ADWR seeks to protect against disease-causing microbiological contaminants (pathogens)
in the drinking water of the onboard water system. Microbiological contamination is a concern
because it can occur after the finished water leaves the public water system from which the water
is obtained. The contamination can occur during the water boarding process if there are problems
with the watering point connections, water transfer equipment, or the sanitary practices
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employed. Contamination can also occur if the aircraft water system is not properly operated and
maintained.
Because the NPDWRs require that nitrate, nitrite, and chlorine dioxide levels be controlled to
regulatory limits and monitored by the public water system (parent system) serving the airport
watering point, the ADWR does not require onboard monitoring for these chemicals. This
assumes that only finished water is boarded for human consumption on aircraft. Finished water
means water that is introduced into the distribution system of a public water system and is
intended for distribution and consumption without further treatment, except as necessary to
maintain water quality in the distribution system (e.g., supplemental disinfection, addition of
corrosion control chemicals) [40 CFR 141.2]. The assumption that only finished water is boarded
on aircraft is based on an FDA requirement that only potable water may be provided for drinking
and culinary purposes on interstate carrier conveyances (ICCs) [21 CFR 1240.80]. However,
aircraft water systems that are boarding water that is not finished water will continue to be
subject to existing NPDWRs, which include requirements for chemical monitoring for nitrate
and nitrite in addition to microbial monitoring. Chlorine dioxide monitoring also would be
required if chlorine dioxide was used as a disinfectant or oxidant in the treatment process.
2.3.2 Maintaining Water Quality Throughout the Supply and
Transfer Chain
The aircraft water system supply and transfer chain refers to the steps necessary to provide
drinking water onboard an aircraft. The supply and transfer chain includes the public water
system used as the source of finished water; the airport (that may be a public water system with
its own source or convey water from another public water system to the watering points and
servicing areas); the watering points and service areas and associated transfer equipment; and the
aircraft water system.
Exhibit 2.3 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 discussion that follows provides protection measures to reduce or
eliminate potential mechanisms and pathways. The ADWR is intended to complement existing
regulations to minimize contamination events and prescribe appropriate response actions if they
occur.
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Exhibit 2.3 Potential Contamination Pathways within the Aircraft Water System
Supply and Transfer Chain
Public Water System
Flightto Next
Airport
Purchased water is contaminated
• Treatment failure
• Distribution system contamination
(e.g.. main break, cross connection
witnbackflow)
Aircraft Water System
k
• Cross connection with
backflow
• Water line break introduces
contamination
Airport
• Cross
contamination
from improper
handling
Lavatory Sink
Galley
Sink/
Coffee
• Boardedwater is contaminated
• Backflow prevention device
failure
• Water quality
degrades /growth of biof i Im
-Improperly designed system
allows contamination
WaterTruck
• Improperly
maintained
water cabinets,
carts, trucks,
and hoses
Water
Cabinet
• Cross contamination of
surfaces due to hand contact,
splash-back, cleaning rags,
aerosols
Public Water System
The public water system is required by the NPDWRs to provide a reliable quality and quantity of
finished water to all consumers. They must perform monitoring and must comply with reporting
and recordkeeping requirements to document the quality of the water provided.
The ADWR requirements for finished water to be boarded are intended to ensure water will be
available for boarding that is fully in compliance with drinking water quality standards.
However, treatment failures or events within the distribution system of the public water system
could result in contamination of the water supplied to the airport or watering point.
In the event the public water system that provides the water to be boarded is not in compliance
with standards, it is required by the NPDWRs to notify all of its customers, which would include
airport authorities and/or air carriers. Violations of drinking water standards for acute
contaminants (which are the contaminants addressed by the ADWR) require notification to
consumers within 24 hours of learning of the violation. The ADWR assumes these events would
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be infrequent and temporary. However, if air carriers are notified of such an event, then air
carriers should ensure personnel responsible for taking appropriate actions regarding the
boarding of water and any follow-up actions if the water is boarded are notified immediately.
Development of a communications strategy to address this situation is described in more detail in
Chapter 9.
Airport Water ing Points
Finished water from a regulated public water system is delivered to the airport and is accessible
to aircraft and water service providers at watering points that are in accordance with FDA
regulations [21 CFR 1240.83]. Water is transferred to the aircraft storage tank either by a direct
hose connection from a water cabinet mounted on the terminal building, a mobile truck, or a 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 may be equipped with a removable container (usually 5 gallons) that is refilled at the
airport's servicing area or catering facility.
FDA regulations for interstate carrier conveyance watering points require that the water supply
meets the NPDWRs [21 CFR 1240.83]. FDA requirements also ensure that the methods and
sanitary conditions for delivery of the water to the aircraft prevent the introduction, transmission,
or spread of communicable diseases [21 CFR 1250.63]. FDA administers and enforces these
requirements through inspections. FDA inspects watering points to ensure they are clean and
sanitary.
Because watering points and servicing areas for aircraft are regulated by FDA, the ADWR does
not duplicate the FDA program. The ADWR aligns with the FDA program by requiring that the
aircraft water system operations and maintenance (O&M) plan include procedures for boarding
water that ensure the water will not become contaminated during transfer. These watering point
and boarding water procedure requirements are discussed further in Chapter 5, which covers the
requirements for the aircraft O&M plan.
Aircraft Water System
The FDA approves the design of aircraft water systems [21 CFR 1250.41], treatment systems [21
CFR 1240.90], and requires that interstate carrier conveyances only provide potable water for
drinking and culinary purposes [21 CFR 1240.80]. In general, the FDA's review of the design of
aircraft water systems includes all of the following:
• Ensuring potable water systems are independent systems not connected to non-potable
systems, or are protected by backflow prevention devices if non-potable water
connections are present (e.g., humidifiers and flush rings on vacuum toilets).
• The equipment making up the water system is made of material suitable for use in a
potable water system.
• The water system is constructed to prevent contamination (e.g., fill connection fittings
are quick-coupling, no more than 3/4" in diameter, clearly labeled "Potable Water
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Filling," and provided with protective dust cover; vents are oriented downward;
backflow prevention devices are installed at possible cross connections; insulation is
protected to prevent water adsorption and contamination; etc.).
Therefore, additional treatment of the water should not be needed prior to boarding the water.
Although protection measures exist for the boarding of water, the opportunity exists for
microbiological organisms to be introduced during the process of boarding water. Contamination
of the aircraft water system by microbiological or chemical contaminants can occur inadvertently
if water is boarded onto an aircraft that is not known at the time to be in violation of drinking
water standards, or if water that does not meet standards is knowingly boarded to operate
essential systems such as toilets. 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 were to enter the system.
Routine disinfection and flushing procedures and other O&M requirements are intended to
control biofilm growth and ensure water quality is maintained.
As illustrated in Exhibit 2.3 there are numerous pathways for potential contamination within the
aircraft water supply and transfer chain. Timely and effective communication is essential
between the responsibilities parties (i.e., public water system, airport, air carrier) as well as with
the appropriate regulatory authorities if a drinking water contamination event occurs.
Communication strategy is discussed in more detail in Chapter 9.
2.3.3 ADWR Public Health Protection Measures
It is impractical for aircraft to monitor the water for microbiological contaminants every time
water is boarded because several samples may be necessary in one day for some aircraft and
coliform bacteria analytical results would not be available for at least 24 hours after sample
analysis has begun. Therefore, results would not be known until long after the water was
consumed.
To provide meaningful public health protection, the ADWR requires air carriers to develop a
comprehensive O&M plan for each aircraft water system to minimize opportunities for
contamination [40 CFR 141.804]. The plan must include procedures for routine disinfection and
flushing which must be performed at frequencies recommended by the aircraft water system
manufacturer. The plan requires periodic testing for total coliform bacteria to confirm the
effectiveness of O&M procedures. It also identifies minimum training content and requires
training of key personnel. In the event that an air carrier becomes aware of contamination on an
aircraft, the ADWR requires corrective action and onboard public notification of passengers
and/or crew, when appropriate.
In addition to the O&M plan, the ADWR requires self-inspections by air carriers of each aircraft
water system and provides for EPA compliance audits. Lastly, the rule requires reporting and
recordkeeping to facilitate compliance tracking and rule implementation.
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3. Aircraft Inventory
Under the ADWR, air carriers are required to submit to EPA an inventory identifying all aircraft
public water systems in their fleet and to update the inventory as fleet changes occur [40 CFR
141.806(b)]. The reporting requirements for inventory are effective April 19, 2011. Compliance
with the requirements of the ADWR will be tracked for each aircraft individually. To facilitate
collection and analysis of aircraft water system data, EPA will use an internet-based electronic
data collection and management system, referred to as the ADWR Reporting and Compliance
System (see Section 7.2.1). This Chapter describes how to identify aircraft that are public water
systems and the information to be reported. It also provides a reference for more information on
how to submit the inventory data.
3.1 Identifying Aircraft Public Water Systems
Air carriers must identify all aircraft in their fleet that are subject to the requirements of the
ADWR and include these aircraft in their inventory that is reported to EPA [40 CFR
141.806(b)(l)]. Although the applicability of the ADWR to aircraft and the definition of an
aircraft public water system have been covered previously in this guidance manual, it is repeated
here because it is pertinent to identifying aircraft that must be included in the air carrier
inventory and will be covered by the coliform monitoring and aircraft O&M plans.
The applicability criteria for an aircraft with an onboard water system to be regulated under the
ADWR are as follows:
• Aircraft that meet the definition of a public water system have an onboard water system of
piped water for human consumption and regularly serve an average of at least 25 or more
individuals daily at least 60 days out of the year.
Piped water for human consumption means the onboard water system provides water
through taps (e.g., in a galley, a lavatory, or drinking fountain). The onboard water can be
supplied to the aircraft via a fill port and piping, or by a removable tank.
A galley is the area of the aircraft where food is cooked and prepared. If the galley has a
water tap, even if there is only a hot water tap, the aircraft will be subject to the ADWR.
EPA considers "human consumption" to occur in a lavatory if there is a tap. Facilities
with toilets without a lavatory tap (as seen in some small, short-range aircraft) are not
considered to be providing water for human consumption under SDWA because tap
water cannot be accessed by passengers or crew. A lavatory sink with a tap provides
water for human consumption even if the tap and basin are only intended for hand
washing and drinking cups are not provided. An aircraft need only have a galley tap or a
lavatory tap or a drinking fountain to meet this criterion.
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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]. The 25-person average
minimum includes the total number of passengers and crew for all of the flights in a day;
the 60 days per year do not need to be consecutive days. 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 public water system. For
example, the ADWR and other NPDWRs do not apply to aircraft that are used solely for
cargo purposes if they do not regularly serve an average of at least 25 people daily, even
if they have an onboard water system.
• The ADWR is limited to aircraft that board only finished water.
The ADWR assumes that only finished water is boarded for human consumption on
aircraft because of the FDA requirement that only potable water may be provided for
drinking and culinary purposes on interstate carrier conveyances [21 CFR 1240.80].
Finished water is defined as water that is introduced into the distribution system of a
public water system and is intended for distribution and consumption without further
treatment, except as treatment necessary to maintain water quality in the distribution
system [40 CFR 141.801]. Disinfection, such as an ultraviolet light disinfection system, is
an example of treatment that may be used to maintain water quality after the water has
been boarded. Carbon filters and particle removal filters are installed on some aircraft
water systems for aesthetic purposes.
An aircraft public water system that boards water that is not of finished quality is not
eligible to comply with the ADWR but is subject to all of the other applicable National
Primary Drinking Water Regulations.
• Aircraft that fly international routes with two or more destinations within US jurisdiction.
Aircraft that fly international routes that make only one stop in the US solely for the
purpose of unloading passengers transported from outside the US and/or loading
passengers for transportation to a destination outside the US are excluded from ADWR
regulations. Thus, under the ADWR, if an aircraft serves two or more US destinations
before returning to an international location they are subject to the ADWR while in the
US.
• Aircraft not excluded from regulation under 40 CFR 141.3.
The SDWA [Section 1411(4)] and NPDWRs [40 CFR 141.3] specifically exclude from
regulation public water systems that meet all of the following criteria: 1) consist only of
distribution and storage facilities and do not have any collection and treatment facilities;
2) obtain all water from, but are not owned or operated by, a public water system; 3) do
not sell water to any person; and 4) are not a carrier that conveys passengers in interstate
commerce.
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Aircraft are carriers; therefore, if aircraft that are public water systems convey passengers
in interstate commerce they are specifically identified as being subject to the drinking
water regulations and cannot be excluded.
A government-owned aircraft used solely for government purposes that is not conveying
passengers in interstate commerce may be excluded from SDWA and ADWR regulations
if it meets the other three criteria. However, if a government-owned aircraft does not
obtain all water from a public water system (i.e., aircraft that board water from a location
that is outside of US jurisdiction), the aircraft would not be excluded from regulation.
As discussed in Chapter 1, it is important to note that the term "interstate commerce"
does not exclusively apply to aircraft conveying passengers between two different states.
3.2 Aircraft Status as "Active" or "Inactive"
One of the aircraft water system inventory details that must be reported is whether each aircraft
water system is under 'active' or 'inactive' status [40 CFR 141.806(b)(l)(ii)]. EPA requires
accurate information on an aircraft water system's status for ensuring accountability and
compliance. Aircraft water systems under active status must comply with the ADWR; aircraft
water systems that are inactive would not be required to comply with the ADWR during the
period of inactivity.
Aircraft water systems are defined in 40 CFR 141.801 as follows:
"Aircraft Water System means an aircraft that qualifies as a public water system under
the Safe Drinking Water Act and the national primary drinking water regulations. The
components of an aircraft water system include the water service panel, the filler neck of
the aircraft finished water storage tank, and all finished water storage tanks, piping,
treatment equipment, and plumbing fixtures within the aircraft that supply water for
human consumption to passengers or crew."
Active status refers to time periods during which an aircraft water system is in normal operation
flying routes in the US. EPA anticipates that this will be the default for most of the operating
life of an aircraft water system. However, there may be some periods within the operating life of
the aircraft where the aircraft water system may be considered inactive.
In order for an aircraft water system to be considered "inactive" for purposes of compliance
determination under the ADWR, the following conditions must be met to avoid the automatic
issuance of a violation by the ADWR Reporting and Compliance System:
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• The aircraft water system must be identified in the ADWR Reporting and Compliance
system as inactive by the end of the compliance period in which the monitoring or
disinfection and flushing requirement is due to be performed;
• Passenger access to the water system must be prevented by (1) disconnecting or
shutting off the water, (2) preventing the flow of water through the tap(s), (3)
allowing water to be supplied only to lavatory toilets and not to any lavatory or galley
tap, or (4) removing the aircraft from passenger service; and
• The missed requirement(s) must be performed prior to the aircraft water system
serving water to the public.
For example, if an aircraft is having unavoidable logistic problems (such as occurred in early
2010 when aircraft in some areas were grounded due to a volcanic eruption) that causes the
aircraft to miss a required routine disinfection and flushing event because the aircraft is out of
service, the air carrier may identify the aircraft water system in the ADWR Reporting and
Compliance System as inactive before the end of the compliance period in which the routine
disinfection and flushing event should have occurred. Once the aircraft returns to service,
passenger access to the water system must be prevented by disconnecting or shutting off the
water, preventing the flow of water through the taps, or allowing water to be supplied only to
lavatory toilets and not to any lavatory or galley tap. The aircraft water system must not provide
water to the public until the missed requirement(s) has been performed.
3.3 Reporting Inventory Information
The air carrier must report its complete inventory of existing aircraft that are public water
systems to EPA no later than April 19, 2011. Aircraft inventory includes but is not limited to the
following:
• The unique aircraft identifier number;
• The status of aircraft water systems as active or
inactive;
• The type and location of any supplemental treatment
equipment installed on the water system; and
• Whether the aircraft water system can be physically
disconnected or shut off, or the flow of water
prevented through the tap(s).
Any changes in aircraft inventory must be reported no later
than 10 days following the calendar month in which the
change occurred [40 CFR 141.806(b)(l)]. This includes
permanent removal of an aircraft from the inventory, or
changes to the active/inactive status, treatment equipment, or
ability to shut off the water or prevent the flow of water to
taps. This also includes adding new aircraft with public water
systems to the fleet.
Prompt notification to EPA of all inventory changes is
Reporting Inventory
Updates and Updated
Coliform Sampling Plans or
O&M plans
The reporting requirement for
inventory updates is no later
than 10 calendar days
following the calendar month
in which the change occurred.
This differs from the
requirement that new
aircraft coliform sampling
plans and operations and
maintenance plans must be
completed and reported
within the first calendar
quarter of aircraft operation.
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necessary to ensure violations are not incurred by aircraft that are out of service or otherwise
inactive, and that new and active aircraft are in compliance with the rule.
The ADWR Reporting and Compliance System and its User Guide will include information on
the inventory update reporting format and how to make inventory changes.
Details regarding the reporting of aircraft inventory information are provided in Chapter 7.
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4. Coliform Monitoring
Total coliforms are a group of closely related bacteria that, with a few exceptions, are not
harmful to humans. Coliforms are abundant in the feces of warm-blooded animals, but can also
be found in aquatic environments, in soil, and on vegetation. Total coliforms have long been
considered an indicator that a potential pathway exists through which fecal contamination could
enter a water system. The absence of total coliforms in the distribution system indicates a
reduced likelihood that fecal contamination and/or waterborne pathogens are present.
The ADWR uses coliform monitoring as a means of periodically evaluating the bacterial quality
of the water on board the aircraft. All aircraft public water systems are required to monitor for
the presence of total coliforms and to further analyze any total coliform-positive samples for the
presence of Escherichia coli (E. coif). E. coli bacteria are members of the total coliform group
that almost always originate from the gut of warm-blooded animals. Therefore, the presence of
E. coli indicates that the water may be contaminated by human or animal wastes. Many of the
analytical methods for total coliforms simultaneously detect the presence or absence of E. coli.
See Section 4.5.2 for more information on analytical methods.
This chapter discusses the types of coliform samples required by the ADWR; coliform sampling
plan requirements; responses to coliform sample results; coliform sampling protocols; laboratory
and analytical method requirements; and reporting of sample results.
4.1 Types of Coliform Samples
There are three types of coliform samples required by the ADWR: routine samples, repeat
samples, and follow-up samples. Special purpose samples are also an option for air carriers, and
replacement samples may be required if routine, repeat, or follow-up samples or sample results
are invalidated by the laboratory or EPA.
Routine Samples
Routine samples are collected on a specified schedule, which is determined by the frequency of
routine disinfection and flushing of the aircraft water system and must be described in the
coliform sampling plan prepared for the aircraft. See Section 4.2.3 for more information on
routine sampling frequencies. EPA intends for air carriers to schedule routine monitoring at
regular intervals throughout the calendar year. Routine monitoring should be scheduled so that
the amount of time between each monitoring event is approximately equal. Air carriers should
not schedule routine monitoring events to take place back-to-back such that samples are taken at
the end of one monitoring period and again at the beginning of the following period. Routine
samples cannot be collected within 72 hours after completing routine disinfection and flushing
procedures [40 CFR 141.803(b)(6)].
For routine sampling, two samples of 100 milliliters (mL) each must be collected, one from a
galley and one from a lavatory tap during each monitoring period [40 CFR 141.803(b)].
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If the aircraft has only one tap, two 100 mL samples must be collected from that tap. An
exception to the requirement for two routine samples each monitoring period is allowed by the
ADWR for aircraft water systems consisting of only one tap and a removable or portable
container that is drained every day of passenger service. These systems must collect only one
100 mL routine sample from the available tap [40 CFR 141.803(b)(2)].
Aircraft with a single water system but more than two possible sampling locations may also
adjust the sample locations each monitoring period if necessary to collect representative samples
throughout the system. See Section 4.2.2 for more discussion on rotating sample locations.
Repeat Samples
When one or more routine samples are total coliform-positive and E. co//-negative, air carriers
have the option to collect repeat samples instead of performing corrective disinfection and
flushing of the system. Repeat samples provide information on the extent of the contamination
event that resulted in the presence of coliform organisms in the routine samples. If the option to
collect repeat samples is selected, three repeat samples of
100 mL each must be collected no later than 24 hours after
the laboratory notifies the air carrier of the routine total
coliform-positive sample results [40 CFR 141.803(c)(3)(iii)].
The three repeat samples must be collected and analyzed
from three taps within the aircraft as follows: the tap that
resulted in the total coliform-positive routine sample, one
other lavatory tap, and one other galley tap. If less than three
taps exist, then a total of three 100-mL samples must be
collected and analyzed from the available taps within the
aircraft water system. For example, if an aircraft has only
two taps, two 100-mL samples would be collected from one
of the taps, and one 100-mL sample would be collected from
the other tap.
If the carrier cannot collect the repeat samples within 24
hours, no extensions to this timeframe are allowed. The air
carrier must proceed with another option.
Follow-up Samples
Repeat Sample
Twenty-four Hour
Timeframe
Repeat samples must be
collected no later than
24 hours after
notification of routine
sample total coliform-
positive and E. coli-
negative results.
No extensions to the
twenty-four hour time
frame are allowed. If
repeat samples cannot be
collected within 24
hours, the air carrier
must proceed with
another option.
Follow-up samples are used to indicate the effectiveness of corrective disinfection and flushing
procedures. Follow-up samples consist of two samples of 100-mL each that must be collected at
the same locations as the routine samples - that is, a galley tap sample and a lavatory tap sample
must be collected if both are available [40 CFR 141.803(e)]. The ADWR does not specify a
timeframe by which follow-up samples must be collected; however, follow-up samples must be
collected prior to providing water to the public for human consumption from the aircraft water
system.
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Follow-up samples must be collected when:
o Corrective disinfection and flushing is performed in response to a total coliform-
positive orE1. co//'-positive sample.
o Corrective disinfection and flushing is triggered by failure to: perform routine
disinfection and flushing or routine coliform monitoring; failure to collect repeat
samples or follow-up samples; or failure to board water from a safe watering point.
Follow-up samples may be collected after routine disinfection and flushing. See Section 4.2.6 for
more information.
Special Purpose Samples
Special purpose samples are not required by the ADWR. They are samples collected by the air
carrier on a voluntary basis, as needed, to indicate the quality of the onboard water. Special
purpose samples may be useful indicators of water quality following repair or replacement of
water system components or fixtures.
Replacement Samples
In the event a routine, repeat, or follow-up sample is invalidated by the laboratory or EPA, a
replacement sample would be required to fulfill the monitoring requirements of the ADWR. The
sample must be collected within the monitoring period applicable to the original sample. For this
reason, EPA recommends routine monitoring be performed early enough in the monitoring
period to allow notification of the need for replacement samples and their collection before the
monitoring period is over.
Further details regarding invalidated samples are provided later in this chapter.
4.2 Coliform Sampling Plans
By April 19, 2011, air carriers must develop a coliform sampling plan for each aircraft in their
inventory [40 CFR 141.802(b)]. 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, but each aircraft must be covered by a plan. Therefore, a single plan could be developed
to cover each aircraft that has identical requirements and schedules. Coliform sampling plans
should include the unique aircraft identifier numbers to which the plan applies.
Once completed, the air carrier must notify EPA that the coliform sampling plan has been
prepared [40 CFR 141.806(a)] and the plan must be included in the aircraft water system O&M
plan. Air carriers need not submit the coliform sampling plans to EPA but EPA can request a
copy of the plan at any time and may also view the plan during compliance audits. When
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 [40 CFR 141.806(a)(2)]. New aircraft may be added to the list of aircraft covered by an
existing plan, or a new plan may be developed. Air carriers must notify EPA electronically using
the ADWR Reporting and Compliance System. If they are unable to report the information
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electronically, they may use an alternative approach as approved by EPA [40 CFR 141.806(d)].
See Chapter 7 for more discussion regarding reporting requirements.
At a minimum, all coliform sampling plans must include the following [40 CFR 141.802(a)]:
• Coliform sample collection procedures.
• Sample tap location(s) representative of the aircraft water system.
• Frequency and number of routine samples to be collected.
• Frequency of routine disinfection and flushing as specified in the operation and
maintenance plan.
• Procedures for communicating sample results to ensure that all required actions are
conducted in a timely manner.
Each of these elements of a coliform sampling plan is discussed in more detail below. An
example coliform sampling plan is provided in Appendix C.
4.2.1 Coliform Sample Collection Procedures
Standardized procedures ensure representative samples are collected and meaningful sample
results are obtained. Proper sample collection procedures will ensure that contaminants on the
surface of faucets and fixtures are not transferred to the sample container. Suggested sampling
procedures are included in Section 4.4.
4.2.2 Sample Tap Location(s) Representative of the Aircraft Water
System
Coliform sample locations should be those most representative of water used for human
consumption by passengers and crew. As described in Chapter 1, human consumption is not
limited to water used only for drinking or beverage preparation.
Because passengers may access water in the lavatory for hand washing, teeth brushing, drinking,
or preparing dehydrated foods, lavatories must be sampled to represent water provided to the
public. To ensure representative sample collection locations are used, the ADWR requires that
routine coliform samples be collected from a lavatory tap and a galley tap during each
monitoring period if the aircraft has taps in these locations. If an aircraft has a single tap, the
sample(s) must be collected from that tap [40 CFR 141.803(b)]. Follow-up samples are collected
consistent with routine sample collection locations.
Since there is a potential for the water temperature in hot water taps to be high enough to kill
existing microorganisms in the sample, thus masking any microbiological contamination in the
aircraft water system, samples should be collected from cold water taps when they are available.
However, if there is only one tap available in the lavatory, then that tap must be used for the
lavatory sample regardless of the temperature. Similarly, when only a hot water tap is available
in the galley such as those used for making hot tea, the galley sample must be collected from the
hot water tap. If a sample is collected from a hot water tap, it is suggested that the temperature of
the water be recorded, if available. The temperature of the water may be useful in diagnosing
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problems in the water system, but measuring the temperature of the water is not required by the
ADWR.
The ADWR requires that sample collection locations be identified in the coliform sampling plan
[40 CFR 141.802(a)(2)]. 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. This information is useful
for follow-up investigations if an issue arises. For example, air carriers have noted to EPA that
being able to identify the specific sample location from which coliform-positive samples were
collected helped detect problematic faucets as well as cleaning issues. This information may
have helped to identify and resolve persistent coliform-positive sample problems.
Air carriers have flexibility to consider a variety of approaches in developing sampling
procedures to collect representative samples, including:
• If more than one galley and lavatory tap are available, rotate the sample collection
locations each monitoring period on a scheduled basis so that the entire aircraft water
system is sampled periodically. For example, Exhibit 4.1 illustrates an aircraft with 3
lavatories and 4 galleys. If the aircraft is on quarterly coliform monitoring, a sample from
a lavatory and a galley on opposite ends of the aircraft may be appropriate during each
monitoring period. The table in Exhibit 4.1 provides an example of how the galleys and
lavatories on this aircraft might be paired for each of the four quarters of sampling. Note
that a different lavatory and galley is sampled each monitoring period so they are all
routinely sampled.
• If more than one galley and lavatory tap are available, select sample collection locations
randomly to obtain representative samples over time.
• If an aircraft has more than one water tank and plumbing system and the systems are not
interconnected, alternate the sample locations between the discrete systems.
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Exhibit 4.1 Example Sample Locations
EL
L1
G4 L2
Monitoring
Period 1
Lavatory 1 &
Galley 3
Monitoring
Period 2
Lavatory 2 &
Galley 1
Monitoring
Period 3
Lavatory 3 &
Galley 2
Monitoring
Period 4
Lavatory 1 &
Galley 4
4.2.3 Frequency and Number of Routine Coliform Samples to Be
Collected
Including the required frequency and number of samples to be collected in the coliform sampling
plan helps ensure personnel responsible for this task will collect the correct number of samples
during the required monitoring period. The number of routine coliform samples that must be
collected is discussed in Section 4.1. The frequency of sample collection can be either monthly,
quarterly, semi-annually, or annually. It is determined by the routine disinfection and flushing
frequency recommended by the manufacturer of the aircraft water system. If the manufacturer
does not recommend a frequency, the air carrier must choose a frequency and a corresponding
routine coliform sampling frequency as specified in the ADWR [40 CFR 141.804(b)(2)(iii)] and
displayed in Exhibit 4.2. Exhibit 4.2 shows monitoring frequencies that correspond to a given
disinfection and flushing frequency [40 CFR 141.803(b)(3)]. Additional voluntary coliform
sampling is encouraged by EPA.
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Any changes to the frequency of required coliform sampling must be reported to EPA and must
be incorporated into the sampling plan and the aircraft water system O&M plan [40 CFR
141.806(b)(6)] as discussed in Chapter 7.
Exhibit 4.2 Coliform Sampling Frequencies Based on
Disinfection and Flushing Frequencies
Minimum Routine Disinfection and
Flushing Frequency
Minimum Routine Coliform
Sampling Frequency
At least 4 times per year = At least
once within every three-month period
(quarterly).
At least 1 time per year = At least once
within every twelve-month period
(annually)
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 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 1 time per year or less = At
least once within every twelve month
period (annually) or less.
At least 12 times per year = At least
once every month (monthly)
4.2.4 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. Air carriers may conduct disinfection and
flushing more frequently, but not less frequently, than the manufacturer recommends. However,
it is the responsibility of the air carrier to ensure that the frequency would not result in damage to
the aircraft water system's components.
4.2.5 Procedures for Communicating Sample Results to Ensure
All 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 results. Notification of both positive and
negative sample results in a timely manner is critical to ensure any required action is promptly
implemented. Required actions may entail repeat or replacement sampling, restricting public
access including notification of passengers and/or crew, corrective disinfection and flushing,
follow-up sampling, or returning to unrestricted access of the water. EPA suggests that
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communications procedures include specific contact personnel names, phone numbers, and back-
up contact information.
4.2.6 Scheduling Coliform Sampling to Minimize Service
Disruption
Each aircraft water system 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 once every monthly period, once every three-month period (quarterly), once every six-
month period (semi-annually), or once every twelve-month period (annually) - a set of two
routine samples must be collected unless the aircraft qualifies for one routine sample because it
has only a single removable/portable tank-based system with a single tap [40 CFR 141.803(b)].
In order to provide meaningful results, routine coliform sampling is
intended to 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.
If any routine,
repeat, or follow-up
sample is total
coliform-positive or
£. co/;-positive, the
entire aircraft water
system is subject to
the applicable
corrective actions.
This is true even if
samples were
collected from
distinct piping and
storage systems on
a single aircraft.
To ensure that routine sample results are not inadvertently influenced
by sampling too soon after a routine disinfection and flushing event,
routine coliform samples must not be collected within 72 hours after
completing routine disinfection and flushing procedures [40 CFR
141.803(b)(6)]. They can, however, be collected immediately prior to a
routine disinfection and flushing event. This option is provided in the
ADWR to minimize unscheduled flight interruptions for sample
collection.
Flight disruptions may be minimized further in the following situation.
If either of the routine samples that were collected immediately prior to the routine disinfection
and flushing procedure test positive for total coliform or total coliform and E. coli, as long as the
air carrier collected a set of follow-up samples after the routine disinfection and flushing
procedure, then the routine disinfection and flushing event would also serve as a corrective
action disinfection and flushing event. However, if the routine sample was E. co//'-positive, a
complete set of follow-up sample results must be total coliform-negative before the air carrier
provides water for human consumption from the aircraft water system and returns to the routine
monitoring frequency for coliform as specified in 40 CFR 141.802. If the routine sample was
total coliform-positive but E. co//'-negative, the follow-up samples need only be collected before
the aircraft water system provides water to the public.
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Tip: Minimizing Flight Disruptions from Coliform Sampling
and Disinfection and Flushing Events
Routine coliform samples must not be collected within 72 hours after completing routine disinfection
and flushing procedures [40 CFR 141.803(b)(6). However, there is no restriction on how much time
must elapse after routine samples are collected and before disinfection and flushing occurs. The
ADWR allows for the performance of both of these tasks while an aircraft is out of service if the
specified routine coliform monitoring frequency and routine disinfection and flushing frequency will be
met. Many of the routine disinfection and flushing frequency options will accommodate this
arrangement.
For example, when an aircraft is taken out of service to perform its routine disinfection and flushing
procedure and the aircraft is also due for collection of its routine coliform samples, the air carrier may
collect the routine coliform samples prior to initiating the routine disinfection and flushing procedure.
Combining these two activities and performing them while the aircraft is already out of service for other
regularly scheduled maintenance may help to reduce associated disruption to flight service. Another
possible benefit is that the sample collector does not have to wait for the aircraft to arrive if it is already
in the hangar for service. The disinfection and flushing procedure can begin before the results of the
routine coliform samples are known. In this case, because the disinfection and flushing procedure has
not yet occurred when the coliform samples are collected, the quality of the water in the routine
samples will be representative of the water that had been served to passengers and crew. If this
practice is implemented, the samples should be collected as soon as possible after taking the aircraft
out of service to avoid water quality deterioration that may be caused by stagnant water.
Furthermore, if the air carrier, as a precaution, also collects a set of follow-up samples after the routine
disinfection and flushing but before the aircraft serves water to the public and the routine samples test
postive, then the routine disinfection and flushing may serve as a corrective action disinfection and
flushing. However, if the routine sample was £. co/;-positive, a complete set of follow-up sample results
must be total coliform-negative before the air carrier provides water for human consumption from the
aircraft water system and returns to the routine monitoring frequency for coliform as specified in 40
CFR 141.802. If the routine sample was total coliform-positive but £. co/;-negative, the follow-up
samples need only be collected before the aircraft water system provides water to the public.
4.3 Responding to Coliform Test Results
If coliform bacteria are detected in any sample collected from an aircraft, the air carrier must
take follow-up action but has some discretion regarding the activities to be performed [40 CFR
141.803(c)(3)]. However, due to the possible imminent public health threat if E. coli is present in
any sample, options for follow-up activities and their timeframes are very limited [40 CFR
141.803(c)(2)].
Exhibit 4.3 provides a general overview of possible coliform sample result scenarios and refers
to additional exhibits presented in this section, which provide required situation-specific actions
based on those sample results. The details of the required follow-up activities presented in this
section are found in 40 CFR 141.803.
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Exhibit 4.3 Overview of Possible Coliform Sample Result Scenarios
[TC(+) means total coliform-positive; TC(-) means total coliform-negative;
EC(+) means E. co//-positive; EC(-) means E. co//-negative]
Collect routine sample(s) per
monitoring period
All ROUTINE
SAMPLES are
TC(-) &. EC(-)
Any ROUTINE
SAMPLES are
TC(+) &EC(-)
Any ROUTINE
SAMPLES are
TC(+) &EC(+)
Restricting Public Access
Some of the response action requirements in the ADWR include the restriction of public access
to the water system to prevent passengers and crew from accessing the water [40 CFR
141.803(d)]. Restricting public access includes three key items: physically disconnecting or
shutting off the aircraft water system, or otherwise preventing flow of water through the taps
where feasible; providing public notification as applicable; and providing alternatives to water
such as bottled water and antiseptic hand gels to enable passengers and crew to maintain sanitary
conditions. The components of restricting public access are presented in Exhibit 4.4.
There may be operational constraints to physically disconnecting the water system. For example,
if water to the taps cannot be shut off without also shutting off water to the toilets, then the air
carrier may determine that physically disconnecting the water system is not feasible.
Furthermore, EPA interprets the ADWR requirement "otherwise preventing the flow of water
through the taps" to be accomplished through means similar to physical disconnection. As a
result, if the "prevention" is easily removed, it would not meet the terms of the ADWR because it
is not similar in effect to physical disconnection and is not an effective means of "preventing the
flow of water through the taps."
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Exhibit 4.4 Restricting Public Access
Physically disconnect or shut
off the aircraft water system,
where feasible,
or otherwise prevent
the flow of water through the taps
If the aircraft water system CANNOT be shut off,
do the following:
Public notification to c re wand passengers
using language applicable to the situation
Provide alternatives to water system (e.g.,
antiseptic hand gels orwipes, bottled water)
If the aircraft water system CAN be shut off,
do the following:
Public notification to crew using language
applicable to the situation
Provide alternatives to water system (e.g.,
antiseptic hand gels orwipes, bottled water)
Air carriers must give public notice for each aircraft as part of restricting access to the water
system.
• If passenger access to the water system is physically prevented through disconnecting or
shutting off the water or the flow of water prevented through the tap(s), or if water is
supplied only to lavatory toilets and not to any lavatory or galley taps, then the ADWR
requires notice that is directed at the crew. Notice to the crew may be conveyed as part of
a mandatory crew briefing or prominently displayed in the galley.
• If the aircraft water system cannot be physically disconnected or the flow of water to the
taps otherwise prevented, prominent notice must be displayed in the galley for the crew
and prominently displayed in the lavatory for the passengers.
Public notification requirements are discussed in detail in Chapter
6[40CFR141.805(c)].
Whether the water system can be physically disconnected or not,
alternatives to water from the aircraft water system, such as bottled
water for drinking and coffee or tea preparation, are required if
such services are provided. In addition, antiseptic hand gels or
wipes and other feasible measures are necessary to help maintain
sanitary conditions for passengers and crew. EPA also recommends
that if public access to the water is restricted, 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.
Bottled Water
The requirement for the use
of bottled water, if water use
is restricted and beverages
are provided, is consistent
with the FDA requirements of
21 CFR 333. This does not
require that bottled water be
provided, but it does require
that bottled water be used to
prepare beverages under
these circumstances.
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4.3.1 Total Coliform-Negative Routine Sample Result
If total coliform bacteria are not detected in any routine sample in a monitoring period, the
aircraft must continue collecting routine samples for total coliform analysis at the frequency
specified in the coliform sampling plan [40 CFR 141.803(c)(l)]. A sample must be total
coliform-positive before it is required to be analyzed for E. coli. Therefore, a sample that is total
coliform-negative is alsoE1. co//'-negative and the aircraft should continue conducting routine
disinfection and flushing.
4.3.2 Total Coliform-Positive and E. co//-Negative Routine Sample
Result
A routine coliform sample result that is total coliform-positive but is E. co//'-negative indicates
the aircraft water system may be vulnerable to contamination by pathogens (e.g., viruses,
bacteria, or parasitic protozoa from fecal contamination) that can cause disease. If any routine
sample is total coliform-positive andE. co//-negative, the aircraft has three options: 1) disinfect
and flush the water system within 72 hours; 2) disinfect and flush on an alternative schedule if
public access to the water system is restricted within 72 hours; or 3) collect repeat samples
within 24 hours and take further action, if necessary [40 CFR 141.803(c)(3)]. These three options
are illustrated in Exhibit 4.5 and described in more detail below.
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Exhibit 4.5 Overview of Options for Response to Total Coliform-Positive
(E. co//-Negative) Sample Results
[TC(+) means total coliform-positive; TC(-) means total coliform-negative;
EC(+) means E. co//-positive; EC(-) means E. co//-negative]
Any ROUTINE SAMPLE is
TC(+)&EC(-)
OR
OR
OR
Option 3:
Collect 3 REPEAT
SAMPLES within
24 hours
See
Exhibit
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Option 1: Disinfect and Flush Within 72 Hours and Collect Follow-up Samples
If an aircraft chooses Option 1 in response to a routine total coliform-positive and E. coli-
negative sample result, they must disinfect and flush the aircraft water system within 72 hours of
being notified of the positive result and collect follow-up samples. After the follow-up samples
are collected, water from the aircraft water system may be provided for human consumption (see
Exhibit 4.6).
• If all of the follow-up sample results are total coliform-negative, the air carrier may return to
routine coliform monitoring and continue serving water to the public. Public notification of
the situation is not required if this option for corrective action is selected and successfully
implemented.
• If either of the follow-up samples are total coliform-positive but E. co//'-negative, the air
carrier must restrict public access within 72 hours after receiving the sample results and
disinfect and flush the water system again, with the process continuing until a complete set of
follow-up samples is total coliform-negative. If the aircraft is returned to service, unrestricted
access to the water system cannot be provided until a set of follow-up samples is total
coliform-negative.
• If any of the follow-up samples are E. co//'-positive, the air carrier must restrict public access
within 24 hours after receiving the sample results and disinfect and flush the water system
when able and collect follow-up samples. Restricted access must be maintained until a
complete set of follow-up samples is coliform-negative. If the aircraft water system cannot be
shut off or physically disconnected, or the flow of water otherwise prevented through the
taps, then the corrective disinfection and flushing with follow-up sampling must be
performed within 72 hours and restricted access must be maintained until a complete set of
follow-up samples is coliform-negative.
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Exhibit 4.6 Total Coliform-Positive and E. co//-Negative Routine Samples:
Option 1: Disinfection and Flushing Details
[TC(+) means total coliform-positive; TC(-) means total coliform-negative;
EC(+) means E. co//-positive; EC(-) means E. co//-negative]
Any ROUTINE SAMPLE
is TC(+) &. EC(-)
OR
Option 2: Restrict public
access within 72 hours.
OR
OR
Option 1: Disinfect and flush
within 72 hours, and collect
FOLLOW-UP SAMPLES priorto
providing water for human
consumption
Option 3: Collect 3 REPEAT
SAMPLES within 24 hours.
ROUTINE
SAMPLE. See
Exhibit 4.9
Disinfect and flush
WHEN ABLE, and
collect FOLLOW-UP
SAMPLES
All
FOLLOW-UP
SAMPLES are
TC(-)&EC(-)
1
,
/ Unrestrict
public access
and return to
routine
\ monitoring
Continue to restrict
public access and
disinfect and flush
until a set of
FOLLOW-UP
SAMPLES is
TC(-) a EC(-)
Any
FOLLOW-UP
SAMPLES are
TC(+) & EC(+)
Follow
requirements for
TC(+)&EC(+)
ROUTINE
SAMPLE. See
Exhibit 4.9
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Option 2: Restricting Public Access Within 72 Hours and Disinfecting and Flushing When Able
If an air carrier chooses Option 2 in response to a routine total coliform-positive and E. coli-
negative sample result, they must restrict public access to the aircraft water system within 72
hours after the laboratory notifies them of the positive test result, provide public notice
appropriately (see Chapter 6), and disinfect and flush the water system on an alternative schedule
(see Exhibit 4.7). Restricting public access enables the air carrier to delay the corrective
disinfection and flushing procedure and follow-up sampling until the activity can be scheduled at
a more convenient time.
After disinfection and flushing and follow-up samples are collected, the aircraft water system can
be unrestricted and water can be provided to passengers and crew.
• If all of the follow-up sample results are total coliform-negative, the system may return to
routine coliform monitoring and continue serving water to the public.
• If either of the follow-up samples are total coliform-positive and E. co//'-negative, the air
carrier must restrict public access within 72 hours after receiving the sample results and
disinfect and flush the water system again, with the process continuing until a complete set of
follow-up samples is total coliform-negative. If the aircraft is returned to service, unrestricted
access to the water system cannot be provided until a set of follow-up samples is total
coliform-negative.
• If any of the follow-up samples are E. co//'-positive, the air carrier must restrict public access
within 24 hours after receiving the sample results and disinfect and flush the water system
when able and collect follow-up samples. Restricted access must be maintained until a
complete set of follow-up samples is coliform-negative. If the aircraft water system cannot be
shut off or physically disconnected, or the flow of water otherwise prevented through the
taps, then the corrective disinfection and flushing with follow-up sampling must be
performed within 72 hours and restricted access must be maintained until a complete set of
follow-up samples is coliform-negative.
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Exhibit 4.7 Total Coliform-Positive and E. co//-Negative Routine Samples:
Option 2: Restricting Public Access
[TC(+) means total coliform-positive; TC(-) means total coliform-negative;
EC(+) means E. co//-positive; EC(-) means E. co//-negative]
Any ROUTINE SAMPLE
is TC(+) & EC(-)
OR
OR
Option 1: Disinfect and flush Ontion2: Restrict
within 72 hours Public access within
72 hours.
f Koo \,
{ Exhibit ) Disinfect and flush WHEN ABL
\**/ and collect FOLLOW-UP
SAMPLES priorto providing
water for human consumption
All Any
FOLLOW-UP FOLLOW-UP
SAMPLES are SAMPLES are
TC(-)&EC(-) TC(+)8.EC(-)
Restrict .
Return to | public /
routine access /
I monitoring I within
72 hours V
\
AND
Disinfect and flush WHEN
ABLE, and collect
FOLLOW-UP SAMPLES
All Any
FOLLOW-UP FOLLOW-UP
SAMPLES are SAMPLES are
TC(-)&EC(-) TCW&ECH
/Continue to restrict \
/ Unrestrict N^ / public access and \
| public access | / to disinfect and
routine I FOLLOW-UP J
\ monitoring / \ SAMPLES is /
\TC(-) & ECO/
OR
Option 3: Collect 3 REPEAT
SAMPLES within 24 hours.
Any
FOLLOW-UP
SAMPLES are
TC(+)&EC(+)
/^See >,
Exhibit I
\*-B/
Follow >.
requirements for \
TC(+) & EC(+) \
ROUTINE 1
SAMPLE. See /
Exhibit 4.9 /
Any
FOLLOW-UP
SAMPLES are
TC(+) & EC(+)
f Follow >.
/ recjuirementsfor \
TC(+) & EC(+) \
i ROUTINE I
\ SAMPLE. See /
\ Exhibit 4. 9 /
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Option 3: Collecting Repeat Samples Within 24 Hours
If an air carrier chooses Option 3 in response to a routine total coliform-positive and E. coli-
negative sample result, they must collect three repeat samples within 24 hours of learning of the
result. One repeat sample must be collected from the same tap as the total coliform-positive
routine sample, one sample must be collected from another galley tap, and the third sample must
be collected from another lavatory tap, if these types of taps are available. If less than three taps
are available, then the samples must be collected from the available taps within the aircraft water
system. It may be necessary for more than one sample to be collected from the same tap. If
samples cannot be collected within 24 hours, the air carrier must choose Option 1 or 2.
Exhibit 4.8 provides an illustration of actions that are required based on the analytical results of
the repeat samples.
There are three possible analytical results and respective follow-up actions for repeat samples:
• If all of the repeat samples are total coliform-negative the aircraft returns to the routine
monitoring frequency and need not restrict access to the water system or conduct corrective
disinfection and flushing.
• If any of the three repeat samples indicate the presence of total coliforms but not the presence
of E. co//', the air carrier can choose one of the following response options:
o Conduct disinfecting and flushing of the aircraft water system within 72 hours of
being notified of the positive result and collect follow-up samples. After the follow-
up samples are collected, water from the aircraft water system may be provided for
human consumption.
• If all of the follow-up sample results are total coliform-negative, the system
may return to routine coliform monitoring and continue serving water to the
public.
• If either of the follow-up samples are total coliform-positive, the air carrier
must restrict public access within 72 hours and disinfect and flush the water
system again, with the process continuing until a complete set of follow-up
samples is total coliform-negative. If the aircraft is returned to service,
unrestricted access to the water system cannot be provided until a set of
follow-up samples is total coliform-negative.
• If any of the follow-up samples are E. co//-positive, the air carrier must
restrict public access within 24 hours and disinfect and flush the water
system when able and collect follow-up samples. Restricted access must be
maintained until a complete set of follow-up samples is coliform-negative. If
the aircraft water system cannot be shut off or physically disconnected, or the
flow of water otherwise prevented through the taps, then the corrective
disinfection and flushing with follow-up sampling must be performed within
72 hours and restricted access must be maintained until a complete set of
follow-up samples is coliform-negative.
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o Restrict public access to the aircraft water system within 72 hours after the
laboratory notifies them of the positive test result, provide public notice
appropriately, and disinfect and flush the water system on an alternative schedule.
After the follow-up samples are collected, water from the aircraft water system may
be provided for human consumption.
• If all of the follow-up sample results are total coliform-negative, the system
may return to routine coliform monitoring and continue serving water to the
public.
• If either of the follow-up samples are total coliform-positive, the air carrier
must restrict public access within 72 hours and disinfect and flush the water
system again, with the process continuing until a complete set of follow-up
samples is total coliform-negative. If the aircraft is returned to service,
unrestricted access to the water system cannot be provided until a set of
follow-up samples is total coliform-negative.
• If any of the follow-up samples are E. co//'-positive, the air carrier must
restrict public access within 24 hours and disinfect and flush the water
system when able and collect follow-up samples. Restricted access must be
maintained until a complete set of follow-up samples is coliform-negative. If
the aircraft water system cannot be shut off or physically disconnected, or the
flow of water otherwise prevented through the taps, then the corrective
disinfection and flushing with follow-up sampling must be performed within
72 hours and restricted access must be maintained until a complete set of
follow-up samples is coliform-negative.
• If any of the repeat samples are E. co//'-positive, the aircraft must meet the requirements for
E. co//'-positive routine or repeat samples described in Section 4.3.3.
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Exhibit 4.8 Total Coliform-Positive and E. co//-Negative Routine Samples:
Option 3: Repeat Sample Details
[TC(+) means total coliform-positive; TC(-) means total coliform-negative;
EC(+) means E. co//-positive; EC(-) means E. co//-negative]
Anv ROUTINE SAMPLE is
TC(+) & EC(-)
OR
„ , , .
Option 1: Disinfect and
flush within 72 hours
OR
OR
Option3: Collects REPEAT
SAMPLES within 24 hours
Option 2: Restrict public
access within 72 hours
See
[ Exhibit |
4.9
Return to
routine
monitoring
hours, and collect
SAMPLES prior to
Disinfect and flush WHEN ABLE,
and collect FOLLOW-UP
SAMPLES priorto providing
waterfor human consumption
Restrict public
access within 72
hours and disinfect
and flush until a set
of FOLLOW-UP
SAMPLES is
TC(-) & EC(-)
Follow
requirements for
TC(+) & EC(+)
ROUTINE
SAMPLE. See
Exhibit 4.9
Return to
routine
monitoring
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4.3.3 E. co//-Positive Routine or Repeat Sample Result Options
The presence of E. coli in a water sample indicates that the water may be contaminated with
human or animal fecal waste. This is a serious situation and requires an immediate response
(within 24 hours of notification of the sample result) by the air carrier.
If E. coli is present in any routine or repeat sample, the air carrier must restrict public access to
the water system, including providing public notice, within 24 hours of learning of the test
result. The air carrier must then conduct corrective disinfection and flushing when able and
collect follow-up samples. Restricted access must be maintained until a complete set of follow-
up samples is coliform-negative [40 CFR 141.803(c)(2)].
If the aircraft water system cannot be shut off or physically
disconnected, or the flow of water otherwise prevented
through the taps, then the air carrier must provide public
notice within 24 hours and conduct corrective
disinfection and flushing no later than 72 hours after the
laboratory notifies the air carrier of the E. co/i-positive
result and collect follow-up samples. Restricted access
must be maintained until a complete set of follow-up
samples is coliform-negative.
Exhibit 4.9 presents the required actions based on E. coli-
positive routine samples or E. co//'-positive repeat samples
that were collected in response to a total coliform-positive
and E. co//'-negative routine sample. Repeat sampling is not an option when any sample is E.
co//'-positive.
If passengers or crew are able
to access the water, the air
carrier must provide public
notice to the passengers and
crew within 24 hours and
disinfect and flush the
aircraft water system no
later than 72 hours after the
laboratory notifies the air
carrier of the E. co//'-positive
result and collect follow-up
samples
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Exhibit 4.9 E. co//-Positive Routine or Repeat Samples: Required Activities
[TC(+) means total coliform-positive; TC(-) means total coliform-negative;
EC(+) means E. co//-positive; EC(-) means E. co//-negative]
Any ROUTINE or REPEAT
SAMPLES are
TC(+)&EC(+)
Restrict public access within
24 hours
If the a ire raft water system
CANNOT be shut off* do
the following:
Shut off* the aircraft
water system where
feasible
If the a ire raft water system
CAN be shut off*, do the
following:
Provide public notification to
crew and passengers
Provide public notification to
crew
Provide alternatives to water system (e.g.,
antiseptic hand gels or wipes, bottled water)
P rovi d e a Ite rn atives to wate r system (e . g .,
antiseptic hand gels or wipes, bottled water)
AND
Disinfect and flush
within 72 HOURS,
and collect
FOLLOW-UP
SAMPLES
AND
Disinfect and flush
WHEN ABLE,
and collect
FOLLOW-UP
SAMPLES
All
FOLLOW-UP
SAMPLES are
TC(-) & EC(-)
i
Any
FOLLOW-UP
SAMPLES are
TC(+) & EC(-)
Any
FOLLOW-UP
SAMPLES are
TC(+) & EC(+)
1
Continue to follow
requirements forTC(+)
& EC(+) ROUTINE
SAMPLE provided in
this exhibit until a set
of FOLLOW-UP
SAMPLES is
TC(-) & EC(-)
*Includes preventing the flow of water through the taps.
There are other violations or situations that require the corrective actions shown in Exhibit 4.9.
Examples of other situations include:
o
o
o
Failing to collect follow-up samples after corrective disinfection and flushing that
was triggered by an E. co//'-positive routine or repeat sample;
Becoming aware of an E. co//'-positive event that resulted from failing to board water
from a safe watering point; and
Boarding water that is otherwise determined to be unsafe due to non-compliance with
the procedures for boarding water that are included in the aircraft O&M plan.
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4.4 Suggested Sampling Protocol
The following is a suggested sampling protocol that could be used for the collection of routine,
repeat, or follow-up samples. Critical steps in the sample collection procedure include ensuring
the sample is representative of water provided to passengers and crew (including any
supplemental treatment), the sample collection bottle does not become contaminated, and the
faucet or fixture to be sampled will not contribute contamination from the external surface.
4.4.1 Materials and Preparation for Sampling
The laboratory that will perform the analyses should be contacted in advance of the planned
sampling collection date. In advance, it should be determined if the laboratory will provide
sample bottles, and if so, how many will be needed. Additionally, it should be determined
whether the laboratory will provide a return shipping cooler and ice packs (shipment of ADWR
samples on ice to obtain a shipping temperature of 10 degrees Celsius or less without freezing
the sample is recommended). Sufficient time should be allowed to obtain materials and to agree
on a sample submittal date.
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.) The analysis of the samples by the
laboratory must begin within 30 hours of sample collection or the sample will be invalid and a
replacement sample will be required [40 CFR 141.803(a)(4)].
Below is a list of suggested materials needed for sampling.
1) Sample collection sheet
2) Laboratory chain of custody form
3) Indelible pen
4) Sample bottles (150-mL sterile plastic with non-toxic cap and dechlorinating agent)
5) Cooler with ice packs (optional) (contained-ice packs are preferable to ice cubes)
6) Rubber, latex, or non-latex exam gloves
When collecting a sample, label the bottle (not the lid) prior to sample collection with the
following information:
• Sample ID correlating to the sample tap location (e.g., lav or gal and aft or fore) 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
For each aircraft, total coliform samples must be collected from a galley tap and a lavatory tap
unless there is only one tap. Both lavatory and galley samples should be collected from a cold
water tap if possible. If the only sampling point in the lavatory or galley is a hot water tap or the
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coffee maker, collect the sample at that location and indicate the sampling location on the sample
collection sheet [40 CFR 141.803(b)].
During sampling, exam 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. The term "tap" in this procedure means water tap, faucet, drinking fountain, or other
fixture which provides water for human consumption to passengers or crew. Do not sample from
leaking taps or taps which allow water to run down the outside of the fixture.
1) Put on gloves.
2) Open tap and allow water to run for at least 30 seconds to flush tap.
3) Reduce water flow so the stream is not greater than 1A inch in diameter, or the width of a
pencil. Check for steady flow; do not change the water flow once the sample collection
has begun, as this could dislodge microbial growth.
4) Remove cap of total coliform sample bottle.
5) Be careful not to contaminate the bottle by touching the interior of the cap or the inside of
the sample container. Do not place cap on counter (which may be contaminated) or in
your pocket to prevent container contamination.
6) Place bottle under water stream allowing for an air gap between top of the bottle and the
water tap. Hold the bottle in one hand and the cap in the other. Fill the bottle to the 100
mL fill line. If the bottle becomes overfilled, do not pour out the sample (this may lead to
sample contamination); instead send it to the laboratory as is.
7) Do not rinse the bottle either before or after sample collection.
8) Replace cap and tighten. Turn off water.
9) Ensure that sample ID matches that recorded on the sample collection sheet.
10) Place bottles into Ziploc® or similar bag. Place bag in cooler or other transport container
(packing the sample on ice (NOT dry ice) is recommended, but optional)
11) 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.
12) Sign and date the following statement on the sample collection sheet. If there was any
deviation from protocol, note this at the bottom of sample collection sheet.
I certify that all samples were collected in accordance with the protocol entitled "Protocol for
Sampling Drinking Water on Aircraft."
Signature Date
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4.5 Certified Laboratories and Analytical Methods
4.5.1 Certified Laboratories
The ADWR specifies that samples will be considered valid only if they are analyzed by a
laboratory certified by a state or by EPA [40 CFR 141.803(a)(6)].
EPA's laboratory certification manual, Manual for the Certification of Laboratories Analyzing
Drinking Water: Criteria and Procedures Quality Assurance, 5th Edition (EPA 815-R-05-004,
January 2005) indicates that EPA's Office of Ground Water and Drinking Water (OGWDW)
will accept National Environmental Laboratory Accreditation Program (NELAP) accreditation as
equivalent to Drinking Water certification. There are some international laboratories that are
accredited by the NELAP program (See http://www.nelac-institute.org/accred-labs.php or
http://www.nelac-institute.org/membership.php).
The following link provides an explanation of the NELAP accreditation program:
http://www.nelac-institute.org/accred-bodies.php
4.5.2 Analytical Methods
The ADWR requires that a certified laboratory be used for all coliform sample analyses, and also
requires 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 total coliform bacteria
andE. coli, as listed in 40 CFR 141.21(f)(3) and 141.21(f)(6) [40 CFR 141.803(a)(3)]. The
current list of approved analytical methods for total coliforms and E. coli is also provided on
EPA's web site at http://www.epa.gov/safewater/methods/pdfs/methods/methods_tcr.pdf
Each sample need only be analyzed for the presence or absence of the organisms; enumeration of
the bacteria present is not necessary.
Discuss with the laboratory the test methods it is certified to perform and the anticipated
timeframe for reporting results, as well as its procedure for reporting results. Because of the
availability of overnight shipping, the preferred laboratory may not be the one closest to the
sampling location.
4.5.3 Sample Invalidation
EPA recognizes that in rare circumstances a total coliform-positive or E. co//'-positive sample
result may not reflect the water quality in the aircraft water system. The ADWR references the
sample invalidation provisions of the Total Coliform Rule (TCR) as found in 40 CFR
141.21(c)(l)(i), (ii), and (iii) for invalidation by EPA, as the State, and in 40 CFR 141.21(c)(2)
for invalidation by the certified laboratory.
These provisions address three scenarios when EPA may invalidate a total coliform-positive
sample.
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The first scenario is if the laboratory establishes that improper sample analysis caused the total
coliform-positive result. If it is a routine sample that is invalidated, then a replacement routine
sample must be collected and analyzed before the end of the monitoring period in order to avoid
a violation for failure to collect the required routine sample(s). If it is a repeat sample that is
invalidated, then a replacement repeat sample must be collected within 24 hours of being notified
of the invalidated repeat sample. This timeframe is consistent with the requirements for
collecting repeat samples within 24 hours of notification under the ADWR. If it is a follow-up
sample that is invalidated, then a replacement follow-up sample should be collected as soon as
possible to ensure compliance.
The second scenario, which is not readily applied to aircraft public water systems, allows EPA to
determine that the total coliform-positive sample resulted from a domestic or other non-
distribution system plumbing problem on the basis of the results of repeat samples. However,
because all of the aircraft water system plumbing is the responsibility of the air carrier, from the
storage tank filler neck to the tap, aircraft water systems do not have "domestic" or "other non-
distribution system plumbing" that would justify the invalidation of a total coliform-positive
sample.
The third scenario allows EPA to invalidate a sample if 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 distribution system. In this scenario, the system must still collect all required
repeat samples and use them to determine compliance. There is no replacement sample required
since the system has collected all repeat samples that are required under the ADWR and
compliance has been determined. To invalidate a total coliform-positive sample under this
scenario, EPA must document the decision and its rationale in writing and make the decision
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.
Under the only laboratory-invalidation scenario, 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.
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4.6 Reporting Sample Results
The reporting requirements for sample results become effective October 19, 2011. As the
primacy agency, EPA will oversee reporting by air carriers. To facilitate collection and analysis
of aircraft water system data, EPA has developed the ADWR Reporting and Compliance System
(ARCS), an Internet-based electronic database. Analytical results for microbiological testing will
be reported directly to this database. ARCS will perform logic checks on data entered and
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. ARCS has a companion User Guide that provides information pertinent to users of the
system. The user guide includes a description of the spreadsheet format and reporting method,
how to access the downloadable spreadsheet and Web user interface, and other key information.
Air carriers should instruct laboratories to either manually enter analytical results into the EPA-
managed Web-based data system, or to electronically upload data files from their laboratory
information management systems (LIMS) to a Web-based data file submission program.
Regardless of the method or personnel used to report the data, 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, it can submit a request to EPA to use an alternate
reporting format. Air carriers may determine the best method of data upload and reporting that
meets their needs. The ADWR does not require laboratory reporting nor prohibit consultants or
other agents from gathering and reporting results on the carrier's behalf. If it is believed that a
result was entered into the data system erroneously, the air carrier has the responsibility to notify
the laboratory or responsible party to rectify the entry.
All routine sample results that are total coliform-negative must be reported to EPA no later than
10 calendar days following the end of the monitoring period in which the sampling occurred [40
CFR 141.806(b)(3)]. Remember that the length of the monitoring period depends on the routine
coliform sampling frequency; therefore, air carriers may need to report the results monthly,
quarterly, semiannually, or annually.
All routine, repeat, or follow-up sample results that are total coliform-positive or E. co//-positive
must be reported to EPA no later than 10 calendar days after receiving the sample results.
Refer to Chapter 7 for more details on the requirements for reporting sampling results.
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5. Operations and Maintenance Plans
5.1 Overview of Requirements and Timeframes
Developing and implementing operations and maintenance (O&M) plans that cover every
aircraft public water system is crucial to tailoring the National Primary Drinking Water
Regulations to the unique needs of aircraft. This chapter discusses each of the ADWR
requirements for O&M plans and 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.
For each aircraft listed in an air carrier's inventory, an aircraft water system O&M plan must be
developed and its completion reported to EPA by April 19, 2011 [40 CFR 141.806(a)(l)]. A
separate plan need not be developed for each aircraft - more than one aircraft may be covered by
the same plan. However, each aircraft water system must be covered by an O&M plan. New
aircraft added to the inventory after April 19, 2011, must be either added to an existing plan or a
new plan developed and reported to EPA by the end of the first calendar quarter during which
the aircraft is placed into operation as a public water system. Air carriers need not submit the
O&M plans to EPA but EPA can request a copy of the plan at any time and may also view the
plan during compliance audits. The ADWR requires air carriers to include the O&M plans in
their FAA-accepted O&M programs [40 CFR 141.804(a)]. Also, any changes to the aircraft
water system O&M plan must be included in the FAA-accepted air carrier O&M program.
In order to ensure that the appropriate multiple barriers to contamination are in place, each
aircraft water system O&M plan must include the components described below [40 CFR
141.804(b)].
5.2 Watering Point Selection Requirement
The O&M plan must specify that all watering points must be selected in accordance with FDA
regulations [21 CFR part 1240, subpart E]. The FDA regulations, in part, state, "Only potable
water shall be provided for drinking and culinary purposes by any operator of a conveyance
engaged in interstate traffic... Such water shall either have been obtained from watering points
approved by the Commissioner of Food and Drugs, or, if treated aboard a conveyance, shall have
been subjected to treatment approved by the Commissioner of Food and Drugs."
An official classification list of watering points that are in accordance with FDA regulations is
anticipated to be available through the FDA website in late 2010. FDA's list of aircraft watering
points and service areas is a complete list of known watering points and service areas on the day
of its posting. The list is derived from FDA's Official Establishment Inventory (OEI) and
supplemented by verifiable information from airline companies, airport authorities, and
cooperating state health authorities with jurisdiction at US airports. The listing is scheduled to be
updated quarterly. If a watering point is not listed or has not been approved, the FDA may permit
its temporary use under such conditions as, in FDA's judgment, are necessary to prevent the
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introduction, transmission, or spread of communicable disease [21 CFR 1240.83(c)]. The
Internet website will provide FDA District Office contact information so that users of the
watering point and service area can communicate directly with FDA to add, remove, or obtain
permission for temporary use of a specific watering point and service area during a quarterly
update period.
EPA and its federal partner FDA stress the importance of effective communication between all
of the responsible parties along the aircraft water supply and transfer chain including public
water systems serving airports, airport authorities, air carriers, and regulatory authorities (i.e.,
state drinking water primacy agencies, FDA, and EPA).
5.3 Routine and Corrective Disinfection and Flushing
The O&M plan must include specific information on the procedures and frequency of routine
disinfection and flushing for aircraft water systems. The procedures and frequency must be in
accordance with the manufacturer's recommendations [40 CFR 141.804(b)(2)]. EPA specifically
designed the rule to allow air carriers to be consistent with the manufacturer recommendations
for disinfecting and flushing aircraft water systems, instead of prescribing the frequency and the
chemical type and concentration to be used. By allowing air carriers to be consistent with the
manufacturer recommendations for disinfection and flushing, the rule requirements will
automatically evolve with technological improvements in aircraft water tank lining and piping
materials, and as more effective disinfectants are developed.
EPA understands that some manufacturers do not provide equipment disinfection and flushing
recommendations and others specify that it be performed as required by the applicable regulating
authority. Where a recommended routine disinfection and flushing frequency is not provided by
the aircraft water system manufacturer, the air carrier must choose a disinfection and flushing
frequency and corresponding routine coliform sampling frequency from the four options
identified in the ADWR (see Section 4.2.3). In addition, air carriers may conduct disinfection
and flushing more frequently, but not less frequently, than the manufacturer recommends.
However, it is the responsibility of the air carrier to ensure the selected frequency would not
result in damage to the aircraft water system's components.
The ADWR requires that the O&M plan identify the following details of disinfection and
flushing practices [40 CFR 141.804(b)(2)]:
• Routine disinfection and flushing frequency (i.e., quarterly; at least three times per year;
semi-annually; annually).
• Type of disinfecting agent - chemical used as the disinfectant (e.g., chlorine dioxide,
chlorine, ozone, etc.).
• Disinfectant concentration - concentration of the disinfecting agent or the diluted
disinfectant solution that is applied to the aircraft water system (e.g., milligrams per Liter
(mg/L), parts per million (ppm)).
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• Disinfectant contact time - amount of time the disinfecting agent or solution is in contact
with aircraft water system components (e.g., 20 minutes, 1 hour, etc.).
• The flushing volume or flushing time - volume of potable water or length of time
required to flush the disinfecting agent out of the aircraft water system (e.g., replace one
tank volume, 5 minutes, etc.).
Corrective disinfection and flushing is triggered by the following situations:
• Total coliform-positive routine sample(s) if the corrective disinfection and flushing
option is selected.
• Any repeat samples are total coliform-positive.
• E. coli is detected in any routine, repeat, or follow-up sample.
• An air carrier fails to conduct routine or corrective disinfection and flushing.
• An air carrier fails to collect routine, repeat, or follow-up coliform samples as required
(see Chapter 4 for coliform monitoring requirements).
• An air carrier boards water from a watering point that is not in accordance with FDA
regulations, that does not meet EPA drinking water standards for transient non-
community water systems, or that may be unsafe due to noncompliance with the boarding
procedures in the aircraft water system O&M plan.
The time frame in which air carriers must conduct corrective disinfection and flushing depends
on which situation or event triggered the corrective action. See Chapter 8 for more information.
Chemicals used in the aircraft water system must meet all applicable laws and regulations and
should be certified as meeting the standards of NSF/American National Standards Institute
(ANSI) 60 or an equivalent standard. This ensures the chemical has been tested and found
acceptable for use in public water supplies.
Examples of disinfection and flushing procedures.
Several air carriers submitted their aircraft water system disinfection and flushing procedures to
EPA. Those procedures were found to have relatively common steps and recommendations. The
following is a list of items that air carriers should consider to ensure disinfection and flushing
procedures are effective. They are not intended to replace manufacturer's recommendations.
• Open all taps and completely drain the water system.
• Remove filters and replace filter caps to provide water-tight seal.
• Make up disinfectant solution following manufacturer's instructions.
• Fill water system tank with disinfectant solution and/or add water until full (full when
water drains out of tank overflow).
• Ensure disinfected water flows from galley and lavatory taps and drinking fountains until
proper disinfectant concentration is measured at all taps or the disinfectant is observed to
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flow from the taps. Various procedures have been suggested to accomplish this task. For
example:
o Flush galley and lavatory taps until disinfecting solution flows from the tap.
o Flush toilets in vacuum waste systems 2 to 5 times with a 15 second interval between
flushes.
o Flush galley and lavatory taps for 3 minutes.
o Flush galley taps enough to run 5 liters of solution through the tap.
o Flush cold water tap in lavatory enough to fill sink, drain the sink, then flush hot
water tap enough to fill sink.
• Top off water system tank with disinfectant solution.
• Hold disinfectant solution in water system for predetermined contact time in accordance
with manufacturer's recommendations.
• Completely drain water system.
• Flush the water system with potable water by allowing the water to flow from each tap
until disinfectant is no longer observed or otherwise detected.
• To ensure disinfectant has been flushed out of the water system, completely drain the
water system after it has been flushed and refill again with potable water.
• Install new filters (installation may be prior to collection of follow-up samples to ensure
the filters do not degrade water quality).
• Remove and clean tap aerators.
• Adhere to procedures and considerations for electronic controls, system pressurization
limits, and tag and safety circuit breakers.
• If the aircraft will be parked for more than three days, drain the water system. When it is
returned to service, perform the disinfection and flushing procedure and then fill the
water system with potable water.
• 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 and flushing 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
disinfection and flushing procedure, replace charcoal filters if installed, and fill with
potable water.
5.4 Follow-up Sampling
The O&M plan must include written procedures for conducting follow-up coliform sampling
after a corrective disinfection and flushing event takes place. Follow-up samples indicate
whether the disinfection and flushing event was successful. See Section 4.3 for corrective actions
based on sample results that require follow-up sampling and could be incorporated into an O&M
plan, and Section 4.4 for recommended sampling procedures.
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5.5 Training of Personnel
Training is required for air carrier staff and contractors responsible for operating and maintaining
the aircraft water system [40 CFR 141.804(b)(4)]. This includes staff that board water, conduct
sampling and disinfection and flushing, or perform self-inspections. Training may be tailored to
individual job descriptions so that it is specific to the tasks the employees are charged with
performing. For example, a person charged exclusively with boarding water will not have to be
trained in the techniques for collecting and transporting
coliform water samples if they will not be performing
that duty.
The purpose of the training is to ensure that personnel
participating in the performance or oversight of the
aircraft water system are knowledgeable of the rule as it
pertains to their job responsibilities. This includes
implications of contaminated water on the health of the
public served by the aircraft water system, effective
operations and maintenance procedures for the system,
the monitoring requirements of the ADWR, how
compliance with the ADWR will be reported to EPA
and tracked by EPA, and the air carrier-specific aspects
of the rule such as the public notification requirements
and aircraft water system shut-off procedures, if
applicable.
The rule requires that, at a minimum, personnel are
trained on the procedures for boarding water, collecting
samples, disinfecting and flushing the water system, and
the public health and safety reasons for the requirements
of the ADWR.
What if individuals that board
water or collect coliform
samples are not air carrier
personnel?
Air carrier personnel might not
perform all of the duties of
boarding water or sampling for
coliform - these services are
often provided by contracted
entities.
Even if air carrier personnel do
not perform the essential duties
in the O&M plan, the air carrier
is responsible for ensuring the
entity providing the services is
adequately trained on proper
procedures. The air carrier need
not provide the training, but
must ensure adequately trained
personnel are used.
The O&M plan must describe training requirements for all personnel involved with the O&M
provisions of the ADWR. At a minimum, persons performing the activity and the supervisor of
the person performing the activity should be included in the training. Based on input from the air
carrier industry, EPA understands that many air carriers will integrate training requirements
under the ADWR with the existing FAA regulated procedures and practices for aircraft operation
and maintenance and carrier ground handling practices. For example, water system self-
inspection training may be conducted in a manner consistent with existing FAA practices for
inspection of an aircraft. Accordingly, the format and delivery method of the training is at the
discretion of the air carrier so that carriers may customize their training programs in a manner
appropriate to the carrier's operations, using a variety of training procedures to satisfy the
requirements of the rule. In view of this situation, EPA has not developed a one-size fits all
training plan.
Training should emphasize the use of sanitary practices in operating and maintaining the water
system in order to maintain water quality and to protect public health. It should also address
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reporting and recordkeeping requirements and procedures to ensure the air carrier remains in
compliance with the ADWR.
The aircraft water system O&M plan must include the air carrier's program for training
personnel responsible for water system O&M activities. The O&M plan 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 plan should always be accessible to
operations staff.
The following training elements and topics are offered by EPA as an ADWR training program
approach solely to assist air carriers. Carriers may develop their own programs as they deem
appropriate based on the nature of their individual operations so long as they are consistent with,
and ensure compliance with, the rule.
The O&M plan should describe the following elements of the training program:
• Training topics and typical training schedule, including the frequency and duration of the
training for each pertinent personnel category.
• Training program for new staff.
• Refresher training for existing staff should be on an annual basis or more frequently as
needed.
Training topics for aircraft water system personnel should include the following elements.
Elements that are mandatory are noted.
• The public health and safety reasons for the ADWR requirements (mandatory).
• ADWR requirement details applicable to their duties.
• Acute contaminants, contaminant pathways, and control measures.
• Procedures for boarding water (mandatory).
• Sample collection procedures for coliform bacteria analysis and transport of samples to
the laboratory (mandatory).
• Routine and corrective disinfection and flushing practices (mandatory).
• Procedures pertaining to aircraft water systems when aircraft are taken out-of-service and
returned to service (e.g., draining, disinfection, flushing).
• Procedures for performing self-inspections.
• Backflow prevention and cross connection control.
• Water treatment equipment maintenance and replacement requirements.
• Reporting and recordkeeping requirements.
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5.6 Procedures for Conducting Self-Inspections
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 units, plumbing fixtures, valves, and backflow prevention devices [40 CFR
141.804(b)(5)].
The purpose of the self-inspection is to make sure the aircraft water system is intact and not
compromised or subject to contamination. A thorough inspection is needed to determine:
• The ability of the water system to 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; and
• The system's reliability and vulnerability.
A complete self-inspection of the entire aircraft water system must be conducted no less
frequently than once every five years [40 CFR 141.808(b)]. The first inspection must be
completed by October 19, 2016, for aircraft that are included in the inventory as of October 19,
2011. EPA has provided flexibility in the rule so that a full self-inspection of an aircraft water
system may be conducted over time rather than all at once so long as a complete self-inspection
of the entire aircraft water system occurs no less frequently than once every five years. This
allows air carriers to develop their own unique self-inspection procedures that coordinate, to the
maximum extent possible, water system self-inspections with the existing aircraft inspection and
maintenance process. An air carrier's self-inspection plan may include references to and
explanations of those existing procedures.
In recognition that each air carrier's self-inspection procedures are likely to be unique since they
will be based on each air carrier's unique FAA-accepted operation and maintenance program,
EPA has not developed a "one-size fits all" set of self-inspection procedures for this guidance
manual. Instead, EPA offers the following general guidance for consideration by air carriers in
the development of self-inspection procedures.
The self-inspection procedures are intended to provide the degree of scrutiny necessary to
identify potential public health risks and reliability issues associated with the aircraft water
system. Generally, a self-inspection of the aircraft water system includes a visual inspection of
the storage tank, distribution system, supplemental treatment, fixtures, valves, backflow
prevention devices and fittings to detect cracks, leaks, corrosion, or damage, and to ensure that
the distribution system piping is correctly attached with no cross-connections. A visual
inspection is a visual examination of an interior or exterior area, installation, or assembly to
detect obvious damage, failure, or irregularity. This level of inspection is made from within
touching distance, unless otherwise specified by the manufacturer or determined to be necessary.
For example, an air carrier may identify the need to perform an internal optical inspection of an
aircraft's water tanks and piping if there are chronic water quality problems (taste, odor, and/or
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positive sample results) that are not corrected by disinfection and flushing or if water flow has
slowed. Also, a mirror may be necessary to enhance visual access to all exposed surfaces in the
inspection area. This level of inspection is made under normally available lighting conditions
such as daylight, hangar lighting, flashlight or drop-light and may require removal or opening of
access panels or doors. Stands, ladders, or platforms may be required to gain proximity to the
area being checked.
Specific reporting and recordkeeping requirements apply to aircraft self-inspections. These
requirements are discussed in Chapter 7.
5.7 Procedures for Boarding Water
The operations and maintenance plan must include requirements and procedures for boarding
water as discussed below.
5.7.1 Boarding Water within the United States
Within the United States, the air carrier must board water from watering points in accordance
with Food and Drug Administration (FDA) regulations [21 CFR part 1240, subpart E]. It is
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 watering points and
service areas that are in accordance with FDA regulations on its website.
FDA regulatory requirements are found in FDA regulations at 21 CFR part 1240, subpart E -
Source and Use of Potable Water and 21 CFR part 1250, subpart D - Servicing Areas for Land
and Air Conveyances. Published FDA guidance is found in the Guide to Inspection of
Conveyances and Support Facilities, April 1995.
http://www.fda.gov/ICECI/Inspections/InspectionGuides/ucm074964.htm. FDA Form 2528
Inspection Summary - Airline Service Area or Watering Point Sanitation further informs airlines
on FDA criteria for determining compliance with FDA regulations.
5.7.2 Transferring Water Safely for Human Consumption
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]. Accordingly, EPA defers to the FDA with respect to regulating watering points such
as water cabinets, carts, trucks, and hoses from which aircraft board water. However, because
aircraft board water via these temporary interconnections, the process of boarding water presents
numerous opportunities for contamination of the drinking water. Therefore, the ADWR requires
that air carriers have in their water system operations and maintenance plans procedures for
boarding water [40 CFR 141.804(b)(6)] that 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.
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5.7.3 Ensuring Water Boarded Outside of the US is Safe for
Human Consumption
EPA understands that aircraft involved in international travel may board water from watering
points at locations that are outside EPA and FDA's jurisdiction. Therefore, it is essential that air
carriers have procedures in place to ensure that the water obtained from these sources is of a
quality that is safe for consumption by passengers and crew. Accordingly, the ADWR requires
that air carriers include in their aircraft water system operations and maintenance plans a
description of how the air carrier will ensure that water boarded outside of the United States is
safe for human consumption [40 CFR 141.804(b)(6)(iii)]. This procedural requirement is
squarely within EPA's authority under SDWA to ensure that water that is boarded outside of the
US and then served to consumers in the US is safe. Consequently, if an aircraft boards water not
in accordance with its water system operation and maintenance plan procedures for boarding
water outside of the US [40 CFR 141.804(b)(6)(iii)], the ADWR, under 40 CFR 141.803(h)(3)
and (i)(3), requires an air carrier to perform the appropriate corrective actions on the aircraft (see
Exhibits 5.1 and 5.2).
5.7.4 Emergency Procedures for Failure to Board Water from a
Safe Watering Point
The Agency is aware that in limited circumstances water is boarded to operate essential systems
such as toilets, but the watering point is not in accordance with FDA regulations or the water
does not meet the NPDWRs. To address these circumstances, 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 was boarded from a watering point not in accordance with
FDA regulations, does not meet NPDWRs applicable to transient non-community water systems
(found in 40 CFR 141.62 and 141.63, as applied to TNCWSs), or is otherwise determined to be
unsafe due to non-compliance with the procedures specified in 40 CFR 141.804(b)(6). When
situations such as these occur, the quality of the water that is boarded will determine the
corrective action and public notification requirements. If the quality of the water to be boarded
does not meet the NPDWRs for transient non-community water systems (i.e., total coliform; E.
coli; nitrate; nitrite; or chlorine dioxide if the PWS serving the watering point (parent system)
uses chlorine dioxide as a disinfectant or oxidant) but the situation is not related to an E. coli-
positive sample result, then the air carrier must follow the requirements under 40 CFR 141.803(1)
Failure to Board Water from a Safe Watering Point (non-E. co//'-positive). Similarly, when water
must be boarded from a watering point that is not in accordance with FDA regulations but the
situation is not known to be related to an E. co//-positive sample result, then the air carrier must
also follow the requirements under 40 CFR 141.803(1) Failure to Board Water from a Safe
Watering Point (non-E. co//'-positive).
If the water that must be boarded is known to have tested positive for E. coli, then the air carrier
must follow the requirements under 40 CFR 141.803(h) Failure to Board Water from a Safe
Watering Point (E. co//'-positive).
It may be necessary for an air carrier to have different emergency response plans for different
types of aircraft, for example, if some aircraft have a separate water system for toilets. Example
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response plans for an E. co//-positive event and non-E. co//'-positive event are provided as
Exhibits 5.1 and 5.2, respectively.
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Exhibit 5.1 Example Response Plan for Failure to Board Water from a Safe
Watering Point (E. co//-positive event)
Response Plan: Failure to Board Water from a Safe Watering Point
[E. coli-positive event]
Step
Action
Timeframe
Responsible Party
Restrict public access, including all of the
following:
Shut off water or otherwise prevent flow to
taps, faucets, and fixtures, if possible.
Develop and deliver public notice for crew
(and post for passengers if water shut off or
flow prevention to taps is not possible).
Provide alternatives to water from the aircraft
water system such as bottled water for
drinking and coffee or beverage preparation;
provide antiseptic hand gels or wipes.
As expeditiously as
possible, but no later
than 24 hours of
learning of the event.
Schedule and perform corrective disinfection
and flushing of the aircraft water system.
As expeditiously as
possible, but no later
than 72 hours of
learning of the event if
the water system is not
shut off or the flow
prevented.
When able, if water shut
off or flow prevented.
Collect two follow-up samples.
Immediately after
corrective disinfection
and flushing.
If any follow-up samples are total coliform-
positive orE. co/;-positive, then repeat
disinfection and flushing with follow-up
sampling.
As expeditiously as
possible, but no later
than 72 hours of
learning of the sample
results if the water
system is not shut off or
the flow prevented.
When able, if water shut
off or flow prevented.
Unrestrict public access to the water.
Only after a complete
set of follow-up samples
is total coliform-
negative.
Report event to the EPA ADWR Reporting
and Compliance System.
Within 10 days of
learning of the event.
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Exhibit 5.2 Example Response Plan for Failure to Board Water from a Safe
Watering Point (non-E. co//-positive event)
Response Plan: Failure to Board Water from a Safe Watering Point
[non-E. coli-positive event]
Step
Action
Timeframe
Responsible Party
Restrict public access, including all of the
following:
Shut off water or otherwise prevent flow to
taps, faucets, and fixtures, if possible.
Develop and deliver public notice for crew
(and post for passengers if water shut off or
flow prevention to taps is not possible).
Provide alternatives to water from the aircraft
water system such as bottled water for
drinking and coffee or beverage preparation;
provide antiseptic hand gels or wipes.
As expeditiously as
possible, but no later
than 72 hours of
learning of the event.
Schedule and perform corrective disinfection
and flushing of the aircraft water system.
When able
Collect two follow-up samples.
Immediately after
corrective disinfection
and flushing and prior to
allowing public access
to the water.
Optional: unrestrict public access to the
water.
Once follow-up samples
are collected.
5a
If either of the two follow-up samples is total
coliform-positive and £. co/;-negative, then
restrict public access and repeat the
disinfection and flushing procedures with
follow-up sampling.
Restrict public access
as expeditiously as
possible, but no later
than 72 hours of
learning of the sample
results.
Disinfect and flush when
able.
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Response Plan: Failure to Board Water from a Safe Watering Point
[non-E. coli-positive event]
Step
5b
6
7
Action
If either of the two follow-up samples is total
coliform-positive and £. co/;-positive, then
restrict public access and repeat the
disinfection and flushing procedures with
follow-up sampling.
Unrestrict public access.
Report event to the EPA ADWR Reporting
and Compliance System.
Timeframe
Restrict access as
expeditiously as
possible, but no later
than 24 hours of
learning of the sample
results.
If water system not shut
off or the flow prevented
disinfect and flush within
72 hours.
If water shut off or flow
prevented, disinfect and
flush when able.
Only after a complete
set of follow-up samples
is total coliform-
negative.
Within 10 days of
learning of the event.
Responsible Party
5.8 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:
• Coliform sample collection procedures
• Sample tap locations representative of the aircraft water system
• Frequency of coliform sampling and number of samples to be collected during each
sampling event
• Frequency of routine disinfection and flushing
• Procedures for communicating sample results
5.9 Aircraft Water Systems Disconnect/Shut-off/Flow
Prevention Statement
The O&M plan must include an explanation of whether the aircraft water system can be
physically disconnected/shut-off or the flow of water through taps prevented. The O&M plan
could include procedures for disconnecting/shutting off the water so personnel have a reference
in the event restricting public access to the water becomes necessary.
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6. Public Notification
Due to the unique characteristics of aircraft water systems, the ADWR includes separate
provisions for air carriers regarding public notification from those required of stationary water
systems under Subpart Q of the NPDWRs. This chapter summarizes the public notification
requirements for specific violations and situations under the ADWR. Some of the public
notification requirements are the same for certain violations and/or situations; therefore, there is
repetitive text in this chapter.
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. Public notification 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 many
of the violations or situations encountered by aircraft water systems pose potential acute health
risks (e.g., an E. co//-positive sample result), notification should be provided as soon as possible,
but is required within 24 hours. All other violations or situations require notification within 72
hours. Timeframes for issuing notice for specific violations and situations are discussed in
subsequent sections in this chapter.
Passengers and crew served by an aircraft water system have a right to be informed of problems
with the drinking water. 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.
Due to the transient nature of the public served by transient non-community water systems
(TNCWSs) such as aircraft, public notice is provided by posting the notice at locations where
passengers may access drinking water from the water system. Notification may be given to crew
through written or verbal means in certain situations.
When a violation or situation arises that requires public notice, the notice can be provided only to
the crew if passenger access to the water system is physically prevented through disconnecting or
shutting off the water, or the flow of water prevented through the tap(s), or if water is supplied
only to lavatory toilets and not to any lavatory or galley taps. If the passengers can access the
water system, then public notice must be provided to them to warn them not to use the water
even for hand washing or brushing teeth.
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In all situations that require public notice, the ADWR requires that the crew receives notice to
ensure that the crew understands and can explain why there is no water available or why the
water, if accessible, should not be used for human consumption.
6.2 Notification of Passengers and Crew
Air carriers must issue public notice to crew for all events described below [40 CFR 141.805].
Notice to passengers may not be required in some cases.
1) When public access to the water is restricted due to a routine, repeat or follow-up total
coliform-positive or E. co//'-positive sample result [40 CFR 141.805(a)(l)].
2) Failure to perform routine disinfection and flushing or failure to collect required routine
samples for coliforms [40 CFR 141.805(a)(2)].
3) Failure to collect the required follow-up samples in response to a sample result that is E. coli-
positive [40 CFR 141.805(a)(3)].
4) Failure to collect the required repeat or follow-up samples in response to a sample result that
is total coliform-positive andE. co//'-negative [40 CFR 141.805(a)(4)].
5) When the air carrier becomes aware of an E. co//'-positive event resulting from water that has
been boarded from a watering point that is not in accordance with FDA regulations, that does
not meet EPA standards for TNCWSs, or has been determined to be unsafe due to
noncompliance with the procedures for boarding water [40 CFR 141.805(a)(5)].
6) When the air carrier becomes aware of a non-E. co//'-positive event resulting from water that
has been boarded from a watering point that is not in accordance with FDA regulations, that
does not meet EPA standards for TNCWSs, or has been determined to be unsafe due to
noncompliance with the procedures for boarding water [40 CFR 141.805(a)(6)].
7) EPA, the air carrier, or the crew otherwise determine that public notification is necessary to
protect public health [40 CFR 141.805(a)(7)].
The specific notice requirements for each violation or situation are discussed further in the
following sections. In most cases, the ADWR specifies health effects language that must be
included in the notice to the crew. Standardized language ensures that the crew (and, indirectly,
the passengers via the crew) receives a consistent message. 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.
Each public notice [40 CFR 141.805(b)]:
• Must be displayed in a conspicuous way when printed or posted;
• Must not contain overly technical language or very small print;
• Must not be formatted in a way that defeats the purpose of the notice;
• Must not contain language that nullifies the purpose of the notice; and
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• 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.
All events requiring notification to passengers and/or 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 or crew or both [40 CFR 141.806(b)(4)]. The ADWR
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. Paper or electronic copies of notices must be kept
for at least three years after issuance [40 CFR 141.807(f)]. See Chapter 7 for more information
on recordkeeping and reporting requirements.
The four main events that trigger notice are described in detail in the remainder of this chapter.
Appendix D of this manual contains example templates for notifying passengers and/or crew of
violations or situations that require public notification under the ADWR.
6.2.1 Notice for Detection of E. coli or Total Coliform Bacteria
Public notification is required when public access to the aircraft water system is restricted in
response to a total coliform-positive sample or an E. co//'-positive sample [40 CFR
141.805(a)(l)]. Air carriers must issue notice within 72 hours of receiving sample results that are
total coliform-positive and E. co//-negative [40 CFR 141.803(c)(3)(ii)] and within 24 hours of
receiving sample results that are E. co//-positive [40 CFR 141.803(c)(2)(i)]. For a total coliform-
positive routine or repeat sample that is E. co//'-negative, air carriers are not automatically
required to restrict public access. If they choose to collect repeat samples or conduct disinfection
and flushing within 72 hours of learning of the positive sample, they are not required to restrict
public access or provide public notification. Samples positive for E. coli, however, always
require restriction of public access including public notification no later than 24 hours after the
laboratory notifies the air carrier of the E. co//'-positive result (see Chapter 4 for more
information).
Exhibit 6.1 provides a flow-chart illustration of the public notification requirements associated
with a total coliform-positive sample result (when public access to the water supply is restricted)
or an E. co//'-positive sample result.
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Exhibit 6.1 Public Notification Requirements in Response to a Total Coliform-
Positive or E. co//-Positive Sample Result
Initiate public notification when restriction of
public access is initiated (i.e., within 72 hours
for sample results that are TC(+) Si EC(-); within
24 hours forEC(+) sample results)
No
Can the water be shut off
(includes preventing the flow
of water through the taps)?
Notice in each lavatory stating
that the water is non-potable [see
40 CFR 141.805(c)(1)]
Yes
Notice in the galley directed at the
crew [see 40 CFR 141.805(c)(2)]
Notice in the galley directed at the
crew [see 40 CFR 141 .805(c)(2)]
i
/ Continue notification \
until unrestricted
' public access '
,' Continue notification ,
until unrestricted
' public access '
If passenger access to the water system is physically prevented through disconnecting or shutting
off the water, or the flow of water prevented through the tap(s), or if water is supplied only to
lavatory toilets and not to any lavatory or galley taps, then notice to passengers is not required,
only to the crew (see Appendix D, Template 2 for E. co//'-positive event and Template 3 for Total
Coliform-positive non-E. coli event). In this situation, the notice to the crew may be conveyed
either as a prominent notice in the galley or as a mandatory crew briefing as described in Section
6.2.5.
If passenger access to the water system cannot be physically prevented through disconnecting or
shutting off the water, or the flow of water cannot be prevented through the tap(s), then public
notice to the passengers is required. The public notice must consist of a prominently displayed,
clear statement in each lavatory indicating 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 (see Appendix D, Template 1). In this situation, the notice to the crew must be
conveyed as a prominent notice in the galley.
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• Notice to the crew must include the following: 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.
• A description of the violation or situation triggering the notice, including the contaminant
of concern.
• When the violation or situation occurred.
• Any potential adverse health effects from the violation or situation, including the required
health effects language for total coliform bacteria or E. coli bacteria, as provided in this
section.
• The population at risk, including sensitive subpopulations particularly vulnerable if
exposed to the contaminant (the provided health effects language should address this
element).
• What the air carrier is doing to correct the violation or situation.
• When the air carrier expects to return the system to unrestricted public access.
Use the following health effects language when any routine, repeat, or follow-up sample is total
coliform-positive, but is negative for 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 found in
[INSERT NUMBER OF SAMPLES DETECTED] 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.
Use the following language for any routine, repeat, or follow-up sample that is positive for E.
coli (note that in this situation, the notice for total coliform-positive samples is not issued, even
though these samples would have also been total coliform-positive):
E. 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.
The air carrier must continue to provide the notice until a set of follow-up samples is negative for
total coliforms.
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6.2.2 Notice for Failure to Monitor, Failure to Conduct Disinfection
and Flushing, and Situations Where Water Does Not Meet
Standards (Non-E. co//-Positive Event)
Air carriers must provide public notice if they fail to collect required routine samples, if they fail
to perform required routine disinfection and flushing, or if they fail to collect repeat or follow-up
samples in response to a sample result that is total coliform-positive and E. co//'-negative. In
addition, notice is required when an air carrier becomes aware of a non-E. co//'-positive event
resulting from water that has been boarded from a watering point not in accordance with FDA
regulations, that does not meet EPA requirements for TNCWSs, or that has been otherwise
determined to be unsafe due to non-compliance with the procedures for boarding water as
described in the aircraft water system O&M plan [40 CFR 141.805(a)(2), (4), and (6)]. A "non-
E. co//'-positive" event is a situation that results in a non-acute event. In other words, the water
quality issue is not due to an E. coli detection in the water supply, and unsafe boarding
procedures have not knowingly resulted in E. coli in the water supply.
For all conditions described above, public notification must be issued to the passengers and/or
crew and restriction of public access implemented within 72 hours.
Exhibit 6.2 provides a flow-chart illustration of the public notification requirements discussed in
this section.
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Exhibit 6.2 Public Notification Requirements for Failure to Monitor, Disinfect and
Flush, or Board Water from a Safe Watering Point (Non-E. co//-Positive)
Initiate public notification when restriction of public
access is initiated (i.e., within 72 hours of discovery of
the failure)
No
Can the water be shut off
(includes preventing the
flow of water through the
taps)?
Notice in each lavatory stating that
the water is non-potable [see 40 CFR
141.805(d)(1)]
Yes
Notice in the galley directed atthe
crew[see 40 CFR 1 41.805(d)(2)]
Notice inthe galley directed atthe
crew[see 40 CFR 1 41 .805(d)(2)]
i
/ Continue notification ,
until unrestricted
' public access '
CContinue notification ,
until unrestricted
public access '
If passenger access to the water system is physically prevented by disconnecting or shutting off
the water, or the flow of water prevented through the tap(s), or if water is supplied only to
lavatory toilets and not to any lavatory or galley taps, then notice to passengers is not required,
only to the crew [see Appendix D, Template 4 - Failure to Perform Routine Disinfection and
Flushing Notice to the Crew; Template 5 - Failure to Perform Routine, Repeat, or Follow-up
Monitoring After a Non-E1. coli-Positive Sample Notice to the Crew; Template 6 - Boarding
Water that Does Not Meet FDA Regulations or EPA Standards for Transient Non-community
Water Systems (Boarded Water Quality or Boarding Procedures) Notice to the Crew (Non-E1.
coli-Positive)]. In this situation, the notice to the crew may be conveyed either as a prominent
notice in the galley or as a mandatory crew briefing as described in Section 6.2.5.
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If passenger access to the water system cannot be physically prevented through disconnecting or
shutting off the water, or the flow of water cannot be prevented through the tap(s), then public
notice to the passengers is required. The public notice must consist of a prominently displayed,
clear statement in each lavatory indicating 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 (see Appendix D, Template 1). In this situation, the notice to the crew must be
conveyed as a prominent notice in the galley.
Notice to the crew must include the following:
• 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.
• A clear statement that it is not known whether the water is contaminated because there
was a failure to perform required routine disinfection and flushing; or a failure to perform
required monitoring; or water was boarded from a watering point that is not in
accordance with FDA regulations, or does not meet the NPDWRs applicable to
TNCWSs, or has otherwise been determined to be unsafe due to noncompliance with the
O&M procedures for boarding water. (Inclusion of the health effects language provided
below should in many cases address this requirement.)
• When and where the unsafe water was boarded, or when the specific monitoring or
disinfection and flushing requirement was not met.
• Any potential adverse health effects from exposure to waterborne pathogens that might
be in the water, as appropriate. (Inclusion of the health effects language provided below
addresses this requirement.)
• The population at risk, including sensitive subpopulations particularly vulnerable if
exposed to the contaminant (the provided health effects language should address this
element).
• A statement indicating when the system will be disinfected and flushed and returned to
unrestricted public access.
Public notices for failure to conduct routine monitoring or disinfection and flushing, or repeat or
follow-up monitoring in response to a sample result that is total coliform-positive and E. coli-
negative, must include the following text. Notices for a non-E. co//-positive event resulting from
water that has been boarded from a watering point not in accordance with FDA regulations, that
does not meet EPA standards for TNCWSs, or is otherwise deemed unsafe due to noncompliance
with the procedures in the aircraft water system O&M plan must also use the following language.
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 IN ACCORDANCE WITH FDA
REGULATIONS (21 CFR PART 1240, SUBPARTE)] or [OTHER APPROPRIATE
EXPLANATION], we cannot be sure of the quality of the drinking water at this time.
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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.
The air carrier must continue to provide the notice until a set of follow-up samples is negative for
total coliforms.
6.2.3 Notice for Failure to Conduct Follow-Up Monitoring and
Situations Where Water Does Not Meet Standards (E. coli-
Positive Event)
Air carriers must provide public notice if they fail to collect required follow-up samples in
response to a sample result that is E. co//'-positive. In addition, notice is required when an air
carrier becomes aware of an E. co//'-positive event resulting from water that has been boarded
from a watering point not in accordance with FDA regulations, that does not meet EPA
requirements for TNCWSs, or that has been otherwise determined to be unsafe due to non-
compliance with the procedures for boarding water as described in the aircraft water system
O&M plan [40 CFR 141.805(a)(3) and (5)]. An "E. co//-positive" event is an event where E. coll
has been detected or is otherwise introduced in the water boarded on the aircraft.
For all conditions described above, public notification must be issued to the passengers and crew
and restriction of public access implemented within 24 hours.
Exhibit 6.3 provides a flow-chart illustration of the public notification requirements discussed in
this section.
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Exhibit 6.3 Public Notification Requirements for Failure to Monitor, Disinfect and
Flush, or Board Water from a Safe Watering Point (E. co//-Positive)
Initiate public notification when restriction of
public access is initiated (i.e., within 24 hours of
discovery of the failure)
No
Can the water be shut off
(includes preventing the flow
of water through the taps)?
Notice in each lavatory stating
that the water is non-potable [see
40CFR 141.805(e)(1)]
Yes
Notice in the galley directed at the
crew [see 40 CFR 141.805(e)(2)]
Notice in the galley directed at the
crew [see 40 CFR 141.805(e)(2)]
i
r
•'' Continue notification
until unrestricted
public access
r Continue notification
until unrestricted
public access
y
If passenger access to the water system is physically prevented by disconnecting or shutting off
the water, or the flow of water prevented through the tap(s), or if water is supplied only to
lavatory toilets and not to any lavatory or galley taps, then notice to passengers is not required,
only to the crew [see Appendix D, Template 7 - Failure to Perform Follow-up Monitoring After
an E. c0//'-Positive Sample Result Notice to the Crew; Template 8 - Boarding Water that Does
Not Meet FDA Regulations or EPA Standards for Transient Non-community Water Systems (E.
co//'-Positive event) Notice to the Crew]. In this situation, the notice to the crew may be
conveyed either as a prominent notice in the galley or as a mandatory crew briefing as described
in Section 6.2.5.
If passenger access to the water system cannot be physically prevented through disconnecting or
shutting off the water, or the flow of water prevented through the tap(s), then public notice to the
passengers is required. The public notice must consist of a prominently-displayed, clear
statement in each lavatory indicating 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
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use (see Appendix D, Template 1). In this situation, the notice to the crew must be conveyed as a
prominent notice in the galley.
Notice to the crew must include the following:
• 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.
• A clear statement that the water is contaminated and there was a failure to conduct
required monitoring; or a clear statement that the water is contaminated because water
was boarded from a watering point that is not in accordance with FDA regulations, or the
water does not meet requirements applicable to TNCWSs, or the water has otherwise
been determined to be unsafe due to noncompliance with the O&M procedures for
boarding water. (Inclusion of the health effects language provided below should in many
cases address this requirement.)
• A description of the contaminant(s) of concern.
• When and where the unsafe water was boarded, or when the specific monitoring
requirement was not met.
• Any potential adverse health effects from the situation, as appropriate. (Inclusion of the
health effects language provided below addresses this requirement.)
• The population at risk, including sensitive subpopulations particularly vulnerable if
exposed to the contaminant (the provided health effects language should address this
element).
• What the air carrier is doing to correct the situation.
• When the air carrier expects to return the system to unrestricted public access.
Public notices for failure to conduct follow-up monitoring in response to a sample result that is
E. co//'-positive must include the following text.
Because required follow-up monitoring and analysis was not conducted after the aircraft
water system tested positive for E. coli, we cannot be sure of the quality of the drinking water
at this time. E. 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.
Notices when an air carrier becomes aware of an E. co//-positive event that is a result of water
that has been boarded from a watering point not in accordance with FDA regulations, that does
not meet EPA standards for TNCWSs, or is otherwise deemed unsafe due to noncompliance with
the procedures in the aircraft water system O&M plan must use the following language. Select
the appropriate phrase from the options inside the brackets and delete the inapplicable phrases:
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Water was boarded that is contaminated with E. coli because [WATER WAS BOARDED
FROM A WATERING POINT NOT IN ACCORDANCE WITH FDA REGULATIONS (21
CFR ART 1240, SUBPARTE)] or [OTHER APPROPRIATE EXPLANATION]. E. 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.
The air carrier must continue to provide the notice until a set of follow-up samples is negative for
total coliforms.
6.2.4 Notice Where Necessary to Protect Public Health
The ADWR provides for notice to be given where EPA, the carrier, or the crew determines it is
necessary to protect public health from potentially serious health effects resulting from short-
term exposure or specific conditions creating a public health risk [40 CFR 141.805(a)(7)]. This
notice provision is intended to address unique circumstances where required notifications under
other provisions in 40 CFR 141.805(a) may not be triggered or may otherwise prove to be
inadequate under the circumstances. Accordingly, this notice provision would not apply to
circumstances where the notification provisions set forth at 40 CFR 141.805(a)(l) through (a)(6)
have been triggered. Furthermore, if passenger access to the water system is physically prevented
through disconnecting or shutting off the water, or the flow of water prevented through the
tap(s), or if water is supplied only to lavatory toilets, and not to any lavatory or galley taps, then
only the crew notice under 40 CFR 141.805(c)(2), (d)(2), (e)(2), and (g) is required as
appropriate. EPA understands that flight crews would be expected to comply with existing airline
policies regarding communication with the public, including how to initiate, conduct, and
document the public notification. This may include notifying or gaining approval from the pilot-
in-command prior to conducting the public notification.
If the public water system that serves the airport has a violation or situation that requires public
notification, they are required to notify their customers including the airport who in turn must
notify the air carriers whose aircraft board water from the watering points at the airport. Air
carriers can use the notice provided by the public water system for the crew notice if all public
notification requirements under the ADWR are met or they can use information from the notice
to supplement their notice.
Notification must be reasonably calculated to reach all passengers and crew that are onboard the
aircraft at the time the notification is made with one or more of the following forms of delivery
applicable to this provision of the ADWR:
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.
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If EPA determines that public notification is necessary, air carriers must provide notification to
passengers and crew within 24 hours of being informed by EPA to issue notification and must
continue notification for the duration determined by EPA (see Appendix D, Template 9).
Exhibit 6.4 provides a flow-chart illustration of the public notification requirements when EPA,
the air carrier, or the crew determines that notification is necessary to protect public health.
Exhibit 6.4 Public Notification Requirements When Notification is Deemed
Necessary by EPA, the Air Carrier, or the Crew
If public notification is required by EPA,
initiate the notification within 24 hours of
being informed by EPA to perform
notification.
If EPA, the air carrier or crew initiate notification, it
must be conducted in a manner to reach all
passengers and crew by using one or more of the
following:
- Broadcast over PA system;
- Posting (in galley and lavatories);
- Hand delivery of notice; or
- Another delivery method approved by the EPA.
EPA-initiated
notification must
continue for the
duration determined
by EPA
While there are general requirements regarding the content of all public notices in the ADWR
(found in 40 CFR 141.805(b) and described in Section 6.2 of this chapter), there are no specific
content requirements for this situation. However, the content requirements specific to other
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violations or situations requiring notification may be used as a guideline, when applicable. In
addition, Template 9 in Appendix E provides an example of a notice that can be used for posting
or hand delivery for this situation.
6.2.5 Crew-only Notice
Under the ADWR, in all situations when public notice must be provided, the rule allows for
notice to be provided only to the crew so long as access to the water system is prevented by (1)
disconnecting or shutting off the water, (2) preventing the flow of water through the tap(s), or (3)
allowing water to be supplied only to lavatory toilets and not to any lavatory or galley tap. This
provision of the ADWR ensures that the crew is notified of the water system status without the
need for placing notices in each lavatory on the aircraft since the passengers would not be
exposed to any health risks associated with the aircraft water system. However, input from air
carriers expressed concern that if the required "prominent" notice to the crew is posted such that
it is viewable by passengers, it may be misinterpreted without the understanding that they are not
exposed to a risk because the aircraft water system has been shut-off EPA understands this
concern. Since the intent of this crew-only notice is to not notify the public when the system is
inaccessible and does not represent a risk to passengers, the "prominent notice in the galley
directed at the crew" does not need to be visible to the passengers. It need only be "prominent"
with respect to the crew. EPA recognizes that any posted notices must be in accordance with
FAA signage requirements.
EPA believes that the following procedure also satisfies the requirement of crew-only
notification when access to the water system is prevented by (1) disconnecting or shutting off the
water, (2) preventing the flow of water through the tap(s), or (3) allowing water to be supplied
only to lavatory toilets and not to any lavatory or galley tap.
1. The "prominent notice to the crew" is read orally by the pilot to the entire crew
during each pre-flight Crew Briefing for which attendance must be mandatory for all
cabin crew members.
2. The oral notice must meet all of the applicable requirements in 40 CFR 141.805
including (c)(2), (d)(2), (e)(2), and (g).
3. A copy of the notice read to the crew by the pilot must be maintained as a record for
three years as required under 40 CFR 141.807(f). EPA may request a copy of the
notice at any time.
Under all situations involving crew-only notice, crew members must be prohibited from
reactivating the water system once it has been established as inoperative. Access to the water
system must not be restored until all of the applicable corrective action requirements of the
ADWR have been met and the FAA regulations that govern the process for reactivating the
water system have been followed.
The air carrier must keep copies of public notices that have been issued to passengers and crew
as required by the ADWR for at least 3 years after issuance [40 CFR 141.807(f)]. Air carriers
may keep electronic copies of these notices in lieu of paper copies.
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7. Recordkeeping and Reporting
This chapter presents the recordkeeping and reporting requirements of the ADWR. The ADWR
recordkeeping requirements are in 40 CFR 141.807, and reporting requirements can be found in
40 CFR 141.806.
7.1 Air Carrier Recordkeeping
Air carriers must keep records to document activities performed for compliance with the ADWR
[40 CFR 141.807]. Many of the records which must be kept are not also reported to EPA.
However, the records must be made available to EPA upon request. EPA may ask to view the
records at any time as part of its ADWR oversight activities. EPA expects records to be made
available within 14 calendar days of its request.
The ADWR does not specify a format in which the records must be retained or a location where
they are to be housed. The air carrier's records retention system should be designed and
organized to enable retrieval of specific records for each aircraft upon request by EPA. Records
may include hard copy and/or electronic files.
7.1.1 Record Maintenance
Exhibit 7.1 summarizes the records that must be kept by the air carrier and the minimum time
period they must be maintained. The dates are consistent with the recordkeeping requirements
for similar items by other types of public water systems.
Exhibit 7.1 Duration of Record Maintenance
Type of Record to be Maintained
Bacteriological Analysis
(Applies to all routine, repeat, and follow-up samples, including any
replacement samples.)
Aircraft Water System Disinfection and Flushing Events
(Performed as routine and corrective action disinfection and flushing
activities.)
Self-Inspection
Coliform Sampling Plans
Water System Operations and Maintenance Plans
Copies of Public Notices to Passengers and Crew
Minimum Retention Time
5 Years
5 Years
10 Years
Maintained on an Ongoing Basis
Maintained on an Ongoing Basis
3 Years After Issuance
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7.1.2 Information Included in Records
The ADWR is specific regarding the minimum information that must be included for each type
of record that is required to be maintained. Additional information may also be retained at the air
carriers' discretion.
• Records of bacteriological analyses include all sample results for routine, repeat, and
follow-up samples (including any replacement samples) as well as results from any special
purpose samples. All of the following information must be retained (this may be standard
information entered on the laboratory data sheet accompanying the sample from collection
through reporting of analysis results):
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.
o The results of the analysis.
• Records of disinfection and flushing include all routine and corrective action disinfection
and flushing events. The records may be kept as a compiled list of events for each aircraft, or
as separate activity records. Because the procedures for disinfection and flushing events are
included in the aircraft water system O&M plan, a separate record for procedures is not
required. However, all of the following information must be recorded and maintained:
o The date and time of the disinfection and flushing event.
o The type of disinfection and flushing event: a routine disinfection and flushing event, a
corrective action event, or an event that meets the criteria for both a routine and a
corrective event (See Chapter 4).
• Records of self-inspections must include the following:
o The completion date of each self-inspection. This may include completion dates of
distinct aspects of the self-inspection, if the inspection is performed as a series of steps
and not as a single activity.
o Copies of any written reports, summaries, or communications related to a given self-
inspection.
• 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.
• Copies of public notices provided to passengers and crew must be maintained to document
the information that was included in the notice.
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7.2 Reporting Requirements
The reporting requirements of the ADWR pertain to an air carrier's inventory of aircraft water
systems, the coliform plan and sampling, the O&M plan and activities, public notification, self-
inspections and deficiencies, and compliance audits [40 CFR 141.806].
7.2.1 Reporting Format
Unless EPA has approved an alternative method of reporting, the ADWR requires air carriers to
report required information electronically. To facilitate the collection and analysis of aircraft
water system data, EPA will use an Internet-based electronic data collection and management
system (ADWR Reporting and Compliance System). Air carriers' primary contact will be issued
a username and password to access the ADWR Reporting and Compliance system. The data
system will perform logic checks on data entered and will calculate final results for
accountability and regulatory oversight. This system is intended to reduce reporting errors and
limit the time involved in investigating, checking, and correcting errors at all levels.
The ADWR Reporting and Compliance System will have a companion User Guide that will
provide information pertinent to users of the system. The User Guide will include a description
of spreadsheet format and reporting method, how to access the downloadable spreadsheet and
Web user interface, and other key information.
7.2.2 Aircraft Inventory
Air carriers are required to report a complete inventory of aircraft that are public water systems.
In addition, they must report any changes to that inventory. Exhibit 7.2 summarizes the reporting
timeline and pertinent information for establishing and maintaining an accurate inventory of
aircraft water systems.
Exhibit 7.2 Reporting Aircraft Inventory
Reporting Item
Aircraft Water System Inventory
(existing aircraft)
Aircraft Water System Inventory
(new aircraft)
Changes to Existing Inventory
Reporting Timeline
April 19,2011
Within the first calendar quarter of
initial operation of the aircraft
No later than 1 0 days following the
calendar month in which the
change occurred
Information to Report to EPA
Unique aircraft identifier number,
active or inactive status, type and
location of supplemental treatment,
and whether the aircraft water
system can be shut off or the flow of
water prevented through the taps
Unique aircraft identifier number,
active or inactive status, type and
location of supplemental treatment,
and whether the aircraft water
system can be shut off or the flow of
water prevented through the taps
Changes to any of the information
reported for the existing aircraft
inventory
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As illustrated in Exhibit 7.2, by April 19, 2011, air carriers must provide EPA a complete
inventory of existing aircraft public water systems [40 CFR 141.806(b)]. Existing aircraft means
any aircraft that was in operation when the final ADWR was published on October 19, 2009, or
any aircraft that was brought into operation by April 19, 2011. The inventory will be reported
directly to ADWR Reporting and Compliance System.
Changes to any information reported for the existing aircraft inventory must also be reported to
ensure EPA has accurate information on aircraft public water systems for the ADWR
implementation oversight program. Inventory changes (e.g., change of status from "active" to
"inactive," adding or removing aircraft, etc.) must be reported within 10 days following the
calendar month in which the change occurred. If no changes are made during that month, no
reporting is required. Exhibit 7.3 illustrates the reporting requirements for aircraft inventory.
Exhibit 7.3 Aircraft Inventory Reporting Requirements
Develop Aircraft Inventory
Report the inventory
change
information within 10
days following
the month in which the
change occurred
For Existing Aircraft.
Report inventory
information
by April 19,2011
If there is a change in inventory
(including adding new aircraft or
removing aircraft)
after submitting the initial
inventory
Aircraft inventory reported to EPA must include all of the following information:
• The unique aircraft identifier number.
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.
Refer to Section 3.2 for information on determining active and inactive status.
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• The type and location of any supplemental treatment equipment installed on the aircraft
water system.
Supplemental treatment equipment includes treatment applied to the finished water to
maintain water quality or to change aesthetic water quality conditions. Examples include
disinfection systems, carbon filters or particle removal 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 considered to be water
treatment equipment.
• Whether the aircraft water system can be physically disconnected or shut off, or the flow of
water prevented through the taps.
This information is important because the ability to shut off the supply of water to all
faucets and other plumbing fixtures that provide water to passengers or crew affects the
requirements for public notification and the timeframe for implementation of corrective
disinfection and flushing.
7.2.3 Coliform Plan and Sampling
For each aircraft water system, air carriers must inform EPA when coliform sampling plans are
completed and report the frequency of coliform monitoring. Copies of coliform sampling plans
must be retained but they are not required to be submitted to EPA. However, EPA can request a
copy of the plan at any time and may also view the plan during compliance audits. The frequency
of coliform monitoring will be tracked and compared to the minimum requirements of the rule,
and used as the basis for determining compliance with the provisions of the ADWR. Exhibit 7.4
summarizes the reporting items and timeline related to establishing and maintaining coliform
sampling plans and conducting coliform monitoring.
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Exhibit 7.4 Reporting for Coliform Plan and Sampling
Reporting Item
Coliform Sampling Plan
(existing aircraft)
Coliform Sampling Plan
(new aircraft)
Changes to required sampling
frequency
All sample results that are
TC(-) & EC(-)
(routine, repeats and follow-up)
Any routine sample TC(+) & EC(-)
Any sample TC(+) & EC(+) (routine,
repeat, and follow-up)
Any repeat or follow-up sample
Return to routine monitoring
Failure to conduct routine monitoring
Failure to collect repeat samples
Failure to collect follow-up samples
Reporting Timeline
April 19,2011
Within the first calendar quarter of
initial operation of the aircraft
No later than 10 days following the
calendar month in which the
change occurred
No later than 10 calendar days
following the monitoring period in
which the sampling occurred.
Within 10 calendar days of
receiving sample results
Within 10 calendar days of
receiving sample results
Within 10 calendar days of
receiving sample results
No later than 10 calendar days
following the return to routine
monitoring
Within 10 calendar days of
discovery of the failure
Within 10 calendar days of
discovery of the failure
Within 1 0 calendar days of
discovery of the failure
Information to Report to EPA
Date the plan has been developed
and the frequency of routine
coliform sampling for each aircraft
Date the plan has been developed
and the frequency of routine
coliform sampling for each aircraft
Changes to the required sampling
frequency
Sample results
Sample results and, if applicable,
whether required notification was
provided to passengers and crew or
crew only
Sample results and whether
required notification was provided to
passengers and crew or crew only
Sample results and whether
required notification was provided to
passengers and crew or crew only
Cessation of public notification or
restricted public access
requirements
Whether required notification was
provided to passengers and crew or
crew only
Whether required notification was
provided to passengers and crew or
crew only
Whether required notification was
provided to passengers and crew or
crew only
For existing aircraft, both sampling frequencies and coliform sampling plan completion must be
reported to EPA by April 19, 2011. For new aircraft placed into operation after the initial
inventory is submitted, sampling frequencies and plan completion must be reported within the
first calendar quarter of initial operation of the aircraft. See Chapter 4 for more information on
coliform sampling plan requirements.
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Changes in coliform sampling frequencies must be reported to EPA no later than 10 days
following the calendar month in which the change occurred. Such changes must also be
incorporated in the coliform sampling plan, although the plan itself need not be submitted.
Changes to coliform sampling frequencies and coliform sampling plans require changes to
disinfection and flushing frequencies and O&M plans. Exhibit 7.5 summarized the implications
of changing the coliform sampling frequency.
Exhibit 7.5 Implications of Changes to Coliform Sampling Frequencies
Report the change
in frequency within 10
days following the month
in which the
change occurred
If there is a change in the frequency
of routine coliform sampling
Report the change
in frequency within 10
days following the month
in which the
change occurred
Change the frequency of routine
disinfection and flushing accordingly
Update the Coliform Sampling Plan
to reflect the changes.
Update the Aircraft Water System
O&M Plan to reflect the changes. The
updated Aircraft Water System O&M
Plan must be included in the
FAA-accepted Operations and
Maintenance Program.
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), six months, or 1 year.
If sample results (or any other event) trigger repeat sampling, or follow-up samples are collected
after disinfection and flushing, the event must be reported to EPA within 10 days of being
informed of sample results by the laboratory including whether the notification was provided to
passengers and crew, or crew only.
All analytical sample results will be reported to the ADWR Reporting and Compliance System.
Air carriers may instruct laboratories to either manually enter analytical results into EPA's
electronic data system, or to electronically upload data files from their laboratory information
management systems (LIMS) to a Web-based data file submission program.
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Regardless of the method or personnel used to report the data, these data files must be in a
format prescribed by EPA. Air carriers may determine the best method of data upload and
reporting that meets their needs. The ADWR does not require laboratory reporting or prohibit
consultants or other agents from gathering and reporting results on the carrier's behalf. If it is
believed that a result was entered into the data system erroneously, the air carrier is responsible
for notifying the laboratory or responsible party to rectify the entry.
Failure to comply with the monitoring 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 collect routine samples according to the schedule in the coliform
sampling plan, failure to collect repeat samples or follow-up samples within the time required,
and failure to use a state or EPA-certified laboratory or EPA-approved analytical methods.
7.2.4 O&M Plans and Activities
For each aircraft water system, air carriers must inform EPA when the O&M plan is completed
and report the frequency of routine disinfection and flushing. Copies of aircraft water system
O&M plans must be retained but are not required to be submitted to EPA. However, EPA can
request a copy of the plan at any time and may also view the plan during compliance audits. The
frequency of routine disinfection and flushing will be tracked and compared to the minimum
requirements of the rule, and used as the basis for determining compliance with the provisions of
the ADWR. Exhibit 7.6 summarizes the reporting items and timeline that are related to
establishing and maintaining O&M plans and conducting O&M activities.
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Exhibit 7.6 Reporting O&M Plans and Activities
Reporting Item or Event
Operations and Maintenance Plan
(existing aircraft)
Operations and Maintenance Plan
(new aircraft)
Changes to disinfection and flushing
frequency
Disinfecting and Flushing
(routine)
Disinfecting and Flushing
(corrective)
Restriction of public access
Shutting off an aircraft water system
Failure to conduct disinfection and
flushing
Failure to board water from a safe
watering point
Reporting Timeline
April 19,2011
Within the first calendar quarter of
initial operation of the aircraft
No later than 10 days following the
calendar month in which the
change occurred
Within 10 calendar days following
the disinfection and flushing
period in which the disinfection
and flushing occurred.
Within 1 0 calendar days of
conducting disinfection and
flushing
Within 10 calendar days of
restriction
Within 10 calendar days of
notification
Within 1 0 calendar days of failure
Within 10 calendar days of
identification of failure
Information to Report to EPA
Plan has been developed and the
frequency of routine disinfection
and flushing for each aircraft
Plan has been developed and the
frequency of routine disinfection
and flushing for each aircraft
Changes to disinfection and
flushing frequency
Routine disinfection and flushing
event was completed
Corrective disinfection and flushing
was completed and whether
required notification was provided to
passengers and crew or crew only
Notification was provided to
passengers and crew or crew only,
corrective action type, and reason
Whether the water system has been
shut off
Whether required notification was
provided to passengers and crew or
crew only and corrective actions
implemented
Whether required notification was
provided to passengers and crew or
crew only and corrective actions
implemented
For existing aircraft, both routine disinfection and flushing frequency and O&M plan completion
must be reported to EPA by April 19, 2011. For new aircraft placed into operation after the
initial inventory is submitted, frequency of routine disinfection and flushing and O&M plan
completion must be reported within the first calendar quarter of initial operation of the aircraft.
See Chapter 5 for more information on O&M plan requirements.
Changes in routine disinfection and flushing frequencies must be reported to EPA no later than
10 days following the calendar month in which the change occurred. Such changes must also be
incorporated in the O&M plans, although the plan itself need not be submitted. Changes to the
routine disinfection and flushing frequencies require changes to the routine coliform sampling
frequencies and coliform sampling plans.
Failure to comply with the disinfection and flushing requirements of this regulation must also be
reported to EPA within 10 calendar days of discovery of the failure. Failure to comply with
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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.
Anytime corrective action (i.e., restriction of public access or disinfection and flushing) is
implemented, air carriers must notify EPA within 10 calendar days of the event and report the
reason for the corrective action, the type of corrective action implemented, and whether required
notification was provided to the passengers and crew or crew only.
7.2.5 Public Notification
All events requiring notification to passengers and crew must also be reported to EPA within 10
days of the event triggering the notification (see Exhibit 7.7). This reporting must include
information on whether the required notification was provided to passengers and crew or crew
only [40 CFR 141.806(b)(4)]. 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.
Exhibit 7.7 Public Notification Reporting Requirements
Reporting Item
Public notification to crew and
passengers
Public notification to crew only
Reporting Timeline
Within 10 calendar days of
notification
Within 10 calendar days of
notification
Information to Report to EPA
Whether required notification was
provided to the passengers and
crew or crew only
Whether required notification was
provided to the passengers and
crew or crew only
7.2.6 Self-Inspections
Air carriers must provide evidence of a self-inspection to EPA within 90 days of completion of
the self-inspection [40 CFR 141.806(c)]; self-inspections of aircraft water systems are required
every 5 years. The report must include evidence that all deficiencies identified in the inspection
have been addressed. See Exhibit 7.8 on reporting requirements for self-inspections.
Exhibit 7.8 Self-Inspection Reporting
Reporting Item
Reporting Timeline
Information to Report to EPA
Completion of self-inspection
90 days after completion of the
self-inspection
Provide evidence that a self-
inspection was completed
Deficiencies identified during self-
inspection
Within 90 days of identification of
the deficiency
Notification that the deficiency has
been addressed, or if not addressed,
provide a description of the
deficiency and an explanation of why
it has not been addressed and a
schedule for addressing the
deficiency as soon as possible
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EPA has provided flexibility in the rule so that a full self-inspection of an aircraft water system
may be conducted over time rather than all at once so long as a complete self-inspection of the
entire aircraft water system occurs no less frequently than once every five years. This allows air
carriers to develop their own unique self-inspection procedures that coordinate, to the maximum
extent possible, water system self-inspections with the existing aircraft inspection and
maintenance process. Consequently, deficiencies may be identified periodically throughout the
compliance period. If any deficiency has not been addressed within 90 days of identification of
the deficiency, 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 [40 CFR 141.806(c)].
If more than 90 days have elapsed since a deficiency was identified and it has not been
addressed, the aircraft will incur a violation of the ADWR if the aircraft is used in passenger
service, even if public access to the water is restricted [40 CFR 141.808(c) and 141.810(e)]. If
the aircraft is not returned to service, such as during extended or heavy maintenance, more than
90 days are allowed for addressing the deficiency without incurring a violation. Exhibit 7.9
illustrates the self-inspection reporting requirements.
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Exhibit 7.9 Self-Inspection Reporting Requirements
Complete a Self-Inspection
By October 19,2016
of the water system components
of each aircraft in the inventory as of October 19, 2011
and within every 5 years thereafter
No deficiencies found
during the
self-inspection
Deficiencies found during the
self-inspection
are addressed
within 90 days of identification or
before water is accessible
to the public
Deficiencies found during the
self-inspection
are not addressed
within 90 days of identification
and the aircraft water system
is accessible to the public
Within 90 days
of completing the
self-inspection,
\ report evidence to EPA
\ that it was completed,
Within 90 days
of completing the
self-Inspection,
report evidence to EPA
that it was completed
/ Within 90 days
/ of completing the
self-inspection,
'. report evidence to EPA
\ th at it was completed ,
Within 90 days
of identifying the
deficiency,
report that all
deficiencies were
addressed within 90
days of identification or
before
unrestricted access to the
water system
was allowed
Within 90 days
of identifying the
deficiency, report a
description of any
deficiencies that we re
not addressed,
why they are not
addressed,
and a schedule for
addressing them
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7.2.7 Compliance Audits
Because EPA performs compliance audits, there are no reporting requirements for the air carrier
related to completion of the audit. However, if deficiencies are identified during the audit, there
are reporting requirements related to the status of the deficiency. If a deficiency is identified
during a compliance audit, the carrier must report to EPA within 90 days of completion of the
audit that the deficiency has been addressed. Exhibit 7.10 provides the compliance audit
reporting requirements related to water system deficiencies.
Exhibit 7.10 Compliance Audit Reporting
Reporting Item
Reporting Timeline
Information to Report
Deficiencies identified during
compliance audits
Within 90 days of notification of the
deficiency
Notification that the deficiency has
been addressed, or if not addressed,
provide a description of the
deficiency and an explanation of why
it has not been addressed and a
schedule for addressing the
deficiency as soon as possible
If any deficiencies have not been addressed within 90 days of identification of the deficiency, 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 [40
CFR141.806(c)].
If more than 90 days have elapsed since a deficiency was identified and it has not been
addressed, the aircraft will incur a violation of the ADWR if the aircraft is used in passenger
service, even if public access to the water is restricted [40 CFR 141.808(c) and 141.810(e)]. If
the aircraft is not returned to service, such as during extended or heavy maintenance, more than
90 days are allowed for addressing the deficiency without incurring a violation.
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8. Violations of the Rule
Implementation and enforcement of National Primary Drinking Water Regulations applicable to
aircraft public water systems is the responsibility of the EPA. Violations of the ADWR are
specified in 40 CFR 141.810. Most of the violations involve failure of the air carrier to perform a
specified action. An important exception is that any routine or repeat coliform sample result that
is E. coli-positive is a violation of the ADWR.
Exhibit 8.1 summarizes rule violations and actions that the ADWR specifies must be taken in
response to the violation, along with the rule citations. The exhibit also provides references to
chapters in this guidance that provide further information on the ADWR requirements that were
violated and the activity that is required in response to the violation. EPA's enforcement options,
including penalties, are not addressed in this table.
In some cases, actions to bring the aircraft water system into compliance with the rule are not
specified in the ADWR and will be determined by EPA. Exhibit 8.1 provides information on the
violations to which this applies. EPA-required actions may be situation-specific.
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Exhibit 8.1 Violations of the ADWR
- Summary -
Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to perform any requirements in
[40CFR 141.803 or 141.804]. This
includes failure to: use analytical methods
approved in accordance with 141.21(f)(3)
and 141.21(f)(6) of the National Primary
Drinking Water Regulations; and/or use
laboratories certified by EPA or a "State".
There are no rule citations specifying actions in response to these
violations. Actions will be determined by EPA. One of the actions could
include replacing the sample.
Chapter 4
Failure to perform routine disinfection
and flushing [40 CFR 141.810(a)]. This
includes failure to conduct routine
disinfection and flushing as specified in
the O&M plan.
The responses specified for this violation under 40 CFR
141.803(c)(3)(ii) are as follows:
(1) Restrict public access to aircraft water system within 72 hours
which includes:
• Physically disconnecting/shutting off aircraft water system,
where feasible, or otherwise preventing the flow of water
through the tap(s).
• Providing public notification to passengers and crew per
40 CFR 141.805.
• Providing alternatives to water from the aircraft water
system (e.g., bottled water, antiseptic hand gels, etc.).
(2) Conduct disinfection and flushing.
(3) Collect follow-up samples. Once samples are collected, aircraft
water can be provided for human consumption.
40 CFR 141.806(b)(5) requires the violation be reported to EPA within
10 calendar days of discovery of the failure.
Chapter 4
Chapter 5
Chapter 6
Chapter 7
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to perform corrective
disinfection and flushing [40 CFR
141.810(a)]. This is triggered by sample
results or failure to perform required
activities.
40 CFR 141.806(b)(5) requires the violation be reported to EPA within
10 calendar days of discovery of the failure. By failing to perform
corrective disinfection and flushing, the air carrier also would have
failed to collect follow-up samples. Therefore, the air carrier must
complete the required responses for failing to collect follow-up
samples for an £. co/;-positive or a total coliform-positive and E. coli-
negative routine or repeat sample, whichever is applicable.
Chapter 4
Chapter 5
Chapter 7
Failure to restrict public access to the
aircraft water supply by not physically
disconnecting or shutting off the
aircraft water system where feasible [40
CFR 141.810(a)]. This is triggered by
sample results or failure to perform
required activities.
By failing to restrict public access by not physically disconnecting or
shutting off the aircraft water system when feasible, the air carrier also
would have failed to perform corrective disinfection and flushing in the
required timeframe and failed to collect the required follow-up
samples. Therefore, the aircraft must complete the required responses
for failing to collect follow-up samples for an £. co/;-positive or a total
coliform-positive and £. co/;-negative routine or repeat sample,
whichever is applicable.
Chapter 4
Chapter 5
Failure to restrict public access to the
aircraft water supply by not providing
public notification [40 CFR 141.810(a)].
This is triggered by sample results or
failure to perform required activities.
There are no rule citations specifying actions in response to this
violation. Actions will be determined by EPA.
Chapter 4
Chapter 6
Failure to restrict public access to the
aircraft water supply by not providing
alternatives to water or other measures
[40 CFR 141.810(a)]. This is triggered by
sample results or failure to perform
required activities.
There are no rule citations specifying actions in response to this
violation. Actions will be determined by EPA.
Chapter 4
Chapter 5
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to provide notification to
passengers and crew [40 CFR
141.810(c)]. This includes public
notification required for passengers and
crew per [40 CFR 141.805] triggered by
sample results, failure to perform required
activities, or as determined by EPA, the air
carrier, or the crew.
There are no rule citations specifying actions in response to this
violation. Actions will be determined by EPA.
Chapter 6
Failure to collect routine coliform
samples [40 CFR 141.810(a)]. This
includes failure to collect and analyze the
required number of coliform samples in
accordance with the coliform monitoring
plan.
The responses specified for this violation under 40 CFR
141.803(c)(3)(ii) are as follows:
(1) Restrict public access to aircraft water system within 72 hours
which includes:
• Physically disconnecting/shutting off aircraft water system,
where feasible, or otherwise preventing the flow of water
through the tap(s).
• Providing public notification to passengers and crew per
[40 CFR 141.805].
• Providing alternatives to water from the aircraft water
system (e.g., bottled water, antiseptic hand gels, etc.).
(2) Conduct disinfection and flushing.
(3) Collect follow-up samples. Once samples are collected, aircraft
water can be provided for human consumption.
40 CFR 141.806(b)(5) requires the violation be reported to EPA within
10 calendar days of discovery of the failure.
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to collect repeat or follow-up
samples as a result of a total coliform-
positive and E. co//-negative result [40
CFR 141.810(a)]. This includes failure to
conduct repeat sampling after routine
samples are found to be positive for total
coliform, and failure to conduct follow-up
monitoring after corrective disinfection and
flushing.
The responses specified for this violation under 40 CFR
141.803(c)(3)(ii) are as follows:
(1) Restrict public access to aircraft water system within 72 hours
which includes:
• Physically disconnecting/shutting off aircraft water system,
where feasible, or otherwise preventing the flow of water
through the tap(s).
• Providing public notification to passengers and crew per
[40 CFR 141.805].
• Providing alternatives to water from the aircraft water
system (e.g., bottled water, antiseptic hand gels, etc.).
(2) Conduct disinfection and flushing.
(3) Collect follow-up samples. Once samples are collected, aircraft
water can be provided for human consumption.
40 CFR 141.806(b)(5) requires the violation be reported to EPA within
10 calendar days of discovery of the failure.
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to collect follow-up samples as
a result of an E. co//-positive result [40
CFR 141.810(a)]. This includes failure to
conduct follow-up monitoring after
corrective disinfection and flushing when a
routine sample is £. co/;-positive.
The responses specified for this violation under 40 CFR
141.803(c)(2)(i), (ii), and (iii) are as follows:
(1) Restrict public access to aircraft water system within 24 hours
which includes:
• Physically disconnecting/shutting off aircraft water system,
where feasible, or otherwise preventing the flow of water
through the tap(s).
• Providing public notification to passengers and crew per
[40 CFR 141.805].
• Providing alternatives to water from the aircraft water
system (e.g., bottled water, antiseptic hand gels, etc.).
(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.
(3) Collect follow-up samples. Follow-up samples results must be
total coliform-negative before aircraft water can be provided for
human consumption.
40 CFR 141.806(b)(5) requires the violation be reported to EPA within
10 calendar days of discovery of the failure.
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to board water from a safe
watering point (non-E. co//-positive
event) [40 CFR 141.810(a)]. When an air
carrier becomes aware of a non-E. coli-
positive event resulting from water that
has been boarded from a watering point
not in accordance with FDA regulations,
does not meet EPA standards for transient
non-community water systems, or has
been determined unsafe due to
noncompliance with procedures for
boarding water specified in the O&M plan.
The responses specified for this violation under 40 CFR
141.803(c)(3)(ii) are as follows:
(1) Restrict public access to aircraft water system within 72 hours
which includes:
• Physically disconnecting/shutting off aircraft water system,
where feasible, or otherwise preventing the flow of water
through the tap(s).
• Providing public notification to passengers and crew per
[40 CFR 141.805].
• Providing alternatives to water from the aircraft water
system (e.g., bottled water, antiseptic hand gels, etc.).
(2) Conduct disinfection and flushing.
(3) Collect follow-up samples. Once samples are collected, aircraft
water can be provided for human consumption.
40 CFR 141.806(b)(4) requires the violation be reported to EPA within
10 calendar days of the event.
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to board water from a safe
watering point (E. co//-positive event)
[40 CFR 141.810(a)]. When an air carrier
becomes aware of an £. co/;-positive
event resulting from water that has been
boarded from a watering point not in
accordance with FDA regulations, does
not meet EPA standards for transient non-
community water systems, or has been
determined unsafe due to noncompliance
with procedures for boarding water
specified in the O&M plan.
The responses specified for this violation under 40 CFR
141.803(c)(2)(i), (ii), and (iii) are as follows:
(1) Restrict public access to aircraft water system within 24 hours
which includes:
• Physically disconnecting/shutting off aircraft water system,
where feasible, or otherwise preventing the flow of water
through the tap(s).
• Providing public notification to passengers and crew per
[40 CFR 141.805].
• Providing alternatives to water from the aircraft water
system (e.g., bottled water, antiseptic hand gels, etc.).
(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.
(3) Collect follow-up samples. Follow-up samples results must be
total coliform-negative before aircraft water can be provided for
human consumption.
40 CFR 141.806(b)(4) requires the violation be reported to EPA within
10 calendar days of the event.
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Any E. co//-positive sample in any
monitoring period [40 CFR 141.810(b)]
(routine and repeat samples are used in
this determination).
The responses specified for this violation under 40 CFR
141.803(c)(2)(i), (ii), and (iii) are as follows:
(1) Restrict public access to aircraft water system within 24 hours
which includes:
• Physically disconnecting/shutting off aircraft water system,
where feasible, or otherwise preventing the flow of water
through the tap(s).
• Providing public notification to passengers and crew per
[40 CFR 141.805].
• Providing alternatives to water from the aircraft water
system (e.g., bottled water, antiseptic hand gels, etc.).
(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.
(3) Collect follow-up samples. Follow-up samples results must be
total coliform-negative before aircraft water can be provided for
human consumption.
40 CFR 141.806(b)(4) requires the violation be reported to EPA within
10 calendar days of the event.
Chapter 4
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Chapter 7
Failure to comply with the reporting
and recordkeeping requirements [40
CFR 141.810(d)]. This includes failure to
report required information, results, or
actions to EPA; and failure to retain
records for the required time period or
failure to retain the required information.
There are no rule citations specifying actions in response to this
violation. Actions will be determined by EPA.
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Violation
Required Response for the Violation
(including citation)
Chapter
Reference for
Further
Information
Failure to conduct a self-inspection or
address a deficiency in accordance
with the O&M plan [40 CFR 141.810(e)].
Self-inspections are required every 5
years. Deficiencies noted during self-
inspections or compliance audits must be
addressed 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.
There are no rule citations specifying actions in response to this
violation. Actions will be determined by EPA.
Chapter 5
Failure to develop a coliform sampling
plan [40 CFR 141.810(f)]. Coliform
sampling plans must be developed by
April 19, 2011, for existing aircraft, or
within the first calendar quarter of initial
operation for new aircraft.
There are no rule citations specifying actions in response to this
violation. Actions will be determined by EPA. One of the actions would
include developing the plan.
Chapter 4
Failure to develop and follow
operations and maintenance plan [40
CFR141.810(f)].
Operations and maintenance plans must
be developed by April 19, 2011, for
existing aircraft, or within the first calendar
quarter of initial operation for new aircraft.
There are no rule citations specifying actions in response to this
violation. Actions will be determined by EPA. One of the actions would
include developing the plan.
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9. Other Water System Considerations
This chapter offers guidance on operations and management considerations for aircraft water
systems that are beyond the regulatory requirements of the ADWR. These are not required
practices, but this information may assist with maintaining the quality of water provided by
aircraft water systems.
This chapter includes sections that address efforts to maintain water quality by limiting bacterial
growth in water systems; supplemental treatment considerations; and additional communications
strategies and recordkeeping practices. Although many of the practices may apply to a given
aircraft water system or specific condition, they will not be applicable to all systems.
9.1 Water Age and Biofilm Management Considerations
Under certain conditions, the design and/or operation of aircraft water systems can cause water
to be held for extended periods of time. Increased water age (described as the length of time
water remains in the aircraft water system after it has been boarded and before it is used or
flushed from the system) is a major factor in water quality degradation. Water quality
degradation may include formation of disinfection byproducts (DBFs), accumulation of
sediments, microbial growth such as biofilms, nitrification, taste and odor problems, and
increased disinfectant decay. Thoroughly disinfecting and flushing the aircraft water system may
help minimize and/or correct these problems.
Biofilm are thought to exist in all distribution systems and are accepted as a normal part of the
distribution system. Biofilms are growths of microorganisms that are typically attached to the
interior surfaces of piping, storage, and plumbing fixtures. 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
increase pipe corrosion, can affect pipe hydraulics, and make microbial disinfection more
difficult. Microbes can enter distribution systems through physical gaps in the distribution
system piping or tank, or due to contamination during the water transfer process to the aircraft.
Microbial growth and biofilm development are a concern when an aircraft water system
experiences excessive water age, higher temperatures, and when nutrients are present in the
water.
Some air carriers "top off or add water to the onboard storage tank on a repeated basis without
completely draining the storage tank. 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. Some also have procedures for draining the
water system due to either very cold or very warm ambient air temperatures. These practices
protect the aircraft water system piping from breakage due to freezing, limit bacterial growth
which can be enhanced in warm water, and also help to minimize water age. Draining of tanks
every three days is a common practice for some air carriers where they do not have a high turn-
over of the water through frequent high-volume boarding events.
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Recommended practices to minimize water age include the following (when and where it is
appropriate to dispose of the water should be considered):
1. Drain and refill tank frequently , when feasible, (e.g., daily, especially when aircraft are
parked overnight in warm climates).
2. Limit the amount of water carried on the aircraft to only what is needed (due to the
weight of water, air carriers typically do this but it is also a good practice for minimizing
water age by maximizing water turn-over).
3. Conduct periodic disinfection and flushing more frequently than the manufacturer's
recommendations if bacterial growth or water age is a concern. It is the responsibility of
the air carrier to ensure that any increase in frequency would not result in damage to the
aircraft water system's components.
4. Disinfect and flush the aircraft water system before serving water to the public if the
water system has been worked on or the aircraft has been inactive or stored for an
extended period (e.g., 3-days or more).
9.2 Considerations for Supplemental Treatment
The rule applies to aircraft that board only finished water for human consumption. In the
ADWR, supplemental treatment is not required to be used with finished water that has been
boarded on the aircraft. EPA believes the rule prescribes the minimum requirements necessary to
provide safe drinking water to passengers and crew onboard aircraft, including the requirement
to board finished water; boarding finished water in accordance with FDA requirements;
transferring the water from the watering point to the aircraft in a manner that ensures it will not
become contaminated during the transfer; compliance monitoring; corrective action; appropriate
training of personnel; implementation of a water system operation and maintenance plan; self-
inspections; compliance audits; reporting; and recordkeeping. However, supplemental treatment
can provide an additional barrier of protection in the event of a failure in any of the basic
protection barriers required under this rule. EPA believes the basic requirements of the ADWR,
when performed consistently and diligently by the air carriers and their agents, provide assurance
that drinking water onboard aircraft is safe for passengers and crew. Based on the information
that EPA has at the time of this rulemaking, there is not sufficient information or data to support
a requirement of supplemental treatment for aircraft water systems or for reducing any of the
minimum requirements based on the installation of supplemental treatment. However, EPA plans
to revisit this issue as part of the Six-Year review of the ADWR under SDWA Section
1412(b)(9) and as more data become available.
9.2.1 Type of Treatment Provided
Specific types of supplemental treatment installed on an aircraft public water system may
provide an additional barrier against contamination. Installation of supplemental disinfection
treatment units is an established practice in some corporate and charter jet fleets as well as in
some new commercial passenger aircraft. Ultraviolet light disinfection systems are examples of
supplemental disinfection units that are installed on some aircraft.
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Supplemental treatment consisting of carbon adsorption and/or particle removal filters is
intended to improve the aesthetic quality of the water and not to provide microbial inactivation.
If not properly maintained, these units may harbor bacteria and promote biofilm growth.
Any supplemental treatment units installed onboard existing or new aircraft must be acceptable
to FAA and FDA and must be installed, operated, and maintained in accordance with the
manufacturer's plans and specifications and FAA requirements. Supplemental treatment units
must not cause the water to violate the standards prescribed in the ADWR.
9.2.2 Supplemental Treatment Maintenance and Operator Training
It is important to educate aircraft maintenance personnel on the details regarding supplemental
treatment, including ensuring the equipment is properly installed, operated, maintained, and
inspected. Manufacturer's recommendations for installation, operation, and maintenance, as well
as any issues that have been encountered, should be reviewed periodically and incorporated into
the training program and the operations and maintenance plan for the aircraft water system.
The consequences of improperly installed, operated, or maintained treatment equipment can
include the degradation of the quality of the water and a false-sense of confidence in the water
provided to passengers and crew.
9.3 Communication Strategy
Stationary public water systems serving airports are usually community water systems and are
required to meet more requirements than are aircraft water systems which are transient non-
community water systems. Despite these requirements, stationary public water systems may
experience temporary periods of non-compliance or water quality degradation. Accordingly,
public water systems that sell or otherwise provide drinking water to other public water systems
(i.e., to consecutive systems) are required to give public notice to the owner or operator of the
consecutive system; the consecutive system is responsible for providing public notice to the
persons it serves. Even though it is the responsibility of the stationary system to provide public
notice to its users, it may be beneficial for airport personnel to establish strong communication
links to the providers of water to the airport to ensure that the airport receives any drinking water
public notice in a timely manner. Likewise, air carrier personnel should establish communication
links with the appropriate airport personnel to ensure that they are notified immediately of any
circumstances that may affect the quality of water supplied to the aircraft. Effective and timely
communications between the public water system, airport, and air carrier may help the air carrier
avoid unknowingly boarding water that does not meet the NPDWRs. Accordingly, EPA plans to
work with FDA to help facilitate communication between all of the responsible parties along the
aircraft water supply and transfer chain.
9.4 Recordkeeping Practices for Boarding of Water
Air carriers are not required by the ADWR to record the volume of water that is boarded onto
aircraft, the date and time of boarding, or the location of boarding. The ADWR did not include
such a requirement because of the large number of records the requirement would entail, and the
limited value of the information. The information was believed to be of limited use since only
finished water from watering points that are in accordance with FDA regulations is to be
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boarded, and water from several sources may be mixed within a given aircraft water system at
any time. This information, however, may be valuable to the air carrier 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 could be traced back to a specific location, the water
quality issue could potentially be identified and resolved. Although the ADWR does not require
information on water that is boarded, air carriers may implement this recordkeeping practice if
desired.
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References
USEPA Office of Ground Water and Drinking Water. 2002a. Health Risks From Microbial
Growth and Biofilms in Drinking Water Distribution Systems. Available at:
http://www.epa.gov/ogwdw/disinfection/tcr/pdfs/whitepaper tcr biofilms.pdf.
USEPA Office of Ground Water and Drinking Water. 2002b. Effects of Water Age on
Distribution System Water Quality. Available at:
http://www.epa.gov/ogwdw/disinfection/tcr/pdfs/whitepaper tcr waterdistribution.pdf
USEPA Office of Ground Water and Drinking Water. January 2005. Manual for the Certification
of Laboratories Analyzing Drinking Water: Criteria and Procedures Quality Assurance. 5th
Edition. (EPA 815-R-05-004).
WHO 2009. Guide to Hygiene and Sanitation in Aviation. 3rd Edition. Geneva, World Health
Organization. Available at:
http://www.who.int/water sanitation health/hygiene/ships/guide hygiene sanitation aviation 3
edition.pdf
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Appendix A
Federal Register Publication of the Final ADWR Requirements
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Agency. No substantive comments were
provided by NDWAC.
On August 8, 2007, EPA consulted
with the Department of Health and
Human Services (HHS) on the proposed
rule. EPA also consulted with HHS on
the final rule and received a favorable
response to the Agency's novel
approach and development of the
ADWR and no issues were raised as a
result of the consultation.
L. Plain Language
Executive Order 12866 encourages
Federal agencies to write rules in plain
language. Whenever possible, EPA
wrote the action in active voice, with
simplified language, and displayed
information in tables to make it easier
for the public to read and understand.
M. Congressional Review Act
The Congressional Review? Act, 5
U.S.C. 801 et seq., as added by the Small
Business Regulatory Enforcement
Fairness Act of 1996, generally provides
that before a rule may take effect, the
agency promulgating the rule must
submit a rule report, which includes a
copy of the rule, to each House of the
Congress and to the Comptroller General
of the United States. EPA will submit a
report containing this rule and other
required information to the U.S. Senate,
the U.S. House of Representatives, and
the Comptroller General of the United
States prior to publication of the rule in
the Federal Register. A Major rule
cannot take effect until 60 days after it
is published in the Federal Register.
This action is not a "major rule" as
defined by 5 U.S.C. 804(2). This rule
will be effective November 18, 2009.
N. Analysis of the Likely Effect of
Compliance With the ADWR on the
Technical, Financial, and Managerial
Capacity of Public Water Systems
Section 1420(d)(3) of SDWA, as
amended, requires that, in promulgating
a NPDWR, the Administrator shall
include an analysis of the likely effect
of compliance with the regulation on
the technical, managerial, and financial
(TMF) capacity of regulated entities.
This analysis can be found in the
Economic and Supporting Analyses
document in EPA's public docket.
Analyses reflect only the impact of new
or revised requirements, as established
by the ADWR; the impacts of previously
established requirements are not
considered.
VIII. References
ATA (Air Transport Association of America,
Inc.) 2003. Air Transport Association:
Aircraft Drinking Water Sampling Program,
Final Report: December 31, 2003. http://
www.airlines.org.
Canada. 2007a. Health Canada. Healthy
Living. Aircraft Inspection Program—
Frequently Asked Questions, http://
www.hc-sc.gc.ca/hl-vs/travel-voyage/
general/inspection/airplane-aeronefs
_e.html.
Canada. 2007b. Health Canada. Healthy
Living. Advisory. Health Canada cautions
air travelers with compromised immune
systems regarding water quality on aircraft.
http://www.hc-sc.gc.ca/ahc-asc/media/
advisories-avis/2006/2006_53_e.html.
Davison, A., Howard, G., Stevens, M., et al.
2005. Water, Sanitation and Health
Protection and the Human Environment,
World Health Organization, Geneva. Water
Safety Plans: Managing drinking-water
quality from catchment to consumer.
http://www.who.int/water_
sanitation Jiealth/.
Lehtola, M., Torvinen, E., Kusnetsov,}., et al.
2007. Survival of Mycrobacterium avium,
Legionella pneumophila, Escherichia coli,
and Caliciviruses in Drinking Water-
Associated Biofilms Grown under High-
Shear Turbulent Flow. Applied and
Environmental Microbiology, 73:2854-
2859.
USEPA. 1986. Water Supply Guidance 29:
Plan for Implementation of the Safe
Drinking Water Act on Interstate Carrier
Conveyance.
USEPA. 1989. National Interim Primary
Drinking Water Regulations; Total Coliform
Rule; Final Rule. Part III. Federal Register,
54:124:27544. (June 29, 1989).
USEPA. 2008. Economic and Supporting
Analyses; Aircraft Drinking Water Rule.
EPA 816-D-08-002.
USEPA. 2008. DRAFT Information Collection
Request for the National Primary Drinking
Water Regulations: Aircraft Drinking Water
Rule. EPA 816-D-08-001.
USFDA. 2005. Title 21—Food and Drugs,
Chapter 1—Food and Drug Administration,
Part 1250—Interstate Conveyance
Sanitation, http://www.accessdata.fda.
gov/.
WHO. 1997. HACCP—Introducing the
Hazard Analysis and Critical Control Point
System. Geneva, Switzerland: WHO.
WHO. 2004. Guidelines for Drinking-Water
Quality. 3rd Edition, Volume 1—
Recommendations, Chapter 4 Water
Supply Plans. Geneva, Switzerland: WHO.
List of Subjects in 40 CFR Part 141
Environmental protection, Chemicals,
Indian-lands, Intergovernmental
relations, Radiation protection,
Reporting and recordkeeping
requirements, Water supply.
Dated: October 5, 2009.
Lisa P. Jackson,
Administrator.
• For the reasons set out in the
preamble, title 40, chapter 1 of the Code
of Federal Regulations is to be amended
as follows:
PART 141—NATIONAL PRIMARY
DRINKING WATER REGULATIONS
• 1. The authority citation for part 141
continues to read as follows:
Authority: 42 U.S.C. 300f, 300g-l, 300g-
2, 300g-3, 300g-J, 300g-5, 300g-6, 300J-J,
300J-9, and 300J-11.
• 2. Part 141 is amended by adding a
new subpart X to read as follows:
Subpart X—Aircraft Drinking Water Rule
Sec.
141.800 Applicability and compliance date.
141.801 Definitions.
141.802 Coliform sampling plan.
141.803 Coliform sampling.
141.804 Aircraft water system operations
and maintenance plan.
141.805 Notification to passengers and
crew.
141.806 Reporting requirements.
141.807 Recordkeeping requirements.
141.808 Audits and inspections.
141.809 Supplemental treatment.
141.810 Violations.
Subpart X—Aircraft Drinking Water
Rule
§ 141.800 Applicability and compliance
date.
(a) Applicability. The requirements of
this subpart constitute the National
Primary Drinking Water Regulations for
aircraft that are public water systems
and that board only finished water for
human consumption. Aircraft public
water systems are considered transient
non-community water systems
(TNCWS). To the extent there is a
conflict between the requirements in
this subpart and the regulatory
requirements established elsewhere in
this part, this subpart governs.
(b) Compliance Date. Aircraft public
water systems must comply, unless
otherwise noted, with the requirements
of this subpart beginning October 19,
2011. Until this compliance date, air
carriers remain subject to existing
national primary drinking water
regulations.
§141.801 Definitions.
As used in this subpart, the term:
Administrator means the
Administrator of the United States
Environmental Protection Agency or
his/her authorized representative.
Air Carrier means a person who
undertakes directly by lease, or other
arrangement, to engage in air
transportation. The air carrier is
responsible for ensuring all of the
aircraft it owns or operates that are
public water systems comply with all
provisions of this subpart.
Aircraft means a device that is used
or intended to be used for flight in the
air.
Aircraft Water System means an
aircraft that qualifies as a public water
system under the Safe Drinking Water
Act and the national primary drinking
water regulations. The components of
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53619
an aircraft water system include the
water service panel, the filler neck of
the aircraft finished water storage tank,
and all finished water storage tanks,
piping, treatment equipment, and
plumbing fixtures within the aircraft
that supply water for human
consumption to passengers or crew.
Aircraft Water System Operations and
Maintenance Plan means the schedules
and procedures for operating,
monitoring, and maintaining an aircraft
water system that is included in an
aircraft operation and maintenance
program accepted by the Federal
Aviation Administration. (14 CFR part
43, 14 CFR part 91, 14 CFR part 121)
Finished Water means water that is
introduced into the distribution system
of a public water system and is intended
for distribution and consumption
without further treatment, except as
treatment necessary to maintain water
quality in the distribution system (e.g.,
supplemental disinfection, addition of
corrosion control chemicals). (40 CFR
141.2)
Human Consumption means drinking,
bathing, showering, hand washing, teeth
brushing, food preparation,
dishwashing, and maintaining oral
hygiene.
Self Inspection means an onsite
review of the aircraft water system,
including the water service panel, the
filler neck of the aircraft finished water
storage tank; all finished water storage
tanks, piping, treatment equipment, and
plumbing fixtures; and a review of the
aircraft operations, maintenance,
monitoring, and recordkeeping for the
purpose of evaluating the adequacy of
such water system components and
practices for providing safe drinking
water to passengers and crew.
Watering point means the water
supply, methods, and facilities used for
the delivery of finished water to the
aircraft. These facilities may include
water trucks, carts, cabinets, and hoses.
§ 141.802 Coliform sampling plan.
(a) Each air carrier under this subpart
must develop a coliform sampling plan
covering each aircraft water system
owned or operated by the air carrier that
identifies the following:
(l) Coliform sample collection
procedures that are consistent with the
requirements of § 141.803(a) and (b).
(2) Sample tap location(s)
representative of the aircraft water
system as specified in § 141.803(b)(2)
and (b)(4).
(3) Frequency and number of routine
coliform samples to be collected as
specified in § 141.803(b)(3).
(4) Frequency of routine disinfection
and flushing as specified in the
operations and maintenance plan under
§141.804.
(5) Procedures for communicating
sample results promptly so that any
required actions, including repeat and
follow-up sampling, corrective action,
and notification of passengers and crew,
will be conducted in a timely manner.
(b) Each air carrier must develop a
coliform sampling plan for each aircraft
with a water system meeting the
definition of a public water system by
April 19, 2011.
(c) The coliform sampling plan must
be included in the Aircraft Water
System Operations and Maintenance
Plan required in § 141.804. Any
subsequent changes to the coliform
sampling plan must also be included in
the Aircraft Water System Operations
and Maintenance Plan required in
§141.804.
§ 141.803 Coliform sampling.
(a) Analytical Methodology. Air
carriers must follow the sampling and
analysis requirements under this
section.
(1) The standard sample volume
required for total coliform analysis,
regardless of analytical method used, is
100 mL.
(2) Air carriers need determine only
the presence or absence of total
coliforms and/or E. coli; a determination
of density of these organisms is not
required.
(3) Air carriers must conduct analyses
for total coliform and E. coli in
accordance with the analytical methods
approved in § 141.21(f)(3) and
(4) The time from sample collection to
initiation of analysis may not exceed 30
hours. Systems are encouraged but not
required to hold samples below 10°C
during transit.
(5) The invalidation of a total coliform
sample result can be made only by the
Administrator in accordance with
§ 141.21(c)(l)(i), (ii), or (iii) or by the
certified laboratory in accordance with
§141.21(c)(2).
(6) Certified laboratories. For the
purpose of determining compliance
with this subpart, samples may be
considered only if they have been
analyzed by a laboratory certified by a
State or EPA. For the purposes of this
paragraph, "State" refers to a State or
Tribe that has received primacy for
public water systems (other than aircraft
water systems) under section 1413 of
SDWA.
(b) Routine Monitoring. For each
aircraft water system, the sampling
frequency must be determined by the
disinfection and flushing frequency
recommended by the aircraft water
system manufacturer, when available,
and as identified in the operations and
maintenance plan in § 141.804.
(1) Except as provided in paragraph
(b)(2) of this section, the air carrier must
collect two 100 mL total coliform
routine samples at the frequency
specified in the sampling plan in
§ 141.802 and in accordance with
paragraph (b)(3) of this section;
(2) The air carrier may collect one 100
mL total coliform routine sample at the
frequency specified in the sampling
plan in § 141.802 for aircraft with a
removable or portable tank that is
drained every day of passenger service,
and the aircraft has only one tap.
Aircraft meeting the requirements of
this paragraph do not have to comply
with paragraph (b)(4) of this section.
(3) Air carriers must perform routine
monitoring for total coliform at a
frequency corresponding to the
frequency of routine disinfection and
flushing as specified in the Table b-1
(Routine Disinfection and Flushing and
Routine Sample Frequencies). Air
carriers must follow? the disinfection
and flushing frequency recommended
by the aircraft water system
manufacturer, when available. Where
the aircraft water system manufacturer
does not specify a recommended routine
disinfection and flushing frequency, the
air carrier must choose a frequency from
Table b-1 (Routine Disinfection and
Flushing and Routine Sample
Frequencies):
TABLE B-1—ROUTINE DISINFECTION AND FLUSHING AND ROUTINE SAMPLE FREQUENCIES
Minimum routine disinfection & flushing per
aircraft
Minimum frequency of routine samples per
aircraft
At least 4 times per year = At least once within every three-month pe-
riod (quarterly).
At least 3 times per year = At least once within every four-month pe-
riod.
At least 1 time per year = At least once within every twelve-month pe-
riod (annually).
At least 2 times per year = At least once within every six-month period
(semi-annually).
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TABLE B-1—ROUTINE DISINFECTION AND FLUSHING AND ROUTINE SAMPLE FREQUENCIES—Continued
Minimum routine disinfection & flushing per
aircraft
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 4 times per year = At least once within every three-month pe-
riod (quarterly).
At least 12 times per year = At least once every month (monthly).
(4) One sample must be taken from a
lavatory and one from a galley; each
sample must be analyzed for total
coliform. If only one water tap is located
in the aircraft water system due to
aircraft model type and construction,
then a single tap may be used to collect
two separate 100 mL samples.
(5) If any routine, repeat, or follow-up
coliform sample is total coliform-
positive, the air carrier must analyze
that total coliform-positive culture
medium to determine if E. coli is
present.
(6) Routine total coliform samples
must not be collected within 72 hours
after completing routine disinfection
and flushing procedures.
(c) Routine Coliform Sample Results.
(1) Negative Routine Coliform Sample
Results. If all routine sample results are
total coliform-negative, then the air
carrier must maintain the routine
monitoring frequency for total coliform
as specified in the sampling plan in
§141.802.
(2) Positive Routine E. coli Sample
Results. If any routine sample is E. coli-
positive, the air carrier must perform all
of the following:
(i) Restrict Public Access. Restrict
public access to the aircraft water
system in accordance with paragraph (d)
of this section as expeditiously as
possible, but in no case later than 24
hours after the laboratory notifies the air
carrier of the E. co7i-positive result or
discovery of the applicable failure as
specified in paragraphs (g) and (h) of
this section. All public access
restrictions, including applicable public
notification requirements, 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
(ii) Disinfect and Flush. Conduct
disinfection and flushing in accordance
with § 141.804(b)(2). If the aircraft water
system cannot be physically
disconnected or shut-off, or the flow of
water otherwise prevented through the
tap(s), then the air carrier must disinfect
and flush the system no later than 72
hours after the laboratory notifies the air
carrier of the E. co7i-positive result or
discovery of the applicable failure as
specified in paragraphs (g) and (h) of
this section; and
(iii) Follow-up Sampling. Collect
follow-up samples in accordance with
paragraph (e) of this section. A complete
set of follow-up sample results must be
total coliform-negative before the air
carrier provides water for human
consumption from the aircraft water
system and returns to the routine
monitoring frequency as specified in the
sampling plan required by § 141.802.
(3) Positive Routine Total Coliform
Sample Results. If any routine sample is
total coliform-positive and E. coli-
negative, then the air carrier must
perform at least one of the following
three corrective actions and continue
through with that action until a
complete set of follow-up or repeat
samples is total coliform-negative:
(i) Disinfect and Flush. In accordance
with § 141.804(b)(2), conduct
disinfection and flushing of the system
no later than 72 hours after the
laboratory notifies the air carrier of the
total coliform-positive and E. coli-
negative result. After disinfection and
flushing is completed, the air carrier
must collect follow-up samples in
accordance with paragraph (e) of this
section prior to providing water for
human consumption from the aircraft
water system. A complete set of follow-
up sample results must be total
coliform-negative before the air carrier
returns to the routine monitoring
frequency as specified in the sampling
plan required by § 141.802; or
(ii) Restrict Public Access. In
accordance with paragraph (d) of this
section, restrict public access to the
aircraft water system as expeditiously as
possible, but in no case later than 72
hours after the laboratory notifies the air
carrier of the total coliform-positive and
E. co7.z'-negative result or discovery of
the applicable failure as specified in
paragraphs (f), (g), and, (i) of this
section. All public access restrictions,
including applicable public notification
requirements, 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. The air carrier must conduct
disinfection and flushing in accordance
with § 141.804(b)(2). After disinfection
and flushing is completed, the air
carrier must collect follow-up samples
in accordance with paragraph (e) of this
section prior to providing water for
human consumption from the aircraft
water system. A complete set of follow-
up sample results must be total
coliform-negative before the air carrier
returns to the routine monitoring
frequency as specified in the sampling
plan required by § 141.802; or
(iii) Repeat Sampling. Collect three
100 mL repeat samples no later than 24
hours after the laboratory notifies the air
carrier of the routine total coliform-
positive and E. co7i-negative result.
Repeat samples must be collected and
analyzed from three taps within the
aircraft as follows: The tap which
resulted in the total coliform-positive
sample, one other lavatory tap, and one
other galley tap. If fewer than three taps
exist, then a total of three 100 mL
samples must be collected and analyzed
from the available taps within the
aircraft water system.
(A) If all repeat samples are total
coliform-negative, then the air carrier
must maintain the routine monitoring
frequency for total coliform as specified
in the sampling plan in § 141.802.
(B) If any repeat sample is E. coli-
positive, the air carrier must perform all
the corrective actions as specified in
paragraphs (c)(2)(i), (c)(2)(ii), and
(c)(2)(iii) of this section.
(C) If any repeat sample is total
coliform-positive and E. co7i-negative,
then the air carrier must perform the
corrective actions specified in
paragraphs (c)(3)(i) or (c)(3)(ii) of this
section, and continue through with that
action until a complete set of follow-up
samples is total coliform-negative.
(d) Restriction of public access.
Restriction of public access to the
aircraft water system includes, but need
not be limited to, the following:
(1) Physically disconnecting or
shutting off the aircraft water system,
where feasible, or otherwise preventing
the flow of water through the tap(s);
(2) Providing public notification to
passengers and crew in accordance with
§141.805.
(3) Providing alternatives to water
from the aircraft water system, such as
bottled water for drinking and coffee or
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53621
tea preparation; antiseptic hand gels or
wipes in accordance with 21 CFR part
333—"Topical Anti-microbial Drug
Products for Over-the-Counter Human
Use" in the galleys and lavatories; and
other feasible measures that reduce or
eliminate the need to use the aircraft
water system during the limited period
before public use of the aircraft water
system is unrestricted.
(e) Post Disinfection and Flushing
Follow-up Sampling. Following
corrective action disinfection and
flushing, air carriers must comply with
post disinfection and flushing follow-up
sampling procedures that, at a
minimum, consist of the following:
(1) For each aircraft water system, the
air carrier must collect a complete set of
total coliform follow-up samples
consisting of two 100 mL total coliform
samples at the same routine sample
locations as identified in paragraphs
(b)(2) and (b)(4) of this section.
(2) Follow-up samples must be
collected prior to providing water to the
public for human consumption from the
aircraft water system.
(3) If a complete set of follow-up
samples is total coliform-negative, the
air carrier must return to the routine
monitoring frequency for total coliform
as specified in the sampling plan
required by §141.802.
(4) If any follow-up sample is E. coli-
positive, the air carrier must perform all
the corrective actions as specified in
paragraphs (c)(2)(i), (c)(2)(ii), and
(c)(2)(iii) of this section.
(5) If any follow-up sample is total
coliform-positive and E. coL'-negative
the air carrier must restrict public access
to the aircraft water system in
accordance with paragraph (d) of this
section as expeditiously as possible, but
in no case later than 72 hours after the
laboratory notifies the air carrier of the
total coliform-positive and E. coli-
negative result. All public access
restrictions, including applicable public
notification requirements, must remain
in-place until the aircraft water system
has been disinfected and flushed in
accordance with § 141.804(b)(2) and a
complete set of follow-up samples is
total coliform-negative. The air carrier
must collect follow-up samples in
accordance with paragraph (e) of this
section. A complete set of follow-up
sample results must be total coliform-
negative before the air carrier provides
water for human consumption from the
aircraft water system and returns to the
routine monitoring frequency for
coliform as specified in § 141.802.
(f) Failure to Perform Required
Routine Disinfection and Flushing or
Failure to Collect Required Routine
Samples. If the air carrier fails to
perform routine disinfection and
flushing or fails to collect and analyze
the required number of routine coliform
samples, the air carrier must perform all
the corrective actions as specified in
paragraph (c)(3)(ii) of this section.
(g) Failure to Collect Repeat or
Follow-up Samples. If the air carrier
fails to collect and analyze the required
follow-up samples as a result of an E.
coL'-positive result, then the air carrier
must perform all the corrective actions
as specified in paragraphs (c)(2)(i),
(c)(2)(ii), and (c)(2)(iii) of this section. If
the air carrier fails to collect and
analyze the required repeat samples or
follow-up samples as a result of a total
coliform-positive and E. co7i-negative
result, then the air carrier must perform
all the corrective actions as specified in
paragraph (c)(3)(ii) of this section.
(h) Failure to Board Water from a Safe
Watering Point (E. coli-positive). For the
aircraft water system, the air carrier
must perform all the corrective actions
specified in paragraphs (c)(2)(i),
(c)(2)(ii), and (c)(2)(iii) of this section
when it becomes aware of an E. coli-
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),
(3) Boarding water that is otherwise
determined to be unsafe due to non-
compliance with the procedures
specified in § 141.804(b)(6).
(i) Failure to Roard Water from a Safe
Watering Point (non-E. coli-positive).
For the aircraft water system, the air
carrier must perform all the corrective
actions specified in paragraphs (c)(3)(ii)
of this section when it becomes aware
of a non-E". co7i-positive event resulting
from:
(1) Boarding water from a watering
point not in accordance with FDA
regulations (21 CFR part 1240, subpart
E),
(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).
§ 141.804 Aircraft water system operations
and maintenance plan.
(a) Each air carrier must develop and
implement an aircraft water system
operations and maintenance plan for
each aircraft water system that it owns
or operates. This plan must be included
in a Federal Aviation Administration
(FAA)-accepted air carrier operations
and maintenance program (14 CFR part
43, 14 CFR part 91, 14 CFR part 121).
(b) Each aircraft water system
operations and maintenance plan must
include the following:
(1) Watering Point Selection
Requirement. All watering points must
be selected in accordance with Food
and Drug Administration (FDA)
regulations (21 CFR part 1240, subpart
E).
(2) Procedures for Disinfection and
Flushing. The plan must include the
following requirements for procedures
for disinfection and flushing of aircraft
water system.
(i) The air carrier must conduct
disinfection and flushing of the aircraft
water system in accordance with, or is
consistent with, the water system
manufacturer's recommendations. The
air carrier may conduct disinfection and
flushing more frequently, but not less
frequently, than the manufacturer
recommends.
(ii) The operations and maintenance
plan must identify the disinfection
frequency, type of disinfecting agent,
disinfectant concentration to be used,
and the disinfectant contact time, and
flushing volume or flushing time.
(iii) In cases where a recommended
routine disinfection and flushing
frequency is not specified by the aircraft
water system manufacturer, the air
carrier must choose a disinfection and
flushing, and corresponding monitoring
frequency specified in § 141.803(b)(3).
(3) Follow-up Sampling. The plan
must include the procedures for follow-
up sampling in accordance with
§141.803(e).
(4) Training Requirements. Training
for all personnel involved with the
aircraft water system operation and
maintenance provisions of this
regulation must include, but is not
limited to the following:
(i) Boarding water procedures;
(ii) Sample collection procedures;
(iii) Disinfection and flushing
procedures;
(iv) Public health and safety reasons
for the requirements of this subpart.
(5) Procedures for Conducting Self-
inspections of the Aircraft Water
System. Procedures must include, but
are not limited to, inspection of storage
tank, distribution system, supplemental
treatment, fixtures, valves, and backflow
prevention devices.
(6) Procedures for Boarding Water.
The plan must include the following
requirements and procedures for
boarding water:
(i) Within the United States, the air
carrier must board water from watering
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points in accordance with Food and
Drug Administration (FDA) regulations
(21 CFR part 1240, subpart E).
(ii) 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.
(iii) A description of how the carrier
will ensure that water boarded outside
the United States is safe for human
consumption.
(iv) A description of emergency
procedures that meet the requirements
in § 141.803(h) and (i) that must be used
in the event that the air carrier becomes
aware that water was boarded to operate
essential systems, such as toilets, but
was boarded from a watering point not
in accordance with FDA regulations,
does not meet NPDWRs applicable to
transient non-community water systems
(§§ 141.62 and 141.63, as applied to
TNCWSs), or is otherwise unsafe.
(7) Coliform Sampling Plan. The air
carrier must include the coliform
sampling plan prepared in accordance
with §141.802.
(8) Aircraft Water System Disconnect/
Shut-off, or Prevent Flow of Water
Through the Tap(s) Statement. An
explanation of whether the aircraft
water system can be physically
disconnected/shut-off, or the flow of
water otherwise prevented through the
tap(s) to the crew and passengers.
(c) For existing aircraft, the air carrier
must develop the water system
operations and maintenance plan
required by this section by April 19,
2011;
(d) For new aircraft, the air carrier
must develop the operations and
maintenance plan required in this
section within the first calendar quarter
of initial operation of the aircraft.
(e) Any changes to the aircraft water
system operations and maintenance
plan must be included in the FAA-
accepted air carrier operations and
maintenance program.
§ 141.805 Notification to passengers and
crew.
(a) Air carriers must give public
notice for each aircraft in all of the
following situations:
(1) Public access to the aircraft water
system is restricted in response to a
routine, repeat or follow-up total
coliform-positive or E. co7i-positive
sample result in accordance with
§141.803(d);
(2) Failure to perform required routine
disinfection and flushing or failure to
collect required routine samples in
accordance with § 141.803(f);
(3) Failure to collect the required
follow-up samples in response to a
sample result that is E. co7i-positive in
accordance with § 141.803(g);
(4) Failure to collect the required
repeat samples or failure to collect the
required follow-up samples in response
to a sample result that is total coliform-
positive and E. cofrnegative in
accordance with § 141.803(g);
(5) In accordance with § 141.803(h),
the air carrier becomes aware of an E.
coL'-positive event resulting from water
that has been boarded from a watering
point not in accordance with FDA
regulations (21 CFR part 1240, subpart
E), or that does not meet NPDWRs
applicable to transient non-community
water systems, or that is otherwise
determined to be unsafe due to non-
compliance with the procedures
specified in § 141.804(b)(6);
(6) In accordance with § 141.803(1),
the air carrier becomes aware of a non-
E. co7.z'-positive event resulting from
water that has been boarded from a
watering point not in accordance with
FDA regulations (21 CFR part 1240,
subpart E), or that does not meet
NPDWRs applicable to transient non-
community water systems, or that is
otherwise determined to be unsafe due
to non-compliance with the procedures
specified in § 141.804(b)(6).
(7) The Administrator, the carrier, or
the crew otherwise determines that
notification is necessary to protect
public health.
(b) Public notification:
(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;
(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.
(c) Public notification for paragraph
(a)(l) of this section must meet the
requirements of paragraph (b) of this
section in addition to the following:
(1) Public notification must include a
prominently displayed, clear statement
in each lavatory indicating 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;
and
(2) A prominent notice in the galley
directed at the crew which includes:
(i) 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;
(ii) A description of the violation or
situation triggering the notice, including
the contaminant(s) of concern;
(iii) When the violation or situation
occurred;
(iv) Any potential adverse health
effects from the violation or situation, as
appropriate, under paragraph (g) of this
section;
(v) The population at risk, including
sensitive subpopulations particularly
vulnerable if exposed to the
contaminant in the drinking water;
(vi) What the air carrier is doing to
correct the violation or situation; and
(vii) When the air carrier expects to
return the system to unrestricted public
access.
(3) If passenger access to the water
system is physically prevented through
disconnecting or shutting off the water,
or the flow of water prevented through
the tap(s), or if water is supplied only
to lavatory toilets, and not to any
lavatory or galley taps, then only the
notice specified in paragraph (c)(2) of
this section is required.
(4) Air carriers must initiate public
notification when restriction of public
access is initiated in accordance with
§ 141.803(d) and must continue until
the aircraft water system is returned to
unrestricted public access.
(d) Public notification for paragraphs
(a)(2), (a)(4), and (a)(6) of this section
must meet the requirements of
paragraph (b) of this section in addition
to the following:
(1) Public notification must include a
prominently displayed, clear statement
in each lavatory indicating 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;
and
(2) A prominent notice in the galley
directed at the crew which includes:
(i) 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;
(ii) A clear statement that it is not
known whether the water is
contaminated because there was a
failure to perform required routine
disinfection and flushing; or a failure to
perform required monitoring; or water
was boarded from a watering point not
in accordance with FDA regulations, or
that does not meet NPDWRs applicable
to transient noncommunity water
systems, or that is otherwise determined
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53623
to be unsafe due to noncompliance with
the procedures specified in
§141.804(b)(6);
(iii) When and where the unsafe water
was boarded or when the specific
monitoring or disinfection and flushing
requirement was not met;
(iv) Any potential adverse health
effects from exposure to waterborne
pathogens that might be in the water, as
appropriate, under paragraph (g) of this
section;
(v) The population at risk, including
sensitive subpopulations particularly
vulnerable if exposed to the
contaminant in the drinking water; and
(vi) A statement indicating when the
system will be disinfected and flushed
and returned to unrestricted public
access.
(3) If passenger access to the water
system is physically prevented through
disconnecting or shutting off the water,
or the flow of water prevented through
the tap(s), or if water is supplied only
to lavatory toilets, and not to any
lavatory or galley taps, then only the
notice specified in paragraph (d)(2) of
this section is required.
(4) Air carriers must initiate public
notification when restriction of public
access is initiated in accordance with
§ 141.803(d) and must continue until
the aircraft water system is returned to
unrestricted public access.
(e) Public notification for paragraphs
(a)(3) and (a)(5) of this section must
meet the requirements of paragraph (b)
of this section in addition to the
following:
(1) Public notification must include a
prominently displayed, clear statement
in each lavatory indicating 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;
and
(2) A prominent notice in the galley
directed at the crew which includes:
(i) 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;
(ii) A clear statement that the water is
contaminated and there was a failure to
conduct required monitoring; or a clear
statement that water is contaminated
because water was boarded from a
watering point not in accordance with
FDA regulations, or that does not meet
NPDWRs applicable to transient
noncommunity water systems, or that is
otherwise determined to be unsafe due
to noncompliance with the procedures
specified in § 141.804(b)(6);
(iii) A description of the
contaminant(s) of concern;
(iv) When and where the unsafe water
was boarded or when the specific
monitoring requirement was not met;
(v) Any potential adverse health
effects from the situation, as
appropriate, under paragraph (g) of this
section;
(vi) The population at risk, including
sensitive subpopulations particularly
vulnerable if exposed to the
contaminant in the drinking water;
(vii) A statement indicating what the
air carrier is doing to correct the
situation; and
(viii) When the air carrier expects to
return the system to unrestricted public
access.
(3) If passenger access to the water
system is physically prevented through
disconnecting or shutting off the water,
or the flow of water prevented through
the tap(s), or if water is supplied only
to lavatory toilets, and not to any
lavatory or galley taps, then only the
notice specified in paragraph (e)(2) of
this section is required.
(4) Air carriers must initiate public
notification when restriction of public
access is initiated in accordance with
§ 141.803(d) and must continue public
notification until a complete set of
required follow-up samples are total
coliform-negative.
(f) Public notification for paragraph
(a)(7) of this section must meet the
requirements of paragraph (b) of this
section in addition to the following:
(l) Notification must be in a form and
manner reasonably calculated to reach
all passengers and crew while on board
the aircraft by using one or more of the
following forms of delivery:
(i) Broadcast over public
announcement system on aircraft;
(ii) Posting of the notice in
conspicuous locations throughout the
area served by the water system. These
locations would normally be the galleys
and in the lavatories of each aircraft
requiring posting;
(iii) Hand delivery of the notice to
passengers and crew;
(iv) Another delivery method
approved in writing by the
Administrator.
(2) Air carriers must initiate public
notification within 24 hours of being
informed by EPA to perform notification
and must continue notification for the
duration determined by EPA.
(g) In each public notice to the crew,
air carriers must use the following
standard health effects language that
corresponds to the situations in
paragraphs (a)(l) through (a)(6) of this
section.
(1) Health effects language to be used
when public notice is initiated due to
the detection of total coliforms only (not
E. coli) in accordance with paragraph
(a)(l) of this section:
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
found in [INSERT NUMBER OF SAMPLES
DETECTED] 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.
(2) Health effects language to be used
when public notice is initiated due to
any E. co7i-positive routine, repeat, or
follow-up sample in accordance with
paragraph (a)(l) of this section:
E. 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.
(3) Health effects language to be used
when public notice is initiated due to a
failure to conduct routine monitoring or
routine disinfection and flushing in
accordance with paragraph (a)(2) of this
section; or when there is a failure to
conduct repeat or follow-up sampling in
accordance with paragraph (a)(4) of this
section; or in accordance with
paragraph (a)(6) of this section, when
the air carrier becomes aware of a non-
E. co7.z'-positive event that is the result of
water that was boarded from a watering
point not in accordance with FDA
regulations (21 CFRpart 1240, subpart
E), or that does not meet NPDWRs
applicable to transient non-community
water systems, or that is otherwise
determined to be unsafe due to non-
compliance with the procedures
specified in § 141.804(b)(6):
Because [REQUIRED MONITORING AND
ANALYSIS WAS NOT CONDUCTED],
[REQUIRED DISINFECTION AND
FLUSHING WAS NOT CONDUCTED]
[WATER WAS BOARDED FROM A
WATERING POINT NOT IN ACCORDANCE
WITH FDA REGULATIONS (21 CR 1240
SUBPART E)], 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.
(4) Health effects language to be used
when public notice is initiated due to a
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53624
Federal Register/Vol. 74, No. 200/Monday, October 19, 2009/Rules and Regulations
failure to conduct required follow-up
monitoring in response to a sample
result that is E. co7i-positive in
accordance with paragraph (a)(3) of this
section; or in accordance with
paragraph (a)(5) of this section, when
the air carrier becomes aware of an E.
co7.z'-positive event that is the result of
water that was boarded from a watering
point not in accordance with FDA
regulations (21 CFRpart 1240, subpart
E), or that does not meet NPDWRs
applicable to transient non-community
water systems, or that is otherwise
determined to be unsafe due to non-
compliance with the procedures
specified in § 141.804(b)(6):
Because required follow-up monitoring
and analysis was not conducted after the
aircraft water system tested positive for E.
coli, we cannot be sure of the quality of the
drinking water at this time. E. 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.
OR
Water was boarded that is contaminated
withE. coli because [WATER WAS
BOARDED FROM A WATERING POINT
NOT IN ACCORDANCE WITH FDA
REGULATIONS (21 CR 1240 SUBPART E)],
or [OTHER APPROPRIATE EXPLANATION].
E. 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.
§141.806 Reporting requirements.
(a) The air carrier must comply with
the following requirements regarding
reporting of the development of the
coliform sampling plan, the operations
and maintenance plan, and the
disinfection and flushing and coliform
sampling frequencies.
(1) The air carrier must report to the
Administrator that it has developed the
coliform sampling plan required by
§ 141.802, which covers each existing
aircraft water system, as well as report
the frequency for routine coliform
sampling identified in the coliform
sampling plan by April 19, 2011. The air
carrier must report to the Administrator
that it has developed its operations and
maintenance plan required by § 141.804
and report the frequency for routine
disinfection and flushing by April 19,
2011;
(2) For each new aircraft meeting the
definition of an aircraft water system,
which becomes operational after
publication of this subpart, the air
carrier must report to the Administrator
that it has developed the coliform
sampling plan required by § 141.802, as
well as report the frequency for routine
coliform sampling identified in the
coliform sampling plan, within the first
calendar quarter of initial operation of
the aircraft. The air carrier must report
to the Administrator that it has
developed the aircraft water system
operations and maintenance plan
required by § 141.804, and report the
frequency for routine disinfection and
flushing within the first calendar
quarter of initial operation of the
aircraft.
(b) The air carrier must report the
following information to the
Administrator:
(1) A complete inventory of aircraft
that are public water systems by April
19, 2011. Inventory information
includes, at a minimum, the following:
(i) The unique aircraft identifier
number;
(ii) The status (active or inactive) of
any aircraft as an aircraft water system
as defined in § 141.801;
(iii) The type and location of any
supplemental treatment equipment
installed on the water system; and
(iv) Whether the aircraft water system
can be physically disconnected or shut-
off, or the flow of water prevented
through the tap(s).
(2) Changes in aircraft inventory no
later than 10 days following the
calendar month in which the change
occurred. Changes in inventory
information include, at a minimum, the
following:
(i) Change in the unique identifier
number for any new aircraft, or any
aircraft removed from the carrier's fleet;
(ii) Change in status (active or
inactive) of any aircraft as an aircraft
water system as defined in § 141.801;
and
(iii) Change to the type and location
of any supplemental treatment
equipment added to or removed from
the water system.
(iv) Change to whether the aircraft
water system can be physically
disconnected or shut-off, or the flow of
water prevented through the tap(s).
(3) All sampling results no later than
10 calendar days following the
monitoring period in which the
sampling occurred. The monitoring
period is based on the monitoring
frequency identified in the coliform
sampling plan required under § 141.802.
Routine disinfection and flushing events
must be reported no later than 10
calendar days following the disinfection
and flushing period in which the
disinfection and flushing occurred. The
disinfection and flushing period is
based on the frequency identified in the
operations and maintenance plan
required under § 141.804.
(4) All events requiring notification to
passengers or crew, or non-routine
disinfection and flushing, or non-
routine sampling, within 10 days of the
event (e.g., notification of positive
sample result by laboratory), including
information on whether required
notification was provided to passengers
or crew or both.
(5) Failure to comply with the
monitoring or disinfection and flushing
requirements of this subpart within 10
calendar days of discovery of the failure.
(6) Changes in disinfection and
flushing and coliform sampling
frequencies no later than 10 days
following the calendar month in which
the change occurred. Changes to an
aircraft's routine coliform sampling
frequency and routine disinfection and
flushing frequency must be included in
the aircraft water system operation and
maintenance plan that is included in the
air carrier operations and maintenance
program accepted by FAA in accordance
with §141.804.
(c) The air carrier must provide
evidence of a self-inspection to the
Administrator within 90 days of
completion of the self-inspection
required under § 141.808(b), including
reporting whether all deficiencies were
addressed in accordance with
§ 141.808(c). The air carrier must also
report to the Administrator within 90
days that any deficiency identified
during a compliance audit conducted in
accordance with § 141.808(a) has been
addressed. 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.
(d) All information required to be
reported to the Administrator under this
subpart must be in an electronic format
established or approved by the
Administrator. If an air carrier is unable
to report electronically, the air carrier
may use an alternative approach that the
Administrator approves.
§141.807 Recordkeeping requirements.
(a) The air carrier must keep records
of bacteriological analyses for at least 5
years and must include the following
information:
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Federal Register/Vol. 74, No. 200/Monday, October 19, 2009/Rules and Regulations
53625
(1) The date, time, and place of
sampling, and the name of the person
who collected the sample;
(2) Identification of the sample as a
routine, repeat, follow-up, or other
special purpose sample;
(3) Date of the analysis;
(4) Laboratory and person responsible
for performing the analysis;
(5) The analytical technique/method
used; and
(6) The results of the analysis.
(b) The air carrier must keep records
of any disinfection and flushing for at
least 5 years and must include the
following information:
(1) The date and time of the
disinfection and flushing; and
(2) The type of disinfection and
flushing (i.e., routine or corrective
action).
(c) The air carrier must keep records
of a self-inspection for at least 10 years
and must include the following
information:
(1) The completion date of the self-
inspection; and
(2) Copies of any written reports,
summaries, or communications related
to the self-inspection.
(d) The air carrier must maintain
sampling plans and make such plans
available for review? by the
Administrator upon request, including
during compliance audits.
(e) The air carrier must maintain
aircraft water system operations and
maintenance plans in accordance with
FAA requirements, and make such
plans available for review by the
Administrator upon request, including
during compliance audits.
(f) The air carrier must keep copies of
public notices to passengers and crew
issued as required by this subpart for at
least 3 years after issuance.
§ 141.808 Audits and inspections.
(a) The Administrator may conduct
routine compliance audits as deemed
necessary in providing regulatory
oversight to ensure proper
implementation of the requirements in
this subpart. Compliance audits may
include, but are not limited to:
(1) Bacteriological sampling of aircraft
water system;
(2) Reviews and audits of records as
they pertain to water system operations
and maintenance such as log entries,
disinfection and flushing procedures,
and sampling results; and
(3) Observation of procedures
involving the handling of finished
water, watering point selection,
boarding of water, operation,
disinfection and flushing, and general
maintenance and self-inspections of
aircraft water system.
(b) Air carriers or their representatives
must perform a self-inspection of all
water system components for each
aircraft water system no less frequently
than once every 5 years.
(c) The air carrier must address any
deficiency identified during compliance
audits or routine 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. This includes any
deficiency in the water system's design,
construction, operation, maintenance, or
administration, as well as any failure or
malfunction of any system component
that has the potential to cause an
unacceptable risk to health or that could
affect the reliable delivery of safe
drinking water.
§141.809 Supplemental treatment.
(a) Any supplemental drinking water
treatment units installed onboard
existing or new aircraft must be
acceptable to FAA and FDA; and must
be installed, operated, and maintained
in accordance with the manufacturer's
plans and specifications and FAA
requirements.
(b) Water supplemental treatment and
production equipment must produce
water that meets the standards
prescribed in this part.
§141.810 Violations.
An air carrier is in violation of this
subpart when, for any aircraft water
system it owns or operates, any of the
following occur:
(a) It fails to perform any of the
requirements in accordance with
§141.803 or §141.804.
(b) It has an E. co7i-positive sample in
any monitoring period (routine and
repeat samples are used in this
determination).
(c) It fails to provide notification to
passengers and crew in accordance with
§141.805.
(d) It fails to comply with the
reporting and recordkeeping
requirements of this subpart.
(e) It fails to conduct a self-inspection
or address a deficiency in accordance
with §141.808.
(f) It fails to develop a coliform
sampling plan in accordance with
§ 141.802, or fails to have and follow an
operations and maintenance plan,
which is included in a FAA accepted
program in accordance with § 141.804.
[FR Doc. E9-24552 Filed 10-16-09; 8:45 am]
BILLING CODE 6560-50-P
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Appendix B
ADWR Quick Reference Guide
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United States
Environmental Protection
Agency
<
Aircraft Drinking Water Rule:
A Quick Reference Guide
^^^^^^H
Title
Purpose
General
Description
Aircraft
Covered by
the ADWR
Components
of an Aircraft
Water
System
Aircraft Drinking Water Rule (ADWR) 74 FR 53590. October 19, 2009
To ensure that safe and reliable drinking water is provided to aircraft passengers and crew by
amending and consolidating National Primary Drinking Water Regulations for aircraft public
water systems (PWSs).
To protect against disease-causing microbiological contaminants through the required
development and implementation of aircraft water system operations and maintenance plans.
The plans include routine disinfection and flushing of the water system, air carrier training
requirements for key personnel, and periodic sampling of the onboard drinking water, as well
as self-inspections of each aircraft water system and immediate notification of passengers and
crew when violations or specific situations occur.
The ADWR applies only to aircraft with onboard water systems that provide water for
human consumption through pipes and regularly serve an average of at least twenty-five
individuals daily, at least 60 days out of the year, and that board only finished water for human
consumption. Human consumption includes water for drinking, hand washing, food preparation,
and oral hygiene.
Aircraft water systems include the water service panel, the filler neck of the aircraft finished
water storage tank, and all finished water storage tanks, piping, treatment equipment, and
plumbing fixtures within the aircraft that supply water to passengers or crew.
Major Provisions
Operations and Maintenance (O&M Plan)
Air carriers develop and implement an O&M plan for each aircraft water system in active service. More than
one aircraft can be covered by the same O&M plan. The water system O&M plan must be included in a Federal
Aviation Administration-accepted aircraft operations and maintenance program. If a new aircraft or PWS is
added to an air carrier fleet, the aircraft is added to an existing O&M plan or a new O&M plan is developed. The
O&M plan for the new aircraft is implemented by the end of the first calendar quarter during which the aircraft is
placed into service.
Each aircraft
water system
O&M plan
includes:
Coliform
^- Watering point selection requirement - all water sources must be from a watering point
selected in accordance with Food and Drug Administration regulations [21 CFR part
1240subpart E].
^ Procedures for routinely disinfecting and flushing the aircraft water system in accordance
with the manufacturer's recommendations.
^- Procedures for follow-up coliform sampling after a corrective disinfection and flushing
event.
^- Training requirements for all staff involved with the O&M provisions of the rule and those
managing or conducting the coliform sampling requirements of the rule.
^ Self-inspection procedures, procedures for boarding water, and the coliform sampling
plan.
^ A statement of whether the aircraft water system can be physically disconnected or shut
off so that the flow of water through the tap(s) is prevented.
Sampling Plan
Air carriers develop a coliform sampling plan covering each aircraft owned or operated by the carrier. Sampling
plans are developed for each new aircraft by the end of the calendar quarter in which the aircraft is placed in
service.
At a minimum, all
plans include the
following:
^ Coliform sample collection procedures.
^ Sample tap location(s) representative of the aircraft water system, including both galley
and lavatory taps.
^- Frequency and number of routine coliform samples to be collected.
^- Frequency of routine disinfection and flushing as specified in the operations and
maintenance plan.
^ Procedures for communicating sample results to ensure any required actions including
repeat and follow-up sampling, corrective action, and notification of passengers and crew
are conducted in a timely manner.
Routine Disinfection and Flushing
Air carriers routinely disinfect and flush aircraft PWSs at the frequency recommended by the water system
manufacturer or, if not specified by the manufacturer, may choose from one of four options.
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*
For additional information
on the ADWR
Call the Safe Drinking
Water Hotline at 1-800-
426-4791; visit the EPA
web site at www.epa.gov/
drink; or contact your EPA
Regional Office.
Coliform Sampling Requirements
All aircraft PWSs sample for total coliform bacteria according to the frequency and procedures described in
the coliform sampling plan. The routine sampling frequency is based on the routine disinfection and flushing
frequency—the more often an aircraft PWS disinfects, the less often it is required to monitor for coliform.
Routine coliform samples may be collected immediately prior to but not within 72 hours after a routine
disinfection and flushing event.
Each routine, repeat, or follow-up sample that is positive for total coliform is tested for the presence of £. coli. If
any sample is positive for £. coli, public notification and corrective disinfection and flushing are triggered.
Air carriers select from specified options for follow-up and corrective measures when routine coliform samples
indicate total coliform but £. coli contamination is not present. The options include collecting 3 repeat samples
within 24 hours or disinfecting and flushing the system with follow-up sampling.
> The disinfection and flushing procedure must be completed within 72 hours unless public access is
restricted.
^ If any repeat sample is positive for coliform, public notification and corrective disinfection and flushing
with follow-up sampling are triggered.
Corrective Disinfection and Flushing
If corrective disinfection and flushing is opted or required, air carriers follow the procedures in their O&M plans.
Unscheduled flight disruptions to perform corrective disinfection and flushing can be minimized by shutting
off the water or preventing the flow of water to the taps. Before allowing unrestricted access to the aircraft
water system, a complete set of two follow-up samples must be collected and submitted for analysis after the
disinfection and flushing event if triggered by a total coliform-positive sample, and must be reported as total
coliform-negative if triggered by an £. co//-positive sample.
Self-Inspection
Each aircraft PWS must be inspected by the air carrier at least every 5 years according to the procedures in their
O&M plans. At a minimum, the self-inspection procedures for an aircraft water system must include inspection
of the storage tank, distribution system, supplemental treatment, fixtures, valves, and backflow prevention
devices. Any deficiencies detected must be addressed, and any deficiency that is unresolved within 90 days of
identification of the deficiency must be reported to EPA.
Public Notification
Notification of passengers and crew onboard the aircraft is required when:
^ Any sample results are total coliform-positive or £. co//-positive.
^ An air carrier fails to perform required routine disinfection and flushing.
^ An air carrier fails to collect required samples.
^ An air carrier boards water from a watering point that does not meet FDA regulations, EPA standards,
or is otherwise determined to be unsafe.
^ EPA, the air carrier, or crew determines public notification is necessary to protect public health.
For £. co//-positive events or when EPA, the air carrier, or crew determines public notification is necessary, notice
must be issued within 24 hours. For all other situations, notice must be issued within 72 hours.
^ Notice to passengers need not be provided if the water is shut off, if flow of water to taps is prevented,
or if water is supplied only to the lavatory toilets and not the lavatory or galley taps.
Reporting and Recordkeeping Requirements
Air carriers submit compliance information to EPA including sampling results; all events requiring public
notification and corrective disinfection and flushing; notification of failure to comply with monitoring or disinfection
and flushing requirements; and evidence of self-inspection, along with a report of unresolved deficiencies. Most
reporting will be done electronically to the ADWR Reporting and Compliance System, a database developed and
supported by EPA.
Records of coliform sampling, disinfection and flushing, self-inspections, and public notices are kept by the air
carrier. Sampling plans and O&M plans are maintained and made available for EPA review.
Key Dates
Within 18
months of the
final rule
April 19,2011
24 months after
the final rule
October 19, 2011
Develop a coliform sampling plan and report to EPA that it has been completed.
Develop O&M plans that cover every aircraft PWS and report to EPA that they have been
completed.
Report the coliform sampling and disinfection and flushing frequencies to EPA for each
aircraft.
Report the complete air carrier inventory of aircraft that are PWSs to EPA.
The compliance date for all other rule requirements applies, unless otherwise noted.
EPA-816-F-10-077
www.epa.gov/drink
October 2010
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Appendix C
Example Col if or m Sampling Plan
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[AIR CARRIER]
Coliform Sampling Plan for [AIRCRAFT MAKE/MODEL]
Prepared for
[AIR CARRIER] Personnel and Contractors
[REVISION # AND DATE OF SAMPLING PLAN]
In Compliance with United States Environmental Protection Agency
Aircraft Drinking Water Rule
40 CFR Part 141 - Subpart X
-------
1. Background & Purpose
The purpose of this Coliform Sampling Plan (CSP) is to describe the activities that will be performed
by [AIR CARPJER] personnel and contractors to collect drinking water samples from onboard
aircraft water systems. Specifically, this CSP outlines the objectives and methods that will be used to
comply with the Aircraft Drinking Water Rule (ADWR) and includes monitoring frequencies,
procedures, and analytical methods to be used by [AIR CARRIER] for drinking water sampling for
total coliform. In addition, it describes the lines of communication for reporting sample results. This
CSP has been prepared in accordance with ADWR requirements.
The purpose of monitoring the aircraft water systems for total coliform is to determine compliance
with the ADWR by ensuring the water meets water quality levels determined safe by Environmental
Protection Agency (EPA). The data collected must be of sufficient quality to clearly determine if the
water onboard the aircraft consistently meets the standards of the ADWR for total coliform and to
avoid false identification of regulatory standard exceedances.
Any [AIR CARRIER] employee or contractor will abide by the protocol set forth in this CSP for the
collection of drinking water samples from aircraft water systems.
2. Applicability
This CSP applies to [AIRCRAFT MAKE/MODEL] and covers the following aircraft: [AIRCRAFT
FAA AIRCRAFT REGISTRY ID NUMBER (a.k.a tail number or N-number)].
Inventory data on each aircraft identified in this CSP, including if the aircraft has a lavatory and/or
galley with a drinking water tap, the number of taps, lavatories, galleys and other information, has
been submitted to EPA in accordance with the ADWR requirements through the ADWR Reporting
and Compliance System.
All terms not defined in this CSP shall have their ordinary meaning, unless such terms are defined in
the ADWR, in which case the statute or regulatory definitions will apply.
3. Routine Monitoring Frequency
The manufacturer of the onboard water systems for [AIRCRAFT MAKE/MODEL] has recommended
that routine disinfection and flushing be conducted at a rate frequency of [once in a one-month period
(monthly), at least once within every three month period (quarterly), at least once within every four
month period, at least once within every six-month period (semi-annually), or at least once within
every 12-month period (annually) or less]. [AIR CARRIER] has chosen to follow the manufacturer's
recommendations (or [AIR CARRIER] has chosen to disinfectant and flush at a rate more frequent
than manufacturer's recommendations: [SPECIFY RATE FREQUENCY FROM ABOVE LIST]).
Consequently, routine total coliform samples will be collected at a rate of [at least once within every
twelve-month period (annually), at least once within every six-month period (semi-annually), at least
once within every three-month period (quarterly), or at least once every month (monthly)].
4. Analyses to be Performed
Sampling may occur at any time during normal airline operations or maintenance activities. However,
routine total coliform samples must not be collected within 72 hours after completing a routine
disinfection and flushing.
-------
All drinking water samples collected from the onboard aircraft water system shall be analyzed for
total coliform. In the event of a total coliform-positive result, the sample shall be analyzed for E.coli.
Each total coliform sample will be sent to be analyzed by a State- or EPA-certified laboratory for
analysis of the drinking water sample(s). In the event of a total coliform-positive sample result, the
sample will be analyzed for E. coll. The protocol for sample collection is described in Section 9 of
this CSP.
5. Aircraft Sampling Sites
In accordance with the ADWR, routine coliform samples will be collected from one galley and one
lavatory tap [change if only one tap available] for total coliform during each monitoring period from
each aircraft identified in this CSP.
The [AIRCRAFT MAKE/MODEL] contains [NUMBER] galley(s) and [NUMBER] lavatory(s) with
taps. The following diagram illustrates the location of the galleys and lavatories. The sample locations
will be rotated each monitoring period to ensure the entire aircraft water system is sampled
periodically. In addition, during each monitoring period, a sample will be collected from a galley and
a lavatory at opposite ends of the aircraft, whenever possible.
[PROVIDE DIAGRAM OF LOCATION OF AIRCRAFT LAVATORIES AND GALLEYS]
Both lavatory and galley samples should be collected from a cold water tap if possible. If the only
sampling point in the lavatory or galley is a hot water tap or the coffee maker, collect the sample at
that location and indicate the sampling location on the sample collection sheet. [Suggest adding: If a
sample is collected from a hot water tap, record the temperature of the water on the sample collection
sheet if available. Temperature maybe a useful diagnostic tool.]
6. Analytical Methods
Specific details regarding the compliance criteria and sample requirements are illustrated in Table 1.
All analytical methods for total coliform and E. coll to be used by the analytical laboratories shall be
those approved by the EPA for drinking water analysis as provided in 40 CFR 141.21(f)(3) and
141.21(f)(6). Current approved analytical methods are provided in Table 2.
Table 1: Sample Requirements
Analyte
Total Coliform, E.
coli
Compliance
Criteria
Presence-absence.
If present, test for
E. coli
Holding
Time
30 hours (not
to exceed)
Sample Volume
(Bottle)
100mL(150-mL
Sterile Plastic with non-
toxic cap)
Preservative1
Cool to 4°C 0.008%
Na2S2O3
1 Preservative to be added to empty bottle by laboratory prior to sample collection.
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Table 2. Approved Analytical Methods [40 CFR 141(f)(3) and 141.21(f)(6)]
Organism
Total Coliforms2
E. coli
Methodology12
Total Coliform Fermentation Technique3'4'5
Total Coliform Membrane Filter Technique
Presence-Absence (P-A) Coliform Test5'7
ONPG-MUG Test8
Colisure Test.9
E*Colite®Test.10
m-ColiBlue24®Test.n
Ready cult®Coliforms 100 Presence/Absence Test.13
Membrane Filter Technique using Chromocult®Coliform Agar.14
Colitag®Test.15
Total Coliform Membrane Filter Technique6
E*Colite®Test.10
m-ColiBlue24®Test.n
Ready cult®Coliforms 100 Presence/Absence Test.13
Membrane Filter Technique using Chromocult®Coliform Agar.14
Colitag®Test.15
Membrane Filtration, Two Step.16' 17
MMO-MUG.18
Colisure Test.19
Citation1
9221A, B.
9222A, B, C.
9221D.
9223.
9222A, B, C.
9222G
Standard Methods for the Examination of Water and Wastewater, 18th edition (1992), 19th edition (1995), or 20th edition (1998).
American Public Health Association, 1015 Fifteenth Street, NW., Washington, DC 20005. The cited methods published in any of these
three editions may be used. In addition, the following online versions may also be used: 9221 A, B, D—99, 9222 A, B, C—97, and 9223
B—97. Standard Methods Online are available at http://www.standardmethods.org. The year in which each method was approved by
the Standard Methods Committee is designated by the last two digits in the method number. The methods listed are the only Online
versions that may be used.
The time from sample collection to initiation of analysis may not exceed 30 hours. Systems are encouraged but not required to hold
samples below 10 deg. C during transit.
Lactose broth, as commercially available, may be used in lieu of lauryl tryptose broth, if the system conducts at least 25 parallel tests
between this medium and lauryl tryptose broth using the water normally tested, and this comparison demonstrates that the false-
positive rate and false-negative rate for total coliform, using lactose broth, is less than 10 percent.
If inverted tubes are used to detect gas production, the media should cover these tubes at least one-half to two-thirds after the sample is
added.
5No requirement exists to run the completed phase on 10 percent of all total coliform-positive confirmed tubes.
MI agar also may be used. Preparation and use of MI agar is set forth in the article, "New medium for the simultaneous detection of total
coliform and Escherichia coli in water" by Brenner, K.P., et. al, 1993, Appl. Environ. Microbiol. 59:3534-3544. Also available from
the Office of Water Resource Center (RC^IOOT), 1200 Pennsylvania Avenue, NW., Washington, DC 20460, EPA/600/J-99/225.
Verification of colonies is not required.
'Six-times formulation strength may be used if the medium is filter-sterilized rather than autoclaved.
The ONPG-MUG Test is also known as the Autoanalysis Collect System.
9A description of the Colisure Test, Feb 28, 1994, may be obtained from IDEXX Laboratories, Inc., One IDEXX Drive, Westbrook,
Maine 04092. The Colisure Test may be read after an incubation time of 24 hours.
A description of the E*Colite Test, "Presence/Absence for Coliforms and£. Coli in Water," Dec 21, 1997, is available from Charm
Sciences, Inc., 36 Franklin Street, Maiden, MA 02148^1120.
UA description of the m-ColiBlue24®Test, Aug 17, 1999, is available from the Hach Company, 100 Dayton Avenue, Ames, IA 50010.
EPA strongly recommends that laboratories evaluate the false-positive and negative rates for the method(s) they use for monitoring
total coliforms. EPA also encourages laboratories to establish false-positive and false-negative rates within their own laboratory and
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sample matrix (drinking water or source water) with the intent that if the method they choose has an unacceptable false-positive or
negative rate, another method can be used. The Agency suggests that laboratories perform these studies on a minimum of 5% of all
total coliform-positive samples, except for those methods where verification/confirmation is already required, e.g., the M-Endo and
LES Endo Membrane Filter Tests, Standard Total Coliform Fermentation Technique, and Presence-Absence Coliform Test. Methods
for establishing false-positive and negative-rates may be based on lactose fermentation, the rapid test for fi-galactosidase and
cytochrome oxidase, multi-test identification systems, or equivalent confirmation tests. False-positive and false-negative information is
often available in published studies and/or from the manufacturer(s).
13The Readycult®Coliforms 100 Presence/Absence Test is described in the document, "Readycult®Coliforms 100 Presence/Absence Test
for Detection and Identification of Coliform Bacteria and Escherichla coli in Finished Waters", November 2000, Version 1.0, available
from EM Science (an affiliate of Merck KGgA, Darmstadt Germany), 480 S. Democrat Road, Gibbstown, NJ 08027-1297. Telephone
number is (800) 222-0342, e-mail address is: adellenbusch@emscience.com.
Membrane Filter Technique using Chromocult Coliform Agar is described in the document, "Chromocult Coliform Agar
Presence/Absence Membrane Filter Test Method for Detection and Identification of Coliform Bacteria and Escherichla coli in
Finished Waters", November 2000, Version 1.0, available from EM Science (an affiliate of Merck KGgA, Darmstadt Germany), 480
S. Democrat Road, Gibbstown, NJ 08027-1297. Telephone number is (800) 222-0342, e-mail address is:
adellenbusch@emscience. com.
15Colitag®product for the determination of the presence/absence of total coliforms and.E. coli is described in "Colitag®Product as a Test
for Detection and Identification of Coliforms and E. coli Bacteria in Drinking Water and Source Water as Required in National
Primary Drinking Water Regulations," August 2001, available from CPI International, Inc., 5580 Skylane Blvd., Santa Rosa, CA,
95403, telephone (800) 878-7654, Fax (707) 545-7901, Internet address http://www.cpiintemational.com.
16EC medium supplemented with 50 (ig/mL of 4-methylumbelliferyl-beta-D-glucuronide (MUG) (final concentration). The 18th edition
(1992) may be used if at least 10 mL of EC medium is supplemented with 50 )ig/mL of MUG before autoclaving. The inner inverted
fermentation tube may be omitted. If the 18th edition is used, apply the procedure in paragraph 40 CFR 141.21(f)(5) for transferring a
total coliform-positive culture to EC medium supplemented with MUG, incubate the tube at 44.5 ±0.2 °C for 24 ±2 hours, and then
observe fluorescence with an ultraviolet light (366 nm) in the dark. If fluorescence is visible, E. coli are present.
Nutrient agar supplemented with 100 (ig/mL of 4-methylumbelliferyl-beta-D-glucuronide (MUG) (final concentration). The 18th
edition (1992) may be used if the membrane filter containing a total coliform-positive colony(ies) is transferred to nutrient agar, as
described in Method 9221B (paragraph 3) of Standard Methods (18th edition), supplemented with 100 ng/mL of MUG. If the 18th
edition is used, incubate the agar plate at 35 °C for 4 hours and then observe the colony(ies) under ultraviolet light (366 nm) in the dark
for fluorescence. If fluorescence is visible, E. coli are present.
18Minimal Medium ONPG-MUG (MMO-MUG) Test, as set forth in the article "National Field Evaluation of a Defined Substrate
Method for the Simultaneous Detection of Total Coliforms and Escherichia coli from Drinking Water: Comparison with Presence-
Absence Techniques" (Edberg et al.), Applied and Environmental Microbiology, Volume 55, pp. 1003-1008, April 1989. (Note: The
Autoanalysis Colilert System is an MMO-MUG test). If the MMO-MUG test is total coliform-positive after a 24-hour incubation, test
the medium for fluorescence with a 366-nm ultraviolet light (preferably with a 6-watt lamp) in the dark. If fluorescence is observed,
the sample is E. coli -positive. If fluorescence is questionable (cannot be definitively read) after 24 hours incubation, incubate the
culture for an additional four hours (but not to exceed 28 hours total), and again test the medium for fluorescence. The MMO-MUG
Test with hepes buffer in lieu of phosphate buffer is the only approved formulation for the detection ofE. coli.
19The Colisure Test. A description of the Colisure Test may be obtained from the Millipore Corporation, Technical Services Department,
80 Ashby Road, Bedford, MA 01730.
7. Materials Required
• Sample collection sheet
• Laboratory chain of custody form
• Indelible pen
• Sample bottles (150-mL sterile plastic with non-toxic cap and dechlorinating agent)
• Cooler with ice packs (optional) (contained-ice packs are preferable to ice cubes)
• Rubber, latex, or non-latex exam gloves
• Safety glasses
8. Safety and Sample Integrity
• Rubber/latex gloves shall be utilized when handling samples to minimize sample contamination
and exposure to sample preservatives.
• Safety glasses shall be worn when filling sample bottles.
• Bottles are to be kept closed until ready to be filled.
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9. Sampling Procedures
A. Pre-sampling Activities
Notify laboratory and place order for sample bottles, labels, and cooler(s) at least 48 hours prior to
sampling. (Note: You will need a separate cooler for each day/location of sample collection.)
B. Sampling Event Preparation
1. Notify ramp personnel to refrain from servicing aircraft water system until completion of
sampling.
2. Pre-label all bottles with the following information:
• Sample ID correlating to the sample tap site location [lav or gal] and location (e.g., aft,
or fore, #1 gal, #2 lav] and other information listed on the laboratory chain of custody
form and sample collection sheet
• Date and time of collection
• Analyses requested (e.g., total coliform)
• Sampler's initials
C. Total Coliform Sampling Procedures
The following steps are to be followed any time total coliform samples are collected from an
aircraft (e.g., routine, repeats, or follow-up samples). The term "tap" in this procedure means
water tap, faucet, drinking fountain, or other fixture which provides water for human
consumption to passengers or crew. Do not sample from leaking taps or taps which allow water to
run down the outside of the fixture.
1) Put on gloves.
2) Open tap and allow water to run for at least 30 seconds to flush tap.
3) Reduce water flow so the stream is not greater than % inch in diameter, or the width of a
pencil. Check for steady flow; do not change the water flow once the sample collection has
begun, as this could dislodge microbial growth.
4) Remove cap of total coliform sample bottle.
5) Be careful not to contaminate the bottle by touching the interior of the cap or the inside of the
sample container. Do not place cap on counter (which may be contaminated) or in your
pocket to prevent container contamination.
6) Place bottle under water stream allowing for an air gap between top of the bottle and the
water tap. Hold the bottle in one hand and the cap in the other. Fill the bottle to the 100 mL
fill line. If the bottle becomes overfilled, do not pour out the sample (this may lead to sample
contamination); instead send it to the laboratory as is.
7) Do not rinse the bottle either before or after sample collection.
8) Replace cap and tighten. Turn off water.
9) Ensure that sample ID matches that recorded on the sample collection sheet.
10) Place bottles into Ziploc® or similar bag. Place bag in cooler or other transport container
(packing the sample on ice (NOT dry ice) is recommended, but optional)
11) 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.
12) Sign and date the following statement on the sample collection sheet. If there was any
deviation from protocol, note this at the bottom of sample collection sheet.
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I certify that all samples were collected in accordance with the sample procedures provided in
the "Coliform Sampling Plan for [AIRCRAFT MAKE/MODEL]".
Signature
Date
13) Submit samples to:
[LABORATORY NAME, ADDRESS] (for those samples collected in [HUB NAME OR
AIRCRAFT LOCATION])
14) The lab shall receive samples within 24 hours of collection.
10. Procedures for Communicating Sample Results
The laboratory will report results in accordance with the Manual for Certification of Laboratories
Analyzing Drinking Water to: [NAME and ADDRESS]. The laboratory reports will include the date
and time of sample receipt, date and time of analysis, protocol used and analyst performing the test.
All sample collection sheets and associated chain of custodies should be forwarded to: [NAME and
ADDRESS]
[AIR CARRIER or NAME] will report all routine, repeat, and follow-up sample results that are total
coliform-negative to the ADWR Reporting and Compliance system within 10 calendar days
following the end of the monitoring period in which the samples were collected.
[AIR CARRIER or NAME] will report all routine, repeat, and follow-up sample results that are total
coliform- or E. coli-positive to the ADWR Reporting and Compliance system within 10 calendar days
of receiving the analytical results.
Table 3 summarizes the lines of communication for specific events related to coliform monitoring.
Table 3: Lines of Communication for Coliform Sampling Results
Event
Receiving sample results from
the Analytical Laboratory
Reporting routine, repeat, and
follow-up sample results to EPA
(including positive results)
Reporting total coliform or E.
co//-positive sample results to
[LIST APPROPRIATE
DEPARTMENT OR NAME]
Ensuring corrective actions are
implemented in accordance with
ADWR
Primary Contact
Name:
Phone Number:
E-Mail:
Name:
Phone Number:
E-Mail:
Name:
Phone Number:
E-Mail:
Name:
Phone Number:
E-Mail:
Back-up Contact
Name:
Phone Number:
E-Mail:
Name:
Phone Number:
E-Mail:
Name:
Phone Number:
E-Mail:
Name:
Phone Number:
E-Mail:
11. Attachments (list all separate documents)
1. Sample Collection Sheet
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Appendix D
Public Notification Templates
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This appendix contains example templates for notifying passengers and crew of violations or
situations that require public notification under the ADWR
The templates are as follows:
• Notice to the Passengers - Template 1. This template can be used for all ADWR
violations or situations requiring public notification to passengers. This notice is required
when passenger access to the water cannot be physically prevented through disconnecting
or shutting of the water, or preventing the flow of water through the taps. This notice
must be posted in the lavatory of the aircraft.
• E. co/i-Positive Notice to the Crew - Template 2. This template can be used for
notifying the crew when a routine, repeat, or follow-up sample tests positive for E. coli
bacteria. This is a prominent notice to the crew in the galley of the aircraft.
• Total Coliform-Positive Notice to the Crew - Template 3. This template can be used
for notifying the crew when a routine or repeat sample tests positive for total coliform
bacteria and public access to the aircraft water system has been restricted. This is a
prominent notice to the crew in the galley of the aircraft.
• Failure to Perform Routine Disinfection and Flushing Notice to the Crew -
Template 4. This template can be used for notifying the crew if the aircraft carrier fails
to perform routine disinfection and flushing of the aircraft water system. This is a
prominent notice to the crew in the galley of the aircraft.
• Failure to Perform Routine, Repeat, or Follow-up Monitoring Notice to the Crew -
Template 5. This template can be used for notifying the crew if the aircraft carrier fails
to collect routine, repeat, or follow-up samples. This is a prominent notice to the crew in
the galley of the aircraft.
• Boarding Water that Does Not Meet FDA Regulations or EPA Standards for
Transient Non-community Water Systems (Boarded Water Quality or Boarding
Procedures) Notice to the Crew - Template 6. This template can be used for notifying
the crew when the air carrier becomes aware of an event which has resulted from water
that has been boarded from a watering point that is not in accordance with FDA
regulations, does not meet EPA standards for transient non-community water systems, or
is otherwise determined unsafe because boarding procedures under the ADWR were not
followed. In this case, these events are referred to as "non-E1. co//'-positive" events
because E. coli is either not detected or not applicable to the event. This is a prominent
notice to the crew in the galley of the aircraft.
• Failure to Perform Follow-up Monitoring After an E. co/i-Positive Sample Result
Notice to the Crew - Template 7. This template can be used for notifying the crew if
the aircraft carrier fails to collect follow-up samples after a routine or repeat sample result
is E. coli -positive. This is a prominent notice to the crew in the galley of the aircraft.
• Boarding Water that Does Not Meet FDA Regulations or EPA Standards for
Transient Non-community Water Systems (E. co/i-positive event) Notice to the Crew
- Template 8. This template can be used for notifying the crew when the air carrier
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becomes aware of an E. co//'-positive event which has resulted from water that has been
boarded from a watering point that is not in accordance with FDA regulations, does not
meet EPA standards for transient non-community water systems, or is otherwise
determined unsafe because boarding procedures under the ADWR were not followed. In
this case, these events are referred to as "E1. co//'-positive" events because E. coli has been
detected or was otherwise introduced in the water boarded on the aircraft. This is a
prominent notice to the crew in the galley of the aircraft.
• Notification to Protect Public Health as Determined by EPA, the Carrier, or the
Crew - Template 9. This template can be used when EPA, the carrier, or the crew
determines it is necessary to issue notice to protect public health. This template is a
generic template that should be modified to reflect the specific situation that is not
covered by the prescribed templates (Templates 2 through 8). This template is intended
for both the crew and passengers and should be posted in conspicuous locations (e.g., the
galley and lavatories). With regard to the crew, prior to issuing a notice, the crew should
first go through the proper chain of command/authority to determine whether a notice
should be issued and, if so, the type of notice that should be provided.
Mandatory language, which must be included as written (with blanks filled in), is presented in
italics in each template. For more information on the requirements for public notification under
the ADWR including a list of violations or situations requiring public notification and the
required timeframe, format and content of the notices, refer to Chapter 6 of this manual.
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Notice to the Passengers - Template 1
WARNING
DO NOT DRINK THE WATER
The water is non-potable. Do not use it for human consumption,
which includes drinking, food or beverage preparation, hand
washing, or teeth brushing.
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E. co//-Positive Notice to the Crew - Template 2
DRINKING WATER WARNING
DO NOT DRINK THE WATER
E. co// Bacteria were Found in the Water Supply on [give date]
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
One of our [routine/repeat/follow-up] coliform samples tested positive for E. coll.
Possible Health Effects
E. coll 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.
People at increased risk should be particularly careful to avoid this water.
Steps We Are Taking
[Describe corrective action (e.g., We have disconnected the aircraft water system. We
will disinfect and flush the water system as soon as possible and conduct follow-up
sampling to ensure the water no longer contains E. coll bacteria.)]
We will inform you when additional samples show no E. coll bacteria and you may drink
the water. We anticipate resolving the problem within [estimated time frame].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Total Coliform-Positive Notice to the Crew - Template 3
DRINKING WATER WARNING
Tests Show Presence of Coliform Bacteria in Water
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
We are required to sample for coliform bacteria on our aircraft [list frequency (i.e.,
monthly, quarterly, semi-annually, annually)]. On [give date], we received notice that the
sample collected on [give date] showed the presence of total coliform bacteria in our
water.
What This Means
This is not an emergency. Total coliform bacteria themselves are generally not harmful.
Coliform are bacteria that are naturally present in the environment and are used as an
indicator that other, potentially harmful, bacteria may be present. Conforms were found
in [INSERT NUMBER OF SAMPLES DETECTED] 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.
People at increased risk should be particularly careful to avoid this water.
Steps We Are Taking
[Describe corrective action (e.g., We will disinfect and flush the water system as soon
as possible and conduct follow-up sampling to ensure the water no longer contains
coliform bacteria.)]
We will inform you when additional samples show no coliform bacteria. We anticipate
resolving the problem within [estimated time frame].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Failure to Perform Routine Disinfection and Flushing Notice to the Crew -
Template 4
DRINKING WATER WARNING
Routine Disinfection and Flushing was Not Performed
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
We are required to routinely disinfect and flush our water system. On [give date], we
failed to perform routine disinfection and flushing and, therefore, it is not known whether
the water is contaminated.
What This Means
Because required disinfection and flushing was not conducted, 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.
People at increased risk should be particularly careful to avoid this water.
Steps We Are Taking
We will disinfect and flush the water system on [give date]. We anticipate having the
water system back in service on [estimated date].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Failure to Perform Routine, Repeat, or Follow-up Monitoring Notice to the
Crew-Template 5
DRINKING WATER WARNING
[(Routine/Repeat/Follow-up)] Coliform Sampling was Not
Conducted
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
We were required to collect [(routine) OR (repeat) OR (follow-up)] coliform samples. On
[give date], we failed to perform the required monitoring and, therefore, it is not known
whether the water is contaminated.
What This Means
Because required monitoring and analysis was not conducted, 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.
People at increased risk should be particularly careful to avoid this water.
Steps We Are Taking
We will disinfect and flush the water system on [give date]. We anticipate having the
water system back in service on [estimated date].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Boarding Water that Does Not Meet FDA Regulations or EPA Standards for
Transient Non-community Water Systems (Boarded Water Quality or Boarding
Procedures) Notice to the Crew - Template 6
DRINKING WATER WARNING
Water was Boarded from a Watering Point that Does Not Meet
Requirements
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
We are required to board water on the aircraft that meets FDA regulations and EPA
standards and follows the boarding procedures prescribed in the Aircraft Drinking Water
Rule (ADWR). On [give date], water was boarded from [provide watering point location]
which was not in accordance with FDA regulations, or did not meet EPA standards for
transient non-community water systems, or was otherwise determined to be unsafe due
to noncompliance with the procedures for boarding water under the ADWR and,
therefore, it is not known whether the water is contaminated.
What This Means
Because [(water was boarded from a watering point not in accordance with FDA
Regulations (21 CFR part 1240, subpart E) 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.
People at increased risk should be particularly careful to avoid this water.
Steps We Are Taking
We will disinfect and flush the water system on [give date]. We anticipate having the
water system back in service on [estimated date].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Failure to Perform Follow-up Monitoring After an f. co//-Positive Sample Result
Notice to the Crew - Template 7
DRINKING WATER WARNING
DO NOT DRINK THE WATER
Follow-up Sampling was Not Conducted After E. coli Bacteria
were Found in the Water Supply
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
We were required to collect follow-up samples after being notified that our water tested
positive for E. coli. On [give date], we failed to perform the required monitoring.
What This Means
Because required follow-up monitoring and analysis was not conducted after the aircraft
water system tested positive for E. coli, we cannot be sure of the quality of the drinking
water at this time. E. 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.
People at increased risk should be particularly careful to avoid this water.
Steps We Are Taking
We will disinfect and flush the water system and collect follow-up samples on [give
date]. We anticipate having the water system back in service on [estimated date].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Boarding Water that Does Not Meet FDA Regulations or EPA Standards for
Transient Non-community Water Systems (E. co//-Positive event) Notice to the
Crew-Template 8
DRINKING WATER WARNING
DO NOT DRINK THE WATER
E. coli Bacteria were Found in the Water Supply Because Water
was Boarded from a Watering Point that Did Not Meet
Requirements
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
We are required to board water on the aircraft that meets FDA regulations and EPA
standards and follows the boarding procedures prescribed in the Aircraft Drinking Water
Rule (ADWR). On [give date], water was boarded from [provide watering point location]
which was not in accordance with FDA regulations, or did not meet EPA standards for
transient non-community water systems, or was otherwise determined to be unsafe due
to noncompliance with the procedures for boarding water under the ADWR. As a result,
E. coli bacteria were found in the water supply.
What This Means
Water was boarded that is contaminated with E. coli because [(water was boarded from
a watering point not in accordance with FDA Regulations (21 CFR part 1240, subpart E)
OR (other appropriate explanation)]. E. 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.
People at increased risk should be particularly careful to avoid this water.
Steps We Are Taking
We will disinfect and flush the water system on [give date]. We anticipate having the
water system back in service on [estimated date].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Notification to Protect Public Health as Determined by EPA, the Carrier, or the Crew
- Template 9
DRINKING WATER WARNING
DO NOT DRINK THE WATER
The water is non-potable. Do not use it for drinking, food or beverage preparation, hand
washing, teeth brushing, or any other consumptive use.
[Insert text to describe the situation triggering the notice].
What This Means
The unsafe situation observed by the crew could lead to contamination of this aircraft's
drinking water. Short term health effects caused by drinking water contamination can
pose increased risk for sensitive populations.
People with severely compromised immune systems, people with an infant, people with
young children, pregnant women, and some elderly should be particularly careful to
avoid this water.
Steps We Are Taking
[Describe corrective action].
This notice is provided by [Aircraft Carrier]. Date distributed: .
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Appendix E
Example Water Safety Plan for an Air Carrier
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Example Water Safety Plan for an Air Carrier
(Revision Date: [list date])
Section 1. Goals and Objectives
Instructions. State the air carrier's goals and objectives for developing and implementing a
water safety plan for aircraft water systems.
Example. This water safety plan (WSP) summarizes Airline XYZ's comprehensive and
systematic risk management approach for assuring the safely of drinking water onboard
[Make/Model] aircraft. Although the water safely plan is not required by regulation, Airline
XYZ believes the water safety plan is a necessary component of a proactive risk management
approach to ensure safe drinking water is obtained, boarded, and maintained for use by aircraft
passengers and crew.
Section 2. Jurisdictional Requirements
Instructions. List all federal, state, and local regulations, standards and guidelines that are
pertinent to the aircraft water transfer and supply chain.
Example. See Table 2.1 below.
Table 2.1. Summary of Aircraft Water System Jurisdictional Requirements for Airline
XYZ
Title
Reference
Regulations
Aircraft Drinking Water Rule
Food and Drug Administration,
Control of Communicable Diseases,
FDA certification of aircraft
sanitation systems including potable
water, sewage, and galleys.
Food and Drug Administration,
Interstate Conveyance Sanitation,
approval and certification of watering
points
http://water.epa.gov/lawsregs/rulesregs/sdwa/airlinewate
r/regs.cfm
21 CFR 1240.
http://www.accessdata.fda.sov/scripts/cdrh/cfdocs/cfcfir/
CFRSearch.cfm?fr=1240.83
21 CFR 1250. US Food and Drug Administration. 2005.
Code of Federal Regulations Subchapter L Part 1250
Interstate Conveyance Sanitation [Online] Available:
http://www.accessdata.fda.sov/scripts/cdrh/cfdocs/cfcfir/
CFRSearch.cfm?CFRPart=1250
Standards
FAA Airworthiness Standards
http://edocket.access.spo.sov/cfr 2003/14cfr43.9.htm
Guidelines
Guidance Manual for the ADWR
WHO Guide to Hygiene and
Sanitation in Aviation, Third edition
USEPA2010
www.water.epa.sov/lawsress/rulesress/sdwa/airlinewater
http://www.who.int/water sanitation health/hvsiene/ship
s/suide hvsiene sanitation aviation 3 edition.pdf
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(2009)
FDA Guide to Inspection of
Interstate Carriers and Support
Facilities
NSF/ANSI1 Standard 60 - Drinking
Water Treatment Chemicals -
Health Effects
NSF/ANSI Standard 61 Drinking
Water System Components - Health
Effects
http://www.fda.sov/ICECI/Inspections/InspectionGuides/
ucm074964.htm
http://www.nsf.ors/business/water distribution/index. asp
? program=WaterDi stributi on Sy s
http://www.nsf.ors/business/water distribution/index. asp
? prosram=WaterDi stributi on S y s
NSF = National Sanitation Foundation International; ANSI = American National Standards
Institute
Section 3. Water Safety Team
Instructions. Identify your employees and other stakeholders that share responsibility for
providing safe drinking water to aircraft passengers and crews. Identify each individual's
specific roles and responsibilities. List responsible parties for each airport location used to board
water for the aircraft addressed by this WSP.
Example.
Name
Title
Organization
Susan Smith
Water Quality Officer
Airline XYZ
John Jones
Maintenance Director
Airline XYZ
Roles and Responsibilities
Development and implementation of
Water Safety Plan and procedures for
transferring water from watering point to
onboard water system; compliance with
ADWR; staff training.
Development and implementation of
aircraft water system flushing and
disinfection program, and associated
employee and vendor training.
Contact Information
Phone:
Fax:
Email:
Phone:
Fax:
Email:
International Airport ([City], [State])
Joe Jones
Chief Engineer
Massachusetts Water
Resources Authority
Jim Jones
Maintenance Director
City Airport
Jeff Jones
Field Supervisor
Potable water supply: Source of supply
meets federal and state drinking water
regulations.
Drinking water quality is maintained
within airport water system.
Drinking water quality is maintained at
watering point (transfer point from
Phone:
Fax:
Email:
Phone:
Fax:
Email:
Phone:
Fax:
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Contract Service Co.
Vendor A
Vendor B
Vendor C
source/airport water system to aircraft
water system). Watering point meets FDA
regulations and has no potential sources of
contamination.
Aircraft water system flushing and
disinfection as directed by Airline XYZ.
Aircraft water system flushing and
disinfection as directed by Airline XYZ.
Aircraft water system flushing and
disinfection as directed by Airline XYZ.
Email:
Phone:
Fax:
Email:
Phone:
Fax:
Email:
Phone:
Fax:
Email:
Phone:
Fax:
Email:
Airport (XYZ) (List Contacts for Each Airport Served)
Section 4. Aircraft Water System Description and Inventory
Instructions. Describe aircraft water system using a brief narrative, overall system schematic
and a table summarizing key specifications for system components.
Examples.
The components of the 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, and any other plumbing fixtures that supply water to
passengers or crew. For (insert make/model) aircraft owned and operated by Airline XYZ, the
following components are also included (provide details):
(Insert schematic for each make/model owned and operated by air carrier that is addressed by
this WSP)
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Figure 4.1. Example Schematic of Aircraft Water System
Fill
Fitting
Fitting
\ O 0-
Service
Panel
Valve
Drain Line
Fitting
Piesstirization
System
Overflow Line
Fill Line
r
Potable Water Tank
Drain Line \
•e N.
Galley
Drinking
Fountain
Table 4.1. Example Summary of Aircraft Water System Com
Component
Storage tank (fixed)
Storage Tank (removable)
Fill line
Distribution lines
Tank overflow lines
Particulate Filter
Specifications
1 tank, 200 gallons, plastic
2 tanks, 5 gallons each, plastic
1 inch (list material of
construction)
3/4 and 1 inch (list materials of
construction)
1 inch, (list material of
construction)
Make and Model
ponents (List Aircraft Type)
Operation and Maintenance
Schedule
Drain if aircraft idle for >48
hrs; drain, clean and disinfect
every 3 months.
Drain, clean and disinfect each
use.
Disinfect and flush every 3
months.
Disinfect and flush every 3
months.
Disinfect and flush every 3
months.
Replace filter every 4 months
or every 1,000 hours.
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Section 5. Hazard Assessment
Instructions. Identify potential hazards and their relative risk for your aircraft water system (low,
medium, high). Identify control measures used to mitigate each potential hazard.
Example.
Table 5.1 Example Summary of Potential Hazard Events and Control Measures
Potential Hazard Event (Estimated Risk
Level)
Control Measures
Water to be boarded is known to have a
NPDWR maximum contaminant level (MCL)
or treatment technique violation that poses a
potential significant public health threat (e.g.,
acute violation of the coliform MCL, acute
violation of the surface water treatment rules,
or exceeding the nitrate or nitrite MCL). (High
risk level)
- Do not board water, if operational needs
(e.g., flush toilets) can be met without boarding
additional water.
- If operational needs cannot be met, board
water and:
• Restrict public access per 40 CFR
141.803(d).
• Notify passengers and crew per 40 CFR
141.805.
Use of watering point, including transfer and
delivery systems, not approved by FDA under
21 CFR 1240.83 (High)
- If used, aircraft is non-compliant with FDA
regulations
- If not used, identify alternate watering points
in accordance with FDA regulations.
Boarded water degrades within onboard water
system (biofilm growth). (Low)
-Conduct routine total coliform monitoring.
-Routinely disinfect and flush aircraft water
system.
Contaminant enters onboard water system due
to system design flaw. (Low to medium; high
risk if E. coif)
Restrict public access per 40 CFR
141.803(d) as warranted by monitoring
results.
Notify passengers and crew per 40 CFR
141.805.
Disinfect and flush aircraft water system.
Resample aircraft water.
Repeat disinfection, flushing, and follow-
up sampling if necessary.
Determine if other maintenance or system
modifications are needed to prevent future
contamination events.
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Backflow due to failure of backflow prevention
devices (Medium; high if sewage is present)
Restrict public access per 40 CFR
141.803(d) as warranted by monitoring
results.
Notify passengers and crew per 40 CFR
141.805.
Disinfect and flush aircraft water system.
Sample aircraft water.
Inspect and repair failed backflow
prevention devices.
Water quantity insufficient to meet minimum
sanitary water demands during flight. (Low to
medium)
Restrict public access per 40 CFR
141.803(d) and based on need (i.e. only
enough water available to flush toilets).
Notify passengers and crew if water is not
shut off at taps. Notify crew only if water
is shut off.
Section 6. Operations & Maintenance Plan
Instructions: Describe standard operating procedures (SOPs) for routine operations of the
onboard water system including boarding water from the airport watering point; collecting water
samples for regulatory compliance; draining the water system; disinfection and flushing of the
water system; and related personnel training requirements. Describe maintenance practices
including disinfection and flushing. Include technical references that provide details of
regulatory requirements and/or recommended practices.
Example:
Table 6.1. Example Summary of O&M Practices
O&M Practice
Watering Point Selection
Requirement
Practices for Boarding Potable
Water and non-potable water
Description
A statement that all water that is
boarded onto the aircraft will be from
a watering point in accordance with
FDA regulations.
1 . Confirm that transfer point meets
FDA requirements.
2. See detailed practices in O&M
Plan.
Reference
ADWR Guidance
Manual (2010);
21 CFR 1240.83;
21CFR 1250.67; FDA
Manual of Sanitation
ADWR Guidance
Manual (2010);
21CFR 1240.83.
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Coliform Sampling Plan
Coliform sampling protocol for
routine, repeat and follow-up samples;
list of certified laboratories; analytical
methods; representative sample
locations; frequency and number of
routine, repeat and follow-up samples;
reporting sampling results.
ADWR Guidance
Manual (2010)
Draining System
Procedures for completely draining
aircraft water system.
WHO (2006). Health
Aspects of Plumbing.
FDA Manual of
Sanitation
Cleaning Water Storage
Tank(s)
Draining procedures; frequency of
routine disinfection and flushing;
disinfection procedures; flushing
procedures; disinfecting agent;
disinfectant concentration;
disinfectant contact time; flushing
volume or flushing time.
Aircraft
Manufacturer's
Guidelines; 21CFR
1250.82.
Disinfection and Flushing
Frequency of routine disinfection and
flushing; disinfection procedures;
flushing procedures; disinfecting
agent; disinfectant concentration;
disinfectant contact time; flushing
volume or flushing time.
Aircraft
Manufacturer's
Guidelines; 21CFR
1250.82;
Inspect system for potential cross
connections; install and maintain
backflow prevention devices as
needed.
Cross Connection Control
21CFR 1250.82; FDA
Manual of Sanitation.
Maintenance for Treatment
Equipment Including Filter
Cartridges
Frequency and procedures for
replacing filter cartridges.
21 CFR 1240.90; FDA
Manual of Sanitation
Maintenance Procedures
Review FAA-accepted aircraft water
system O&M plan
14 CFR 43-
Maintenance,
Preventive
Maintenance,
Rebuilding, and
Alteration; 21 CFR
1250.30.
Self-inspection Procedures
Inspection of the storage tank, piping,
supplemental treatment, plumbing
fixtures, valves, and backflow
prevention devices.
ADWR Guidance
Manual (2010)
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Personnel Training
Training topics include: public health
and safety issues; ADWR
requirements, sample collection,
boarding water, flushing and
disinfection procedures,
communications and emergency plan,
O&M plan
ADWR Guidance
Manual (2010); WHO
Guide to Hygiene and
Sanitation in Aviation,
Third edition (2009).
Section 7. Communications and Emergency Plan
Instructions. Identify specific events that require communication, and the communications
strategy needed to address the event.
Example.
Table 7.1 Communications and Emergency Plan
Event
Communications Strategy
Key Contacts
ADWR monitoring yields
positive result.
If source of water is known,
notify PWS and Airport Water
System Manager of water
quality issue and to discuss
possible resolution. Notify
public per 40 CFR 141.805.
Report to EPA per 40 CFR
141.806.
Contact Name:
Phone:
Fax:
Email:
Coliform monitoring was not
conducted as required.
Notify passengers and crew
per corrective action
requirement (see Table 8.2
below). Report to EPA.
Contact Name:
Phone:
Fax:
Email:
Disinfection and flushing of
aircraft water system was not
conducted as required.
Notify passengers, crew, EPA
per corrective action
requirement (see Table 8.2
below).
Contact Name:
Phone:
Fax:
Email:
Backflow prevention device
does not pass
testing/inspection.
Inspector notifies Air Carrier.
Contact Name:
Phone:
Fax:
Email:
Source water monitoring
detects contamination.
PWS notifies Air Carrier and
Airport. Air Carrier contacts
alternate PWS.
Contact Name:
Phone:
Fax:
Email:
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Boarded water quality meets
federal and state regulations
for finished water.
PWS sends periodic reports
(annual water quality reports
or more frequent if issues
arise) on regulatory
compliance. Air Carrier calls
PWS to discuss any water
quality issues.
Contact Name:
Phone:
Fax:
Email:
Section 8. Corrective Actions
Instructions. Identify corrective actions that will be implemented if ADWR requirements are not
met (See Table 8.1). Maintain record of corrective actions taken and how/when problems were
resolved (See Table 8.2).
Examples:
Table 8.1 Summary of Corrective Actions
ADWR-related Issue
Failure to board water from a safe watering
point (E. co/i-positive).
Failure to board water from a safe watering
point (non-El co/i-positive).
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.
Corrective Action
Perform all of the following corrective
actions:
1 . Restrict public access per 40 CFR
141.803(d) as expeditiously as possible and
within 24 hours after laboratory notifies air
carrier of sample results. Restriction applies
until aircraft water system has been
disinfected and flushed and a complete set of
follow-up samples is total coliform-negative.
2. Disinfect and flush per 40 CFR
141.804(b)(2).
3. Conduct follow-up sampling per 40 CFR
141.803(e).
Disinfect and flush per 40 CFR
141.804(b)(2). Notify passengers and crew.
1 . Notify passengers and crew.
2. Within 10 calendar days of discovery of
failure, report failure to EPA per 40 CFR
141.806.
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ADWR-related Issue
Corrective Action
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 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.
(1) For failure to collect routine, repeat or
follow-up samples, restrict public access to
aircraft water system; (2) 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, (3)
conduct disinfection and flushing within 72
hours (if water system cannot be
disconnected), (4) collect follow-up samples.
(5) Within 10 calendar days, report failure to
EPA per 40 CFR 141.806.
Failure to conduct a self-inspection or
address a deficiency in accordance with 40
CFR 141.808. Self-inspections are required
every 5 years. Deficiencies identified during
self-inspections or compliance audits must be
addressed within 90 days. Deficiencies
identified during extended or heavy
maintenance must be addressed before the
aircraft is returned to service.
Conduct a self-inspection and provide
evidence to EPA that the self-inspection was
completed and whether all deficiencies have
been addressed [40 CFR 141.806(c)]. 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.
Failure to develop a coliform sampling plan
in accordance with 40 CFR 141.802.
Coliform sampling plans must be developed by
April 19,2011.
Report to EPA within 10 calendar days of
discovery of the failure.
Failure to perform any of the requirements
for coliform sampling (per 40 CFR 141.803)
or the O&M plan (per 40 CFR 141.804).
Perform the requirements specified in 40 CFR
141.803 or 40 CFR 141.804 as applicable,
and report to EPA. Notify passengers and
crew.
Routine sample is total coliform-positive
and E. co/i-negative.
Perform at least one of the following three
corrective actions and continue with that
action until a complete set of repeat samples
is total coliform-negative or a complete set of
follow-up samples is collected:
1. Disinfect and flush per 40 CFR
141.804(b)(2).
2. Restrict public access per 40 CFR
141.803(d).
3. Conduct repeat sampling per 40 CFR
141.803(c).
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ADWR-related Issue
Corrective Action
Routine sample is E. co/i-positive.
Perform all of the following corrective
actions:
1. Restrict public access per 40 CFR
141.803(d) as expeditiously as possible and
within 24 hours after laboratory notifies air
carrier of sample results. Restriction applies
until aircraft water system has been
disinfected and flushed and a complete set of
follow-up samples is total coliform-negative.
2. Disinfect and flush per 40 CFR
141.804(b)(2).
3. Conduct follow-up sampling per 40 CFR
141.803(e).
Repeat sample is E. co/i-positive.
Perform all of the following corrective
actions:
1. Restrict public access per 40 CFR
141.803(d) as expeditiously as possible and
within 24 hours after laboratory notifies air
carrier of sample results. Restriction applies
until aircraft water system has been
disinfected and flushed and a complete set of
follow-up samples is total coliform-negative.
2. Disinfect and flush per 40 CFR
141.804(b)(2).
Failure to provide notification to passengers
and crew in accordance with 40 CFR
141.805.
Implement public notification and the
correction necessary to remove the need for
public notification.
Failure to comply with the reporting and
recordkeeping requirements of the ADWR.
Implement a reporting and recordkeeping
process and procedure.
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Table 8.2. Summary of Corrective Actions Taken and Problem Resolution
Event Identified
(Date)
Corrective Actions Taken (Date)
Source of Problem
Identified
Date
Problem
Was
Resolved
Failure to conduct
routine monitoring
for coliforms (9/1/09)
Restrict public access to aircraft
water system (9/2/09).
Notify passengers and crew
(9/2/09).
System disinfected and flushed
(9/4/09).
New employees trained (9/5/09).
Follow-up samples collected
(9/5/09).
New employees
needed training in
sampling
requirements and
procedures.
9/7/09
Section 9. Recordkeeping
Instructions. Identify all documents related to aircraft water system and Water Safety Plan. List
the date for the current revision and location of the document.
Example.
Document
Coliform Sampling Plan
Bacteriological Analyses
Operations & Maintenance
Plan
Disinfection and Flushing
Records
Corrective Action Reports to
EPA
Self-Inspection Records
Public Notices
Revision Date
Sept. 2009
2004-2009
March 2009
2004-2009
Multiple
1999-2009
2010-2013
Location of Master Copy
Server X, Corporate Office
Server A, Corporate Lab
Server X, Corporate Office
Server Z, Corporate Office
Server Z, Corporate Office
Server Z, Corporate Office
Server Z, Corporate Office
Section 10. Annual Review of Water Safety Plan
Instructions. Review Sections 1-8 of Water Safety Plan and update/revise as needed. Complete
review at least annually and whenever there is a change in process, procedures, equipment,
regulations etc. Include revision date on title page of Plan. Distribute revised Plan to Water
Safety Team and other stakeholders.
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