Airline Water Study 2019 Key Links, Documents, Definitions and Studies

by Charles Platkin, PhD

KEY LINKS

EPA’s ADWR Info Site

Full-Text of the ADWR for Reference

National Primary Drinking Water Regulations, Subtext X

National Primary Drinking Water Regulations: Drinking Water Regulations for Aircraft Public Water Systems; Proposed Rule 

Guidance Manual for the Aircraft Drinking Water Rule (ADWR) – Interim Final 

Aircraft Drinking Water Rule Part 1 – Introduction – June 2011

Aircraft Drinking Water Rule Part 2 – Coliform Monitoring and Sampling Plans – June 2011

Aircraft Drinking Water Rule Part 3 – Operations and Maintenance Plans – June 2011

Aircraft Drinking Water Rule Part 4 – Public Notification – June 2011

Aircraft Drinking Water Rule Part 5 – Recording and Recordkeeping – June 2011

Aircraft Drinking Water Rule Training Part 6 – Violations of the Rule – June 2011

KEY DOCUMENTS:

Along with the ADWR webpage and ADWR manual, the following documents provided our team insights on the workings of airline water regulations. 

January 2005: Water Quality in Airplanes: Water Bulletin, Cornell University 

August 2005: Administrative Order on Consent and Request for Information (Order) that resolves American Airlines, Inc.’s non-compliance with the Safe Drinking Water (Act) and the National Primary Drinking Water Regulations

August 10, 2005: Administrative Order on Consent and Request for Information (Order) that resolves Northwest Airlines, Inc.’s non-compliance with the Safe Drinking Water (Act) and the National Primary Drinking Water Regulations

January 18-19, 2006: Initial Scoping Workshop on the Development of Regulations for Aircraft Public Water Systems

July 8, 2008: Comments of the Air Line Pilots Association, International on the EPA Proposed Rule – National Primary Drinking Water Regulations: Drinking Water Regulations for Aircraft Public Water Systems

July 8, 2008 – Comments of the Association of Flight Attendants – CWA on the EPA’s Proposed Rule for Aircraft Public Water Systems

June 25, 2009: Supplemental Comments of the Air Transport Association of America, Inc. on EPA’s Proposed Drinking Water Regulation for Aircraft Public Water Systems

August 25, 2011: FAA Responds to Request for Information Regarding the Applicability of the ADWR

March 24, 2016: A warning letter from the FDA to Winner Aviation Corp. for lack of compliance to FDA regulations for watering points

May 13, 2016: A warning letter from the FDA to Horizon Air Industries, Inc. for lack of compliance to FDA regulations for watering points

KEY ADWR DEFINITIONS 

Sources:

  • National Primary Drinking Water Regulations, Subpart X: Aircraft Drinking Water Rule (EPA)
  • Interstate Conveyance Sanitation (FDA)              

Air carrier: 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 [ADWR, CFR Subpart X]

Aircraft: means a device that is used or intended to be used for flight in the air. 

Aircraft Water System: 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.

Aircraft Water System Operations and Maintenance Plan: 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.

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.

Conveyance: any land or air carrier 

Finished Water: 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., booster disinfection, addition of corrosion control chemicals). 

[Water used for] Human Consumption: [water used for] drinking, bathing, showering, hand washing, teeth brushing, food preparation, dishwashing, and maintaining oral hygiene.

Public Water System: a system for the provision to the public of water for human consumption through pipes or, after August 5, 1998, other constructed conveyances, if such system has at least fifteen service connections or regularly serves an average of at least twenty-five individuals daily at least 60 days out of the year. Such term includes: any collection, treatment, storage, and distribution facilities under control of the operator of such system and used primarily in connection with such system; and any collection or pretreatment storage facilities not under such control which are used primarily in connection with such system. Such term does not include any ‘‘special irrigation district.’’ A public water system is either a ‘‘community water system’’ or a ‘‘noncommunity water system.’’

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.

Self-Inspection: 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. 

Transient non-community water systems: means a non-community water system that does not regularly serve at least 25 of the same persons over six months per year.

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. 

Useful Background Articles and Reports

Useful Background Studies

 

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