Potable Water
Potable
water supplies on U.S. airlines are jointly regulated by the Environmental
Protection Agency (EPA), the Food and Drug Administration (FDA), and the
Federal Aviation Administration (FAA). In accordance with the Safe Drinking Water Act
(SDWA), EPA regulates water quality in public water systems, including those
that supply water to the airports and the drinking water once it’s onboard the
aircraft. The regulatory structure for all public water systems relies upon
self-monitoring and reporting of results to the primacy (primary enforcement)
agency, which for aircraft public water systems is EPA. The EPA signed an Aircraft
Drinking Water Rule (ADWR) on October 5, 2009, the purpose of which
is to “ensure that safe and reliable drinking water is provided to aircraft
passengers and crew … [by] providing air carriers with a feasible way to comply
with the … SDWA … and the national primary drinking water regulations
(NPDWRs).” (Refer to the EPA
webpage Aircraft Drinking Water Rule for additional information and
occasional updates.)
The Proposed
Aircraft Drinking Water Rule was published on April 9, 2008 in the Federal
Register. In developing this proposal, EPA sought the views of all
interested stakeholders. AFA-CWA played a significant role in representing the
interests of flight attendants throughout this process by submitting comments
on the proposed rule and by attending three stakeholder workshops
in 2005,
2006
and 2007.
During the second workshop, in January 2006, AFA-CWA staff presented The Flight
Attendant Position on Airline Drinking Water, which summarizes the
laws and regulations governing airplane drinking water, hygiene and sanitation,
and contrasts this legal framework with the actual, sometimes deplorable
conditions present in cabins, galleys and lavs.
Sanitation and Hygiene
The FDA
has jurisdiction over water used in food preparation including coffee, tea and
ice and the pipes, tankers, etc. at the airport where aircraft obtain water.
The FDA also regulates food-handling operations by, for example, requiring that
running water and soap be provided to facilitate proper hand washing by
food-handling employees; see 21
Code of Federal Regulations PART 1250 INTERSTATE CONVEYANCE SANITATION
and the FDA
Guide to Inspections of Interstate Carriers and Support Facilities.
The FAA, working with the EPA and FDA, oversees operation and maintenance
programs covering all parts of the aircraft, including the potable water
system.
AFA-CWA
has also been an active participant in the long-term process of updating the International Health
Regulations (IHR), an international legal instrument binding on 194
countries including the U.S. AFA-CWA’s ability to affect the IHRs is the result
of our membership in the International
Transport Workers’ Federation (ITF), an organization granted
observer status in the International Civil
Aviation Organization (ICAO). ICAO, a UN Agency, is the “global forum
for cooperation among its Member States and with the world aviation community.”
A collateral benefit of our work with ICAO has been the ability to participate
in a recent process to draft a third edition to the Guide to Hygiene and
Sanitation in Aviation (GHSA), a document by the World Health Organization (WHO). A
downloadable PDF version of the Guide to hygiene and sanitation in aviation
(third edition), including Module 1 – Water and Module 2 – Cleaning and
disinfection of facilities, is available at
this link. Additional chapters on Food, Waste Disposal, Vector Control
and Cargo will be included in the final version of the GHSA 3rd
edition, to be published on some future date.