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 civil aviation [and] works to achieve its vision of safe, secure and
sustainable development of civil aviation through cooperation amongst its
member States.” 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). An advance
copy of the Guide, including an Introduction and chapters on airport
and airplane Water systems and Cleaning and Disinfection of Facilities, has
been available on the Internet since May 2009. 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.