Airport Community, Water Quality Events, and the Aircraft Drinking Water Rule (2018)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

5 CHAPTER ONE INTRODUCTION BACKGROUND AND OBJECTIVES Airports rely on the quality of the drinking water provided by the water utility (also referred to as the regulated public water system) that serves the airport; airport tenants, passengers, and employees rely on the quality of the drinking water at the airport. Although drinking water is most often reliably safe to consume and use, events can occur that render it unsafe or potentially unsafe. When notified that a drinking water quality event affects an airport, the airlines, ground service providers, and ice and food caterers as well as other food service providers evaluate the details of the event and its effect on their opera- tions. They then quickly make decisions about how to protect public health and mitigate the effect. For airlines, prompt and detailed notification of a water quality event provides greater opportunity to protect public health and reduce the impact of the event on their crew, passengers, and fleet. Receiving notification when an airport is not affected by an event that is occurring elsewhere in the water utility’s distribution system is equally important to help avoid unnecessary operational disruptions. There have been instances when the drinking water supplied to the airport has been compromised or an airport drinking water distribution system has encountered issues. When the drinking water quality event originates in the water utility that serves the airport, recent experiences have shown that airports are often not informed directly by the water utility. In addition, some airports do not have a standard operating procedure (SOP) in place to conduct notifications to their tenants. Airlines have reported that it is often difficult for them to obtain information directly from a water utility about a drinking water quality event and then determine if it affects an airport they serve. The objective of this synthesis is to document the stakeholders in the drinking water quality event’s communication chain; how airports are organized around drinking water; general practices for water utility notifications to consumers; and any established protocols that involve notification in order to minimize impacts to airlines, the public, and employees. This project describes airport experiences with water quality–related events, including how the airport becomes aware of the event and then implements notifications to the airport community. For this synthesis, the airport community includes airport manage- ment and decision makers, airlines, ground service providers contracted by the airlines or by the airport to board water onto aircraft, and ice and food caterers that are contracted by the airlines or airport to serve aircraft. Other airport tenants reliant on safe drinking water for their operations were not included in the synthesis research, but they may also benefit from this report. The original title of this synthesis was “Airport Experience with Implementing Notifications Required by the Aircraft Drinking Water Rule.” The Aircraft Drinking Water Rule (ADWR; 40 CFR 141.800–141.810; EPA 2009) is a regulation under the Safe Drinking Water Act (SDWA) that is tailored specifically for aircraft that are classified as a public water system. The ADWR mandates that airlines take corrective action for each aircraft public water system that boarded water after the air carrier became aware of an unsafe water quality event. The ADWR also requires that under specific circumstances airlines must provide notifications to crew and passengers who have access to the water on the aircraft. The title of the synthesis was modified by the researchers and synthesis panel to reflect that the project addressed notifications for unsafe and potentially unsafe water quality events at airports and is not limited to those required by the ADWR. TYPES OF WATER SYSTEMS SERVING AIRPORTS AND THEIR PUBLIC NOTIFICATION REQUIREMENTS Most airports are pass-through customers of a water utility, meaning that they are provided water that is ready for human consumption and requires no further treatment. For this report, the term water utility refers to a regulated public water system that serves a community, municipality, or airport. Airports that are customers of water utilities are not required to monitor water quality, although they sometimes do so voluntarily. Airports have important obligations for maintaining the quality of the water and can be responsible for maintenance of and repairs to the drinking water infrastructure on airport property. Such infrastructure commonly includes distribution pipes, storage tanks, and pump stations.

6 Some airports, however, are regulated as public water systems. These airport water systems either have their own sources of water, such as wells and related treatment systems, or they purchase finished water from one or more water utilities and provide additional treatment of the purchased water (e.g., booster disinfection to maintain a chlorine residual). Water utilities, airport public water systems, and aircraft public water systems must comply with the Safe Drinking Water Act. Under the SDWA, EPA sets national primary drinking water regulations that are health-based standards for drinking water quality. Among other requirements, they must monitor water quality and report the results to the applicable regulatory agency (typically, a state drinking water program). They must also provide notification to the public if monitoring results, treatment system failures, or other activities indicate a potential or a confirmed public health threat. SDWA regulations for public water systems are extensive; however, the specific requirements that apply to each of these types of water systems (water utility, airport, and aircraft) are very different. More information about the SDWA and its regulations can be found at https://www.epa.gov/ground-water-and-drinking-water. Public notification requirements of the SDWA are designed to ensure that consumers know about water quality issues and how to protect themselves from potential risks. The Public Notification Rule (40 CFR 141.201–141.204) applies to water utili- ties and airport public water systems (aircraft public water systems are subject to different public notification requirements). The Public Notification Rule establishes requirements regarding the form, manner, frequency, and content of a public notice. The rule specifies three categories, or tiers, of public notification. Each tier stipulates the maximum amount of time allowed to distribute the notice and the methods to do so (EPA March 2010). Tier 1 is most applicable to airport operations. Tier 1 situations require immediate notice and are triggered by a circum- stance with the potential for human health to be immediately impacted. Immediate notice means consumers must be notified no more than 24 hours after the water utility becomes aware of the situation. Various methods can be used to distribute the notice, including physically posted notices, broadcast media (such as radio and television), and e-communications such as reverse 911 systems. Reverse 911 systems inform consumers via a database of contact information for phone, email, and text messages. The content of the notice must include a description of the violation or situation, when it occurred, potential adverse health effects, actions consumers should take, and what the water utility is doing to correct the problem, among other details. The water utility must also issue updates on the status of the situation. The other two tiers of public notice apply when there is not an immediate threat to public health. The particular circum- stance determines the time frame—which can vary from within 30 days to within 12 months of learning about the situation— and the manner of issuing these public notices. Drinking water quality events addressed by these notices do not affect the operations of airlines, ice and food caterers, or other food service providers because such events do not have immediate health impacts. However, airport and tenant employees may need to be notified if there are health risks associated with consuming the water over longer terms, such as a period of several months or years. In responding to a water quality event, each water utility follows the communication procedures established by its state drinking water regulatory agency and its emergency response plans. Communication procedures can vary among water utili- ties. In some cases, an airport may receive notice about a water quality event through media announcements; in other cases, it may have direct communication with the water utility. THE AIRCRAFT DRINKING WATER RULE AND AIRCRAFT POTABLE WATER SUPPLY AND TRANSFER CHAIN Airlines have operations and maintenance programs to ensure that the water they provide to passengers and crew on aircraft is safe to drink and that their aircraft water systems remain in good condition. They must also comply with the requirements of the ADWR, a regulation of the SDWA. EPA finalized the ADWR in October 2009, and air carriers began fully implementing the rule in October 2011. The ADWR regulations are very different from those covering the airport public water system or the water utility from which aircraft obtain their water. The ADWR was developed because the requirements that apply to stationary public water systems, such as restau- rants drawing from their own well systems or water utilities, could not feasibly cover the logistical realities of an aircraft public water system or airline operations. The ADWR addresses routine disinfection and flushing of the aircraft water system, routine monitoring for coliform bacteria, aircraft water system operations and maintenance plans, and corrective actions if water that has been boarded onto aircraft does not meet drinking water standards. Corrective actions are also required by other situations. EPA’s Quick Reference Guide for the ADWR provides an overview of the rule’s requirements and is included in Appendix A.

7 The ADWR does not apply to all aircraft: it applies to aircraft that meet the definition of an aircraft public water system. An aircraft public water system has an onboard water system that uses piped water for handwashing or food preparation and that serves at least 25 people per day for at least 60 days per year (EPA October 2010; 40 CFR 141.2). Aircraft are excluded from the ADWR if they fly international routes with only one stop in the United States before returning to an international location. Other exclusions apply and are described in ADWR guidance developed by EPA (EPA October 2010). Under the ADWR, aircraft public water systems must board only finished water (water that is safe for consumption with- out further treatment) from a watering point that is in accordance with United States Food and Drug Administration (FDA) regulations. Finished water is another term for potable water or safe drinking water. Aircraft public water systems are unique in that they may board water from multiple locations in one day. As such, the quality of the onboard water is dependent on the quality of the water provided by each airport and the sanitary conditions and procedures used in each step of the aircraft water supply and transfer chain. Figure 1 presents the process by which potable water is transferred from the water utility serving the airport to the aircraft public water system. The term public water system, or PWS, used in the figure is the same as water utility used in this report. The figure also identifies the regulatory agency responsible for oversight of each step. This potable water supply and transfer chain begins with the water utility that provides the finished water. The airport may be a public water system or be a customer of the water utility that serves the airport. The state primacy agency (the state drinking water regulatory agency) oversees implementation of the SDWA at water utilities and airport public water systems. From the airport terminals, the water flows to aircraft watering points such as water cabinets, trucks, or carts. Some aircraft use refillable water containers that are serviced by caterers or airline personnel. From the watering points, water is boarded by ground service providers to the aircraft water system, where it is accessible to passengers and crew through lavatory or galley fixtures. FDA has jurisdiction over the water transfer process, including the watering points and ground service providers, and the water used for food preparation (culinary water) onboard the aircraft; EPA has jurisdiction over the drinking water onboard the aircraft. FIGURE 1 Aircraft potable water supply and transfer chain. Source: EPA ADWR training materials (EPA n.d.). Prior to each departure, aircraft may either completely empty and fill the water storage tank or simply top it off. Once the aircraft reaches its next destination, this process can be repeated as necessary.

8 ROLES AND RESPONSIBILITIES RELATED TO SAFE DRINKING WATER AT AIRPORTS Table 1 summarizes key participant roles and responsibilities of water utilities, regulatory agencies, airport management, and the airport community regarding safe drinking water at airports. Researchers developed the table’s content based on input from synthesis participants and knowledge of the regulatory agencies listed. These are, therefore, examples of roles and responsibilities, and responsible parties and their duties may differ from this summary. TABLE 1 ROLES AND RESPONSIBILITIES RELATED TO SAFE DRINKING WATER AT AIRPORTS Key Participant Role Responsibilities Water Utility/Public Water System • Operate and maintain the water utility to provide a safe and reliable supply of drinking water in compliance with the SDWA. • Provide public notice to consumers in the event that a confirmed or potentially unsafe drinking water quality incident occurs. Airport Management • Ensure operations and maintenance of the airport water system in such a manner as to provide a safe and reliable supply of drinking water throughout the airport distribution system. • Provide notice to the airport community in the event that a confirmed or potentially unsafe drinking water quality incident occurs. Airport Operations/Emergency Response Manager • Issue notifications, including status updates, to appropriate members of the airport community with applicable messaging. • Manage emergency response actions and follow-up throughout the water quality event. Airline Corporate Environmental Manager • Identify aircraft affected by a drinking water quality event and the appropriate responses to protect public health and mediate operational challenges. Airline Station Manager • Notify corporate environmental managers, ground service providers, and caterers of drinking water quality events and status updates. Airline ADWR and Operations and Maintenance Personnel • Perform routine operations and maintenance of aircraft drinking water systems and implement corrective actions as required. • Implement ADWR compliance activities and reporting. Ground Service Providers • Maintain watering points as required, lock out watering points as appropriate during water quality events, and perform corrective actions to return the watering points to normal safe operation after the event is resolved. EPA • Oversee and enforce the requirements of the ADWR. • Oversee and enforce implementation of the SDWA by states. • Assist in notifying air carriers of details of the water quality event by forwarding information that may be received. State Drinking Water Program (Primacy Agency) • Oversee and enforce the requirements of the SDWA on public water systems in the state. FDA • Oversee and enforce the requirements of regulations applicable to interstate carrier conveyances, including the operation and sanitary condition of watering points. • Approve for clearance watering points affected by an unsafe drinking water quality event after the incident is resolved by the public water system. Local Health Departments • Oversee and enforce compliance with the FDA Food Code for terminal restaurants and ice and food caterers. • Inspect and oversee aircraft watering points if contracted by FDA to do so. Source: The Cadmus Group LLC. TYPES OF DRINKING WATER QUALITY EVENTS THAT COULD AFFECT AN AIRPORT Drinking water quality events are situations in which the water serving an airport is either known or suspected to be con- taminated or otherwise unsafe to consume. The most significant of these events involve contaminants that cause acute health effects. Such contaminants cause a severe onset of illness after short-term exposure. Notifications about these events may include instructions to boil the water before use, recommendations to avoid drinking the water, or warnings not to use the water at all. Other water quality events include situations where the color, cloudiness, or taste of the water may raise consumer concerns; the water pressure is too low; or the water service is disrupted. Although they occur infrequently, these events can originate at the water utility serving the airport or within airport property. Drinking water quality events are characterized by specific terminology. The term used depends on the degree of the public health risk and on the policies of the state drinking water regulatory agency or the water utility. An event might merit “boil water advisories,” “boil water orders,” “do not use orders,” or water quality “notices” or “alerts.” Table 2 presents some of the

9 types of public notification issued by water utilities and examples of situations that trigger them. Researchers developed the table based on experiences and knowledge of drinking water quality events. TABLE 2 TYPES OF DRINKING WATER QUALITY EVENTS AND EXAMPLE SITUATIONS Type of Drinking Water Quality Event Example Situations Triggering the Event Boil Water Notice or Boil Water Alert Microbial contamination and the potential for disease-causing organisms to be present is indi- cated by water quality monitoring results or water treatment failure, or a waterborne disease outbreak is occurring. Do Not Drink Chemical contamination from backflow events or water treatment failures renders the water unsafe to drink, even if boiled, but the water can be used for other purposes, includ- ing basic sanitation. Do Not Use Chemical contamination, such as algal toxins, is present and can cause adverse health effects through skin contact or inhalation as well as through drinking the water, even if the water is boiled. Precautionary Notice—Health Advisory or Health Alert Water is potentially unsafe due to an operational event or emergency incident, such as a main break. Consumers are advised to take precautions appropriate for the situation. These alerts often advise boiling the water even if a public health threat has not been confirmed. Precautionary Notice—Consumer Alert Operational activities are underway that could temporarily affect the color or provision of drinking water. Such activities include water distribution system flushing or scheduled main replacement. Source: The Cadmus Group LLC. CONSEQUENCES OF AIRPORT WATER QUALITY EVENTS FOR THE AIRPORT COMMUNITY Airports and airlines have active programs to ensure safe drinking water. However, during some events airport management, airlines, and other tenants are responsible for responding to the situation. During a water quality event, airport management is obligated to shut off public drinking fountains, restroom faucets, and other sources of drinking water or to post notices that they are not usable. Upon notification of an event, airlines make decisions to avoid having aircraft affected by the event, thus potentially reduc- ing the need for ADWR-related corrective actions. If aircraft board water that does not meet drinking water standards related to contaminants that cause acute health effects, the ADWR requires that the aircraft water system be disinfected and flushed and that follow-up coliform sampling be performed (40 CFR 141.804). Air carrier response can also include public notifica- tion to aircraft crew (40 CFR 141.805). Notification to the crew must be issued within 24 or 72 hours of the airline learning that a water quality event affected the boarded water; the time frame depends on the public health significance of the event. Notification to crew is not necessary if the corrective actions are completed within the 24- or 72-hour time frame. Passengers on the aircraft also receive notification about the water if the corrective actions are not completed within the specified 24- or 72-hour time frame and passengers are able to access the water on the aircraft. These efforts have both operational and finan- cial significance. They illustrate how important it is for airlines to receive notice of a water quality event as soon as possible. The more quickly an airline is informed that the water at an airport may be compromised, the more quickly the airline can make appropriate operational decisions. Even short delays in issuing notice, particularly during peak departure times, can affect several aircraft. Ice and food caterers and other food service providers likewise rely on safe drinking water to prepare food, ice, or water- based beverages. During a water quality event, caterers and vendors cease operations if they cannot ensure the safety of the products they are preparing. Special procedures for tableware, laundry, and utensil sanitation are used. They must also discard any food, beverages, and ice that were prepared with unsafe water (FDA Food Code 2013, 8-404.11). Ground service providers should be informed of water quality events so that they know not to board water onto aircraft or so that they understand why water cabinets and other aircraft watering points may be locked out of service. They also need to be informed when an event has been resolved so that they can implement appropriate actions, such as flushing and disinfect- ing the watering points and related piping, hoses, and connections before using the equipment to board water onto aircraft.

10 ORGANIZATION OF THIS REPORT The remainder of this report presents the methods used and findings of the synthesis project. The report is organized as follows: Chapter 2. Methods – Describes the literature review and interview methods and questions used to conduct the study, along with a description of how the airport interview participants were selected. Chapter 3. Practices and Findings from Interviews – Presents the major findings of the participant interviews and lit- erature search, including notification methods, challenges, and suggested elements of SOPs for drinking water quality events. Chapter 4. Conclusions and Further Research – Summarizes the major findings and conclusions of the study, and addi- tional research to fill gaps in knowledge. Appendix A – Contains EPA’s Quick Reference Guide for the Aircraft Drinking Water Rule. Appendix B – Provides the questions used for the water utility, airport, and airline personnel interviews. Appendix C – Provides an example water cabinet maintenance SOP at an international terminal that reflects International Air Transport Association recommendations.