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

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SUMMARY AIRPORT COMMUNITY, WATER QUALITY EVENTS, AND THE AIRCRAFT DRINKING WATER RULE Protecting public health by providing safe drinking water and other health-related prac- tices is a priority for all members of the airport community. Airport management, airlines, and other airport tenants share a common objective of providing safe drinking water to their employees, tenants, and the public. Drinking water quality events that affect airports can trigger a spiral of operational challenges for the airports, airlines, and other tenants. Receiving prompt and accurate information about an event is essential for airport manage- ment and tenants to address and mitigate its adverse effects. Airlines have reported that it is often difficult for them to obtain information about a drinking water quality event and determine if it affects an airport they serve. Airport management fills a critical role by distributing the essential information and minimizing the time it takes for notification of an event to reach the airport’s tenants. A drinking water quality event is a situation in which consuming the water presents a potential or certain risk to public health. The water quality event may originate from the water utility that serves the airport (the regulated public water system) or from a problem with the water system infrastructure within the airport property. Events can be caused by bacteria, algal toxins, or chemical contaminants detected in the water or by a water treat- ment or distribution system failure. Drinking water quality events can also be precaution- ary, as when a situation within the water system creates the potential for contaminants to enter or for water service to be disrupted. Examples of events that may trigger precaution- ary notices include a water main break, a scheduled routine water main flushing program that could result in cloudy or discolored water, and planned water service disruption for water main replacement. Regardless of where the event originates, an effective airport notification process for all drinking water quality events is important. Airports, airlines, ground service providers, and ice and food caterers as well as other food service establishments take measures to ensure that their operations have safe drinking water. If the airport experiences a drinking water quality event, each tenant makes event- specific decisions regarding how it will respond to protect public health. In many cases, the consequences may be significant. The EPA Aircraft Drinking Water Rule (ADWR; 40 CFR 141.800–141.810) mandates airlines take corrective action for each aircraft’s public water system whose water does not meet standards for human consumption; disinfecting and flushing the water system on each affected aircraft is one of the corrective actions. Once airlines are informed of an event, they make operational decisions on whether to stop boarding water from that location and take measures to protect the health of passengers and crew on any aircraft that may be affected by the water in question. This report synthesizes: 1. General practices by which water utilities (also referred to as regulated public water systems) notify airports and other customers of drinking water quality events;

2 2. Observations from airports and airlines about their experiences learning of a drink- ing water quality event, either by receiving notification from the water utility or from other means; and 3. Procedures by which airport leadership notifies their airport community of drinking water quality events. While the emphasis of this report is on notifications that specifically help airlines address the requirements of the ADWR, it is also applicable to all airport tenants whose operations depend on safe drinking water. The original title of this synthesis was “Airport Experience with Implementing Notifications Required by the Aircraft Drinking Water Rule,” but it was modified by the consultant and synthesis panel to “Airport Community, Water Quality Events, and the Aircraft Drinking Water Rule” to reflect that the project also addresses notifications of unsafe and potentially unsafe drinking water that affect airports and other tenants. Information for this synthesis was obtained from telephone interviews with airport lead- ership from 11 U.S. air carrier airports, one water utility serving a small non-hub regional airport, two water utilities serving a large-hub airport, and three U.S.-based airlines. The interviews followed a project-specific questionnaire. The 11 airports were purposefully selected to capture a diversity of operations, protocols, and experiences with drinking water quality events. Information was also obtained from four EPA Regional Office personnel who are responsible for oversight of the ADWR, and the U.S. Food and Drug Administration’s (FDA’s) Interstate Travel Program Manager. All information was obtained between July 2016 and April 2017. Airports, airlines, and other members of the airport community are partners in address- ing water quality events that affect airports. Airports can provide an invaluable service to airlines and other tenants by assisting with dissemination of water quality event information. A significant finding of this synthesis is a need for outreach to airport management to increase awareness of the value of active airport participation in the drinking water quality event notification process. Consistent and timely dissemination of critical information can occur when airports serve as a primary contact for a notification of an event and then convey that notice to airport tenants, particularly to airlines. Other key findings of the synthesis include the following: • Airports have excellent targeted emergency notification systems. Airports that have had experience with drinking water quality events apply airport emergency plans or standard operating procedures (SOPs) that include these systems. Using a targeted notification list helps ensure that appropriate personnel are notified, whether they are located onsite at the airport or offsite (e.g., an airline’s corporate environmental personnel). • Having appropriate airport personnel included on the water utility’s critical contact list for drinking water emergencies can facilitate prompt and accurate notification of events. It may be necessary for airport management to directly contact the water utility and request to be added to the critical contact list. It is very important to keep contact information current. • Because drinking water quality events are infrequent, airports that have not previ- ously experienced them lacked SOPs or even informal communications strategies to address them. • Several of the synthesis participants consider drinking water quality events to be emer- gencies and maintain that they should be handled as such. • Airports that do not currently have SOPs for drinking water quality events generally agreed that existing emergency notification systems and procedures could be amended to accommodate these events. Water quality event options may need to be created or

3 SOPs developed so that the appropriate event type is used and the notification reaches only the desired recipients. In the process of conducting this synthesis, the research team identified several topics for additional research as well as resources that would be useful to support drinking water quality at airports and related notification procedures. The research topics are described in the report conclusions and include the following: • Event SOP templates or other tools for the most common issues related to drinking water–related events. • Tabletop exercises for the airport community to address various drinking water quality events, and inclusion of notification protocols and essential messaging in the exercises. • Clarification of the regulatory and contractual responsibilities and obligations of an airport for issuing notices or performing additional sampling when a water quality event that originates at the water utility affects the airport. There is also interest in airport legal obligations related to the ADWR that should be included in lease agree- ments between airlines and airports. • Information on voluntary water quality monitoring programs of the airport drinking water system: what to monitor, how the data can be used, what responses are appro- priate to sample results, and with whom the results might be shared. • Practices for addressing water cabinet operations and maintenance and parties responsible for those activities. • Regulations and suggested SOPs for maintaining water quality throughout the air- port, including the complete water supply and distribution process and communica- tions practices. • List of the water utilities that serve airports. • Clarification of the role of FDA at airports during a water quality event. • Considerations for airport water system treatment and operations regarding regula- tory, operational, and financial implications. • Water quality and cabinet maintenance at terminals that serve international flights.