Effect Measure

I don’t fly as much as I used to but I still fly too often for my likes and when the cart comes around for the free beverages it’s either orange juice “with no ice” or a bloody mary mix “with no ice.” I rarely drink water, but if I did, I would never drink the water out of a pitcher, as offered to me a couple of weeks ago on Air Canada. From a bottle, maybe, but since bottled water isn’t as well regulated as tap water, I usually don’t partake. I know a fair amount about public drinking water, but one day I was seated on a plane next to somebody who knew a lot about airplanes and he said he’d never drink water on an airplane. Shortly thereafter the news carried stories that the US EPA had determined that 15% of water on a sample of 327 aircraft flunked the total coliform standards and inspections showed that all aircraft were out of compliance with the national drinking water standards. As a result, EPA crafted a new Aircraft Drinking Water Rule (ADWR), just issued. Sounds like a good idea, as far as it goes. But it doesn’t go very far.

So which agencies in the US regulate drinking water on airplanes anyway? Too many:

In the United States, drinking water safety on airlines is jointly regulated by the EPA, Food and Drug Administration (FDA), and Federal Aviation Administration (FAA). EPA regulates the public water systems that supply water to the airports and the drinking water once it is onboard the aircraft. FDA has jurisdiction over culinary water (e.g., ice) and the points where aircraft obtain water (e.g., pipes or tankers) at the airport. In addition, air carriers must have FAA-accepted operation and maintenance programs for all aircraft, this includes the potable water system. (EPA)

Yikes. Before the water gets on the plane, it’s regulated by EPA until it gets into the plane via a tanker truck or pipes, where it is regulated by the Federal Aviation Administration (FAA). Once it gets on board the plane as drinking water, EPA again regulates it, unless it is used for coffee, tea or ice, for which “culinary use” it is regulated by the Food and Drug Administration (FDA). And the FAA also oversees the operation and maintenance programs for aircraft, including the potable water system. And now, with the new ADWR, EPA will be tightening the water you drink after it gets on the plane (unless it’s used for ice or coffee or tea, that is). And they are doing it because when they last looked, the water you drank from a pitcher (which presumably was the same water that made the ice but that’s the problem of the FDA) was (literally) pretty shitty looking. One of seven flunked the coliform rule for drinking water.

Coliforms are a class of organisms associated with the intestinal tracts of warmblooded animals. Failure of the total coliform rule (or one of its more constrained variants, like fecal coliforms) does not mean that the water contains pathogens, even if it was all E. coli (which despite its name, is not made up only of E. coli). After all, your gut is full of E. coli and you don’t get sick as a result. Only some strains of E. coli are a problem. But failure of the coliform rule is an indicator that there is a problem because it signals the potential for pathogens in the water. Somewhere along the way it got contaminated by organisms associated with the intestines of warmblooded animals. I don’t want to drink water that fails the coliform rule. It’s water that is higher risk of also having disease causing agents, including intestinal viruses and parasites as well as pathogenic bacteria. Hence the coliform rule.

And hence the new EPA ADWR for water on airplanes. It covers the water service panel, storage tanks, pipes, valves, treatment devices, and plumbing fixtures within the aircraft that supply water to passengers or crew, but the FDA is still responsible for regulating the watering points (the water cabinets, carts, trucks, and hoses which put the water aboard the plane). It does not cover any flights originating outside the US.

What does the ADWR require? The objective is to make the usual drinking water rules accommodate the special setting of an airplane (and presumably the special lobbying abilities of the airplane industry). It’s a combination of increased sampling requirements, best practices (e.g., disinfection and flushing of water systems), training, record keeping and a few other things, all meant to protect the public “while allowing air carriers flexibility in how they achieve these objectives.” Flexibility is good and the ADWR has plenty of it. Here are the major requirements:

  • Developing and implementing operations and maintenance plans and coliform sampling plans.
  • Routine disinfection and flushing based on manufacturer recommendations and routine monitoring.
  • Self-inspection of the aircraft water system every five years.
  • Corrective action in response to sample results or other situations that may be a public health risk.
  • Public notification in response to situations that may be a public health risk.
  • Periodic compliance audits by EPA.

EPA is giving the airlines 18 months to get ready, so drink accordingly. In fact even after 18 months you might want to be careful, as this is all self-regulation. The airlines establish the sampling and testing schedules depending upon whatever the manufacturer of their equipment says is best, or if there are no such recommendations or they conflict, according to what the airlines thinks is best. Besides the requirement for sampling, to be determined by the airline, they have to inspect their water systems — once every 5 years. Of course they can also get audited by the EPA. I’m guessing they’ll take their chances on that, since nothing much has happened to them for violating the drinking water standards up to now.

So it’s not a helluva lot. The airlines claim it will still cost them big bucks. The EPA estimate isn’t chump change: just under $7 million. For me or you, that’s a lot of money and we know it will be passed on to us as passengers in ticket prices. EPA estimates that just under 710 million passengers travel each year on planes affected by the rule, so that would mean it might cost each of us one cent on each ticket.

In order to make up for it and remain competitive the airlines will probably have to cut corners in other areas. Maybe charge extra for life vests or seat cushions that float?

Comments

  1. #1 01jack
    October 14, 2009

    I don’t know, but I wouldn’t have thought that the airlines make ice. I assumed that it was another food commodity provided by the catering company.

  2. #2 Eric Lund
    October 14, 2009

    When I flew them last December, US Airways was charging for non-alcoholic beverages in flight. I hear they have since dropped the charge, because nobody else was charging for beverages. However, this regulation might inspire some other airline to try charging for in-flight beverages, and if other airlines go along with it it may stick. That’s how it went with checked baggage fees: they started with charges for the second bag, and in less than a year most US airlines were charging fees for the first checked bag on domestic flights. The most prominent exception: Southwest still lets you check two bags for free (there always was a charge for the third bag).

  3. #3 Dave Syzdek
    October 14, 2009

    I think the problems that the EPA found on aircraft was with the water quality in the lavatory faucets which I doubt few people would drink from. Last time I used a lavatory on an aircraft there was a sign on the faucet saying not to drink. I imagine that ice is from a caterer or perhaps ice machines at the airport. I’m not sure about water used for making coffee or tea….

  4. #4 E. Brown
    October 14, 2009

    A little light reading from the UK – slightly dated, but relevant to the topic:

    The Microbiological Quality of Water Onboard Aircraft: 2003
    “A study of the microbiology of aircraft water distribution systems examined 850 samples of water from mains, bowser and aircraft sources at 13 airports in England Wales, Scotland and Northern Ireland. The quality of water was determined by coliforms, faecal indicators (E. coli, enterococci, sulphite reducing clostridia (SRC), Ps. aeruginosa and aerobic colony count (ACC). The microbiological quality of water varied between airports and across the supply chain.”

    http://www.hpa.org.uk/webw/HPAweb&HPAwebStandard/HPAweb_C/1197382219694?p=1158945066455

    The Public Health Laboratory Service was rolled into the UK’s Health Protection Agency in 2003 after this report was complete – the division is now called Centre for Infections.

  5. #5 revere
    October 14, 2009

    Dave S.: My understanding was that the lav and kitchen water were from the same tank. The sampling will require samples from each. According to air industry sources I asked, the problem with water was an open secret in the industry.

  6. #6 abc
    October 14, 2009

    My husband is an airline employee–he says that the ice used for drinks is bagged ice just like you’d get in any store, but he won’t use it because the containers they put it in aren’t cleaned regularly.

  7. #7 revere
    October 14, 2009

    abc: Thanks for the clarification. It does, however, underline once again the problem. The ice containers are FDA responsibility, not the EPA, so it winds up the same.

  8. #8 BostonERDoc
    October 14, 2009

    It gets even better: A scientist by the name of Dr. Gerber from Univ. of Az (aka Dr. Germ) has done microbial sampling of aircraft restrooms and seat back trays. He found high counts of MRSA on the seat back trays on 4 of 6 flights he tested and the colliform count in the aircraft restrooms would send anyone crying to their mother. The highest level of contamination was the sink handle. I have always recommended that you use alcohol based hand gel after going to the restroom on the plane or after touching the seat back tray. Slowly but surely the air carriers are starting to provide alcohol hand sanitizers–Virgin Atlantic leads the way.

    The WHO recently published its hygiene and sanitation recommendations for the aviation industry in June 2009 apparently before consulting with Dr. Gerber and you wont like it if you read it Revere. It essentially looks the other way for those rapid turn around flights most of us reading this take when we fly. Turns out they were crafted by yep you guessed it–aviation stakeholders. The flight attendant union had some input but a lot of what they wanted in the recs was not passed for obvious reasons–money.

    The question is: what is the real health threat to us? We are exposed to bacteria, viruses and fungi all the time–in fact most of us are breathing them in right now but our immune system keeps them at bay. I think our immune response may be slightly blunted during air travel since the cabins are pressurized to 5 to 8K above sea level thereby subjecting us to hypobaric hypoxia. I have seen a handful of studies carried out years ago that show natural killer cells are incompetent at high altitudes but that is about al the research that has been done on the topic.

  9. #9 wazza
    October 14, 2009

    Coffee and tea are presumably all right, because the water is boiled as part of the preparation process…

  10. #10 Atlantic
    October 14, 2009

    Can you please comment on this article from The Atlantic which questions the value of vaccines: http://www.theatlantic.com/doc/print/200911/brownlee-h1n1

  11. #11 revere
    October 15, 2009

    wazza: You are correct. The context there was that FDA regulates that water, not EPA.

    Atlantic: Dealing with the vaccine confusion is a game of whack a mole. I had read the Atlantic piece, and it isn’t as bad as Holland’s, but it confuses issues over seasonal and swine flu vaccines. It spends a lot of time on the question of efficacy in the elderly age group (Tom Jefferson is becoming somewhat of an Evidence Based crank, BTW, but I agree with the issues that Lone Simonsen has raised and have posted on it a couple of times here). However this is not the issue for swine flu vaccination, but it throws everything into the same pile. I haven’t decided whether to take the time to deal with this or not.

  12. #12 Coturnix
    October 15, 2009

    I buy a 20oz Coke bottle at the gate and that’s all I drink on a plane. If I run out, I get a can of Coke – no cup, no ice. If it is a very long intercontinental flight, I may get coffee in the morning, which is so hot I gather the heat must have killed most of the living stuff in it.

  13. #13 glock
    October 15, 2009

    I was contemplating a Steripen for my trip to China just in case of unforeseen circumstances but figured I may never REALLY need it, so opted for the iodine tabs as a CYA last resort ( I’ve never had a problem there using the usual cautions, unlike Mexico)
    Now maybe I can justify the expense after reading this….
    I always figured bottled water was relatively safe from bio hazards. Chemicals are always another story.

  14. #14 abc
    October 15, 2009

    The assumption that all potential pathogens in water destined to be made into tea or coffee will be killed by boiling makes me uncomfortable–especially given that, while the cabin is pressurized, the pressure isn’t as high as that found at sea level. Who knows how hot the water really gets before it boils?

  15. #15 revere
    October 15, 2009

    abc: You make an interesting point, but most intestinal pathogens would be well handled even at less than 100 deg C. There are some pathogens that form cysts that might not but they would be pretty uncommon in this setting. So I think you are pretty safe with coffee and tea made on the plane unless the container they are put in is contaminated. That’s all FDA territory.

  16. #16 Anne
    October 15, 2009

    The coliform count can be misleading: it turns out that coliforms just love to live in pulp mills (huge tanks of warm water loaded with cellulose; many paper-making machines are literally dripping with bacterial slime). Untreated pulp mill effluent is just loaded with coliforms – but essentially no pathogen risk, since human pathogens don’t really live well in pulp mills (unless the mill toilets feed into the effluent). Of course there are chemical nasties you have to get rid of, but most pulp mills need to do additional treatment above and beyond what is required to deal with the chemical problems to cut down their (harmless) coliform count. Still, it’s a small price to pay to be able to keep coliform count as a proxy for pathogen risk.

  17. #17 revere
    October 15, 2009

    Anne: Indeed the coliform count has many defects. But its use in this instance still suggests a problem. Coliforms shouldn ‘t be part of the airplane ecosystem.

  18. #18 g336
    October 17, 2009

    The safest things to drink on aircraft would be bottled & canned beverages served on the plane or bought inside the secure areas.

    What I do on long flights is buy a sandwich and a soda (my soda consumption in total is 0 to 2 a week) for a meal, and count on there being bottled water or similar on the flight.

    Figure the extra cost of food bought at the airport, as part of your cost of travel. Assume you’re going to spend $15 on food each way, and be glad if you can do it for less. You’re already going to spend money on ground transportation, so don’t begrudge yourself the cost of a reasonable meal at 40,000 feet.

    Think of this for a moment: crossing a continent in 6 hours, and eating a meal at 40,000 feet. Those two facts by themselves ought to overcome a lot of complaints.

  19. #19 red rabbit
    October 17, 2009

    Hm. I suppose this explains the Ethiopia-Rome-NYC flight on which the entire plane got ill. I was blaming the food on the ground in Ethiopia, which was a gorgeous lunch at the Addis-Ababa Hilton (ground service on Ethiopian Airlines is incredible, but the flights are ultimately appalling).

    Essentially, for the average healthy Westerner headed home, the risk of a diarrheal illness, while gross when considering how one gets them, is not exactly life-and-death. Air Canada is a big loder on lots of counts (says the Canadian) but the water jug is the least of my worries on their flights.

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