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?