Initiative forestalls possible penalties

A dozen major U.S. airlines plan to increase their efforts to ensure the safety of water on their airplanes, reflecting an agreement in principle reached recently with the Environmental Protection Agency (EPA) in lieu of enforcement action.

The water tanks and lines on airliners will have to be flushed and disinfected; airport service trucks bringing water to airplanes also will have to be flushed and disinfected.

"The cost is not trivial," said Tom Skinner of the EPA's enforcement and compliance office. "The airplanes will have to be taken to disinfection stations, which are not available at every airport."

For the airlines that have reached agreements with the EPA to do this work, involving every one of their airplanes over the next 12 months, the total cost could run into the millions of dollars.

"It was pretty clear," Skinner said, "We get to the agreements or we were prepared to take unilateral enforcement action."

Starting Nov. 9 and ending about Dec. 8, some 169 aircraft will have their water tested for coliform bacteria, which is a sign of fecal contamination, as well as for residual chlorine (an indication of whether the chemical was an effective disinfectant). This number of aircraft is regarded as a statistically significant sample. Basically, the EPA is expanding its aircraft water sampling program of last August and September. Those tests found that the water in some 13 percent of the aircraft tested did not meet EPA water quality standards (see ASW, Sept. 27).

The Air Transport Association (ATA), the trade association representing those airlines carrying most U.S. passengers, believes the EPA testing was flawed and that the number of aircraft with water not meeting EPA standard is closer to about 5 percent. The confirmatory round of EPA water testing now under way represents an effort to put that issue to rest. Airlines will be notified of any coliform results, EPA officials said. The EPA plans to post the results for the general public in January 2005.

The ongoing water testing is unrelated to the agreements signed between 12 airlines and the EPA. They have agreed to repetitive flushing and disinfection of both the airplanes and the supply trucks. They have agreed to quarterly meetings with EPA officials to more closely monitor and coordinate efforts to ensure that airplane water meets EPA standards.

Skinner said, "Water quality on airplanes is a complex issue. An airplane can make 10 trips and receive water from as many sources, both inside and outside the U.S."

Two carriers among ATA's member airlines did not reach agreements with the EPA. One is Southwest Airlines [LUV], whose flight routes are entirely domestic, and therefore the water quality on its airplanes is not threatened by the uncertain quality of foreign water supplies. The other carrier is Delta Air Lines [DAL], which flies both domestically and overseas. A Delta official said, "Delta elected not to sign the agreement in principle because our water testing programs already exceed its sampling requirements."

"In the recent EPA testing, all samples taken from Delta aircraft met drinking water quality standards," the Delta official added.

The water quality program is growing in scope. EPA officials said regional airlines and charter operators also would be affected.

Benjamin Grumbles from the EPA's water office, said, "Our objective is that airplane water is as safe as that in stationary public water systems."

"The EPA wants every airline operating under the Safe Water Drinking Act," he said.

Operators can expect heightened attention on the safety of airplane water over the next three years. In the first year, additional data will be collected through stepped up sampling, flushing, etc. At the end of that time, EPA officials plan to issue a Notice of Proposed Rule Making (NPRM) outlining requirements specifically targeted to the airline industry for ensuring that the water supplying aircraft galleys and lavatory sinks meets EPA standards. A comment period and publication of a final rule will push this effort to final regulatory resolution by the end of the third year.

There may be a security aspect to the water quality issue - the susceptibility of aircraft water systems to terrorist interdiction. One possible scenario: a slowly-dissolving capsule containing a strong pathogen inserted into the airplane's water tanks, or possibly pumped in from a water-supply truck. Carbon filters in the supply lines, placed to remove particulate matter, might well serve a critical secondary role in forestalling such a dissolving capsule scenario.